Terms of Service

Last Updated: April 17, 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 18 years old to use Lucilla. By using the App, you represent and warrant that you meet this age requirement and have the legal capacity to enter into these Terms.

2.1 Geographic Availability

Lucilla is distributed through three storefronts — the Apple App Store, the Google Play Store, and the Solana Mobile Seeker dApp Store. Each storefront publishes Lucilla to a slightly different list of countries, and Lucilla's on-device geofence (lib/services/geo_restriction_service.dart) blocks paid Step Matches in a smaller list of jurisdictions inside otherwise-available countries. The matrices below state the current posture per storefront as of the “Last Updated” date at the top of these Terms.

2.1.1 Apple App Store (~128 countries available)

Lucilla is published to the App Store in the countries listed as “Available on App Release” in App Store Connect > Pricing and Availability for the Lucilla app. The authoritative list lives in App Store Connect; the following countries are explicitly excluded (App Store status: “Not Available”), grouped by reason:

• Sanctions (OFAC + adjacent): Cuba, Iran, North Korea, Syria, Russia, Belarus, Venezuela, Myanmar (Burma), Sudan, Iraq, Libya, Afghanistan
• Cryptocurrency banned or severely restricted: China (mainland), Algeria, Bangladesh, Bolivia, Egypt, Morocco, Nepal, Pakistan, Türkiye, Tunisia, Turkmenistan
• Gambling / skill-game prohibitions: Saudi Arabia, United Arab Emirates, Kuwait, Qatar, Oman, Bahrain, Yemen, Brunei, Indonesia, Malaysia, Maldives, Vietnam, Lebanon
• Pending in-country legal representation or tax registration: Brazil (pending Brazilian tax registration), South Korea (pending Korean local representative under PIPA), India (pending state-level sub-geofence build-out before re-enabling)
• Other Apple-side exclusions: Anguilla, Barbados, Bhutan, Guyana, Liberia, Madagascar, Malawi, Mauritania, Montserrat, Nauru, Palau, São Tomé and Príncipe, St. Vincent and the Grenadines — not currently distributed by Apple in those storefronts

2.1.2 Google Play Store (~142 countries targeted)

The Play Console “targeted countries” list overlaps the Apple list above but is not identical. The same sanctions / crypto / gambling / pending-legal exclusions apply on Google Play, but several small territories that Apple does not currently distribute to (Aruba, Comoros, Djibouti, Eritrea, Gibraltar, Guinea, Haiti, Liechtenstein, Monaco, Samoa, San Marino, Somalia, Togo, Vatican City) are targeted on Play. Conversely, Apple distributes to Eswatini, Kosovo, and Montenegro, which are not currently targeted on Play. The on-device geofence in § 2.1.4 below applies identically regardless of which store the user installed from.

Play Console's default “Rest of World” toggle remains enabled for forward compatibility with countries Google adds after release; any country added by Google in the future automatically inherits the in-app geofence in § 2.1.4 below.

2.1.3 Solana Mobile Seeker dApp Store

The Seeker dApp Store does not enforce country-level distribution restrictions — any Seeker device worldwide can install Lucilla. Because Seeker does not act as a regional gatekeeper, the in-app geofence in lib/services/geo_restriction_service.dart is the sole enforcement layer for Seeker users. Users in any country listed under § 2.1.1 above who install Lucilla via Seeker can still browse free features, but paid Step Matches and USDC subscriptions are blocked by the in-app geofence at run-time. Lucilla treats Seeker users in sanctioned countries identically to App Store / Play Store users in those countries — all paid surfaces are unavailable.

2.1.4 On-device geofence (applies to all three storefronts)

Independent of the storefront a user installs from, Lucilla blocks paid Step Matches on-device for the following jurisdictions. The authoritative list lives in lib/services/geo_restriction_service.dart and is enforced live via the device's GPS at the moment a paid match is attempted:

• US states (12): Hawaii, Utah, Washington, Idaho, Montana, Florida, Nevada, Arizona, Arkansas, Connecticut, Louisiana, South Dakota
• Sanctioned countries (8): Cuba, Iran, North Korea, Syria, Russia, Belarus, Venezuela, Myanmar
• Australian sub-national: Northern Territory and Australian Capital Territory pending an RGB / gambling-regulator opinion on commitment-contract fitness contests
• Canadian sub-national age gate: 19+ in British Columbia, Alberta, Manitoba, Quebec, Nova Scotia, PEI; 18+ elsewhere

This geofence applies only to paid Step Matches that involve a USDC stake. Free Step Matches, fitness tracking, social features, USDC rewards from sponsoring businesses, and all other App features remain available everywhere the storefront installs the App.

