Terms of Service

Last Updated: February 19, 2026

1. Acceptance of Terms

By accessing or using Lucilla ("the App"), you agree to be bound by these Terms of Service ("Terms"). If you do not agree to these Terms, do not use the App.

2. Eligibility

You must be at least 13 years old to use Lucilla. By using the App, you represent and warrant that you meet this age requirement. Users aged 13-17 may use all app features except paid step matches (see Section 6). Users must be 18 or older to participate in paid step matches due to financial contract and KYC/AML regulatory requirements (see Section 22 for details).

3. Account Registration

• You must provide accurate, current, and complete information during registration
• You are responsible for maintaining the confidentiality of your account credentials
• You are responsible for all activities under your account
• Notify us immediately of any unauthorized account access
• We reserve the right to suspend or terminate accounts that violate these Terms

4. Subscriptions & Payments

4.1 Subscription Plans

Early Bird Pricing (First 100,000 Users):

• Lucilla+: $9.99 USDC/month or $99.99 USDC/year
• Creator: $14.99 USDC/month or $150.00 USDC/year

Early bird pricing is available to all users who sign up within the first 100,000 accounts. After 100,000 users, prices transition to standard pricing below.

Standard Pricing (After 100,000 Users):

• Lucilla+: $11.99 USDC/month or $119.99 USDC/year
• Creator: $19.99 USDC/month or $199.99 USDC/year

Partner Pricing (Same as Standard — requires partner verification):

• Partner Lucilla+: $11.99 USDC/month or $119.99 USDC/year
• Partner Creator: $19.99 USDC/month or $199.99 USDC/year

Partner plans provide the same features and pricing as standard plans but require partner email verification or partner code redemption through a verified partner organization.

4.2 Billing & Payment Methods

• Subscriptions automatically renew unless canceled before the end of the current billing period
• Payment processing: All subscription payments are made exclusively with USDC from your Lucilla wallet (powered by Circle). Lucilla does not use Apple App Store, Google Play Store, or Samsung Galaxy Store in-app purchase systems for subscriptions — the app is free to download on all app stores
• How it works: Your Lucilla wallet is charged the subscription amount in USDC at the start of each billing cycle (monthly or annual). If your wallet has insufficient USDC balance at renewal time, your subscription will not renew and will revert to the free tier
• Auto-renewal: By subscribing, you authorize Lucilla to automatically deduct the applicable USDC subscription fee from your Lucilla wallet at the beginning of each renewal period until you cancel. You will receive a reminder notification before each renewal
• Prices are subject to change with 30 days' notice
• Refunds: Since payments are made in USDC on the Base blockchain, all transactions are final. No refunds for partial billing periods. If you believe a charge was made in error, contact us at social@lucilla.ca

4.3 Cancellation

• Cancel anytime through your account settings within the Lucilla app
• Cancellation takes effect at the end of the current billing period — you retain access to paid features until then
• No partial refunds for unused time
• After cancellation, your account reverts to the free tier. Your wallet balance, earned USDC, and content remain intact

5. USDC Wallet & Cryptocurrency

5.1 Wallet Services

Lucilla provides two types of wallets powered by Circle:

Agent Wallet (AI-Managed, Developer-Controlled)

• Purpose: Enable fast, seamless AI-powered transactions without requiring passkey confirmation each time
• How it works: Lucilla holds the wallet keys, allowing the app to automatically process transactions on your behalf
• Best for: Everyday transactions — joining competitions, purchasing content, tipping creators, buying event tickets
• Default limits: $100 per transaction, $100 per day, $500 per week
• Customizable: You can adjust all limits at any time in Wallet > Agent Wallet > Settings
• Your control: You can withdraw funds at any time to your Modular Wallet or external wallet
• Security: Funds are held in Circle's secure infrastructure

Modular Wallet (User-Controlled, Non-Custodial)

• Purpose: Full user control with passkey authentication for larger amounts and long-term storage
• How it works: YOU control your wallet via passkey — only you can authorize transactions
• KYC limits apply: Transaction and withdrawal limits are based on your KYC verification tier (see Section 22)
• Recovery phrase: You can view your recovery phrase in wallet settings to backup your wallet
• Best for: Larger balances, withdrawals, external transfers
• Security: We do not have access to your Modular Wallet funds or private keys

You can use both wallet types simultaneously: Agent Wallet for everyday convenience, Modular Wallet for full control and security. Both wallets are subject to the KYC verification limits set in your Account settings.

5.2 Onramp & Offramp (Buying and Selling USDC)

Lucilla partners with Coinbase for fiat-to-crypto and crypto-to-fiat conversions:

Coinbase Onramp (Buying USDC)

• Requirements: Coinbase account (Coinbase handles its own KYC/identity verification)
• How it works: Log in to Coinbase → Purchase or transfer USDC → USDC sent directly to your Lucilla wallet on Base blockchain
• Fees: Set by Coinbase (0-2%, FREE for Coinbase One members)
• Limits: Based on your Coinbase account verification level

Coinbase Offramp (Selling USDC / Cash Out)

• Requirements: Coinbase account with linked bank account
• How it works: Send USDC from your Lucilla wallet to Coinbase → Convert to fiat → Withdraw to bank
• KYC: Handled entirely by Coinbase
• Fees: Set by Coinbase

Important — USDC Usage in Lucilla:

• Lucilla does NOT sell USDC directly — all crypto purchases and sales are handled by Coinbase
• USDC is used within the app for: subscriptions (Lucilla+ and Creator), step match entry commitments, tipping creators, purchasing content, and geo/QR reward campaigns
• Subscription payments are made exclusively with USDC from your Lucilla wallet — not through Apple App Store, Google Play Store, or Samsung Galaxy Store
• You must comply with Coinbase's User Agreement
• Payment failures or disputes with Coinbase must be resolved directly with Coinbase
• For wallet and blockchain details, see Circle Programmable Wallets Documentation

5.2a Onramp Provider Responsibilities & KYC

The purchase of USDC within the Lucilla app is facilitated exclusively through Coinbase, a licensed and regulated cryptocurrency exchange. Lucilla does not directly sell, exchange, or convert fiat currency to cryptocurrency.

• Coinbase is the onramp provider: All fiat-to-USDC transactions are processed by Coinbase, which is registered as a Money Services Business (MSB) with FinCEN and holds state money transmitter licenses in applicable US jurisdictions
• KYC is handled by Coinbase: Coinbase performs its own Know Your Customer (KYC) identity verification before allowing users to purchase USDC. This includes government ID verification, address verification, and sanctions screening as required by federal and state regulations
• Compliance is Coinbase's responsibility: Coinbase is solely responsible for complying with all applicable financial regulations, anti-money laundering (AML) laws, sanctions screening (OFAC), and reporting requirements (SARs, CTRs) related to the onramp and offramp of fiat currency to and from USDC
• Lucilla's role is limited: Lucilla provides the in-app integration that connects users to Coinbase's onramp/offramp service. Lucilla does not process, hold, or transmit fiat currency at any point during the purchase or sale of USDC
• Purchase limits and restrictions: Purchase limits, supported payment methods, geographic restrictions, and fees for buying or selling USDC are set and enforced by Coinbase, not by Lucilla

5.3 User Identity Verification & Platform Security

While Coinbase handles onramp KYC, Lucilla independently collects and verifies user identity information as a protective measure for platform security, fraud prevention, and regulatory compliance:

Information Collected by Lucilla

• Email address: Required for account creation and communication
• Phone number: Used for SMS verification, account recovery, and two-factor authentication
• Location data: GPS location used for geo reward verification, geographic eligibility enforcement (paid match state restrictions), and fraud detection
• Government-issued ID: Required for Tier 3+ KYC verification — includes front and back of driver's license, passport, or government ID card
• Live face verification: A live selfie (camera-enforced, no photo uploads) is required for identity verification. This is compared against the photo on your submitted ID to confirm you are the person on the document

