Privacy Policy

Who we are

Lugji is developed and operated by Lugji Limited / 錄記有限公司, a Hong Kong company. Contact: info@lugji.app.

Core principle: Lugji has no servers — your content never reaches Lugji

Lugji is built on one premise: Lugji operates no servers; your meeting content, audio, and encryption keys are never transmitted to Lugji and Lugji cannot access them. This isn’t a policy promise; it’s a structural fact of how the product is built.

Recording: audio files are stored locally on your iPhone.
Speech-to-text: uses Apple’s built-in on-device speech recognition, performed on the device.
AI summaries: in the current version, processed entirely on your device using Apple’s built-in models (Foundation Models) — not using Apple’s servers / Private Cloud Compute, and not using any cloud.
Organising & writing: the transcript is turned into Markdown, given a date and tags, and written into the Obsidian vault you choose (in your own iCloud Drive, under your control).

For transparency: AI features run entirely on-device in the current version. A future version may use Apple’s Private Cloud Compute (Apple-operated, privacy-preserving servers); if introduced, we will disclose it explicitly. Whatever the technology, your content never reaches Lugji.

What we collect

Email signup (this website)

Purpose: to send you Lugji product updates and news, and nothing else (per HK PDPO Data Protection Principle 1).
Lawful basis: your explicit consent, via double opt-in.
We collect only your email address. We do not track clicks.
We use a third-party email service provider (Buttondown) to send communications; your email address is processed by that provider under its own privacy policy.
You can unsubscribe at any time using the link in every email.

Contact form (this website)

Purpose: to respond to enquiries you submit via our contact / enterprise-enquiry form, and nothing else.
Lawful basis: your explicit consent (by submitting the form).
We collect: name, email, company (optional), phone (optional), and your message.
We use a third-party form-delivery service (Web3Forms) to receive submissions; the data is processed by that provider under its own privacy policy and forwarded to us by email.
We use this data only to respond to your enquiry; it is not used for marketing and not sold.

iOS app

Recordings, transcripts, and notes stay primarily on your device and your own iCloud Drive; we cannot access them.
iCloud is a service provided by Apple Inc., and its data handling is governed by Apple’s privacy policy.

Analytics

This website uses Cloudflare Web Analytics (privacy-friendly, cookieless).
Cloudflare may receive limited technical data (e.g. IP address, browser type, and page-view information) to provide traffic statistics, processed under its own privacy policy.
We do not use Google Analytics.

What we don’t do

We don’t sell data.
We don’t track you across sites.
We don’t share your email with third parties for their own purposes.
We don’t fingerprint devices.

Children

The Service is not directed at children under 13, and we do not knowingly collect children’s personal data.

If HK PDPO applies to you, you reside in the EU (GDPR Articles 13–22), or you are a California resident (CCPA), you have the following rights:

Access, Rectification, Erasure, Restriction, Data Portability, and Objection.
(CCPA) the right to know what personal data is collected, to request deletion, and not to be discriminated against for exercising your rights. We do not sell your personal data.
Right to lodge a complaint with a supervisory authority:
- Hong Kong: Office of the Privacy Commissioner for Personal Data (PCPD) — pcpd.org.hk
- EU: the Data Protection Authority in your country of residence

To exercise any right, email info@lugji.app; we will respond within 30 days.

Cookies

This website does not use tracking cookies.

Data retention

Email subscribers: until you unsubscribe. After you unsubscribe, we may retain necessary records for a reasonable period to demonstrate that consent was obtained and to comply with legal obligations.
App users: data is stored on your device and your iCloud; we have no access and no copy to retain.

International data transfer

Some of our service providers (e.g. the email service Buttondown, the form-delivery service Web3Forms, the website infrastructure Cloudflare) may process data outside Hong Kong. Where applicable, we take reasonable steps to ensure such transfers comply with applicable data-protection laws.

Data breach notification

In the event of a security incident affecting personal data we hold (e.g. email subscriber data), we will provide notification in accordance with applicable laws and regulatory requirements.

Legal basis (summary)

HK Personal Data (Privacy) Ordinance (PDPO)
EU General Data Protection Regulation (GDPR, where applicable)
California Consumer Privacy Act (CCPA, where applicable)
Email collection: explicit consent via double opt-in

Policy updates

Any material change will be communicated to subscribers by email and the effective date updated.

Lugji Limited / 錄記有限公司 Registered office: Unit 2904-05, 29/F, Universal Trade Centre, 3 Arbuthnot Road, Central, Hong Kong Contact: info@lugji.app

Effective date: 17 May 2026

Last updated: 14 June 2026