Privacy Policy

Lucia Travel

Shanghai Zhuangshen Yintong Technology Co., Ltd.

Last Updated: February 19, 2026

This Privacy Policy describes the privacy practices of Shanghai Zhuangshen Yintong Technology Co., Ltd. ("Lucia Travel", "we", "us", or "our") and how we handle personal information that we collect through our mobile applications (the "App"), our website located at luciatravel.ai (the "Site"), and through any other applications, websites, or services that we own or control and that link to this Privacy Policy (collectively, the "Service"). The Service is designed to be an AI-powered platform for travel planning and recommendations and may support bookings of travel-related products and services (e.g., tickets, accommodations, transportation, local experiences) through integrations with third parties. AI transparency disclosure: When using the Service, you are interacting with an AI-driven conversational system and not a human operator. This Privacy Policy does not apply to any products, services, websites, or content offered by third parties that are governed by their respective privacy policies. PLEASE READ CAREFULLY BEFORE USING OUR SERVICE. BY ACCESSING THE SITE AND/OR USING OUR SERVICE, YOU AFFIRM THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO THIS PRIVACY POLICY AND OUR TERMS OF SERVICE. IF YOU DO NOT AGREE, DO NOT USE THE SERVICE. IF YOU USE THE SERVICE ON BEHALF OF SOMEONE ELSE, YOU REPRESENT THAT YOU ARE AUTHORIZED TO ACCEPT THIS PRIVACY POLICY ON THAT INDIVIDUAL’S BEHALF.

1. Who We Are and How to Contact Us

Controller/Operator: Shanghai Zhuangshen Yintong Technology Co., Ltd. (Shanghai, China)Website: luciatravel.aiEmail (privacy & support): support@luciatravel.aiMailing Address: 180 Longtai Rd, Shanghai, China

2. Personal Information We Collect

We collect personal information in the following ways:

2.1 Information you provide to us

Contact and account information, such as your first and last name, email address, phone number (if provided), and password.

Third-party login information, if you choose to create an account or sign in using a third-party service (e.g., Google or Apple). We receive information as permitted by your settings on that third-party service for authentication and account linking.

Travel preferences and interests, such as budget range, travel pace, interests (e.g., food, culture, nature), and other preference signals you choose to provide or that we infer from your use of the Service to personalize your experience.

Travel program memberships you choose to store, such as frequent flyer or hotel loyalty programs.

Reservation and itinerary information, such as flights, lodgings, tickets, activities, and related itinerary details you enter or connect to the Service.

Payment information necessary to complete transactions. Payments are processed by PayPal and/or other payment providers you select. We do not receive or store your full payment card details; we may receive transaction confirmations and limited payment-related metadata (e.g., payer name, transaction ID).

Content and metadata of messages and prompts you submit through the Service, including conversation content, timestamps, and related context you provide.

Communications we exchange with you, including when you respond to surveys or contact us with questions or feedback.

Any other information you choose to provide, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

2.2 Automatic data collection

We and our service providers may automatically log information about you, your device, and your interaction with the Service, such as:

Device and network data, such as operating system type and version, device manufacturer and model, browser type, screen resolution, device type (phone/tablet/computer), IP address, language settings, and general location information (e.g., city/region).

Usage and activity data, such as pages or screens viewed, time spent, navigation paths, interaction events, access times, and whether you opened or engaged with our communications.

Security and reliability data, such as log files and diagnostic events, to help protect the Service and troubleshoot issues.

2.3 Mobile app permissions and device data (iOS and other mobile platforms)

Depending on the features you use, the App may request access to certain device permissions. You can grant or deny permissions when prompted and change your choices at any time in your device settings. We use permissions only to provide the feature you choose to use.

Location (optional): If you enable location-based features, we may access your approximate or precise location (based on your device settings) to provide the requested feature (e.g., nearby recommendations or on-trip guidance).

Photos / Camera (optional): If you use photo-based features, we may access photos or camera content you choose to capture/upload to provide the feature (e.g., menu/sign translation from an image).

Microphone (optional): If you use voice features, we may access microphone input to process your request (e.g., voice translation).

Notifications (optional): If you enable push notifications, we may send service-related notifications (e.g., itinerary reminders or updates).

If you do not grant a permission, the related feature may be unavailable.

We do not use the Apple Advertising Identifier (IDFA) for targeted advertising, and we do not use your data for cross-context behavioral advertising. We do not permit third parties to use data from our App for their own advertising purposes.

2.4 Cookies, pixels, and similar technologies (Site)

On the Site, we may use cookies, local storage, and pixel tags (web beacons) to enable functionality, remember preferences, measure performance, and understand usage patterns. You can control cookies through your browser settings.