Authentication Methods

Lucilla supports multiple authentication methods, each providing additional layers of identity assurance:

• Google Sign-In: Authentication through your Google account. Google verifies your identity through their own authentication systems and provides Lucilla with your verified email address, display name, and profile photo. Google's account security features (2FA, suspicious login detection) add an additional layer of protection
• Apple Sign-In: Authentication through your Apple ID. Apple verifies your identity through their own authentication systems and provides Lucilla with your verified email address (or a private relay email) and display name. Apple's device-based biometric verification (Face ID, Touch ID) adds strong identity assurance
• Passkey authentication: Cryptographic passkeys tied to your device's secure enclave, protected by your device's biometric authentication (fingerprint or face recognition). Passkeys cannot be phished, guessed, or reused across sites
• Biometric verification: Device-level biometric authentication (fingerprint, Face ID, or equivalent) is used to authorize sensitive actions including wallet transactions, account changes, and identity verification

Passkey-Protected Actions & Bot Prevention

To prevent bots, automated scripts, and malicious behavior on the platform, the following actions require passkey or biometric verification:

• Social posts and comments: Every post, comment, and content submission requires passkey authentication, making it extremely difficult for bots to generate content on the platform
• Geo/QR reward campaign creation: Creating any geo reward, QR reward, or advertising campaign requires biometric verification. This prevents bots, malicious actors, or unauthorized users from placing fraudulent or harmful promotional content on the Rewards Map
• Wallet transactions: Sending USDC, entering paid matches, tipping, and all financial actions require biometric or passkey confirmation
• Account changes: Changing email, phone number, recovery settings, or deleting your account requires re-authentication
• Match actions: Accepting, creating, and settling paid step matches requires authenticated confirmation

These measures ensure that every meaningful action on Lucilla is taken by a verified human being, significantly reducing the risk of fraud, bot activity, impersonation, and platform abuse.

5.4 Risks

• Cryptocurrency values fluctuate
• Blockchain transactions are final and cannot be reversed
• Lost recovery phrases cannot be recovered
• You assume all risks associated with cryptocurrency use

5.5 Lucilla Does Not Sell Cryptocurrency

Lucilla is a health and wellness platform — not a cryptocurrency exchange, broker, or money transmitter. We want to be transparent about our relationship with digital assets:

• We do not sell, trade, or exchange USDC, stablecoins, or any other cryptocurrency. All purchases and sales of USDC are handled exclusively by Coinbase, a licensed and regulated third-party cryptocurrency exchange (see Section 5.2)
• We do not issue, mint, or create any cryptocurrency or digital token. USDC is issued by Circle Internet Financial and is fully backed by US dollar reserves
• We do not provide financial advice or make any representations about the value, suitability, or investment potential of USDC or any digital asset

5.6 Smart Contracts & Non-Custodial Fund Management

Lucilla uses smart contracts deployed on the Base blockchain (an Ethereum Layer 2 network) to manage the flow of funds in step matches, geo/QR reward campaigns, and other platform transactions. Smart contracts are used specifically to ensure trust and transparency — so that users do not need to rely on Lucilla holding their funds:

How Smart Contracts Protect You

• Lucilla does not hold user funds during transactions. When you enter a paid step match, your USDC entry commitment is sent directly to the match smart contract on the blockchain — not to a Lucilla-owned account. The smart contract holds the funds in escrow until the match is validated and settled
• Automated, trustless settlement: When a match concludes and results are validated, the smart contract automatically distributes the prize pool to the winner(s) and the platform fee to Lucilla. No human intervention is required or possible — the rules are enforced by code on the blockchain
• Verifiable on-chain: Every transaction, entry commitment, prize distribution, and fee payment is recorded on the public Base blockchain. Anyone can independently verify that funds were distributed correctly by inspecting the smart contract and transaction history
• Geo/QR rewards: When a business funds a geo reward campaign, the USDC is deposited into the reward smart contract. When users claim rewards, the smart contract distributes the reward directly to the user's wallet. Unclaimed funds can be withdrawn by the campaign creator at any time by deactivating the campaign
• Refunds and cancellations: If a match is cancelled or refunded, the smart contract returns funds directly to the participants' wallets. Lucilla does not hold or process refunds — the smart contract executes them automatically

Lucilla's Revenue Model

Lucilla generates revenue only through the following transparent, clearly defined channels:

• Subscription fees: Monthly or annual subscription payments for Lucilla+ (Pro) and Creator Pro tiers, paid exclusively with USDC from your Lucilla wallet
• Platform service fees on paid matches: A percentage fee (typically 5%) deducted from the prize pool of paid step matches at the time of settlement. This fee is deducted and distributed by the smart contract — Lucilla receives it only after the match is fully settled and the winner is paid
• Platform service fees on geo/QR campaigns: A percentage fee on geo/QR advertising campaigns (see Section 10.2 for tier-based fee structure)
• Platform service fees on creator features: A percentage fee on paid voice/video rooms, content purchases, and creator monetization features

What Lucilla does not do:

• We do not earn interest, yield, or returns on user funds held in smart contracts or wallets
• We do not lend, stake, invest, or otherwise use user funds for any purpose other than the specific transaction the user initiated
• We do not commingle user funds with company funds — user funds in smart contracts and Modular Wallets are entirely separate from Lucilla's operating accounts
• We do not charge hidden fees — all fees are disclosed in these Terms and are visible in the app before you confirm any transaction

6. Step Challenges & Competitions

6.1 Eligibility

• Must be 18+ and not residing in prohibited jurisdictions
• Competitions may be restricted based on local regulations in certain jurisdictions
• We reserve the right to verify eligibility and identity

6.2 Fair Play

• Using third-party apps or devices to artificially inflate step counts is prohibited
• Cheating, hacking, or manipulation will result in account termination
• We use a multi-layered Fair Play validation system that includes heart rate cross-referencing, confidence scoring, and smart step caps to detect abnormal activity
• Heart rate validation: For Fitbit users, daily heart rate zone data (Fat Burn, Cardio, Peak minutes) is compared against step counts. High step counts with no corresponding heart rate activity reduce your confidence score
• Verified steps: In paid matches, your verified step count (raw steps adjusted by confidence score) determines the winner, not raw step count
• Smart step caps: Soft cap of 50,000 steps/day (flagged without HR support), hard cap of 100,000 steps/day
• Device eligibility is enforced for paid matches — using an unapproved or ineligible wearable device will result in match invalidation and forfeiture of your entry commitment (see Section 6A)
• Disputes are resolved at our sole discretion

6.3 Payouts

• Winners receive USDC to their Lucilla wallet
• Payouts processed within 24-48 hours of challenge completion
• You are responsible for any taxes on winnings

6A. Wearable Devices & Fitness Tracking

6A.1 Approved Wearable Devices

Lucilla maintains an approved device list organized by accuracy tier based on peer-reviewed Mean Absolute Percentage Error (MAPE) studies. Your device tier determines which match types you are eligible to participate in.

Tier 1 — Excellent (Less than 4% step-count error)

Brand	Models
Fitbit	Charge 6, Inspire 3
Apple Watch	Series 8, Series 9, Series 10, Ultra 2
Samsung	Galaxy Watch 6, Galaxy Watch 7
Google	Pixel Watch 2, Pixel Watch 3
Garmin	Forerunner 265, Forerunner 965, Fenix 8

Tier 2 — Good (4–8% step-count error)

Brand	Models
Apple Watch	SE
Samsung	Galaxy Watch 5
Google	Pixel Watch 1
Amazfit	GTR 4, T-Rex 3
Polar	Vantage V3
COROS	APEX 2 Pro
Huawei	Watch Fit 3

Tier 3 — Moderate (8–15% step-count error, free matches only)

Source	Details
Phone pedometers	Apple Health (iPhone motion coprocessor), Samsung Health (Samsung phones), Google Fit (Android phones)

Tier 3 devices are NOT eligible for paid matches. They may only be used for free matches and challenges.