United States — state-level restrictions on paid matches. Free matches, fitness tracking, USDC rewards from sponsoring businesses, and all other App features remain available in every US state where the App is downloadable. However, paid Step Matches (matches where users stake USDC) are automatically disabled by in-app geofencing for users physically located in the following states, where commitment-contract style fitness contests face active or potential restriction:

• Hawaii (HI) — Complete gambling prohibition
• Utah (UT) — Constitutional gambling ban
• Washington (WA) — Skill-based games treated as gambling
• Idaho (ID) — Full ban on paid fantasy / skill contests
• Montana (MT) — Full ban on paid fantasy / skill contests
• Florida (FL) — Wagering on any game of skill prohibited
• Nevada (NV) — Gaming license required (not yet held)
• Arizona (AZ) — Registration required (not yet held)
• Arkansas (AR) — Active enforcement against similar apps
• Connecticut (CT) — Skill-gaming restrictions
• Louisiana (LA) — Parish-by-parish; full block by default
• South Dakota (SD) — Skill-gaming restrictions

2.2 Sub-national / regional restrictions

Within available countries, additional regional restrictions apply where local laws diverge from the national position:

• Canada — minimum age varies: 19+ in British Columbia, Alberta, Manitoba, Quebec, Nova Scotia, and Prince Edward Island; 18+ elsewhere. Paid Step Matches operate normally in all provinces as skill-based commitment contracts under the same legal framework used by HealthyWage and StepBet across Canada.
• Australia — Northern Territory and Australian Capital Territory: additional gambling-style regulation may apply if matches are interpreted as wagering; Lucilla blocks paid matches in NT and ACT pending a published opinion.
• Germany — Schleswig-Holstein: different licensing regime from the rest of Germany under the Glücksspielstaatsvertrag; paid matches operate normally but additional regional rules may apply to advertising.
• India (currently excluded App Store-wide): When re-enabled, paid matches will be blocked in Tamil Nadu, Andhra Pradesh, Telangana, Karnataka, Assam, Odisha, Nagaland, and Sikkim per state-level skill-gaming prohibitions.
• Brazil (currently excluded App Store-wide): When re-enabled, will require local tax-residency registration; paid features may be restricted to specific Brazilian states.
• US Tribal lands and Native American reservations: Some federally-recognized tribal lands have separate gaming compacts; paid matches on tribal lands may be subject to those compacts rather than the surrounding state law. Lucilla treats users on tribal lands the same as users in the surrounding state for geofencing purposes.
• US territories: Puerto Rico, US Virgin Islands, Guam, American Samoa, and the Northern Mariana Islands are treated under US federal rules; paid matches are available except where the territory has its own restrictive law (e.g., American Samoa restricts most paid contests).

The authoritative, frequently-updated list of where Lucilla operates and where it does not is published at lucilla.ca/availability. The version of that page in effect at the time you use the App governs.

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

Lucilla offers three consumer subscription tiers. Paid tiers are billed monthly by card via Stripe at lucilla.ca/subscription. Applicable sales tax / VAT / GST is added at checkout based on your billing location. On-chain USDC rewards, wallets, and step-match commitments are separate from subscription billing and remain on Base as described in Section 5.

• Free: $0 — basic features, including step matches, USDC rewards from sponsors, and fitness tracking. Includes 10 rewards and a $100/month distribution cap, with a 10% platform fee on rewards.
• Creator: $9.99/month (USD, card via Stripe) — creator monetization tools, custom rewards, profile shop, and everything in Free. Includes 50 rewards and 1,000 distributions/month, with a 5% platform fee on rewards.
• Business: $29.99/month (USD, card via Stripe) — enterprise campaigns, analytics dashboard, multi-location support, and everything in Creator. Includes 100 rewards and 2,500 distributions/month, with a 4% platform fee on rewards.

4.2 Pricing Tiers

Lucilla offers the following pricing tiers for individuals and businesses:

• Free: Basic features, limited reward claims, standard support
• Creator: Creator monetization features, custom rewards, profile shop, lower platform fees
• Business: Enterprise campaigns, analytics dashboard, multi-location, priority discovery
• Enterprise: Business-grade features, dedicated support, custom integrations (see Section 10A)

4.3 Billing

• Subscriptions automatically renew monthly unless canceled
• You will be charged through your app store account (Apple, Google, or Samsung)
• Prices are subject to change with 30 days' notice
• Refunds are handled per app store policies (generally no refunds for digital content)

4.4 Cancellation

• Cancel anytime through your app store subscription settings
• Cancellation takes effect at the end of the current billing period
• No partial refunds for unused time

5. USDC Wallet & Cryptocurrency

5.1 Wallet Services

Lucilla provides two kinds of user-owned USDC wallets, both issued through Circle. They hold your USDC; they differ only in how transactions are authorized.