2.5 Web analytics (GA4) — Site only

We use Google Analytics 4 (GA4) on the Site to understand how visitors interact with the Site and to improve performance and user experience. GA4 may use cookies and similar technologies to collect usage and device information from Site visitors. Our mobile applications do not use GA4 for in-app analytics at this time.

2.6 Cookie consent (EEA/UK and similar jurisdictions)

Where required by applicable law (for example, in the European Economic Area or the United Kingdom), we will present a cookie consent banner and will not set non-essential cookies (such as analytics cookies) unless and until you provide consent. You can withdraw or change your consent choices at any time through the cookie/banner settings (where available) or by adjusting your browser settings.

2.7 Sensitive information (please read carefully)

The Service is not designed to collect highly sensitive personal information such as government identification numbers (e.g., passport or national ID), full financial account information (e.g., full credit card numbers or bank account numbers), precise home addresses, or health information. We do not request or require such information, and you should not provide it when using the Service. If you choose to enter such information, it may be captured in your conversation history. Please exercise caution and avoid submitting sensitive or inappropriate information through the Service.

3. How We Use Personal Information

We use personal information for the following purposes:

Provide and operate our Service, including account creation and management, itinerary generation, travel recommendations, and (where applicable) facilitating bookings and order management.

Communicate with you, including responding to requests, providing customer support, sending service announcements, reminders, updates, surveys, and security alerts.

Improve, monitor, personalize, and protect the Service, including troubleshooting, testing, research, and security monitoring.

Develop and improve our AI features and safeguards, including measures intended to improve output quality and reduce harmful outputs. We may create aggregated, de-identified, or anonymized data for these purposes.

Compliance and protection, including enforcing our Terms of Service, preventing fraud and abuse, and complying with applicable laws and lawful requests.

4. AI Processing (OpenAI) and Data Controls

To provide AI-powered features, we use third-party AI technology providers, including OpenAI, to process certain inputs and generate outputs. Depending on the feature you use, the information shared with the AI provider may include:

Content you submit (e.g., chat prompts, messages, itinerary inputs, translation text, or images you choose to upload for translation).

Trip context and preferences you choose to provide (e.g., interests, budget, pace, group type, selected POIs).

Optional location context if you enable location-based features (e.g., to recommend nearby places or provide on-trip guidance).

We share only the information reasonably necessary to provide the requested AI functionality.

OpenAI data controls. We use OpenAI API services with data controls designed so that content sent via the API is not used by OpenAI to train or improve OpenAI models by default, unless you explicitly opt in or as otherwise required under OpenAI’s terms and applicable law. OpenAI and other providers may retain certain data for a limited period for security and abuse monitoring, subject to their policies and contractual commitments.

4.1 Notice regarding AI processing

When you use AI features (such as itinerary generation, recommendations, menu/photo translation, or voice translation), we may send certain information you submit to our AI service provider (currently OpenAI) to generate the requested output. This Privacy Policy describes what information may be shared and for what purposes. You can control what you share by choosing what you submit and by enabling or disabling optional permissions (such as location, photos, and microphone) in your device settings. If you do not enable optional permissions, related features may be unavailable.

5. Consent to Electronic Communications and SMS (If Applicable)

By using the Service, you consent to receiving electronic communications from us related to your account and the Service (e.g., notices, disclosures, reminders, and updates). These communications may be sent by email or other electronic means. If we offer SMS notifications and you choose to enable them, you may stop receiving SMS messages at any time by replying STOP. Message and data rates may apply. If you have questions, contact us at support@luciatravel.ai.

6. How We Disclose Personal Information

We may disclose personal information to third parties as described below:

6.1 Service providers (Google Cloud, MongoDB, support)

We may disclose personal information to third-party service providers that perform services on our behalf, such as hosting, cloud computing, databases, security, customer support, and maintenance. Our infrastructure uses Google Cloud. Our database services use MongoDB (including managed offerings). We also use AI service providers (such as OpenAI) as service providers/processors to help provide AI-powered features.

6.2 Payment processing (PayPal)

Payments are processed by PayPal and/or other payment providers you select during checkout. Payment providers handle payment information in accordance with their own privacy policies.

6.3 Travel partners (for bookings, where applicable)

If you request to make reservations or purchases for travel-related products or services, we may disclose personal information to third-party travel partners or merchants to facilitate those reservations or purchases.

6.4 Professional advisors

We may disclose personal information to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services they render to us.

6.5 Authorities and others

We may disclose personal information to law enforcement, government authorities, or private parties where we believe in good faith it is necessary or appropriate for compliance, protection, or security purposes (e.g., to respond to legal process, protect rights and safety, and prevent fraud).