6A.2 Paid Match Device Requirements

To participate in paid matches (matches requiring a USDC entry commitment), your device must meet the following requirements:

• Maximum 8% MAPE: Only Tier 1 and Tier 2 devices are eligible for paid matches
• Approved list only: Your device must appear on the approved device list above
• One device per match: You must use a single approved device for the duration of each match
• Device verification: Lucilla may verify the device source of your step data and reject data from unapproved devices

Using an unapproved device for a paid match will result in match invalidation and forfeiture of your entry commitment.

6A.3 Bridge-Sync Devices

Certain wearable devices do not integrate directly with Apple Health or Google Health Connect. Instead, they sync step data through a companion app that bridges to the platform health service:

Bridge-sync devices: Garmin, Amazfit, Polar, COROS, Huawei Watch, Xiaomi, and Suunto

How bridge-sync works:

• Your wearable records steps locally
• The companion app (e.g., Garmin Connect, Zepp, Polar Flow, COROS, Mi Fitness, Suunto) syncs data from the wearable via Bluetooth
• The companion app pushes step data to Health Connect (Android only)
• Lucilla reads step data from Health Connect

Huawei exception: Huawei Health does not write to Health Connect natively. Huawei Watch users must install the third-party Health Sync app (available on Google Play, approximately €3.49) to bridge data from Huawei Health to Health Connect. Battery optimization must be disabled for both Huawei Health and Health Sync.

Sync delay by device: The delay between when steps are taken and when they appear in Health Connect varies by manufacturer:

• Garmin: 15–30 minutes (Garmin Connect runs a persistent foreground service — most reliable bridge-sync device)
• Polar: Every 30 minutes (Polar's published sync interval), plus after workouts and goal completions
• Amazfit, COROS, Xiaomi, Suunto: 30–60 minutes in background. Opening the companion app triggers an immediate sync.
• Huawei (via Health Sync): Every 15 minutes automatically

Battery optimization: Bridge-sync companion apps must have battery optimization disabled (also called "unrestricted background activity") on your Android phone. Without this, the operating system may kill the companion app and prevent it from syncing your wearable data. This is especially critical on Samsung (One UI), Xiaomi (MIUI/HyperOS), and Huawei (EMUI) phones, which are more aggressive with background app restrictions. See the in-app Sync Guide for per-brand instructions.

Eligibility restrictions due to sync delay:

• NOT eligible for any intraday matches (10-minute, 30-minute, 1-hour, and 2-hour matches), whether free or paid — the sync delay makes real-time step verification unreliable for short-duration matches
• Eligible for daily, weekly, and monthly matches (both free and paid) — the sync delay is negligible relative to the match duration

Note: Bridge-sync is only available on Android via Health Connect. iOS users must use Apple Watch or Fitbit for direct integration.

6A.3a Wearable Auto-Sync Reliability

For paid matches, your wearable must automatically sync step data. If your steps fail to sync after a match, you may forfeit the match to your opponent (see Section 11.3 Forfeit Win rule). Here is how reliably each device auto-syncs:

Device	Auto-Syncs?	Action Required
Apple Watch	Always	None — HealthKit is a system service
Samsung Galaxy Watch	Always	None — Health Connect is a system service
Google Pixel Watch	Always	None — Fitbit is a system app on Pixel phones
Fitbit	Usually	Re-authenticate in Lucilla if token expires (rare)
Garmin	Usually	Disable battery optimization for Garmin Connect app
Amazfit	Usually	Disable battery optimization for Zepp app
COROS	Mostly	Disable battery optimization for COROS app
Huawei Watch	Yes (Huawei phones) / Usually (other phones)	On non-Huawei phones, disable battery optimization for Huawei Health
Polar	Not reliably	Open Polar Flow app manually after your match to force sync to Health Connect

Android battery optimization warning: Some Android phones (especially Xiaomi, Samsung, Huawei) aggressively kill background apps. If you use a bridge-sync device, disable battery optimization for your companion app: Settings > Apps > [App] > Battery > Unrestricted.

6A.4 Platform Compatibility

iOS (iPhone)

Device	Integration
Apple Watch (all approved models)	Direct sync via Apple Health
Fitbit (Charge 6, Inspire 3)	Cross-platform — syncs via Fitbit app to Apple Health

Android

Device	Integration
Samsung Galaxy Watch (all approved models)	Sync via Samsung Health to Health Connect. Samsung Health writes to Health Connect when opened or reconnected — open Samsung Health after your match to trigger sync
Google Pixel Watch (all approved models)	Sync via Health Connect. Wear OS writes basic step data to Health Connect during workouts. Full workout data syncs through the Fitbit app (1–2 min if app is open, 15–30 min in background)
Fitbit (Charge 6, Inspire 3)	Cross-platform — syncs via Fitbit app to Health Connect
Garmin (Forerunner 265, 965, Fenix 8)	Bridge-sync via Garmin Connect to Health Connect
Amazfit (GTR 4, T-Rex 3)	Bridge-sync via Zepp app to Health Connect
Polar (Vantage V3)	Bridge-sync via Polar Flow to Health Connect
COROS (APEX 2 Pro)	Bridge-sync via COROS app to Health Connect
Huawei (Watch Fit 3)	Bridge-sync via Huawei Health + Health Sync app (€3.49) to Health Connect. Huawei Health does not write to Health Connect natively
Xiaomi (Smart Band, Watch)	Bridge-sync via Mi Fitness to Health Connect
Suunto (Race, Peak Pro)	Bridge-sync via Suunto app to Health Connect

6A.5 Device Accuracy Disclaimer

• Accuracy ratings (MAPE tiers) are based on peer-reviewed studies and independent testing at the time of device approval
• Actual accuracy may vary depending on wrist placement, walking speed, terrain, arm swing, and individual biomechanics
• Lucilla does not guarantee the accuracy of any wearable device
• Lucilla reserves the right to update the approved device list, add new devices, remove devices, or change tier classifications at any time with 14 days' notice
• Updated device lists will be published at lucilla.ca/approved-devices
• If your device is removed from the approved list or downgraded, active paid matches will be honored through completion

6A.6 Step Sync & Validation Window

For daily, weekly, and monthly step matches, the following sync and validation rules apply:

• Midnight Cutoff: Steps are counted until midnight (00:00) on the match end date. Any steps recorded after midnight do not count toward the match.
• 12-Hour Validation Window: After midnight, you have up to 12 hours to ensure your steps are synced to Lucilla. The system will automatically attempt to validate your match results during this window.
• 30-Minute Grace Period: If your steps have not synced after the 12-hour window, the system provides a final 30-minute grace period with frequent sync checks before declaring a forfeit.
• Forfeit: If your steps are still not synced after the full validation window (12 hours + 30 minutes), your match will be forfeited regardless of how many steps you actually took. It is your responsibility to sync your steps.

How to sync your steps (by device type):

• Fitbit & Google Fit: Steps are synced automatically at midnight via server-side API — no action needed from you.
• Apple Watch: Open the Lucilla app — HealthKit syncs steps from the watch every few seconds. No additional action needed.
• Samsung Galaxy Watch: Open Samsung Health first (to trigger data write to Health Connect), then open Lucilla.
• Google Pixel Watch: Open the Fitbit app first (to trigger Bluetooth sync from watch), then open Lucilla. Wear OS may write basic step data to Health Connect automatically, but full data requires the Fitbit app.
• Bridge-sync devices (Garmin, Amazfit, Polar, COROS, Xiaomi, Suunto): Open your companion app (e.g., Garmin Connect, Zepp, Polar Flow) to sync your wearable to Health Connect, then open Lucilla.
• Huawei Watch: Open both Huawei Health and the Health Sync app to trigger sync to Health Connect, then open Lucilla.

Important: For paid matches, failure to sync your steps within the validation window means you forfeit the match and your entry commitment. Lucilla is not responsible for sync delays caused by third-party wearable apps or services.