Agent Wallet (user-owned, Lucilla-authorized for convenience)

• Ownership: The wallet and all USDC inside it belong to you, not to Lucilla. Lucilla does not commingle Agent Wallet balances with company assets.
• Authorization model: Lucilla holds the Circle signing authorization so the app can execute transactions on your behalf within limits you set. This is a convenience layer — it is still your money.
• Purpose: Fast, seamless transactions without a passkey prompt every time — joining competitions, claiming geo/QR rewards, tipping creators, buying event tickets, subscribing to creators.
• Default limits: $100 per transaction, $100 per day, $500 per week (you can raise or lower these).
• Customizable: Adjust all limits at any time in Wallet > Agent Wallet > Settings.
• Your control: Withdraw to your Smart Wallet or any external Base wallet at any time. Revoke the app's authorization at any time.
• Security: Funds sit in Circle's infrastructure; Lucilla holds only the authorization token, not raw private keys.

Smart Wallet / Modular Wallet (user-owned, passkey-authorized)

• Ownership: The wallet and all USDC inside it belong to you. Lucilla never receives or stores your passkey.
• Authorization model: Secured by a WebAuthn passkey on your device (Face ID / fingerprint / device PIN). Only you can authorize transactions. Lucilla literally cannot move funds out of this wallet — we do not have the signing authority to do so.
• Purpose: Larger balances, withdrawals, external transfers, long-term storage.
• KYC limits: Apply at the on/off-ramp layer (Circle / Coinbase Pay / Transak), not at the wallet itself.
• Recovery: You can view your recovery phrase in wallet settings to back up the wallet independently of Lucilla. If you lose both your passkey and your recovery phrase, neither Lucilla nor Circle can recover your funds.
• Best for: Larger balances, off-platform transfers, self-custody.

Both wallets are yours. Use them simultaneously — Agent Wallet for everyday low-friction activity, Smart Wallet for larger balances and full self-custody. KYC verification thresholds (Section 22) govern how much USDC can flow through each wallet per day / year, regardless of which you use.

5.2 Not a Financial Institution

Lucilla is not a bank, money transmitter, or financial institution. We do not hold deposits, issue loans, or provide financial advisory services. USDC held in your wallet is not insured by the FDIC or any government agency. USDC rewards are not guaranteed investments and should not be treated as such.

5.3 Platform Fees on USDC Transactions

Lucilla deducts platform fees from reward pools and certain transactions. Fee rates are configurable and vary by subscription tier and reward type. Current fee schedules are available in the App and may be updated with 30 days' notice.

5.4 Onramp Providers (Buying USDC)

Lucilla partners with third-party payment processors to allow you to purchase USDC directly in the app:

Coinbase Pay

• Requirements: Must have a Coinbase account
• How it works: Log in to Coinbase, transfer or buy USDC, sent to your Lucilla wallet
• KYC: Already verified through Coinbase
• Fees: 0-2% (FREE for Coinbase One members)
• Limits: Based on your Coinbase account limits

Important:

• Lucilla does NOT process payments directly - all transactions are handled by our onramp partners
• Fees are set by the payment provider, not Lucilla
• You must comply with the onramp provider's Terms of Service
• Payment failures or disputes must be resolved with the provider
• USDC purchases are final and non-refundable once delivered to your wallet

5.5 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

5A. Platform Security & Early Access Program

5A.1 Security Architecture

Lucilla employs multiple layers of security to protect your assets and data:

• Non-custodial wallets: Your wallet keys are controlled by you through Circle Modular Wallets. Lucilla does not have direct access to move your funds without your authorization
• Transaction limits: Built-in daily and per-transaction limits protect against unauthorized large transfers
• Smart contract safeguards: All smart contracts are deployed on Base blockchain with standard security patterns including access controls, reentrancy guards, and pausability
• Multi-signal verification: Reward claims are verified through multiple independent signals before any funds are released
• Biometric authentication: Device-level biometric security (fingerprint, face recognition) protects your account access

5A.2 Early Access & Community Testing

Lucilla is in active development and continuously improving. As an early adopter, you are part of our community testing program:

• You may encounter occasional bugs or unexpected behavior — we appreciate your patience and feedback
• You can report bugs directly from your Account page in the app. Bug reports help us improve the platform for everyone
• We actively monitor all transactions and smart contract interactions for anomalies
• New features may be rolled out gradually and may change based on community feedback

