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Privacy Policy

Our privacy commitment

In support of Lucero Speaks’ mission to help
teens, teens, and caregivers find sanctuary and experience a journey of
self-discovery (we call this an “
using our online wellness app and content, we are committed to protecting the
privacy of our users and providing a safe, online environment. Lucero Speaks is
committed to only collecting from Teen, Tween, or Caregiver Explorers (we
describe in more detail the various users of our app below) the information
needed to make each child’s Exploration their own and make it as good as
possible and permit a Teen, Tween or Caregiver of a Tween to share progress of
that Teen or Tween with any Explorer within that youth’s online group (“

Lucero Speaks does not allow third-party
advertising in an Exploration, and Lucero Speaks does not sell, lease, or
otherwise trade for value any personal information of any App Users.  App User
information is only used to provide and improve our App.

This Privacy Policy describes the way in
which Lucero Speaks, LLC (who we call “
Lucero Speaks,
we” or “us”)
collects, uses, discloses, and safeguards personal information provided to us by
children, parents, caregivers, guardians and others (who we call “App

Users” or “Explorers
” or “you”)
when they use our downloadable app or any other location that links to this
Privacy Policy (we refer to this as the “

Table of Contents

  1. Types of App User
    information we collect
  2. How we use App User
  3. How we share App User
  4. How we protect App User
  5. Users’ rights regarding
    their information
  6. Lucero Speaks and
    children’s information privacy
  7. Storage and retention of
    App User information
  8. Updates to this policy
  9. How to contact us

  1. Types of User information we collect 

We collect certain information from App
Users, depending on the type of App User who is using the App.  These are the
types of App Users:

  • Caregiver Explorer
    or “
    Caregivers” (parents and
    guardians of Tween and Teen Explorers).
  • Tween Explorers
    or “
    Tweens” (a child below the
    age of 13 who uses the App).
  • Teen Explorers
    or “
    Teens” (a child 13 and
    above who uses the App).
  • Crew Captain
    (a Parent or Legal Guardian of a Teen or Tween Explorer in the Crew who
    administers a Crew). 

A Caregiver, Tween or Teen Explorer account will be linked to a Crew through invitation by a Crew Captain (and acceptance by the Caregiver, Tween or Teen). A Teen or Tween Explorer may or may not be linked to a Crew, as elected by that Teen or Tween Explorer.  With respect to Tweens only, any parent or other legal guardian of a Tween, whether or not that person is a Caregiver Explorer, must approve a Tween creating an account and starting to use the App, and that parent or legal guardian can request access to the information in that Tween’s  account.

More information on each type of account can
be found in our Terms of Use.

Information Collected From Users 

We collect information from App Users when
they send it to us. For example, when you accept an invitation to join a Crew
and create an account, provide a response to a prompt in the Exploration, or
otherwise contact us with a customer support question, chat, comment, or
request, we may collect and use this information you provide as more detailed


If you submit any information relating to
other people in connection with your use of the Services, you are telling us
that you have the authority to do that and you permit Lucero Speaks to use and
share the information in accordance with this Privacy Policy.

Teen or Tween Explorers

We collect information about Teen or Tween
Explorers when a Teen or Tween Explorer establishes an account, either by (i)
being invited to join a Crew and to create an account by the Crew Captain (in
the case of a Tween, with approval of the Tween’s parent or guardian, whether or
not that parent or guardian is a Caregiver Explorer), (ii) when a Teen Explorer
creates an account on their own, or (iii) when a Tween Explorer creates an
account on their own with approval of the Tweens parent or guardian. We are
committed to collecting the minimum amount of information about Teens or Tweens
as is needed to operate the App. 

When a Lucero Speaks Teen or Tween Explorer
account is created, we collect the Teen or Tween’s:

  • Email Address
  • Password
  • Username
  • Crew name if there is one

Teen and Tween Explorers will create their own unique username.  Usernames are used to log in but are not visible to other App Users except for Tween and Teen Explorers and/or Caregivers within the same Crew.  After creating a username, the Teen or Tween Explorer then selects a fictional avatar name and appearance from a list of options, which are the only ways that Explorers are differentiated within a Crew.   