6A.7 Intraday Match Workout Tracking

Intraday matches (10-minute, 30-minute, 1-hour, and 2-hour) have additional requirements:

• Active workout required: You must start a Walk or Workout on your wearable before the match begins. Only steps taken during active workout sessions count toward the match result.
• Live data polling: Lucilla polls step data every 5 minutes from HealthKit (iOS) or Health Connect (Android) to update the live match leaderboard.
• Workout details tracked: For Apple Watch, Pixel Watch, and Galaxy Watch 4+, Lucilla also collects heart rate (average and maximum), active calories burned, and distance during your workout. This data is displayed in the match details screen.
• Fitbit limitation: Fitbit syncs steps via server-side API. Real-time heart rate, calories, and distance data is not available during Fitbit intraday matches — only step count is shown.
• Match completion: When the match ends, you will receive a push notification reminding you to stop your workout on your wearable.
• Multiple workout sessions: If you stop and restart your workout during a match, all workout sessions within the match period are combined.
• Validation window: Intraday matches have a 30-minute sync buffer after the match end time, followed by a 30-minute grace period. If your steps have not synced within this window, the match may result in a forfeit.

Eligible devices for intraday matches:

• Auto-detect workout: Apple Watch, Google Pixel Watch, Samsung Galaxy Watch 4+ (Wear OS) — Lucilla can verify your workout is active
• Manual confirmation: Fitbit (all models), Samsung Galaxy Watch 3/Active/Gear (Tizen) — you must confirm you started your workout
• Blocked: All bridge-sync devices (Garmin, Amazfit, Polar, COROS, Huawei Watch, Xiaomi, Suunto) — 15-30 minute sync delay is too slow for real-time tracking

7. Content, Social Feed & Conduct

7.1 Your Content

• You retain ownership of content you post (photos, messages, etc.)
• You grant us a license to use, display, and distribute your content within the App
• You are responsible for your content and its legality
• Passkey-Protected Posting: All posts, comments, and content submissions require passkey authentication to verify you are a real person and to prevent bot activity

7.2 Social Feed & Content Discovery

Lucilla's social feed surfaces content based on genuine community engagement:

• Engagement-Based Visibility: The most popular and most engaged content (likes, comments, shares) is surfaced more prominently in the feed
• No Digital Ads: Lucilla does NOT show banner ads, pop-up ads, interstitial ads, or sponsored posts in your feed. Your experience is organic and ad-free
• Content Word Filtering: You can set custom word filters to block content containing specific words or topics you don't want to see
• Discovery Feed: Explore popular content from the broader community, trending step matches, and active challenges

7.3 Anti-Bot Protection

• Passkey Requirement: Every piece of content (posts, comments, replies) requires passkey verification, making it extremely difficult for bots or automated scripts to operate
• Anti-Bot Detection System: Lucilla actively monitors for automated behavior patterns, rapid posting, duplicate content, and bot-like activity. Suspicious accounts are flagged and may be suspended
• Human-First Platform: These combined measures ensure Lucilla remains a platform of real people sharing genuine health and fitness experiences

7.4 Prohibited Conduct

You may NOT:

• Post illegal, harmful, threatening, or abusive content
• Harass, bully, or intimidate other users
• Impersonate others or misrepresent your identity
• Spam, scam, or engage in fraudulent activity
• Reverse engineer, hack, or exploit the App
• Use bots, scripts, or automated tools to post content or interact with the platform
• Share explicit or adult content

8. Creator Content & AI Tools

8.1 AI Content Generation

• Lucilla provides AI tools to help you create content (images, text, social posts)
• AI-generated content is provided "as is" without warranties
• You are responsible for reviewing and editing AI outputs before publishing
• AI may occasionally produce inaccurate or inappropriate content - use your judgment

8.2 Creator Revenue Model & Monetization

Lucilla uses a transparent subscription revenue model for creator monetization:

Revenue Splits:

• Lucilla+ (Tier 1): Creators keep 80% of all subscriber and room revenue; 20% platform fee
• Creator (Tier 2): Creators keep 90% of all subscriber and room revenue; 10% platform fee
• No shares, no bonding curves, no dividends, no phantom equity — straightforward revenue sharing

Creator Earnings:

• Earn USDC from paid room entry fees and content subscriptions
• Earn from tips and sponsorships
• Earn referral commissions for new users you bring to the platform
• Withdrawals subject to KYC tier limits (see Section 17)

Important Notes:

• Revenue splits apply to net amounts after payment processing fees
• No guarantee of earnings — income depends on creator activity and audience engagement
• We reserve the right to modify revenue split percentages with 30 days notice

9. Lucilla AI Journal

9.1 Journal Functionality

• Lucilla provides an AI-powered journal where you can chat with an AI assistant
• Journals are private by default and stored securely
• You can search your past journal entries within the app
• Journal data is encrypted and only accessible to you

9.2 Sharing Journals

You can choose to share your journal entries publicly:

• Anonymous sharing (default): Your journal is shared to lucilla.app without revealing your username or identity
• Public sharing with attribution: You can optionally attach your username to shared journals
• What gets shared: User prompts and AI responses only (no metadata or timestamps)
• Search & Discovery: Shared journals are searchable on lucilla.app by all users

9.3 Journal Privacy

• By default, your journals are PRIVATE and never shared
• You must explicitly choose to share each journal entry
• Once shared, journal entries cannot be un-shared (they're on the blockchain)
• Lucilla does not read, monitor, or use your private journals for any purpose except providing the service

9.4 AI Limitations

• Lucilla AI is NOT a therapist, medical professional, or licensed counselor
• Do not rely on AI for medical, legal, or financial advice
• AI responses may be inaccurate, incomplete, or inappropriate
• If you're experiencing a mental health crisis, contact a professional or call a crisis hotline

10. Geo/QR Advertising & Rewards

10.1 How Geo Rewards Work

• Businesses and creators can place USDC rewards at physical locations or on QR codes
• Users "claim" rewards by visiting the location or scanning the QR code
• Rewards are distributed on a first-come, first-served basis until the reward pool is depleted
• GPS verification required for location-based rewards

10.1a Eligibility & KYC Requirements for Geo/QR Rewards

Geo/QR rewards are promotional incentives — not financial competitions. As such, they have different eligibility requirements than paid step matches:

Claiming Rewards (All Users)

• KYC tier: No identity verification required to claim geo/QR rewards. Users at any KYC tier (including Tier 1 — email only) may claim rewards
• Age: Available to all users aged 13 and older. No 18+ requirement (claiming a reward is receiving a promotional incentive, not entering a financial contract)
• Subscription: No paid subscription required to claim rewards. Free-tier users may claim rewards
• Account required: You must have a Lucilla account with a wallet to receive claimed USDC
• Withdrawal limits still apply: While claiming is unrestricted, withdrawing USDC from your wallet to an external address is subject to your KYC tier withdrawal limits (see Section 22)

Creating Campaigns (Advertisers & Businesses)

• Subscription required: You must have an active Pro or Creator Pro subscription to create geo/QR reward campaigns
• Funded wallet: You must have sufficient USDC in your Lucilla wallet to fund your campaign
• KYC tier: No specific KYC tier is required to create campaigns. However, if you need to deposit large amounts of USDC to fund campaigns, your deposit and on-ramp limits are governed by your KYC tier
• Age: You must be at least 18 years old to create advertising campaigns
• Legal responsibility: By creating a campaign, you represent that you have the legal authority and capacity to do so, and that you comply with all applicable laws (see Section 10.4)

10.2 Creator & Business Fees

Lucilla charges platform fees on Geo/QR advertising campaigns based on subscription tier:

Pro Tier (Personal Use):

• Base fee: 10% on campaigns under $100/month
• Volume pricing: Fee increases to 20% as spend grows (prevents abuse)
• $100+/month: 5% fee (encourages larger campaigns)

Creator Pro Tier (Businesses & Creators):

• Flat fee: 10% on all campaigns (no volume scaling)
• Priority placement: Your campaigns appear first in search results
• Analytics dashboard: Track claim rates, user engagement, ROI

10.3 Campaign Expiration & Refund Policy

What happens to unclaimed rewards?

