Effective Date: 24 September 2025
Company: Lu’lu’a Digital
App: Buzzle
Contact: hello@luluadigital.com
Lu’lu’a Digital (“Lu’lu’a Digital,” “Buzzle,” “we,” “our,” or “us”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, store, transfer, protect, and otherwise process information when you access or use Buzzle.
Buzzle is a personal finance diary, tracking, reflection, and insight application. Because Buzzle may involve personal, financial, behavioural, receipt, and AI interaction data, we take privacy seriously.
By using Buzzle, you acknowledge that you have read and understood this Privacy Policy.
1. Scope of This Policy
This Privacy Policy applies to information collected through Buzzle, including our mobile apps, web apps, related services, support channels, and other features operated by Lu’lu’a Digital.
This Policy does not apply to third-party websites, platforms, payment providers, app stores, or services that we do not control.
2. Information We Collect
We may collect the following categories of information.
2.1 Account and Identity Information
We may collect:
1. name or nickname
2. email address
3. login credentials or authentication identifiers
4. profile image or avatar, if provided
5. account ID
6. subscription status
7. account creation date
8. account settings
9. support contact details
We do not intentionally collect your full payment card details. Payment details are handled by payment providers or app stores.
2.2 Profile, Onboarding, and Personalization Information
may collect information you provide during onboarding or through “About You” settings, including:
1. budgeting reason
2. financial struggle or focus area
3. current tracking method
4. preferred guidance style
5. motivation for improving money habits
6. country
7. timezone
8. preferred currency
9. date format
10. time format
11. week start day
12. household or lifestyle information, such as whether you spend for yourself, a partner, children, or pets, if you choose to provide it
13. other optional profile information you choose to provide
This information helps Buzzle personalize your experience, AI responses, summaries, suggestions, and app defaults.
2.3 Financial Diary Information
When you use Buzzle, you may enter financial and personal finance information, including:
1. expenses
2. income
3. savings
4. bills
5. budgets
6. recurring entries
7. categories
8. needs or wants labels
9. merchant names
10. transaction dates and times
11. currencies
12. payment methods
13. notes
14. goals
15. planned spending
16. spending reflections
17. totals, summaries, and historical records
You choose what information to enter into Buzzle.
2.4 Receipt and Scan Information
If you use receipt scanning or upload receipt images, we may collect and process:
1. receipt images
2. extracted receipt text
3. merchant name
4. branch or location shown on the receipt
5. receipt date and time
6. items purchased
7. quantities
8. prices
9. discounts
10. taxes
11. totals
12. currency
13. receipt number
14. payment method shown on the receipt
15. OCR or AI extraction results
16. corrections you make to extracted receipt data
Receipts may contain personal data. You should only upload receipts you are comfortable storing and processing in Buzzle.
2.5 Reflection, AI Chat, and Interaction Data
If you use AI, reflection, chat, or insight features, we may collect:
1. messages or questions you submit
2. AI-generated responses
3. spending summaries
4. recommendation history
5. feedback on AI responses
6. conversation metadata
7. prompts or context used to generate responses
8. safety, moderation, or diagnostic logs
2.6 Usage and Analytics Data
We may collect information about how you use Buzzle, including:
1. screens viewed
2. buttons tapped
3. features used
4. time spent in the app
5. onboarding completion
6. subscription interactions
7. receipt scan usage
8. AI feature usage
9. error events
10. crash logs
11. performance logs
12. diagnostic data
13. feature engagement patterns
2.7 Device and Technical Information
We may collect technical information such as:
1. device model
2. operating system
3. app version
4. browser type, if using the web app
5. IP address
6. language settings
7. region settings
8. device identifiers where permitted
9. session identifiers
10. network information
11. log data
12. security events
2.8 Payment and Subscription Information
If you purchase a paid subscription or start a free trial, payment providers or app stores may process your payment information.
We may receive limited billing information such as:
1. subscription plan
2. subscription status
3. free trial status
4. renewal date
5. cancellation status
6. payment provider customer ID
7. transaction ID
8. payment status
9. billing email
10. country or tax region where necessary
We do not store full credit card numbers or complete payment credentials.
2.9 Support and Communications
If you contact us, we may collect:
1. your name
2. email address
3. support messages
4. screenshots or files you send
5. issue details
6. device and app information relevant to support
7. communication history
3. How We Collect Information
We collect information:
1. directly from you when you enter it into Buzzle
2. automatically when you use Buzzle
3. from your device or app environment
4. from payment providers or app stores
5. from third-party services used to operate Buzzle
6. from support communications
7. from AI, OCR, analytics, and security systems
4. How We Use Information
We may use information for the following purposes.