5A.3 Limitation of Liability for Smart Contracts & Blockchain

IMPORTANT: While we take every reasonable precaution to ensure the security and correctness of our smart contracts and platform:

• Smart contracts on blockchain are immutable once deployed — if a bug exists in a deployed contract, it cannot be edited in place (though we can deploy updated versions and migrate)
• Blockchain transactions are irreversible — once confirmed on-chain, transactions cannot be undone by Lucilla or any third party
• Lucilla is not responsible for losses resulting from: smart contract vulnerabilities discovered after deployment, blockchain network outages or congestion, third-party wallet provider issues, user error (sending to wrong addresses), or events beyond our reasonable control
• Our total liability for any claim is limited to the amount of USDC you deposited in the 90 days prior to the incident
• We maintain operational reserves and continuously audit our systems, but no technology platform can guarantee 100% uptime or zero defects

5A.4 What We Do If Something Goes Wrong

In the unlikely event of a security incident or smart contract issue:

• We will notify affected users promptly and transparently
• We will pause affected features until the issue is resolved
• We will make reasonable efforts to recover or compensate affected funds where technically possible
• We will publish a post-incident report explaining what happened and how we're preventing recurrence

5A.5 Your Responsibility

• Keep your device secure and up to date
• Enable biometric authentication when available
• Do not share your account credentials or wallet recovery phrases
• Report suspicious activity immediately through the app
• Only deposit amounts you are comfortable using on the platform

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 anti-fraud measures to detect abnormal activity
• 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

6.4 Group Challenges & Sponsored Competitions

Anyone — businesses, friends, family, or organizations — can sponsor step challenges on Lucilla:

• Sponsor eligibility: Any Lucilla user or enterprise customer can fund a challenge prize pool from any location worldwide. Sponsoring is a promotional contribution, not wagering
• Fully sponsored (free-to-enter): When a sponsor fully funds the prize pool and participants pay no entry fee, users in ALL locations — including geographically restricted states — can participate and receive USDC prizes. This is legally classified as a promotional giveaway/sweepstakes
• Mixed funding: If participants also stake USDC alongside sponsor funds, geographic restrictions apply (see Competition Rules Section 2A)
• Sponsorship never influences outcomes — winners are determined solely by verified step performance
• Sponsored challenge terms (duration, goals, prizes) are displayed before you join
• Lucilla is not responsible for sponsor obligations beyond distributing the funded prize pool

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, and Huawei Watch

How bridge-sync works:

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

Sync delay: Bridge-sync devices typically have a 15-30 minute delay between when steps are taken and when they appear in Health Connect. This delay varies by manufacturer and sync settings.

Eligibility restrictions due to sync delay:

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

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

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)	Direct sync via Samsung Health / Health Connect
Google Pixel Watch (all approved models)	Direct sync via Health Connect
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 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

7. Content & 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

7.2 Prohibited Conduct

You may NOT:

• Post hate speech, slurs, or content targeting protected groups
• Post threats of violence, harassment, bullying, or doxxing
• Share sexual content, nudity, or anything sexualizing minors (zero tolerance)
• Post content promoting self-harm or suicide
• Spread misinformation that causes real-world harm (e.g. fake USDC giveaways, impersonation)
• Run scams, pyramid schemes, or request seed phrases / private keys
• Engage in illegal activity, incite violence, or promote terrorism
• Spam, use bot activity, impersonate, or astroturf
• Share content that infringes third-party copyright or trademark
• Reverse engineer, hack, or exploit the App

7.3 Moderation Actions

• Report: any user can report any post, message, or profile. Categories: spam, harassment, hate speech, violence or threats, nudity or sexual content, illegal activity, self-harm, scam or fraud, misinformation, or other. Reports are rate-limited (max 20 per user per 24 hours) to prevent brigading.
• Block: any user can block any other user. Blocking hides posts, severs follow relationships in both directions, and blocks direct messages.
• Auto-hide: posts with 3 or more valid reports in a 30-day window are automatically hidden from the feed pending human moderator review.
• Auto-remove: posts with 10 or more valid reports are automatically removed.
• Account suspension: repeated violations result in account suspension. Suspensions may be appealed by emailing social@lucilla.ca.
• Review SLA: we aim to review reported content within 24 hours.

7.4 Age Verification & Minor Protection

When a user's government ID indicates they are under 18, Lucilla applies the following compliance hold:

• New paid-match entry is immediately blocked. The user cannot join, host, or be invited to any new match with a monetary stake. Free matches, rewards, and social features remain available.
• Matches already in progress complete normally. It would be unfair to opposing participants — who entered in good faith — to cancel a match mid-play. Whoever wins is paid the prize per the standard rules.
• USDC already credited to the user's wallet remains with the user. Lucilla does not and cannot reverse on-chain transactions that have already settled.
• New earnings are blocked going forward until the user re-verifies showing age 18+. The compliance hold stops future accumulation; it does not reach backward in time.
• Re-verification is always available via Account Settings → Identity Verification. A successful re-verification showing 18+ immediately restores full access. This is a compliance hold, not a permanent ban.
• Appeals for mis-identification may be sent to social@lucilla.ca.