• Active campaigns: Your geo/QR campaign stays live until you deactivate it or funds run out
• Deactivating campaigns: You can deactivate your campaign at any time via the smart contract
• Unclaimed funds refund: When you deactivate a campaign, ALL unclaimed USDC is automatically returned to your wallet
• No time expiration: Campaigns do not auto-expire based on time
• Example: You fund a $100 campaign, users claim $60, you deactivate → you get $40 refunded instantly

10.4 Advertiser & Business Responsibilities

• Biometric verification required: Creating any geo reward, QR reward, or advertising campaign requires biometric authentication (fingerprint or face recognition) on your device. This protective measure ensures that only verified human users can place promotional content on the platform and prevents bot-generated, fraudulent, or unauthorized campaigns
• You are responsible for funding your campaigns with sufficient USDC
• Campaigns automatically pause when funds are depleted
• Once claimed by users, rewards CANNOT be refunded (only unclaimed funds are refundable)
• You must comply with all applicable local, state, provincial, national, and international advertising laws and regulations
• Prohibited: Misleading ads, adult content, illegal products or services, scams, or any content that violates applicable law

10.4.1 Business Licensing & Regulatory Compliance

If you are a business, organization, or individual using Lucilla's Geo/QR reward features to promote products, services, or your physical location, you are solely responsible for ensuring that your business operations comply with all applicable laws and regulations, including but not limited to:

• Business licenses and permits: Obtaining and maintaining all business licenses, permits, health permits, food handling certifications, professional licenses, and any other authorizations required to legally operate your business in your jurisdiction
• Tax obligations: Collecting and remitting all applicable sales taxes, value-added taxes (VAT), goods and services taxes (GST/HST), excise taxes, and any other taxes required by your jurisdiction. You are solely responsible for all tax reporting and compliance related to sales or transactions that result from your Lucilla campaigns
• Consumer protection laws: Complying with all applicable consumer protection, truth-in-advertising, and fair trading laws, including accurate representation of products, services, pricing, and promotional terms
• Industry-specific regulations: Complying with all regulations specific to your industry, including but not limited to food safety regulations, alcohol and tobacco advertising restrictions, pharmaceutical advertising rules, financial services regulations, real estate advertising requirements, and health and wellness product claims
• Data protection and privacy: Complying with all applicable privacy and data protection laws (e.g., GDPR, CCPA, PIPEDA) with respect to any customer data you collect through or in connection with your campaigns
• Employment and labor laws: Complying with all applicable employment, labor, and contractor laws if your promotional activities involve employees or contractors
• Zoning and location-based restrictions: Ensuring that your use of geo-based rewards is consistent with local zoning laws, signage regulations, and any location-specific advertising restrictions

10.4.2 Nature of Lucilla's Role

Lucilla provides a technology platform for distributing digital promotional rewards (USDC tokens) to users who visit specified locations or scan QR codes. Lucilla's role is limited to:

• Facilitating the distribution of USDC rewards from your funded campaign wallet to claiming users
• Providing GPS and QR-based verification that users visited the specified location or scanned the specified code
• Providing campaign analytics and management tools

Lucilla does not:

• Endorse, verify, or vouch for any business, product, service, or promotional offer listed on the platform
• Verify that any advertiser holds the required business licenses, permits, or regulatory approvals to operate their business or sell their products
• Assume responsibility for the quality, safety, legality, or accuracy of any product, service, or promotional offer
• Act as a party to any transaction between an advertiser and a user that occurs as a result of a geo/QR reward campaign — the reward itself is a promotional incentive distributed by the advertiser, not a purchase or payment for goods or services
• Collect, remit, or report any taxes on behalf of advertisers or businesses

10.4.3 Disclaimer of Liability

Lucilla is not liable for any loss, damage, claim, fine, penalty, or legal action arising from:

• An advertiser's failure to obtain required business licenses, permits, or regulatory approvals
• An advertiser's failure to comply with tax collection, reporting, or remittance obligations
• An advertiser's violation of consumer protection, advertising, or trade practice laws
• Any harmful, fraudulent, misleading, or illegal conduct by an advertiser or business using the platform
• Any products or services that are defective, unsafe, misrepresented, or illegal
• Any disputes between advertisers and users, or between advertisers and third parties, arising from campaigns run on the platform
• Any injury, loss, or damage suffered by users who visit a physical location promoted through a geo reward campaign

By using Lucilla's Geo/QR advertising features, you agree to indemnify, defend, and hold harmless Lucilla, its affiliates, officers, directors, employees, and agents from and against any claims, liabilities, damages, losses, costs, or expenses (including reasonable legal fees) arising out of or related to your campaigns, your business operations, your products or services, or your violation of any applicable law or regulation.

10.4.4 Physical Location & Property Rules

If your geo reward campaign directs users to a physical location, you are solely responsible for:

• Property authorization: Obtaining written permission from property owners, landlords, or property managers before placing geo rewards at or directing foot traffic to any location you do not own or control. This includes shopping centers, plazas, office buildings, parks, and any shared or leased spaces
• Public property and municipal regulations: Complying with all applicable municipal bylaws, public space usage regulations, sidewalk and pedestrian ordinances, and park rules when placing rewards in or near public areas. Some jurisdictions require permits for commercial promotional activities on public property
• Trespassing prevention: Ensuring that your campaign does not encourage, require, or incentivize users to trespass on private property, enter restricted areas, or access locations they are not authorized to visit. Placing geo rewards on or near private property without the owner's permission may constitute trespassing or unauthorized solicitation under local law
• Public safety: Ensuring that your campaign does not create unsafe conditions such as overcrowding, traffic hazards, obstruction of emergency exits or pathways, or any situation that could endanger users or the public
• Respect for others: Ensuring that your campaign does not disrupt other businesses, residents, or members of the public. You must not use geo rewards to harass, stalk, target, or cause harm to any individual, business, or organization
• Natural environments and protected areas: If placing rewards in or near parks, trails, nature reserves, conservation areas, beaches, forests, or other natural environments, you must respect all environmental protection laws, Leave No Trace principles, and park regulations. You must not place rewards in protected wildlife habitats, restricted conservation zones, or areas where increased foot traffic could cause environmental damage. You are responsible for any environmental harm or regulatory violations resulting from your campaign
• Remote and hazardous locations: You must not place rewards in remote, dangerous, or difficult-to-access locations that could put users at risk of injury. This includes but is not limited to cliff edges, bodies of water, construction sites, roadways, railway lines, rooftops, or any location that requires specialized equipment or training to access safely
• Accessibility: Ensuring that reward locations are reasonably accessible and do not require users to put themselves in dangerous or unlawful situations to claim them

Lucilla is not responsible for any trespassing, property damage, environmental damage, personal injury, nuisance complaints, or legal claims arising from users visiting locations promoted through your geo reward campaigns. The advertiser assumes full liability for all consequences of directing foot traffic to any physical location.

10.4.5 Prohibited Campaign Content

Geo/QR reward campaigns must not promote, glorify, or be associated with:

• Violence and weapons: Content promoting violence, terrorism, armed conflict, weapons sales, or glorification of war or violent acts
• Hate and discrimination: Content promoting hatred, discrimination, or hostility based on race, ethnicity, national origin, religion, gender, gender identity, sexual orientation, disability, age, or any other protected characteristic
• Illegal substances and activities: Content promoting illegal drugs, controlled substances (except where legally licensed), illegal gambling, money laundering, or any criminal activity
• Adult and explicit content: Sexually explicit material, pornography, or content inappropriate for minors (Lucilla is available to users aged 13+)
• Harassment and harm: Content intended to harass, bully, intimidate, stalk, or cause harm to any individual, group, or organization
• Misinformation: Deliberately false or misleading health claims, conspiracy theories presented as fact, or content designed to deceive the public
• Regulated products without compliance: Tobacco, alcohol, cannabis, firearms, pharmaceuticals, financial products, or other regulated goods or services advertised without the required disclaimers, age-gating, or regulatory compliance

10.4.6 Campaign Content Review & Removal

Lucilla reserves the right to review, flag, suspend, or permanently remove any campaign that:

• Violates these Terms of Service, the prohibited content policy above, or applicable law
• Promotes illegal products, services, or activities
• Contains misleading, deceptive, or fraudulent content
• Promotes violence, hatred, discrimination, or harm
• Is the subject of user complaints, legal inquiries, or regulatory action
• Poses a risk to user safety or platform integrity

Removal of a campaign does not constitute an admission of wrongdoing by Lucilla or a determination of liability. Unclaimed USDC from removed campaigns will be returned to the advertiser's wallet unless prohibited by legal process (e.g., court order, regulatory freeze).