Caregiver Explorers

When registering with Lucero Speaks,
Caregivers are asked to provide personal information consisting of email
address, username, and a password for their account. Lucero Speaks may
also collect from Caregivers the information listed under the

Teen or Tween Explorers section
above regarding Teen or Tween Explorers associated with Caregivers for purposes
of linking the Teen or Tween and Caregiver accounts in the same Crew.  As with
Teen and Tween Explorers, Caregiver Explorers will create their own unique
username,  fictional avatar name and appearance from a list of options.

For Caregiver Explorers with a paid
membership, we may also collect payment information. Note, Lucero Speaks does
NOT directly store credit card information — all credit card information and
transactions are stored by our third-party payment providers, such as the app
store through which you purchased your membership. 

Information Collected From Devices and Use
of the App

Exploration Results

As Teens or Tweens use the App, we collect
information on the features they interact with, social and emotional skills they
encounter, and questions answered (“
Exploration Results”).
This information could include, but is not limited to, data on which activities
a Teen or Tween completes, Lucero Speak created content that Teens or Tweens can
send back and forth — like an image that says “You are awesome!”, and log
entries from their Exploration, such as “What I like to do when I feel happy”
and “Things that help when I am feeling stressed”.  As described further in the
next section, we use Exploration Results to customize a Teen or Tween’s
Exploration and for analysis (but only after being de-Identified or aggregated
as described

Certain Exploration Results are shared with all Explorers in a Crew such as the number of spins on a feature called spark, what island/day an Explorer is on in an Exploration/Journey, and what badges they have earned. Other components of a Tween’s or Teen’s Exploration Results may be visible to their parent or legal guardian  and made available by their parent or legal guardian to Caregiver(s) in the Crew to allow for monitoring of the Teen or Tween’s progress.   Explorers each have the option to share other Exploration Results with other Explorers within their Crew, in addition to the basic Exploration Results we discuss above which are shared automatically with the rest of the Crew.    

Device data and information collected by
technology (e.g., cookies)

Like most websites and online services,
Lucero Speaks automatically collect certain technical information from your
computer or mobile device over time and across different websites when you use
the App, such as your IP address, your browser type, your operating system, the
pages you view on the App, the pages you view immediately before and after you
access the App, and other information about your use of the App. All of this
information may be collected through use of “cookies,” which are small text
files that the App save on your computer using your web browser and access when
you return, and other similar technologies, like “pixel tags,” which are pieces
of code placed on a web page that can collect information about whether a User
has been to a certain web page or clicked on a specific advertisement.

The information collected through these technologies includes information about the way you arrive at and use our website, products and services, including the pages you visit, the links you click, how frequently you access the product, or whether you open emails or click links contained in the emails we send you. It also includes information about high-level geographic location, such as a User’s state or region as approximated by the User’s IP address, for reasons such as associating a User with the appropriate Exploration, product improvement, and sending locally relevant marketing communications to Caregivers. We and our third-party providers also collect analytics data, for example through the use of tools such as Google Analytics, to measure traffic and usage trends for the website and to understand more about the demographics and behaviors of our Users. We also use third-party advertising providers to collect information about Caregivers who visit areas of the App that are not directed to Teen or Tween Explorers. This includes information used to deliver interest-based advertising to Caregivers, including advertising for our App, when those Users visit third-party websites, and provide us with statistics about the effectiveness of our advertising on third-party websites.

We and our third-party providers may use the information collected through these technologies for the purposes described in this Privacy Policy, including delivering content, analyzing our Users’ experience on the App, and delivering advertising to Caregivers when they visit other websites and applications. Cookies and these other technologies placed within the Lucero Speaks Game or within other areas of the App directed to Teen or Tweens will be used only in support of the Service’s internal operations, like providing access to the Games and their features, individualizing content, and improving and optimizing the App. We do not allow third-party targeted advertising providers to collect information from the Teen or Tween-directed portions of the App.    