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 Bonded Curve & Monetization

Lucilla uses a Square Root Bonding Curve for creator monetization:

How It Works:

• Followers = Value: Your creator token price increases based on the square root of your follower count
• Formula: Token Price = Base Price x sqrt(Followers)
• Example: 100 followers = 10x base price, 10,000 followers = 100x base price
• Why square root? Prevents excessive speculation while rewarding genuine growth

Creator Earnings:

• Earn USDC when followers purchase your creator tokens
• Earn from content subscriptions (Pro tier required)
• Earn from tips and sponsorships
• Withdrawals subject to KYC tier limits (see Section 22)

Important Notes:

• Creator tokens are NOT securities or investment instruments
• Token values are based solely on creator popularity, not financial performance
• No guarantee of earnings or token value appreciation
• We reserve the right to modify the bonding curve formula with 30 days notice

9. Lucilla AI Journal & Live Tracking

9.1 Journal Functionality

• Lucilla provides an AI-powered journal and live tracking surface covering three tabs: Macros (meal & macronutrient logs), Exercise (workouts, sets, reps, distance), and Journal (free-form text + AI-assisted reflection).
• Your journal, macros, and exercise logs are PRIVATE by default and only readable by you. Firestore security rules lock direct reads of Users/{uid}/journal_entries, macros_entries, and exercise_entries to the owning account.
• You can search your own history within the app at any time.

9.2 Community View on lucilla.app / lucilla.ca (Anonymized)

Journal posts that users explicitly opt in to publish to the community feed on lucilla.app / lucilla.ca are force-anonymized on the web. The server strips your username, user ID, and profile picture before the entry is served to web visitors. Web readers see the journal text, any attached macros or exercise numbers, and the timestamp — but never an identity that could link the content back to you. This anonymization is a one-way transformation that happens server-side at read time; even Lucilla's web pages cannot resolve an anonymized entry back to a Lucilla account without going through an admin-only audit endpoint used solely for legal-hold or law-enforcement requests.

This lets the broader wellness community benefit from collective insights — what people are cooking, which workouts are working — without exposing individuals.

9.3 Live Tracking Subscriptions (Enhanced Profile)

Inside the Lucilla app, users may optionally enable a creator tracking subscription on their Enhanced Social Profile. This is a user-run monetization feature; Lucilla facilitates it but the relationship is between creator and subscriber.

• Creator controls the price. In Profile > Creator Pricing, a creator sets a monthly subscription price (free or paid USDC).
• Creator controls the audience tier (subscribers, subscribersAndFriends, subscribersAndFollowers). The strictest setting is subscribers-only; the most open setting still paywalls strangers.
• Subscribers see live tracking in real time. Full macros, exercise, and journal history for that creator — updated as the creator logs it.
• Non-subscribers see a paywall stub with aggregate teasers (daily totals only, no body content or photos).
• The network feed on the Social tab shows today's daily-total aggregates from creators you already have a relationship with, without body content. Tapping through takes you to the creator's profile, where the paywall takes over.
• Creator earnings flow per the standard subscription payout rules (Section 8). Platform fee follows the creator's tier (Free / Creator / Founder / Enterprise).

Enabling subscriptions is entirely optional and is the only way another Lucilla user can see your identified (non-anonymized) live journal / macros / exercise feed. Without a subscription, a friend or follower only ever sees (a) the anonymized web stream on lucilla.ca, or (b) aggregate daily-total teasers on the in-app social feed — never the full entries.

9.4 Journal Privacy Guarantees

• By default, nothing is shared — not to the web feed, not to friends, not to subscribers, not to Lucilla staff.
• Each publication path (anonymous web feed, subscriber access, post attachment) requires an explicit opt-in.
• Lucilla does not read, mine, train AI on, or monetize your private journal content. Only the AI coaching features you explicitly invoke pass your entries to a model — and only for the duration of that session.
• Entries published to the anonymized web feed cannot be de-anonymized on request, but YOU can delete them from lucilla.ca at any time via your profile controls; the anonymized copy is pulled within 24 hours of deletion.
• Entries published to Subscriber / Friend / Follower audience tiers can be revoked by the creator at any time. Existing subscribers keep access to what they already downloaded to their device cache, but future requests return a 403.