10.5 User Data Sharing with Reward Providers

By using Lucilla and claiming geo/QR rewards, you agree that your basic contact information may be shared with the businesses and creators whose rewards you claim. Specifically:

• What is shared: Your display name, email address, and phone number (if provided) may be shared with the business or creator whose reward campaign you participated in
• Purpose: To allow businesses to send you promotional offers, thank-you messages, loyalty communications, and campaign-related notifications
• When it is shared: Your information is shared when you claim a geo/QR reward or visit a participating business through the Lucilla platform
• Opt-out: You may opt out of data sharing with businesses at any time in your account privacy settings. Note that opting out may limit your ability to participate in certain reward campaigns that require data sharing as a condition of participation
• Business obligations: Businesses receiving your data must comply with applicable privacy laws (GDPR, CCPA, PIPEDA, CAN-SPAM) and may only use your information for legitimate business communications related to their services. Businesses may not sell, transfer, or share your information with unrelated third parties
• Campaign analytics: Businesses receive aggregated and individual visit data including visit timestamps, duration, and frequency to measure campaign effectiveness

This data sharing is a core feature of the Lucilla platform. It enables businesses to build direct relationships with their customers and provides you with personalized offers and communications from businesses you have chosen to visit. By creating an account and accepting these Terms, you consent to this data sharing as described above.

10.6 User Responsibilities (Claiming Rewards)

• You must physically visit locations or scan QR codes to claim rewards
• GPS spoofing, VPNs, or location manipulation is prohibited
• One claim per user per campaign (no multi-accounting)
• We reserve the right to revoke rewards obtained fraudulently

10.5.1 Personal Safety

You are solely responsible for your own safety when visiting geo reward locations. By choosing to visit a reward location, you acknowledge and accept the following:

• Exercise caution and common sense at all times. Assess the safety of any location before approaching it
• Do not trespass on private property, enter restricted or fenced-off areas, or ignore posted "No Trespassing" or "Private Property" signs to claim a reward
• Do not enter construction sites, industrial zones, rooftops, abandoned buildings, or any location that is clearly not intended for public access
• Do not put yourself in dangerous situations — no reward is worth risking your personal safety or breaking the law
• If a reward location appears unsafe, inaccessible, or requires you to break any law to reach it, do not attempt to claim it. Report the campaign to Lucilla through the app's report feature
• Be aware of your surroundings, especially when visiting unfamiliar locations or locations after dark

10.5.2 Respect for Property, Nature & the Environment

When visiting geo reward locations, you must respect all property, natural environments, and the communities around you:

• Private property: Do not enter private property without permission. If a reward appears to be located on private land, do not attempt to claim it — report the campaign instead
• Public spaces: Follow all posted rules, signs, and regulations in public parks, plazas, beaches, and community spaces. Do not block pathways, entrances, or emergency exits
• Parks and trails: Stay on designated paths and trails. Do not create new paths, cut switchbacks, or venture off-trail to reach a reward location. Follow all park rules and regulations
• Wildlife and ecosystems: Do not disturb, feed, chase, or approach wildlife. Do not remove plants, rocks, shells, or natural features. Keep a safe and respectful distance from all animals
• Leave No Trace: Carry out everything you bring in. Do not litter, leave food waste, or abandon any items at reward locations. Leave the location in the same or better condition than you found it
• Protected and conservation areas: Respect all restrictions in national parks, nature reserves, conservation areas, marine protected areas, and heritage sites. Some areas may have seasonal closures, restricted zones, or permit requirements — it is your responsibility to know and follow them
• Noise and disturbance: Be respectful of noise levels, especially in residential areas, nature preserves, and locations where wildlife may be sensitive to human activity
• Cultural and historical sites: Treat cultural landmarks, monuments, cemeteries, religious sites, and historical locations with respect. Do not deface, climb on, or damage any structures or artifacts
• Water safety: Exercise extreme caution near bodies of water including rivers, lakes, oceans, and cliffs. Do not enter water to claim a reward. Do not stand on unstable edges or cliffs

10.5.3 Liability Disclaimer

Lucilla is not responsible or liable for any injury, death, illness, property damage, trespassing claim, environmental violation, fine, legal action, or any other loss or harm arising from your decision to visit a geo reward location. You visit all reward locations entirely at your own risk. Lucilla does not verify the safety, accessibility, legality, or suitability of any reward location. By using the Geo/QR reward feature, you agree to accept full personal responsibility for your actions and decisions when visiting reward locations.

11. Step Challenges & Fitness Competitions

11.1 Discovery & Matchmaking

Lucilla provides a discovery system where users can find fitness partners and join competitions:

• User Discovery Tab: Swipe-style interface to find nearby or global fitness partners
• Location-based matching: Find users in your city or country for local meetups
• AI-powered matching: Our WASM processor analyzes your fitness goals, activity level, and preferences to suggest compatible partners
• Privacy controls: You control what profile information is visible in discovery
• Chat before competing: Message potential opponents before creating a match

11.2 Free Matches vs Paid Matches

Free Matches (No USDC Required):

• Available to all users including those under 18 years old
• No entry fee or stake required
• Earn: Achievement badges, leaderboard rankings, XP points, and social recognition
• Duration: 1 day, 7 days, or 30 days
• No geographic restrictions - available worldwide
• Match types: 1v1, Free-for-All (FFA), Team Matches, Goal-Based
• Unlimited participation - join as many free matches as you want

Paid Matches (Financial Commitment Required):

• Age requirement: Must be 18+ to participate (ID verification required)
• Entry commitment: Minimum $1 USDC (no maximum with full KYC)
• Winner takes pot: Highest verified step count wins entire prize pool (minus 5% platform fee, deducted at settlement — not at entry)
• Geographic availability: Available worldwide (except Hawaii, Utah, Washington, Idaho, Montana, Florida, Nevada, Arizona, Arkansas, Connecticut, Louisiana, South Dakota in the US)
• Verification required: Only ID-verified users (Tier 3+) can participate in paid matches
• Anti-cheating verification: Step counts are validated using our AI fraud detection system

11.3 Match Rules & Winner Determination

• 1v1 Matches: Participant with higher verified step count wins entire pot (minus 5% fee deducted at settlement)
• Free-for-All (FFA): 3-10 participants, ranked by verified step count, top performer wins
• Team Matches: 2v2 or larger teams, team with highest combined steps wins
• Goal-Based: All participants who hit goal split prize pool equally (similar to StepBet)
• Draw: If players have the exact same verified step count, OR the leader's margin is less than 5% of their verified steps, the match is declared a DRAW — all tied players are refunded equally (minus 1% draw fee)
• Forfeit Win: If one player's wearable syncs data but the opponent's fails to sync within the validation window, the player who synced wins by forfeit. If neither syncs, both receive a full refund
• Deferred Fees: No fee is taken at entry — your full commitment is escrowed on-chain. Fees are applied only at match settlement (5% on win, 1% on draw). Once joined, the only outcomes are Win or Draw
• Disqualification: Cheating, suspicious patterns, or device manipulation results in commitment forfeiture

11.4 Legal Classification of Step Matches

Paid Step Matches are skill-based fitness competitions, NOT gambling:

• Structured as "commitment contracts" (legally recognized model used by StepBet, HealthyWage, DietBet)
• Outcomes are 100% dependent on your physical activity and effort
• NO element of chance - winner determined solely by step counts
• Legal worldwide in most jurisdictions without gambling licenses (including UK, EU, Canada, Australia, Japan, etc.)
• Does NOT constitute gambling under UK Gambling Act 2005 (skill-based, not chance-based)
• Prohibited only in specific US states where daily fantasy sports or skill-based contests are restricted
• Users are responsible for ensuring compliance with local laws in their jurisdiction

11.5 Geographic Restrictions & Location Verification

Paid Step Matches are NOT available in the following jurisdictions:

Fully Blocked US States (all paid matches prohibited):

• Hawaii (HI)
• Utah (UT)
• Washington (WA)
• Idaho (ID)
• Montana (MT)
• Florida (FL)

Partially Blocked US States (paid matches restricted pending regulatory review):

• Nevada (NV)
• Arizona (AZ)
• Arkansas (AR)
• Connecticut (CT)
• Louisiana (LA)
• South Dakota (SD)

Blocked Countries (all paid matches prohibited):

• Cuba, Iran, North Korea, Syria, Russia, Belarus, Venezuela, Myanmar

Location Verification Enforcement:

• Real-time GPS verification: When joining a paid match, your device's GPS location is checked against blocked jurisdictions in real-time
• KYC residence check: Your verified KYC residence country and state are checked against blocked jurisdictions
• Server-side enforcement: All geo-restriction checks are performed server-side and cannot be bypassed by modifying the app
• Compliance logging: All paid match attempts (both allowed and blocked) are logged for regulatory compliance and audit purposes

Travel Policy: Geo-restrictions are based on your current physical location, not your permanent residence. If you travel from a blocked state to an allowed state, you may participate in paid matches while physically present in the allowed jurisdiction. Conversely, if you travel to a blocked jurisdiction, paid matches will be unavailable regardless of your home state.

Prohibited Location Manipulation:

• GPS spoofing, location faking, or any method of misrepresenting your physical location is strictly prohibited
• Using VPNs or proxy services to circumvent geographic restrictions is prohibited
• Violations will result in immediate account suspension, forfeiture of all pending wagers, and permanent ban
• Lucilla employs GPS spoofing detection technology to identify fraudulent location data

Free Step Matches (no wager) remain available in all jurisdictions. Only paid/wagered matches are subject to geographic restrictions.

11.6 Cryptocurrency On/Off-Ramp Geographic Restrictions

While Step Matches are available worldwide, Coinbase on/off-ramp services (buy/sell USDC with fiat) may not be available in all countries due to Coinbase's compliance requirements:

• Availability depends on your country and Coinbase's regulatory requirements
• For Coinbase availability details: Coinbase Supported Countries

12. Voice & Video Rooms

12.1 Room Types

Lucilla provides real-time voice and video chat rooms powered by LiveKit:

• Audio-only rooms: Voice chat for up to 100 participants
• Video rooms: Video chat for up to 20 participants
• Hybrid rooms: Mix of audio and video participants
• Public rooms: Anyone can join and discover
• Private rooms: Invite-only, password-protected

12.2 Room Policies

• Recording: Rooms may be recorded if the creator enables recording. You will be notified before joining a recorded room.
• Moderation: Room creators can mute, kick, or ban participants
• Content rules: Prohibited content includes:
  • Nudity, sexual content, or adult material
  • Harassment, hate speech, or threats
  • Illegal activity or promotion of violence
  • Spam, scams, or unsolicited advertising
• Privacy: By joining a room, you consent to other participants seeing/hearing you
• Paid rooms: Creators can charge USDC entry fees (10% platform fee applies)

12.3 Room Advertising & Sponsorships

• Creators can display ads in their rooms (Creator Pro subscription required)
• Ads must comply with our content policies (no adult content, scams, or misleading claims)
• Room participants can "tip" creators or pay for ad-free access
• Platform takes 10% fee on room ads and sponsorship deals

13. Intellectual Property

• Lucilla and all related trademarks are owned by us
• The App and its content are protected by copyright and other laws
• You may not copy, modify, or distribute our content without permission

14. Health & Fitness Disclaimers

• Step counts and health data may not be 100% accurate
• Use fitness features at your own risk
• We do not provide medical advice or diagnoses

15. Third-Party Services

The App integrates with third-party services including Apple Health, Google Health Connect, Samsung Health, Circle (wallets), Coinbase (onramp/offramp), Firebase (infrastructure), Apple App Store, Google Play Store, and Samsung Galaxy Store. We are not responsible for third-party services or their terms. For details:

• Circle: circle.com/legal | Circle Developer Docs
• Coinbase: Coinbase User Agreement

16. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW:

• Lucilla is provided "AS IS" without warranties
• We are not liable for indirect, incidental, or consequential damages
• Our total liability is limited to the amount you paid us in the past 12 months
• We are not responsible for lost cryptocurrency, data, or profits

17. Indemnification

You agree to indemnify and hold us harmless from claims arising from your use of the App, violation of these Terms, or infringement of third-party rights.

18. Termination

• You may delete your account at any time in App Settings
• We may suspend or terminate accounts for Terms violations
• Upon termination, your data will be deleted per our Privacy Policy
• Blockchain transactions are permanent and cannot be deleted

19. Changes to Terms

We may update these Terms at any time. We will notify you of material changes via email or in-app notification. Continued use after changes constitutes acceptance.

20. Governing Law & Disputes

• These Terms are governed by the laws of Delaware, USA
• Disputes will be resolved through binding arbitration (not class action)
• You waive the right to a jury trial

21. Miscellaneous

• Severability: If any provision is invalid, the rest remains in effect
• No Waiver: Our failure to enforce a right does not waive it
• Entire Agreement: These Terms constitute the entire agreement between you and us

22. Identity Verification & Account Limits

Age Requirement

You must be at least 13 years old to create a Lucilla account.

You must be at least 18 years old to participate in:

• Paid Step Matches — skill-based fitness competitions with USDC entry commitments

Available to all users (13+):

• Free step matches and challenges
• Social feed, voice/video rooms
• AI content creation and journaling
• Lucilla Web (sharing and discovering health journals)
• Discovery and matching with fitness partners
• Earning USDC from content creation, geo/QR rewards, or referrals
• Withdrawing funds (subject to KYC tier limits below)

Why 18+ for paid matches only? Even though step matches are simply walking competitions, the USDC entry commitment creates a financial contract. Minors (under 18) lack legal capacity to enter binding financial contracts under most jurisdictions. Additionally, KYC/AML regulations under the Bank Secrecy Act and FinCEN rules require adult identity verification for financial transactions. This is the same requirement used by StepBet, HealthyWage, DietBet, and other fitness competition platforms. The restriction is about the money, not the walking — all users 13+ can compete freely in non-paid matches.