6.6 Business transferees

We may disclose personal information to acquirers and other relevant participants in business transactions (or negotiations) involving a merger, acquisition, reorganization, sale, or other disposition of all or any portion of our business or assets.

6.7 Partners (embedded deployments)

If the Service is provided through an embedded solution on a third-party partner site, we do not share your identifiable personal information or conversation history with that partner by default.

7. Do We Sell Personal Information?

We do not sell personal information. We also do not share personal information for cross-context behavioral advertising (as those terms are commonly used in certain privacy laws).

8. Third-Party Login and Social Networking Services

We may allow you to log in through third-party services (e.g., Google or Apple). If you use these features, the third-party service may share certain information with us as permitted by your settings and that service’s policies. We use that information to authenticate you and provide the Service. If you choose to share activities to a social network, your sharing is subject to the social network’s terms and privacy policy.

9. Privacy Choices and Rights

9.1 Account deletion

You may request that we delete your account by contacting us at support@luciatravel.ai. We may ask for information to verify your identity before processing your request.

9.2 Access, correction, and other requests

Depending on where you live, you may have rights to request access to, correction of, deletion of, or other actions regarding your personal information. To make a request, please contact us at support@luciatravel.ai. You are entitled to exercise applicable rights free from discrimination.

Withdrawal of consent (where applicable). Where we rely on your consent to process certain information (such as optional permissions or AI processing notices presented in-app), you may withdraw your consent at any time by changing your App settings and/or device permission settings. Withdrawing consent will not affect processing already performed, but it may limit certain features.

9.3 Marketing communications

If we send marketing emails, you may opt out by following the unsubscribe instructions in the email or by contacting us at support@luciatravel.ai. Even if you opt out of marketing communications, you may continue to receive service and account-related messages.

10. Security

We employ technical, organizational, and physical safeguards designed to protect the personal information we collect, including access controls and encryption where appropriate. However, no security measures are failsafe and we cannot guarantee the security of your personal information. No system can prevent disclosure of information you voluntarily provide in free-text chats. We strongly discourage you from entering sensitive or inappropriate information into the Service.

11. Use of the Service by Minors

The Service is not intended for individuals under the age of 18. If you have reason to believe that a person under 18 has provided personal information to us, please contact us at support@luciatravel.ai and we will take reasonable steps to delete such information.

12. Retention of Personal Information

We retain personal information only for as long as necessary to provide the Service and for the purposes described in this Privacy Policy, including to comply with legal obligations, resolve disputes, and enforce agreements. Residual copies may remain in backups for a limited period. Usage data is generally retained for a shorter period, except when used to strengthen security, improve functionality, or where we are legally required to retain it for longer. Content you submit for AI features (such as chat prompts and images used for translation) is retained only as long as reasonably necessary to provide and improve the Service, resolve disputes, and maintain security, and may be deleted or de-identified when no longer needed, subject to legal and operational requirements.

13. International Data Transfers

Because we use global service providers (including Google Cloud, MongoDB services, PayPal, and OpenAI) and may process data using infrastructure located in multiple jurisdictions, your personal information may be transferred to, stored in, or processed in countries other than your country of residence. Where required by applicable law, we implement appropriate safeguards for cross-border transfers (such as contractual protections). If you are located in the European Economic Area (EEA) or the United Kingdom, we rely on appropriate transfer mechanisms such as Standard Contractual Clauses (SCCs), as applicable.

14. Additional Notice for PRC Residents (Mainland China)

If you are a resident of the People’s Republic of China (for purposes of this section, excluding Hong Kong SAR, Macau SAR, and Taiwan), and we process your personal information, we will comply with applicable PRC data protection laws (including the Personal Information Protection Law). This may include obtaining separate consent for cross-border transfers where required. Overseas recipients and purposes: We may transfer personal information to service providers outside mainland China to provide core functionality, including (1) Google Cloud and/or MongoDB for hosting and database services, (2) OpenAI for AI response generation, and (3) PayPal for payment processing. The categories of personal information involved may include account/contact information, device and usage information, and the content you submit (such as chat prompts and itinerary inputs). We use secure transmission and access controls to protect such transfers. You may contact us at support@luciatravel.ai to exercise your rights, including access, correction, deletion, and withdrawal of consent, as applicable.

15. Changes to This Privacy Policy

We may modify this Privacy Policy from time to time. If we make material changes, we will notify you by updating the Last Updated date and posting the updated policy on the Service, or as otherwise required by law.

16. How to Contact Us

If you have any questions about this Privacy Policy or our privacy practices, or to submit a personal information request, please contact us:Email: support@luciatravel.aiMailing Address: 180 Longtai Rd, Shanghai, China