Information from Third Parties

We may obtain information about you or your
use of the App from third parties and sources, such as our vendors, like single
sign-on providers you can use to log into the App, web hosting providers, or
analytics providers. In certain circumstances, you may give us permission to
access your information from some of these services offered by third parties.
The information we obtain from third-party services depends on your
account/privacy settings with those third parties and the third parties’ privacy
policies. You are responsible for reviewing the privacy policies of these third
parties and adjusting your settings to meet your preferences. When you access
the App through third-party platforms, you are authorizing us to collect, store,
and use such information and content in accordance with this Privacy Policy.
Please keep in mind that any information provided to us by a third party may
also be subject to that third party’s privacy policy.

  1. How we use User information

How we use Caregiver information

We use the Caregiver information we collect for the following purposes:

  • To allow Caregivers to register for and use the App, such as when you securely log
    into your account, to send a communication about a Tween’s progress or a
    Tween’s account, or provide feedback to us. For confidentiality purposes,
    information we gather about a Tween’s Exploration (other than certain
    Exploration Results noted

    about a Tween is only provided to a Caregiver Explorer who is the Tween’s
    parent or guardian.
  • To process payments. 
  • To communicate with Caregivers, Tweens, and
    Teens regarding your account, including providing
    information about changes to the Terms of Use or Privacy Policy, updates
    regarding our services, security alerts, communication about your linked
    Teen or Tween’s progress or account, or responses to customer support
  • To send marketing communications of
    potential interest to Caregivers. You can choose
    to stop receiving marketing emails from us by following the instructions
    contained in these emails. 

How we use Explorer

We use the Explorer information
we collect for the following purposes:

  • To measure a Teen or Tween’s Exploration
    Results and provide certain Exploration Results to Caregiver on a Crew as described

  • To adapt, personalize, and customize the
    Teen or Tween Explorer experience to the Teen or Tween’s learning needs.

No advertisements are delivered by Lucero
Speaks to Teen or Tweens through the Service.

How we use all User information

We use all User information we collect for
the following purposes:

  • To monitor, maintain, analyze and improve
    the functionality of the App.
  • To assess and improve the products and
    services and its content, and to improve the user experience.
  • As we believe to be necessary and
    appropriate to comply with applicable laws and regulations; to comply with
    legal process; to respond to requests from governmental authorities; to
    detect violations of and enforce our Terms of Use; to protect the security
    of the website, products and services; to protect the rights, privacy,
    property, or safety of Lucero Speaks, you, or others; and to allow us to
    pursue any available remedies or to limit damages that we may sustain.

De-Identified or Aggregated Information

From the information collected through the
Services, Lucero Speaks may create de-identified or aggregated data. What this
means is we remove certain identifiers and delineative features of the data
collected that make it personally identifiable to a particular User so that it
no longer allows a User to be directly or indirectly identified. We may use or
disclose such de-identified or aggregated data for lawful and legitimate
business purposes, including to analyze, build and improve the Services and
promote our business. When we share such information, it will not be shared in a
way that could be used to identify a User.

  1. How we share User information

We only share information collected in
limited circumstances. We do not disclose the personal information of Teen or
Tweens to third parties for marketing or promotional purposes.

We share User information with third parties
as follows:

  • Where a Teen or Tween Explorer account is
    linked to a Caregiver, that Teen or Tween Explorer’s
    information will be shared with the Caregiver as
    discussed above.
  • To third parties that perform certain
    services for us such as analytics, credit card processing, or research or
    evaluation of the App, provided those service providers agree to safeguard
    the information, keep it confidential, and use it only for the purposes
    permitted by our agreements.
  • To inform or support the consideration,
    negotiation, or completion of a possible merger, sale, financing or transfer
    of all or a portion of our business to another entity. If some or all our
    assets are acquired or otherwise transferred or licensed, including in
    bankruptcy, Lucero Speaks shall take reasonable steps to subject such
    acquirer to the same commitments stated under this Privacy Policy. 
  • While unusual, where you have instructed us
    to share the information, for example, to support inquiries either at your
    direction or with your informed consent.
  • As we believe to be necessary and
    appropriate to comply with applicable laws and regulations; to comply with
    legal process; to respond to requests from governmental authorities; to
    detect violations of and enforce our Terms of Use; to protect the security
    of the website, products and services; to protect the rights, privacy,
    property, or safety of Lucero Speaks, you, or others; and to allow us to
    pursue any available remedies or to limit damages that we may sustain.
  1. How we protect User information