KYC Verification Tiers

Lucilla operates a tiered verification system to ensure compliance with anti-money laundering (AML) and know-your-customer (KYC) regulations:

Tier 1: Unverified (Email Only)

• Requirements: Email registration only
• Paid Matches: Not allowed (cannot verify age 18+)
• Withdrawal Limits: $3,000/day
• Why This Limit: Federal "Travel Rule" requires identity verification above $3,000/day in crypto transactions

Tier 2: Phone Verified

• Requirements: Phone number verification via SMS
• Paid Matches: Not allowed (phone doesn't prove age)
• Withdrawal Limits: $3,000/day
• Why Limited: Phone verification doesn't satisfy age verification requirements for skill-based competitions

Tier 3: ID Verified (Enhanced KYC)

• Requirements: Government-issued photo ID + live selfie verification
• Process:
  • Upload front of ID (driver's license, passport, or government ID)
  • Upload back of ID (if applicable)
  • Take live selfie (camera enforced - no uploads)
  • AI verification completes in 30-60 seconds
• Features:
  • Age verified (18+)
  • Paid fitness competitions allowed
  • Unlimited competitions per day
  • Higher commitment limits per match
  • Withdrawal limit: $10,000/day
• Why $10k limit: Federal Currency Transaction Report (CTR) threshold - we file reports for amounts above this

Tier 4: Full KYC (Bank Linked or Enhanced+)

• Requirements: Enhanced KYC + bank account verification or additional documentation
• Features:
  • Unlimited withdrawals (we file CTRs for transactions $10k+)
  • Unlimited competition commitments
  • Priority customer support
  • Advanced features access

Verification Process

What We Verify:

• Age: You must be 18+ (verified via government ID)
• Identity: Name matches ID document
• Liveness: Live selfie proves you're a real person (not a photo or deepfake)
• Address: (For higher tiers) Proof of residence

How Verification Works:

• Live Photo Requirement: You must take a photo using your device's camera (gallery uploads are blocked)
• AI detects screen artifacts, lighting inconsistencies, and depth to ensure liveness
• Currently uses passive liveness (single photo analysis)
• May upgrade to active liveness (video with movement) in the future
• Instant Results: AI verification completes in 30-60 seconds
• Privacy: Your ID is encrypted and securely stored in compliance with data protection laws

Account Limits by Tier

Tier	Age Verified	Paid Matches	Withdrawal Limit
Unverified	No	Not Allowed	$3,000/day
Phone Verified	No	Not Allowed	$3,000/day
ID Verified	Yes (18+)	Unlimited	$10,000/day
Full KYC	Yes (18+)	Unlimited	Unlimited*

*CTR reports filed for daily transactions exceeding $10,000 as required by federal law

Prohibited Actions

You may NOT:

• Create multiple accounts to avoid limits
• Use fake IDs or someone else's ID
• Manipulate photos to pass liveness checks
• Share accounts with others
• Use VPNs to hide location

Consequences:

• Account suspension or termination
• Forfeiture of funds
• Legal action for fraud
• Permanent ban from platform

Data Privacy & Security

• Your ID and selfie are encrypted and stored securely
• We comply with GDPR, CCPA, and applicable data protection laws
• Your ID is only used for age/identity verification
• We never share your ID with third parties (except as required by law)
• You can request deletion of your ID after verification (account may revert to lower tier)

23. Referral Program

Overview

The Lucilla Referral Program allows users to share their unique referral code with friends and earn USDC rewards when those friends subscribe to a paid plan.

⚠️ Important: Only YOU (the referrer) earn rewards, not the person using your code.

How It Works

• Every Lucilla user automatically receives a unique referral code in the format: LUCXXXXXXXX
• You can share your code via QR code, copy link, or share link: https://lucilla.app/ref/YOURCODE
• New users can enter your code during signup
• Existing users can enter your code within their first 30 days of account creation

Earning Rewards

When someone uses your referral code and subscribes to a paid plan, you earn:

• $5 USDC per month for each month they maintain an active paid subscription
• Maximum of 6 months of rewards per referred user ($30 total)
• Rewards are paid automatically when the referred user makes their monthly payment
• Rewards are deposited into your Lucilla Smart Wallet

Referral Code Limits

• One code per account: Users can only use ONE referral code per account, ever
• Cannot be changed: Once a referral code is applied, it cannot be removed or replaced
• 30-day window: Existing users can only enter a code within 30 days of account creation
• No self-referrals: You cannot use your own referral code

Reward Restrictions

• Rewards are only paid when the referred user has an active paid subscription (Pro or Creator Pro)
• No rewards during free trials
• If a referred user cancels, rewards stop immediately
• Maximum 6 months of rewards per referred user
• Rewards are non-transferable and cannot be exchanged for cash

Fraud & Abuse

We reserve the right to:

• Suspend or terminate accounts engaging in fraudulent referral activity
• Withhold or revoke rewards from suspicious referrals
• Modify or terminate the referral program at any time
• Investigate unusual referral patterns

Examples of fraudulent activity:

• Creating fake accounts
• Using stolen payment methods
• Coordinating with others to game the system
• Using bots or automated scripts

Tax Implications

• Referral rewards may be considered taxable income in your jurisdiction
• You are responsible for reporting and paying any applicable taxes
• Lucilla does not provide tax advice - consult a tax professional

For complete Referral Program details, see: Referral Program Terms

24. Anti-Money Laundering (AML) & Compliance

Lucilla is committed to preventing financial crime and complies with U.S. Anti-Money Laundering (AML) regulations, including the Bank Secrecy Act (BSA) and OFAC sanctions.

Transaction Screening

All transactions are automatically screened for:

• OFAC Sanctions: Compliance with Office of Foreign Assets Control (OFAC) sanctions list
• Transaction Velocity: Monitoring for unusual transaction patterns and frequencies
• Structuring Detection: Identifying attempts to avoid $10,000 reporting thresholds
• Geographic Anomalies: Detecting unusual location patterns
• Risk Assessment: Automated risk scoring (0-100 scale) for every transaction

Transaction Limits

To prevent fraud and comply with regulations, the following limits apply:

• Hourly Limit: Maximum 10 transactions per hour
• Daily Limit: Maximum 50 transactions per day
• Daily Volume: Maximum $10,000 USD in total transaction volume per day

Know Your Customer (KYC) Requirements

Identity verification is REQUIRED for:

• Single transactions of $1,000 or more
• Cumulative daily transactions exceeding $1,000
• Any transactions flagged as high-risk by our automated systems

KYC Verification Process:

• Upload government-issued photo ID (driver's license, passport, or state ID)
• Take a selfie for identity verification
• Verification typically completed within minutes using AI technology
• Failure to complete KYC when required will result in transaction blocking

Suspicious Activity Monitoring

We automatically monitor for suspicious activity, including:

• Large or unusual transactions
• Rapid transaction sequences (high velocity)
• Round number transactions (e.g., exactly $5,000, $10,000) that may indicate money laundering
• Transactions from unusual geographic locations
• Transactions during unusual hours (e.g., 3am-5am)
• Multiple transactions just under $10,000 (structuring)
• New accounts making large transactions

Our Rights & Actions

We reserve the right to:

• Block Transactions: Prevent transactions that appear suspicious or violate limits
• Freeze Accounts: Temporarily freeze accounts pending investigation
• Request Documentation: Require additional identity verification or transaction documentation
• Report to Authorities: File Suspicious Activity Reports (SARs) with FinCEN (Financial Crimes Enforcement Network) when required by law
• Cooperate with Law Enforcement: Share transaction data with law enforcement agencies pursuant to legal process
• Terminate Accounts: Permanently terminate accounts involved in illegal activity

User Responsibilities

By using Lucilla, you agree to:

• Provide accurate and truthful identity information
• Not use Lucilla for any illegal activities, including money laundering, terrorism financing, or sanctions evasion
• Not attempt to structure transactions to avoid reporting thresholds
• Not create multiple accounts to circumvent transaction limits
• Comply with all applicable federal, state, and local laws
• Respond promptly to requests for additional information or documentation

Prohibited Transactions

The following activities are strictly prohibited:

• Transactions with OFAC-sanctioned individuals, entities, or countries
• Money laundering or structuring transactions
• Terrorism financing
• Drug trafficking or proceeds from illegal activities
• Human trafficking
• Participation in prohibited competitions in restricted jurisdictions
• Fraud or identity theft

Data Retention for Compliance

Transaction data is retained for 7 years as required by federal law. This includes:

• Transaction amounts and timestamps
• Wallet addresses (sender and recipient)
• Geographic location data
• Risk scores and flags
• KYC verification documents

Consequences of Violations

Violations of AML policies may result in:

• Immediate transaction blocking
• Account suspension or termination
• Forfeiture of funds involved in illegal activity
• Reporting to law enforcement
• Civil and criminal penalties under federal law

25. Contact Information

For questions about these Terms:

• Email: social@lucilla.ca
• Website: lucilla.app