Privacy Policy

Effective Date : 13/11/2022


This Privacy Policy sets out how Lungy uses and protects any information that the users of this App give while using this app. This privacy policy should be read in conjunction with our Terms and Conditions and the Medical Disclaimer. Please read this privacy policy carefully as we will not be held responsible in case there is a breach of this policy on your part.  



a.    Lungy is committed to protecting and respecting your privacy in compliance with the European Union's General Data Protection Regulation (GDPR) and UK's Data Protection Act 2018.


b.    Lungy does not request or require any personal identifiable information such as name, email address, date of birth or address for functionality.


c.    Downloading, accessing, or otherwise using this App indicates that you have read this privacy policy and consent to its terms. If you do not consent to the terms of this privacy policy, please do not download, access, or otherwise use this App.  


d.    If you are a minor in the jurisdiction in which you reside, you may use this App only with the consent of your parent or legal guardian. We will not be held liable for any cause of action due to a breach of this privacy policy.  




a. Lungy does not currently collect or require any personal identification information such as name, email address, date of birth, gender, and country to access and use the app. There is no login screen or registration to access the app

b. You may be expected to provide your financial details (such as credit or debit card details) via your Apple ID, to Apple App Store in order to become a paid subscriber or purchasers of this App. Additionally, Lungy may collect purchase data to aid with managing and handling user subscriptions, purchases and promotions. This data may be collected but is not linked to your identity and only stored with anonymous App User IDs.


b. Lungy uses the microphone to recognise and respond to user breathing. No audio or microphone data is ever recorded, streamed, transmitted or stored. The microphone data is analysed and stored as encrypted numerical breathing data after each breathing exercise you complete. This data is entirely anonymised, the data remains on your device and is on-device encrypted.

c. Additionally, Lungy can use the camera (with TrueDepth on supported devices), with subsequent face-tracking, to help you position the phone for optimal breathing detection. The use of the camera positioning screen is entirely optional and at the user's discretion. No depth, video or camera data is ever recorded, streamed, transmitted or stored. No identifiable or recognisable face or face-tracking data is ever stored, and is only used for the purpose of tracking the positioning and orientation of the face. The positioning and any facial tracking data is not saved to the device at any time and these data only exist whilst i) a user's face is detected and ii) the camera positioning screen is visible to the user and will be immediately deleted and unrecoverable as soon as: i) a user's face is no longer detected and/or ii) the camera positioning screen is no longer visible or active. If you would prefer to not use this face-tracking feature, please select 'Without Camera' during the tutorial, or set Face-Tracking to Off in 'Settings'.


d. Your privacy is a priority to us. For this reason, Lungy does not share any identifiable or user information with remote or cloud servers, it is not transferred, and stays on your device.

e. You may optionally enable 'Apple Health' to store Mindful Minutes after each breathing session. This is entirely optional, the data will stay securely in the Apple Health, and will never be read or shared.




a.    We only collect information from you directly through this App.




a.    We may use the information collected through this App for the following:


i.             Improve our services and how we operate our App;


ii.           Market research activities to offer you better services;


iii.          Marketing and promotional purposes to spread a message about our App;


iv.          Enhance the user experience for using this App, our products and services;


v.           Personalise our services and make recommendations;


vi.          User authentication to ensure the safety and security of your account;


vii.         Provide and deliver products and services at your request;


viii.        Protect, investigate, and deter fraudulent, unauthorised or illegal activity.


b.    Apart from the above, we may also use information collected through this App for record keeping, quality control and for sending promotional materials.


c.    We do not use your personal information for commercial purposes.

d.    We do not give access to any third-parties any data collected, including your: personal information, purchasing data, camera data, any face / face-tracking data, microphone data, usage data or breathing data. These data will never leave your device and will never be stored by us or any third parties.




a.    All data is stored on your device, and is on-device encrypted. Additionally, please ensure you set a passcode on your device for added security.




a.    Your personal information, breathing and progress data will be stored locally on your device and encrypted. Please ensure you set a passcode on your device for added security.


b.    We are committed to ensuring that your data including personal information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.


c.    Any information we collect will remain confidential and apart from us, no one else will be able to access this data.  


d.    Once you delete your account on our App, your personal information will be automatically deleted.


e.    If you would like to know the details of your personal information which we hold, please write to us at 




As of date 13th November 2022, we do not use cookies or other similar technologies. If you have any feedback or complaint against our App or website, please write to us at:  



a.    If you are a registered user of our App, we offer you an opportunity to review, correct, update or delete your personal information. You can do this by either of the following ways:


(i) By emailing us at:  


b.   You have the right to ask us not to process your personal information for marketing, promotional, and research purposes. You can exercise your right to prevent such processing by checking or unchecking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at :  



We do not share your personal information with third-parties without your prior consent except:

a.    To comply with applicable laws or respond to lawful requests and legal processes.


b.    To protect our rights and property, our agents, our customers, to enforce our agreements, policies and terms of use.


c.    In an emergency such as to protect the personal safety of any person.



a.    Our App and website may be connected to third party websites and apps. It is your responsibility to ensure that you adhere to Apple Store’s Privacy Policy.

b.    Our App and website may contain links to other websites or mobile applications. However, once you leave our App or website, we have no control over third-party websites and mobile applications. We are not responsible for protecting your privacy on these third-party websites and mobile applications. You should conduct due diligence and carefully read the privacy policies applicable to that website or App in question.  




a.     If you have any complaint or concern regarding your personal information under this privacy policy, please contact us at: We suggest that you put in the subject line of any email or communication “Privacy Policy” or “Privacy Complaint.”  We will try our best to respond within 45 days.


b.    In the event of any dispute or claim arising out of or relating to the use of your personal information, you will attempt in good faith to negotiate a written resolution of the matter directly with us. If the matter remains unresolved for sixty days after notification (via email, certified mail or personal delivery) that a dispute exists, the parties will attempt to resolve the matter via mediation. The parties shall mutually agree to appoint a mediator.


c.    Under no circumstance, will the parties resolve the dispute by arbitration, litigation or jury trial except if required by law.  



a.    Our privacy policy is subject to change at any time without notice. Please review this policy periodically to make sure that you are aware about the changes. We will not beheld responsible if you are not aware about the recent changes to the policy. The recent changes can be found at the top of this policy.


b.    This policy is effective from 13/11/2022. If you have any questions related to this privacy policy or how we handle your personal information, please contact us at You may also contact our Data Protection Officer directly.


These Terms are effective and were last updated on 13/11/2022. 


Lungy (developed by Pi-A) is based out of London, United Kingdom.