Effective Date: 7th February, 2026

Last Updated Date: 11th February, 2026

1. Introduction

Welcome to Heirlune. We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how Slow Living LDN. Limited (“the Company,” “we,” “us,” or “our”) collects, uses, and safeguards your information when you use the Heirlune application (“the App”) and the services provided through it.

This policy is designed to comply with the Data Protection Act 2018, the UK General Data Protection Regulation (UK GDPR), the EU GDPR, and the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

2. Information We Collect

2.1. Categories of Personal Information

In the preceding 12 months, we have collected the following categories of personal information:

• Identifiers: Name, email address, unique user ID.
• Commercial Information: Subscription records and payment history (processed via third-party stores).
• Internet/Electronic Network Activity: App usage statistics and interaction with features. (via Google Analytics).
• Audio & Device Permissions: To provide core functionality, the App may request access to your device’s microphone and audio settings.
• Microphone Access: While our technical framework may request microphone permission to support media playback and background audio services, we do not record, collect, or store any voice or ambient audio data.
• Audio Playback: We process audio data locally on your device to facilitate the playback of meditations and soundscapes.
• Inferences: Preferences users share with us and behaviour patterns derived from usage data to improve meditation recommendations and user experience.

2.2. Tracking & Consent

We use Google Analytics to monitor and analyse usage. We only activate tracking technologies after you have provided explicit, affirmative consent. You may withdraw this consent at any time via the “Account” page within the App.

3. Legal Bases for Processing (UK/EU GDPR)

Under the UK GDPR, we process your data based on the following legal grounds:

• Performance of a Contract: To provide the meditations, journaling tools, and account management services as outlined in our Terms and Conditions.
• Consent: For non-essential tracking (Google Analytics) and any optional marketing communications you choose to receive.
• Legitimate Interests: To improve our services, ensure the security of the App, and prevent fraudulent activity.
• Legal Obligation: To comply with statutory requirements, such as UK tax and accounting laws.

4. Payment Processing

Payment is handled exclusively via the Apple App Store or Google Play Store. We do not “sell” or “share” your financial information. Your transaction data is subject to the privacy policies of the respective app store providers. We receive confirmation of payment but do not hold your credit or debit card details.

5. Third-Party Service Providers & Data Transfers

We utilise third-party providers to operate the App:

• Bubble Group, Inc: Infrastructure and database hosting.
• Google Analytics: Performance and usage analysis.

International Transfers: As the Company is based in the United Kingdom and uses US-based infrastructure (Bubble), your data may be transferred to and processed in the United States. 

6. California Privacy Disclosures (CCPA/CPRA)

• No Sale or Sharing: We do not “sell” your personal information for monetary consideration, nor do we “share” it for cross-context behavioural advertising.
• Sensitive Personal Information: We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

7. Your Rights

Regardless of your location, you have the following rights under UK and international law:

• Right to Access: Request a copy of the personal data we hold about you.
• Right to Erasure (Right to be Forgotten): Request that we delete your personal information, subject to certain legal exceptions.
• Right to Rectification: Request that we fix inaccurate or incomplete data.
• Right to Object/Restrict: Object to our processing of your data or request that we restrict how we use it.
• Right to Data Portability: Request a transfer of your data to another organisation.
• Right to Non-Discrimination: We will not provide a different quality of service if you choose to exercise your privacy rights.

8. Data Retention and Account Deletion

We retain your data only for as long as your account is active or as needed to provide you with the Services. To delete your account and all associated data, please contact us at the email address below. We aim to process erasure requests within 30 days.

9. Security

We implement industry-standard security measures provided by Bubble Group, Inc. You are responsible for safeguarding your account credentials and password.

10. Contact Us

To exercise your rights or for any queries regarding this policy, please contact us:

Data Controller: Slow Living LDN. Limited

Company Number: 15039908

Address: Street: 71-75 Shelton Street Covent Garden, London, WC2H 9JQ

Email: hello@slowlivingldn.com