Luura Finance Ltd
| Version | 1.1 |
|---|---|
| Effective date | 10 June 2026 |
| Owner | Kiesha Okeowo, Director |
| Scope | Phase 1: manual entry. There is no bank connection in this phase. This policy will be updated before Open Banking features launch. |
| Review frequency | Annually, or following material changes to the business, regulatory requirements, or data processing activities |
Luura Finance Ltd is a UK-based finance app that helps you manage money with less effort. In Phase 1, you add transactions, bills and notes manually. There is no bank connection yet.
Luura Finance Ltd is the data controller for the personal data described in this policy.
Luura is available to people aged 16 and over.
If you are 16 or 17, your account must be part of a family plan held by a parent or guardian. The parent or guardian is the subscription holder and is responsible for payment and the terms of the plan. Your in-app data remains your own, and the same rights described in this policy apply to you.
We only collect what we need to run the service and support you.
There is no automatic bank data import in this phase.
UK GDPR requires us to have a lawful basis for everything we do with your data. Here is each purpose alongside the basis we rely on.
| What we do | Lawful basis |
|---|---|
| Show and organise your manually entered transactions, bills and insights | Contract |
| Personalise your dashboard, summaries and in-app experience | Contract |
| Manage subscriptions billed through the Apple App Store or Google Play | Contract and legal obligation |
| Store and display your mood entries | Your explicit consent |
| Monitor performance, fix bugs and improve features | Legitimate interests |
| Protect the service against misuse or security issues | Legitimate interests and legal obligation |
| Send important service messages and respond to support requests | Contract |
| Send marketing emails, if you have opted in | Your consent |
We do not sell your data to advertisers.
Mood entries can reveal information about your wellbeing, so we treat them with extra care. We only process mood data with your explicit consent, which we ask for in the app before you log your first mood. You can withdraw consent at any time in settings, and you can delete individual mood entries whenever you like. Mood data is never shared with third parties and is never used for marketing.
We share data with trusted providers who help us run Luura. They only receive what is necessary for their service.
| Partner | Purpose | Location |
|---|---|---|
| Apple / Google | Subscription billing and app distribution through the App Store and Google Play. Apple and Google act as independent controllers for payment data; Luura receives only subscription status, never card details. | Global (with UK GDPR safeguards) |
| Bubble.io | Application platform and hosting | AWS (EU and US servers) |
| Google Analytics | Measure usage and improve experience, in aggregate | EU / US (with UK GDPR safeguards) |
If laws require it, we may share data with authorities to protect users and comply with legal obligations.
Luura runs on Amazon Web Services (AWS) via the Bubble platform. Data may be processed in the UK, EU or US, depending on the provider. Where data leaves the UK, we rely on UK adequacy decisions or put in place the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses to keep it protected.
Retention periods are set out in full in our Data Retention Policy. In summary:
| Data type | Retention period |
|---|---|
| Account information | Duration of your account, plus up to 30 days following an account deletion request |
| Manual entries, mood entries, notes and settings | Duration of your account, plus up to 30 days following a deletion request |
| Marketing and waitlist data | Until you unsubscribe or withdraw consent, or 24 months after last engagement, whichever is sooner |
| Support messages | Up to 24 months after your enquiry is closed |
| Analytics data (aggregated or anonymised) | Up to 12 months |
| Security and audit logs | Up to 12 months |
| Financial and accounting records, including subscription records | 6 years, or longer where legally required |
You can request deletion at any time. Some records, such as payment and accounting records, must be kept for 6 years to meet legal obligations even after your account closes. See section 9 for your rights.
You can:
Email info@luurafinance.app to make a request. We will respond within one month, as required by law.
We use cookies and similar technologies to keep you signed in, remember preferences and measure performance. You can manage cookies in your browser or device settings, or through the cookie preferences tool on our website, though some features may not work correctly if cookies are disabled.
We use encryption in transit (HTTPS), modern authentication, role-based access and audit logging. Passwords are stored using industry-standard hashing. Only authorised personnel and providers can access the minimum data needed to operate the service. You can read more in our Security Policy.
No system is perfectly secure, so please use a strong, unique password and keep your login details private.
We may update this policy as Luura evolves. If we make significant changes, we will notify you in the app or by email and update the date at the top of this page.
Questions or requests about your data?
Approved by
Kiesha Okeowo
Director
Luura Finance Ltd