The User information we collect is stored and
processed in environments designed to allow only authorized individuals to
access the infrastructure where this information is stored. Because we
understand and respect the trust placed in us to properly protect your
information, Lucero Speaks takes great care to maintain commercially reasonable
standards of data security and protection and continues to implement those
measures for our infrastructure where User information is stored.

Lucero Speaks and its service providers
maintain strict administrative, technical, and physical measures designed to
safeguard the information we process. We use industry-standard SSL encryption
when collecting or transferring your information. Other safeguards include but
are not limited to data encryption, firewalls, multi-factor authentication for
our personnel with access to your information, and physical-access controls.

You can protect against unauthorized account
access by selecting and protecting passwords appropriately, including using
unique, multi-character passwords, ensuring devices are only accessed by those
authorized to use them and taking care to sign out of online accounts (not just
Lucero Speaks, but all online accounts) after you or your Teen or Tween
Explorers are finished using them. Access to information associated with User
accounts is limited to those Lucero Speaks staff members who require such access
to support our App, who are designated and trained to maintain the security and
confidentiality of User information.

  1. Users’ rights regarding their information

Access, correction or deletion of

Caregiver Explorers
have the right to access, correct or delete their personal information which is
collected and used by Lucero Speaks. Personal information can be accessed and
changed by contacting our customer support at
. You also
can access and review certain account-related details by logging into your
online account. 

Caregiver Explorers of a Tween or a Tween may contact our customer support at any time to
request access to, deletion of, or correction of any personal information we
have collected from or about their Tween Explorer child associated with their
account, including a request to us to cease collecting personal information from
those Tween Explorers. Please be aware a request to delete or cease collecting
personal information may lead to closing of the relevant User’s account or the
inability to use the products or App or certain portions of the products or
App.  If a Teen who is 16 years old or younger is a citizen of the European
Union, a parent or legal guardian of that Teen can also contact us for the above

When a correction, deletion or other change
to Teen or Tween Explorer personal information is requested and validated,
Lucero Speaks will make the correction, deletion or other change as soon as
reasonably practicable and in accordance with privacy laws.    

Upon request by an Explorer, we will delete the Explorer from the Crew.

Opting out of email communications

You can opt out of receiving commercial or
promotional emails from Lucero Speaks by following the unsubscribe instructions
indicated in the email, manage your communication preferences or by contacting
customer service. Lucero Speaks communication preferences can be managed through
our preference center, available through a link in the footer of our commercial
or promotional emails, through which App Users can specify which types of
communications they would like to receive.

California privacy rights

California law also grants its residents
certain rights regarding the collection and use of their personal information. 

Subject to certain limitations, California
residents have the following rights:

  • Right to know.
    You have the right to know and request information about the categories and
    specific pieces of personal information we have collected about you within
    the last 12 months, as well as the categories of sources from which such
    information is collected, the purpose for collecting such information, and
    the categories of third parties with whom we share such information. You
    also have the right to know if we have sold or disclosed your personal
  • Right to delete. You
    have the right to request the deletion of your personal information, subject
    to certain exceptions. 
  • Right to opt out.
    You have the right to opt out of any sales of your personal information.
    Note that while Lucero Speaks does not monetize the personal information of
    any User of the App by providing it to a third party in exchange for money
    (except in the context of a potential sale of the company), California law
    has a broader definition of the term “sell” which includes making user
    information available to a third party for the purposes of targeted
    advertising. As described above, when we work with our advertising partners,
    we allow them to collect information about Caregiver Explorers who visit areas of the App that are not directed to Teen or
    Tween Explorers. These Caregiver Explorers can
    direct us to stop allowing the collection of their information in this way
    by opting out of cookies through our cookie preference center, accessible
    within the footer of our website at By contrast,
    Speaks does not sell, lease or otherwise trade for value any personal
    information of Teen or Tween Explorers, including within the Games
  • Right to not be
    discriminated against
    . You have the
    right to be free from discrimination for exercising these rights. Please
    note that if the exercise of these rights limits our ability to process
    personal information we may no longer be able to provide you with our
    products and services. 

