Luciato Privacy Policy

Effective Date: April 11, 2026

This Privacy Policy applies to Luciato for iPhone and Mac, including the iOS app, the iOS keyboard extension, and the macOS app. Luciato is offered by Tutelon LLC ("Tutelon," "we," "our," or "us").

1. What Luciato Does

Luciato helps you create text from speech. Depending on the platform and the features you choose, Luciato can transcribe speech, generate AI Draft output, apply writing preferences, insert or copy text, sync settings through iCloud, and manage App Store subscriptions.

2. Data We Process

When you use Luciato's cloud-powered features, we may process:

• Recorded speech and audio chunks that you submit for transcription.
• Dictated text and AI Draft instructions used to return the result you requested.
• Optional dictation context such as selected languages, vocabulary, writing preferences, and app context when those fields are included to improve results.
• Subscription and service state such as pseudonymous registration identifiers, subscription level, quota state, purchase-validation details, and related billing status needed to operate subscription-gated cloud features.
• Diagnostics and analytics data such as app events, crash data, performance data, request timing, and coarse failure reasons.
• Settings and local state such as consent state, keyboard settings, vocabulary, writing preferences, selected languages, and cross-device sync data.

Apple manages the App Store account and iCloud account you use with Luciato. We do not receive your Apple ID email address, real name, or similar Apple account profile information from Apple or iCloud. When Luciato syncs supported settings across your devices, that sync is handled through Apple's iCloud services rather than Tutelon servers.

3. How We Collect Data

• Directly from you when you speak into the microphone, use Transcribe or AI Draft, change settings, contact us, or subscribe.
• From your device and app session when Luciato checks permissions, app integrity, subscription state, crash/performance signals, or local configuration.
• From Apple when StoreKit, App Store receipts, App Store Server APIs, App Store Server Notifications, iCloud, or platform services are used to determine subscription access, manage settings sync, and support app functionality.
• From our service providers when they help us securely process requests, validate app integrity, or deliver analytics and crash reporting.

4. How We Use Data

• Provide cloud transcription, AI Draft generation, and subscription-gated features.
• Improve reliability, security, abuse prevention, and service operations.
• Verify app integrity and protect the service from unauthorized use.
• Manage subscriptions, quota windows, restores, and billing-related state.
• Sync supported settings across your devices through Apple's iCloud services when enabled by the product design.
• Diagnose crashes, errors, and performance issues.
• Respond to support requests and comply with legal obligations.

We rely on Apple platform services to determine App Store subscription status and to manage supported cross-device settings sync. Those Apple-managed services do not give us your Apple ID email address, name, or similar account identity details. Tutelon only receives the app-level subscription and service information needed to validate access to Luciato's cloud features and operate the service.

5. Service Providers and Sharing

We share data only as reasonably necessary to operate Luciato. Current categories of providers include:

• Cloud hosting, networking, and edge infrastructure providers that help route, secure, and deliver Luciato service traffic.
• Third-party speech-to-text and AI processing providers that process submitted audio, text, and relevant request context when you use Luciato's cloud transcription or AI Draft features.
• Analytics, crash-reporting, and app-integrity providers that help us monitor reliability, diagnose failures, and protect the service from abuse.
• Platform and payment providers, including Apple that support App Store subscriptions, billing, receipts, app distribution, iCloud sync, and related platform services.

We require third parties that process Luciato data on our behalf to provide protections that are at least consistent with this Privacy Policy and applicable law.

6. Retention and Deletion

• Cloud-submitted audio and text: Luciato is designed to process submitted audio, dictated text, and AI Draft instructions ephemerally and not to intentionally retain that content after processing is complete.
• Local diagnostic copies: Luciato may keep a recent local recording copy on your device for playback or troubleshooting features. Those copies stay on-device until replaced, removed, or the app's local storage is cleared.
• Settings and sync data: settings stored locally, in the App Group container, or in iCloud key-value storage remain until changed or removed by later app activity or device/account controls. Cross-device settings sync is handled through Apple's iCloud services rather than Tutelon servers.
• Operational records: limited security, subscription, billing, abuse-prevention, support, crash, and analytics records may be retained for as long as reasonably necessary to run and protect the service, resolve disputes, and comply with law.

If you want to request deletion of data we control, contact us at [email protected]. We may need additional information to verify the request and determine what data is subject to deletion.

7. Your Choices and Controls

• iOS consent: Luciato for iPhone requires explicit in-app agreement before Transcribe or AI Draft can use cloud processing. You can withdraw that consent later in the app's Privacy & Consent settings.
• macOS control: Luciato for Mac offers cloud and local transcription modes. If you do not want cloud processing, choose Local transcription where available or avoid cloud features.
• Subscriptions: App Store subscriptions are billed and managed by Apple. You can manage or cancel subscriptions through your Apple account.
• Permissions: you can control microphone, speech, accessibility, automation, keyboard full access, and iCloud permissions through Apple platform settings.

8. Platform-Specific Notes

• iOS keyboard extension: Luciato's keyboard requires Open Access for cloud features such as Transcribe and AI Draft. Ordinary typing is not intentionally sent to Tutelon merely because the keyboard is enabled; Luciato's cloud processing is tied to the supported cloud actions you choose to invoke.
• macOS auto-insert: if you choose Luciato's optional auto-insert workflow, Luciato uses Apple Events and related accessibility or automation permissions on your Mac to paste text back into the target app.

9. Advertising and Sale of Data

Luciato does not sell your personal data. We do not use your Luciato content for third-party advertising, and Luciato does not include third-party advertising networks.

10. Children

Luciato is not directed to children under 18, and we do not knowingly collect personal data from children under 18 through Luciato. If you believe a child has provided personal data to us, contact us so we can review the issue.

11. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will post the updated policy here and change the effective date above.

12. Contact

If you have questions, privacy requests, or support issues about Luciato, contact:

• Email: [email protected]
• Company: Tutelon LLC