4.1 To Provide and Operate Buzzle
We use information to:
1. create and manage your account
2. save your financial entries
3. display your diary, wallet, reflection, and settings
4. process receipts
5. generate summaries and insights
6. manage budgets and currency settings
7. sync data across devices
8. provide app features
9. process subscriptions
10. provide customer support
4.2 To Personalize Your Experience
We may use your profile, onboarding answers, financial entries, usage patterns, and preferences to personalize:
1. AI responses
2. Buzzly messages
3. spending summaries
4. suggested categories
5. insights
6. reminders
7. tips
8. app defaults
9. paywall messaging
10. feature recommendations
4.3 To Provide AI and OCR Features
We may process your data through AI, machine learning, OCR, or similar technologies to:
1. extract information from receipts
2. classify expenses
3. generate reflections
4. answer questions about your spending
5. summarize habits
6. provide suggestions
7. detect patterns
8. improve feature accuracy
AI and OCR outputs may be inaccurate. You are responsible for reviewing important information.
4.4 To Improve and Develop Buzzle
We may use information to:
1. understand how users interact with Buzzle
2. fix bugs
3. improve performance
4. improve design and user experience
5. develop new features
6. test features
7. train, evaluate, or improve internal systems where permitted
8. measure engagement
9. improve AI, OCR, categorization, and personalization
4.5 To Create Aggregated, Anonymised, or De-Identified Insights
We may create aggregated, anonymised, or de-identified information from app usage, financial behaviour patterns, receipt data, onboarding answers, AI interactions, and other data.
We may use such information to:
1. create benchmarks
2. identify general spending trends
3. understand user behaviour
4. improve Buzzle
5. conduct research
6. develop commercial insights
7. create reports
8. support partnerships
9. share general trends with partners, researchers, businesses, or other third parties
10. develop new products, services, analytics, models, or features
We do not intend for aggregated, anonymised, or de-identified information to identify you personally.
4.6 To Communicate With You
We may use your information to:
1. send app notices
2. respond to support requests
3. send security alerts
4. notify you about changes
5. send billing or subscription updates
6. send product updates where permitted
7. request feedback
4.7 To Protect Buzzle and Users
We may use information to:
1. detect fraud
2. prevent abuse
3. secure accounts
4. investigate suspicious activity
5. enforce our Terms
6. protect our rights
7. comply with law
8. respond to lawful requests
5. Legal Bases and Consent
Where required by applicable law, we rely on one or more lawful bases to process personal data, including:
1. your consent
2. performance of a contract with you
3. compliance with legal obligations
4. legitimate business interests
5. protection of rights, safety, security, and fraud prevention
6. other bases permitted by applicable law
Where we rely on consent, you may withdraw consent where applicable. Withdrawal of consent may affect your ability to use certain features.
6. How We Share Information
We do not sell or rent your personal information.
We may share information in the following circumstances.
6.1 Service Providers
We may share information with service providers who help us operate Buzzle, including providers for:
1. cloud hosting
2. database storage
3. authentication
4. analytics
5. crash reporting
6. AI processing
7. OCR processing
8. payment processing
9. subscription management
10. email delivery
11. customer support
12. security
13. data backup
14. app infrastructure
These service providers may process information on our behalf, subject to applicable contractual, technical, and legal safeguards.
6.2 Payment Providers and App Stores
If you purchase a subscription, payment providers or app stores may process payment information.
We may share or receive limited data necessary to manage subscriptions, verify purchases, prevent fraud, process refunds, and provide paid features.
6.3 AI and OCR Providers
Where necessary to provide AI or receipt scanning features, we may send relevant information to AI or OCR service providers for processing.
This may include receipt images, extracted text, expense entries, notes, onboarding answers, chat messages, or context necessary to generate a response or feature.
6.4 Legal and Compliance
We may disclose information if we believe in good faith that disclosure is necessary to:
1. comply with law
2. respond to lawful requests
3. protect our rights
4. enforce our Terms
5. prevent fraud or abuse
6. protect users or the public
7. respond to legal proceedings
8. investigate security incidents
6.5 Business Transfers
If Lu’lu’a Digital is involved in a merger, acquisition, investment, financing, restructuring, partnership, sale of assets, insolvency process, or similar transaction, information may be transferred, disclosed, or evaluated as part of that transaction.
Information may be treated as a business asset, subject to applicable law and reasonable safeguards.
6.6 Aggregated, Anonymised, or De-Identified Information
We may disclose, license, share, commercialize, or otherwise make available aggregated, anonymised, or de-identified information that does not reasonably identify you.
This may include general behavioural insights, market trends, usage statistics, spending patterns, benchmarks, reports, or research outputs.