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 Reward Types

Lucilla supports the following reward types that businesses and creators can offer:

• USDC Payment: Direct USDC sent to the claimant's wallet
• Promo Discount: A promotional discount or offer redeemable at the business
• Event Access: Access to an event, experience, or exclusive content
• Honeypot Geo Ad: A location-based reward placed on specific geographic areas (hex zones), available to users who visit the area
• Social USDC: USDC rewards distributed through social interactions and sharing

10.2 Claim Methods

Rewards can be claimed using the following methods:

• QR Code: Scan a QR code displayed at the business or shared digitally
• Geo Location: Visit the specified physical location with GPS verification
• Geo + QR Redeem (Two-Step): First, claim the reward by visiting the geographic location. Then, redeem the reward by scanning a QR code at the business. Both steps must be completed to receive the reward. A 6-character redemption code is generated at claim and must be presented at redemption.

10.3 Mystery Rewards

Businesses may configure Mystery Rewards, where the exact reward amount is randomized from business-configured tiers. When you claim a Mystery Reward:

• The reward amount is randomly selected from the tiers configured by the business
• Each tier has a probability set by the business
• The result is final and cannot be re-rolled or disputed
• Mystery Rewards are distributed fairly using verifiable randomization

10.4 Recurring Rewards & Schedules

Businesses may configure rewards that automatically activate on specific days and times (e.g., "Happy Hour Fridays 4-6 PM"). Recurring rewards:

• Are available only during the scheduled time windows
• May have limited quantities per activation period
• Follow the same claim rules as standard rewards

10.5 Referral Codes for Rewards

Users may receive referral codes linked to specific reward campaigns. When you share a referral code and another user claims a reward using it, you may earn a bonus as configured by the business. Referral bonuses are subject to the same terms as standard rewards.

10.6 XP Points & Streak Bonuses

• Users earn platform XP (experience points) for claiming rewards and completing platform activities
• XP points track your engagement level and may unlock platform benefits
• Consecutive daily claims may earn streak bonuses as configured by the reward campaign
• XP points have no cash value and cannot be exchanged for USDC or any other currency
• Lucilla reserves the right to modify the XP system at any time

10.7 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

10.8 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

Reward-Specific Fees:

• Promo Rewards: First N rewards free per month (varies by tier), then a per-promo fee applies
• Event Rewards: A percentage of the ticket price or a flat fee per event access granted
• Honeypot Geo Ads: Per-hex per-month fee based on geographic coverage area
• Fee schedules are available in the App and are subject to change with 30 days' notice

10.9 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

10.10 Advertiser Responsibilities

• 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 local advertising laws and regulations
• Prohibited: Misleading ads, adult content, illegal products, scams

10.11 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.

10.12 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 (unless the campaign allows multiple claims)
• We reserve the right to revoke rewards obtained fraudulently

10A. Enterprise Platform

10A.1 Enterprise Accounts

Enterprise accounts are business accounts separate from personal user accounts. Enterprise features are designed for businesses that wish to create and manage reward campaigns, team operations, and customer engagement at scale.

• Enterprise accounts require business registration and acceptance of these Terms
• Enterprise accounts are subject to additional enterprise-specific agreements as applicable
• A personal Lucilla account is required to create an enterprise account

10A.2 Enterprise Handle System

Each enterprise account is assigned a unique handle in the format @businessname.

• Handles must be unique across the platform
• Handles are subject to a 30-day change cooldown after modification
• Lucilla reserves the right to reclaim handles that infringe on trademarks, are misleading, or violate our content policies
• Handles cannot be sold, transferred, or traded between accounts

10A.3 Enterprise Pricing

Enterprise customers are subject to the following fee structure:

• Per-reward fees: A percentage fee is applied to each USDC reward distributed through the platform, varying by reward type and volume
• Location-based fees: A monthly fee per active business location registered on the platform
• Enterprise trial: New enterprise accounts receive a 3-month free trial period with full access to enterprise features
• Custom pricing: Enterprise customers with significant volume may negotiate custom pricing

Detailed pricing is available at lucilla.app/enterprise and is subject to change with 30 days' notice.

