LUYA
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Privacy Policy

This Privacy Policy describes how Luya Labs Inc. (“LUYA”, “we”, “us” or “our”) collects, uses, stores, shares and protects personal information when you visit our websites, use the LUYA mobile application, connect a Luya X-1 growing system, participate in Founder 100, contact customer support, or otherwise use LUYA products and services.

Before you read

We aim to handle personal information transparently.

We care about privacy and aim to handle personal information in a transparent, reasonable and secure manner. If you do not agree with this Privacy Policy, please discontinue use of the applicable services.

Third-party websites, platforms and services may have their own privacy practices, and this Policy does not govern their independent processing activities.

Last updated: August 2026

1.Scope of This Policy

This Privacy Policy applies to:

  • LUYA websites and landing pages
  • The LUYA mobile application
  • LUYA smart growing devices
  • LUYA cloud services
  • Founder 100 and other early-user programs
  • Customer support and after-sales services
  • Email, SMS, and marketing communications
  • Surveys, video interviews, and user research
  • Reviews, photos, videos, and other content voluntarily submitted to LUYA
  • Other online or offline interactions related to these services

2.Account and Identity Information

Depending on how you interact with LUYA, we may collect:

  • Name
  • Email address
  • Telephone number
  • Username and login credentials
  • Account identifiers associated with Google, Apple, or other third-party sign-in services
  • General location information such as country, state, or city
  • Founder 100 application information
  • Other information you voluntarily provide

3.Order and Transaction Information

We may collect products purchased, order numbers, purchase dates, shipping and billing addresses, refund or return information, Founder 100 purchase status, subscription information, and seed tray or consumable orders.

Full payment card information is generally processed directly by our payment service providers. Unless necessary to provide the service, LUYA does not itself store complete payment card numbers.

4.Luya X-1 Device Information

When you connect or use a LUYA device, we may collect technical information such as:

  • Device serial number and device ID
  • Firmware and app version
  • Device online and connectivity status
  • IP address and network-related technical information
  • System logs and error logs
  • Device configuration
  • Device activation and account binding information
  • Feature usage information

5.Growing and Environmental Data

Because LUYA is a smart growing system, we may collect temperature, humidity, lighting parameters, irrigation status, pump and fan operation, nutrient usage, growing-cycle information, seed and tray type, tray identifiers, growth stage, harvest timing, alerts and abnormal conditions, and other plant-related system data.

We may use this information to operate the growing system, optimize growing strategies, improve product performance, and develop new growing recipes and services.

6.Cameras, Plant Images, and Visual Data

Certain LUYA products include cameras. Their primary purpose is to observe plant growth, create plant-growth time series, identify growth stages, analyze plant coverage, colour and condition, detect mold, yellowing, water stress or other abnormalities, optimize growing parameters, and enable features such as time-lapse imagery.

Images or video may be processed locally on the device or through LUYA cloud infrastructure.

LUYA cameras are designed primarily to observe plants within the growing system, not to monitor people in the household. If people, home surroundings, or other personal information are incidentally captured within the camera's field of view, we will treat that information in accordance with this Privacy Policy.

Unless separately disclosed and, where required, appropriately authorized, LUYA does not use its plant-monitoring cameras for facial recognition, identity verification, biometric identification, or continuous monitoring of household members.

We may use anonymized, de-identified, or aggregated plant images and growing data to improve algorithms, train plant-analysis models, develop growing strategies, and conduct product research.

7.App and Website Usage Information

When you use the LUYA App or visit our websites, we may automatically collect:

  • IP address, browser type, operating system, device type, app version
  • Pages viewed, click activity, session information, time spent on pages
  • Referral source
  • Crash information and performance data
  • Advertising or marketing attribution information

8.Cookies and Similar Technologies

LUYA websites and services may use cookies, pixels, SDKs, local storage, analytics technologies, advertising identifiers and similar technologies.

Essential functions

To operate websites, apps, authentication and device services.

Analytics

To understand traffic, usage and product performance.

Personalization

To remember settings and preferences.

Advertising and marketing

To measure campaigns, attribute conversions, create advertising audiences and, where permitted, deliver more relevant advertising.