7. What We Do Not Share for Third-Party Marketing
We do not share your individual financial diary, receipts, notes, account details, reflection chats, or identifiable personal data with third parties for their own direct marketing purposes without your consent.
We do not allow third parties to directly contact you using your identifiable personal financial data unless you have agreed or the law permits it.
8. Data De-Identification
We may use techniques intended to remove or reduce the ability to identify you from information, including aggregation, anonymisation, pseudonymisation, hashing, generalisation, suppression, or other technical and organisational measures.
No method of de-identification is perfect. However, we will take reasonable steps designed to prevent de-identified information from being used to identify you, where required by law.
9. Data Retention
We retain personal data for as long as necessary to:
1. provide Buzzle
2. maintain your account
3. provide support
4. comply with legal obligations
5. resolve disputes
6. enforce agreements
7. prevent fraud
8. maintain security
9. keep backups
10. maintain business records
11. improve and develop Buzzle
Expense and diary data is generally retained while your account is active unless you delete it or request deletion.
If you delete your account, we will delete or de-identify personal data associated with your account unless retention is required or permitted for legal, billing, tax, security, fraud prevention, backup, dispute resolution, or legitimate business purposes.
Aggregated, anonymised, or de-identified information that no longer reasonably identifies you may be retained and used after account deletion.
10. Data Security
We use reasonable administrative, technical, and organisational safeguards designed to protect personal data against unauthorized access, collection, use, disclosure, copying, modification, disposal, loss, and similar risks.
These safeguards may include encryption in transit, secure cloud infrastructure, access controls, authentication, monitoring, and other measures.
However, no method of transmission or storage is completely secure. We cannot guarantee absolute security.
You are responsible for keeping your login credentials secure.
11. International Transfers
Your information may be processed, stored, or transferred outside Brunei Darussalam or your country of residence.
Data protection laws in those countries may differ from the laws of your country.
Where required, we will take reasonable steps to ensure that cross-border transfers are made in accordance with applicable data protection requirements.
12. Data Breaches
If we become aware of a security incident involving personal data, we will take reasonable steps to investigate, contain, and address the incident.
Where required by law, we will notify affected users, regulators, authorities, or other relevant parties.
13. Your Rights
Depending on applicable law, you may have rights to:
1. request access to your personal data
2. request correction of inaccurate or incomplete personal data
3. request deletion of personal data
4. withdraw consent where processing is based on consent
5. request information about how your personal data is used or disclosed
6. object to or restrict certain processing where applicable
7. request a copy or export of certain data where available
8. close your account
9. lodge a complaint with an appropriate authority where applicable
Brunei’s PDPO includes individual rights relating to access and correction of personal data, and obligations around protection, retention, and transfers of personal data outside Brunei.
To exercise your rights, contact us at support@luluadigital.com.
We may need to verify your identity before responding.
We may decline, limit, or charge for requests where permitted by law.
14. Updating Your Information
You may update certain information directly in Buzzle, including profile details, onboarding answers, app format settings, and some account preferences.
If you cannot update information directly, you may contact us.
15. Optional Information
Some information is optional.
If you choose not to provide optional information, certain features, suggestions, AI responses, or insights may be less personalized.
You may update optional information in the app where available.
16. Children’s Privacy
Buzzle is not directed to children under 13.
We do not knowingly collect personal data from children under 13 without appropriate consent.
If we learn that we have collected personal data from a child under 13 without required consent, we will take reasonable steps to delete such information.
17. Third-Party Links and Services
Buzzle may contain links to third-party websites, app stores, payment platforms, legal pages, or services.
We are not responsible for the privacy practices of third parties. You should review third-party privacy policies before providing information to them.
18. Marketing Communications
We may send you service-related messages such as account notices, security alerts, billing updates, and important app notices.
Where permitted, we may send product updates, offers, or promotional messages.
You may opt out of promotional communications where required by law. You may still receive service-related messages.
19. Automated Decision-Making
Buzzle may use automated systems to generate summaries, categorize expenses, suggest insights, personalize experiences, detect usage patterns, or identify potential issues.
These automated outputs are informational only and should be reviewed by you. We do not intend for automated outputs to make legally binding or similarly significant decisions about you.
20. Changes to This Privacy Policy
We may update this Privacy Policy from time to time.
If changes are material, we will take reasonable steps to notify you, such as by posting the updated Policy in Buzzle, showing an in-app notice, or contacting you where appropriate.
Your continued use of Buzzle after the updated Policy takes effect means you acknowledge the updated Policy.
21. Contact Us
If you have questions, requests, or concerns about this Privacy Policy or how your information is handled, please contact:
Lu’lu’a Digital
Email: hello@luluadigital.com