10A.4 Enterprise Data Access

Enterprise customers receive access to campaign analytics and performance data. This data is subject to the following restrictions:

• Anonymized analytics only: Enterprise customers receive aggregated, anonymized data about campaign performance (claim rates, geographic distribution, time patterns, engagement metrics)
• No individual identification: Enterprise customers cannot identify individual users through the analytics provided. Raw user data is retained by Lucilla and is not shared with enterprise customers
• Compliance: Enterprise customers must comply with all applicable privacy laws when using analytics data
• Data retention: Campaign analytics are available for the duration of the enterprise subscription plus 90 days

10A.5 Business Profiles & Shop Tab

Enterprise customers may create public business profiles that include:

• Shop tab: A public-facing page showcasing active reward campaigns, promotions, and business information
• Marketing posts: Businesses may publish marketing content that appears in the Lucilla social feed, subject to our content policies (Section 7)
• Business hours: Publicly displayed hours of operation
• Social links and contact information: Publicly visible business contact details and social media links
• Team management: Businesses may add staff members, assign roles (owner, manager, staff), and manage permissions for their enterprise account
• Employee tipping: Users may tip business staff members via USDC. Tips are sent directly to the staff member's Lucilla wallet. Lucilla does not deduct platform fees from tips

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 step count wins entire prize pool (minus 5% platform fee)
• Geographic availability: Available in the countries where the Lucilla app is distributed through the Apple App Store (~145 countries) and Google Play Store (~157 countries), except the following US states where paid skill-based contests are restricted: Hawaii, Utah, Washington, Idaho, Montana, Florida, Nevada, Arizona, Arkansas, Connecticut, Louisiana, South Dakota. See Section 11.5 for the full list of restricted jurisdictions and the Competition Rules for the complete app-distribution footprint.
• 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 step count wins entire pot
• Free-for-All (FFA): 3-10 participants, ranked by 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)
• Ties: Prize pool split equally among tied participants
• 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 in specific US states and countries as listed in Section 11.5 below
• Users are responsible for ensuring compliance with local laws in their jurisdiction

11.5 Geographic Restrictions & Location Verification

Paid Peer Competition Restrictions

Paid peer competitions are NOT available in the following US states. This list is authoritative and is enforced live by the device-location geofence in lib/services/geo_restriction_service.dart:

• Hawaii (HI) — Complete gambling prohibition
• Utah (UT) — Constitutional gambling ban
• Washington (WA) — Skill-based games treated as gambling
• Idaho (ID) — Full ban on paid fantasy / skill contests
• Montana (MT) — Full ban on paid fantasy / skill contests
• Florida (FL) — Wagering on any game of skill prohibited
• Nevada (NV) — Gaming license required (not yet held)
• Arizona (AZ) — Registration required (not yet held)
• Arkansas (AR) — Active enforcement against similar apps
• Connecticut (CT) — Skill-gaming restrictions
• Louisiana (LA) — Parish-by-parish; full block by default
• South Dakota (SD) — Skill-gaming restrictions

Paid competitions are available in all other US states and all Canadian provinces (age 18+, or 19+ in BC, Alberta, Manitoba, Quebec, Nova Scotia, PEI).

Sponsored challenges and free competitions are available in all US states and provinces — they are promotional contests, not skill-based wagering.

Countries where the app is NOT distributed and/or paid competitions are fully blocked. The authoritative per-platform list lives in § 2.1.1 (Apple) and § 2.1.2 (Google Play) above. Summary by reason:

• US sanctions (both app availability AND paid competitions blocked on every store): Cuba (CU), Iran (IR), North Korea (KP), Syria (SY), Russia (RU), Belarus (BY), Venezuela (VE), Myanmar (MM); additionally Sudan (SD), Iraq (IQ), Libya (LY), Afghanistan (AF) are not distributed on either store.
• Cryptocurrency banned or severely restricted: China mainland (CN), Algeria (DZ), Bangladesh (BD), Bolivia (BO), Egypt (EG), Morocco (MA), Nepal (NP), Pakistan (PK), Türkiye (TR), Tunisia (TN), Turkmenistan (TM).
• Gambling / skill-game prohibitions: Saudi Arabia (SA), United Arab Emirates (AE), Kuwait (KW), Qatar (QA), Oman (OM), Bahrain (BH), Yemen (YE), Brunei (BN), Indonesia (ID), Malaysia (MY), Maldives (MV), Vietnam (VN), Lebanon (LB).
• Pending in-country registration / local representative: Brazil (BR) — pending Brazilian tax registration; South Korea (KR) — pending Korean local representative under PIPA; India (IN) — pending state-level sub-geofence build-out for Tamil Nadu, Andhra Pradesh, Telangana, Karnataka, Assam, Nagaland, Sikkim, Odisha.
• Apple-side small-territory exclusions: Anguilla, Barbados, Bhutan, Guyana, Liberia, Madagascar, Malawi, Mauritania, Montserrat, Nauru, Palau, São Tomé and Príncipe, St. Vincent and the Grenadines. This list is not exhaustive and is updated over time.