If you are a California resident and would
like to exercise any of these rights, please submit an email request to
  with the
subject line, “California Rights Request.” We may need to verify your identity
before processing your request, which may require additional personal
information from you, or that you log into your Lucero Speaks account. In
certain circumstances, we may decline or limit the scope of our compliance with
your request, particularly where we are unable to verify your identity or locate
your information, or as permitted by law. 

If you are submitting a request through an
authorized agent, the authorized agent must provide us with your signed written
permission stating that the agent is authorized to make the request on your
behalf. We may also request that any authorized agents verify their identity and
may reach out to you directly to confirm that you have provided the agent with
your permission to submit the request on your behalf. 

Users resident in the European Economic
Area (EEA), United Kingdom, and Switzerland

If you are a resident of the EEA, UK, or
Switzerland, the following information applies with respect to personal
information (or personal data) collected through your use of our App. As noted
above, Lucero Speaks processes personal information consistent with our
disclosures in this Privacy Policy.

We process personal information on the
following legal bases:

  • With your consent
  • As necessary to Lucero Speaks to perform its
    obligations under the App Terms of Use.
  • As necessary for our legitimate business
    interests to provide the App where those interests do not override your
    fundamental rights and freedoms related to data privacy.

Note, the information we collect may be
transferred, stored and processed in Canada and the United States or any other
country where we or our processors maintain offices. We will work to make
transfers of personal information to a third country or an international
organization subject to appropriate safeguards under applicable law.

You are entitled to the rights under Chapter
III of the EU General Data Protection Regulation and the UK GDPR, or Section 2
of the Swiss Federal Act on Data Protection concerning the processing of your
information, which includes rights to access, correct, delete, restrict or
object to our use of, or receive a portable copy of your personal information.
You also have a right to lodge a complaint with your local data protection
regulator. To make a request or otherwise exercise your rights, please contact
us at

. To honor such a request, we will need to verify your identity and residency,
which may require additional supporting information.

  1. Lucero Speaks and children’s information privacy

In our commitment to protect the privacy of
children, Lucero Speaks does not ask for or require children to provide personal
information beyond that which is reasonably necessary to support the operation
of Lucero Speaks’ App. Information collected from our Teen or Tween Explorers is
never disclosed for third-party advertising or any kind of behaviorally targeted
advertising. For information on how consumers can ask questions or file
complaints related to Lucero Speaks’ Privacy Policy and practices, please email


  1. Storage and retention of User information

Information collected through the App may be
transferred, stored and processed in Canada and the United States or any other
country where we, or affiliates, or our processors maintain offices, which may
not provide the same level of protection for your personal information as your
country, state, or province of residence, in which case it will be subject to
and may be available to the government under the laws of that jurisdiction,
including law enforcement, regulatory, and national security authorities.  

We retain your personal information for as
long as we have a relationship with you, although we retain the right to delete
User accounts after a period of inactivity. After our relationship has ended, we
also may retain your personal information for as long as required by law or to
investigate or defend against potential legal claims.

  1. Updates to this policy

If we update this Privacy Policy, we will
notify you by posting a new Privacy Policy on this page and updating the Last
Modified date at the bottom of this policy. If we make any changes that
materially change the ways we process or protect your information going forward,
we will provide additional notification of changes. If we make any revisions
that materially change the ways in which we use or share the information
previously collected from you through the App, we will give you the opportunity
to consent to such changes before applying them to that information.

  1. How to contact us

If you have questions or concerns regarding
the way in which your personal information has been used, please contact us at

, or by mail at 501 Congress Avenue, Suite 150, Austin, Texas, 78701.

Last Modified Date: November 25, 2022