Privacy Policy
1. Data Controller
This Privacy Policy applies to services provided by:
- Bluegate Studio, a trading name of Luinannon OÜ
- Registry code: 17535432 (Estonian Commercial Register)
- Address: Tornimäe tn 5, Kesklinna linnaosa, Tallinn, Harju maakond, 10145, Estonia
- Email: studio@luinannon.com
2. Services Overview
Bluegate Studio is a software development company that builds and operates mobile and web applications for its clients. As part of these services, Bluegate Studio provides SMS-based two-factor authentication (2FA) and one-time passcode (OTP) verification to end users of its client applications.
3. Data We Collect
In connection with our SMS messaging services, we collect and process the following data:
- Mobile phone number: Provided by the end user during account registration in a client application.
- Messaging consent status: Whether the end user has opted in to receive SMS verification codes.
- Message delivery metadata: Delivery status and timestamps, used solely for service reliability and troubleshooting.
4. How We Use Your Data
Your mobile phone number and related data are used exclusively for the following purposes:
- Sending one-time passcodes (OTPs) for account login and identity verification.
- Sending verification codes for password resets and security checks.
- Maintaining delivery logs for service reliability.
We do not use your mobile phone number or messaging data for marketing, advertising, or promotional purposes.
5. SMS Messaging Disclosure
By providing your phone number and giving explicit consent during registration in one of our client applications, you agree to receive SMS messages containing one-time passcodes (OTPs) for authentication and account verification purposes.
- Message frequency: Messages are sent only when you initiate a login, password reset, or identity verification request. No recurring or scheduled messages are sent.
- Message and data rates may apply depending on your mobile carrier and plan.
- Opt-out: You may opt out at any time by replying STOP to any message received from us. You will receive a confirmation and no further messages will be sent.
- Help: Reply HELP to any message for assistance, or contact us at studio@luinannon.com.
6. Data Sharing and Non-Disclosure
We do not share, sell, or provide your mobile phone number or messaging consent data to third parties or affiliates for marketing or promotional purposes.
Your phone number is shared only with the following third-party service provider, solely for the purpose of delivering SMS verification codes:
- Twilio Inc. (San Francisco, CA, United States) — SMS delivery infrastructure. Your phone number is transmitted to Twilio exclusively for OTP message delivery. Twilio's data processing is governed by their own Privacy Policy.
Personal data is not shared with any other third party, organisation, or affiliate beyond what is strictly necessary for the delivery of verification messages. Data is transferred at the minimum level required for service operation.
7. Data Retention
Your mobile phone number and messaging consent data are retained for as long as your account remains active in the relevant client application. Upon account deletion or opt-out, your data is removed from our messaging systems within 30 days, subject to any legal retention obligations.
8. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. All data transmissions to our SMS service provider are encrypted in transit.
9. Your Rights
Depending on your jurisdiction, you may have the following rights:
- Access the personal data we hold about you.
- Request correction of inaccurate data.
- Request deletion of your data.
- Object to or restrict processing of your data.
- Withdraw your consent to receive SMS messages at any time by replying STOP.
To exercise any of these rights, contact us at studio@luinannon.com.
10. Changes to This Policy
We may update this Privacy Policy from time to time. The "Last updated" date at the top of this page indicates when the policy was last revised. Continued use of our services after any changes constitutes acceptance of the updated policy.
11. Contact
If you have any questions about this Privacy Policy or our data practices, please contact us:
- Email: studio@luinannon.com
- Address: Tornimäe tn 5, Kesklinna linnaosa, Tallinn, Harju maakond, 10145, Estonia