9.Customer Support Information

When you contact us, we may collect contact information, support tickets, emails and chat records, device diagnostic information, telephone or video-support information, and photos or videos you voluntarily provide.

We use this information to troubleshoot issues, provide support, and improve LUYA products.

10.Founder 100 and User Research

If you participate in Founder 100 or another LUYA research program, we may also collect application responses, user-profile information, product feedback, survey responses, likelihood-to-recommend information, recorded interviews, unboxing videos, growing photos and videos, product reviews, bug reports, usage scenarios, and other user-generated content.

Where an interview is recorded, we will provide appropriate notice. Use of Founder 100 content for marketing may also be governed by the applicable Founder 100 Participation Terms and content permissions.

11.How We Use Information

Providing LUYA products and services

  • Create and manage accounts
  • Activate and bind devices
  • Operate smart-device functionality and growing functions
  • Provide App features
  • Process orders, deliver products and manage subscriptions
  • Provide customer support

Improving LUYA

  • Analyze product usage and diagnose bugs
  • Improve device reliability and user experience
  • Optimize growing recipes
  • Improve plant-analysis algorithms
  • Develop new products and features

Personalizing growing experiences

Based on plant variety, growth stage, environmental conditions, device status and historical growing performance.

Security and fraud prevention

Account security, authentication, fraud prevention, device security, cybersecurity, and investigation of abnormal activity.

Customer communications

Service notices, order updates, device alerts, software updates, security notices and customer-support communications.

Marketing

Where permitted by law or with required consent: product updates, Founder Program information, new-product announcements, growing content, offers and event information. You may unsubscribe from marketing emails at any time.

12.Artificial Intelligence and Algorithms

LUYA may use machine learning, computer vision and other artificial-intelligence technologies to analyze plant images, growth speed, plant colour, plant coverage, environmental parameters, historical growing data and device status.

These technologies may be used to identify plant growth stages, detect abnormal conditions, optimize growing environments, predict harvest timing, provide personalized growing recommendations and improve LUYA plant models.

Where appropriate, we take reasonable steps to reduce the use of directly identifying personal information in model-development activities where such information is not necessary.

13.How We Share Information

We do not sell personal information to data brokers simply in exchange for money. However, we may disclose information to third parties when reasonably necessary to operate LUYA.

Service providers

Cloud infrastructure, database and storage, authentication, payment processing, shipping and logistics, customer-support platforms, email and messaging, analytics, error monitoring, and advertising and marketing technology providers. These providers generally process information to perform services on our behalf.

Business partners

Where reasonably necessary, partners supporting Founder 100, Lighthouse projects, logistics, customer service, events or other collaborations.

Legal and safety purposes

To comply with law, respond to court orders or valid government or regulatory requests, protect LUYA, users or public safety, or investigate fraud, security incidents or unlawful conduct.

Corporate transactions

If LUYA is involved in financing, a merger, acquisition, restructuring, sale of assets or similar transaction, information may be disclosed or transferred as part of that transaction, subject to appropriate protections.

14.Advertising Data and “Sale” or “Sharing”

Certain U.S. privacy laws may define some transfers of information through advertising technology as a “sale” or “sharing” of personal information even when LUYA does not receive cash in exchange for the data. For example, certain advertising cookies, pixels, advertising identifiers and cross-site advertising technologies may constitute “sharing” under applicable privacy laws.

Where required by applicable law, LUYA will provide appropriate opt-out mechanisms, which may include a “Do Not Sell or Share My Personal Information” control. Where legally required, LUYA will also process applicable Global Privacy Control (“GPC”) signals.

15.Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide LUYA services, maintain accounts, support warranties and customer service, comply with financial and tax requirements, resolve disputes, prevent fraud and meet legal obligations.

Different categories of information may have different retention periods. When information is no longer reasonably needed, we may delete, anonymize, de-identify or aggregate it. Information that has been anonymized or de-identified so that it cannot reasonably be linked to an individual may be retained for research, product improvement and statistical purposes.

16.Data Security

LUYA uses reasonable administrative, technical and organizational safeguards designed to protect personal information. Depending on the circumstances, these may include encryption, access controls, authentication, network-security measures, logging and monitoring, permission separation, security updates and backups.

No Internet transmission or electronic storage system can be guaranteed to be completely secure. If you believe your LUYA account or device may have been compromised, please contact us promptly.

17.Your Privacy Rights

Depending on where you live and whether applicable law covers LUYA, you may have rights to:

  • Confirm whether we process your personal information
  • Access personal information we hold about you
  • Correct inaccurate information
  • Delete personal information
  • Obtain a portable copy of certain information
  • Opt out of certain targeted advertising
  • Opt out of the sale or sharing of personal information
  • Limit certain uses of sensitive personal information
  • Withdraw consent where processing is based on consent
  • Appeal certain privacy-request decisions
  • Exercise privacy rights without unlawful discrimination

18.California Privacy Rights

If the California Consumer Privacy Act (“CCPA”), as amended by the CPRA, applies to LUYA, California residents may have the right to know, access, delete and correct personal information; to opt out of sale or sharing; to limit certain uses and disclosures of sensitive personal information; and to non-discrimination.

Where permitted by law, an authorized agent may submit certain requests on a consumer's behalf. If LUYA engages in activity that qualifies as a “sale” or “sharing” under applicable law, LUYA will provide the legally required opt-out mechanisms and will honour applicable Global Privacy Control signals where required.

19.New Jersey and Other U.S. State Privacy Rights

If the New Jersey Data Privacy Law or another applicable U.S. state privacy law applies to LUYA, residents of those states may have rights including confirmation of processing, access, correction, deletion, data portability, opting out of targeted advertising, sale of personal data or certain profiling, and other rights provided by applicable law.

LUYA will process qualifying requests as required by applicable law.

20.Exercising Your Privacy Rights

You may submit a privacy request by contacting privacy@luyaxyz.com.

Please indicate whether you would like to access your information, correct information, delete your account, delete personal information, opt out of applicable advertising-data sharing, unsubscribe from marketing, or exercise another privacy right.

To protect your information, we may take reasonable steps to verify your identity.

21.Children's Privacy

LUYA products and services are primarily intended for adults and household purchasing decision-makers and are not directed to children under 13.

LUYA does not knowingly collect personal information online from children under 13 unless applicable legal requirements are satisfied and any required parental or guardian consent has been obtained. If we learn that personal information from a child under 13 was collected without appropriate authorization, we will take reasonable steps to delete it.

If you believe a child has provided personal information to LUYA, please contact us.

22.International Data Transfers

LUYA may use cloud infrastructure, vendors and technical providers located in the United States or other countries. As a result, information may be processed or stored outside the country or region where you live.

Where required by applicable law, we will use appropriate measures designed to protect data transferred internationally.

23.Marketing Communications

You may unsubscribe from marketing emails at any time — by clicking the “Unsubscribe” link in a marketing email, changing account settings, or contacting LUYA.

Even if you opt out of marketing, we may continue sending necessary non-marketing communications such as order notices, security alerts, product-safety information, important device notices and account communications.

24.Account Deletion

Where the LUYA App provides account functionality, you may request account deletion using the method provided in the App or by contacting LUYA through the privacy channels listed above.

After account deletion, certain information may be retained where reasonably necessary for legal obligations, financial records, fraud prevention, warranty support, dispute resolution or security purposes.

25.Third-Party Services

LUYA services may integrate with third-party platforms such as Apple, Google, AWS, payment providers, email providers, analytics services, advertising platforms and social-media services.

These third parties may independently process personal information. We encourage you to review their respective privacy policies.

26.Changes to This Privacy Policy

We may update this Privacy Policy as LUYA products, technologies, legal requirements or business practices evolve. If we make material changes, we may provide notice through our website, the LUYA App, email or another appropriate method.

The “Last updated” date at the top of this Policy indicates the latest revision.

27.Contact Us

If you have questions about this Privacy Policy, your personal information, or LUYA privacy practices, please contact:

Luya Labs Inc. — Privacy Team

Email: privacy@luyaxyz.com

Address: 12 Bellaire Drive, Princeton, NJ 08540, USA