Users in blocked or undistributed locations cannot install the Lucilla app through their regional store. Users in locations where the app IS distributed but paid competitions are blocked may still enjoy free Step Matches, fitness tracking, social features, and geo-rewards. Only paid Step Matches are restricted in those jurisdictions.

Location Verification Enforcement

Lucilla enforces geographic restrictions using real-time GPS verification:

• Real-Time GPS Check: When joining a paid Step Match, your device's current GPS location is collected and verified server-side. Paid matches require location services to be enabled.
• KYC Residence Check: If you verified your identity from a sanctioned country, your account is permanently restricted from paid matches regardless of your current location.
• Server-Side Enforcement: All location checks are performed on our servers and cannot be bypassed through client-side modification.
• Compliance Logging: All paid match geo-restriction checks (both allowed and blocked) are logged for regulatory compliance and audit purposes.

Travel Policy: Location restrictions are based on where you are when you play, not where you live. If you live in an allowed state but travel to a blocked state, you cannot play paid matches while in the blocked state. Conversely, if you live in a blocked state but travel to an allowed state, you can play paid matches while in the allowed state.

Prohibited Location Manipulation

You may NOT:

• Use GPS spoofing apps or tools to fake your location
• Use VPNs or location masking to circumvent geographic restrictions
• Modify the app to bypass location verification
• Use emulators or virtual devices with fake GPS data

Violations will result in immediate account suspension, forfeiture of all match funds, and permanent ban from the platform.

11.6 Cryptocurrency On/Off-Ramp Geographic Restrictions

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

• Sanctioned countries are fully blocked from all paid services (see Section 11.5)
• Coinbase availability: 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

13.1 Ownership

All content, features, functionality, software, designs, and technology of the App are owned by Lucilla Inc. and are protected by copyright, trademark, patent, trade secret, and other intellectual property laws. This includes but is not limited to:

• The Lucilla name, logo, and all brand elements, which are registered trademarks of Lucilla Inc.
• The geo-reward distribution system and algorithms
• The proprietary location intelligence location intelligence system
• The Mystery Reward randomization mechanism
• The two-step Geo + QR redemption process
• The step challenge matching and verification systems
• The bonding curve creator monetization model
• All proprietary algorithms, data models, and technical processes

13.2 Restrictions

You may NOT:

• Copy, modify, distribute, or create derivative works based on the App or its components
• Reverse engineer, decompile, or disassemble any part of the App or its underlying technology
• Scrape, crawl, or use automated means to extract data, algorithms, or business logic from the App
• Attempt to replicate, recreate, or build competing products based on Lucilla's proprietary reward distribution algorithms, proprietary location intelligence, or two-step redemption processes
• Remove, alter, or obscure any copyright, trademark, or proprietary notices
• Use Lucilla's intellectual property for any purpose not expressly permitted by these Terms

13.3 User License

Subject to your compliance with these Terms, Lucilla grants you a limited, non-exclusive, non-transferable, revocable license to access and use the App for your personal, non-commercial use (or for authorized business use if you hold an Enterprise account).

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 (Apple Health, Google Fit, Samsung Health, Circle, Firebase, Coinbase Pay). We are not responsible for third-party services or their terms.

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 18 years old to participate in:

• Paid Step Matches - skill-based fitness competitions with financial commitments

No age restriction for:

• Free matches and challenges
• Voice/video rooms
• AI content creation and journaling
• Earning USDC from content creation, ads, or referrals
• Withdrawing funds (subject to KYC tier limits below)

Why only paid matches require 18+? Skill-based competitions with financial commitments are regulated under gaming laws in most states, which require participants to be legal adults.

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, GPS spoofing, or any method to hide or fake your location (see Section 11.5)

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. Vids (Short Video Feed)

Lucilla provides a short-form video feed ("Vids") similar to other social video platforms:

• Users can create, upload, and share short videos (up to 60 seconds)
• Videos appear in the Vids feed for other users to discover
• Content must comply with our Community Guidelines (Section 7)
• Videos may be used to fulfill reward claim requirements (e.g., "Watch Video Ad" requirement)
• Lucilla may feature or promote videos at its discretion

26. Reward Claim Requirements

Businesses and creators may configure requirements that users must complete before claiming a reward. Available requirement types include:

• Poll: Answer a business poll question
• Survey: Complete a short survey
• Leave Review: Write a review of the business
• Watch Video Ad: View a promotional video
• Global Steps: Achieve a minimum step count
• Time at Location: Spend a minimum time at the business location
• Loyalty Streak: Maintain consecutive visit streaks
• Treasure Hunt: Visit multiple locations in sequence
• Follow Business: Follow the business on Lucilla
• Follow Creator: Follow the reward creator
• Like Post: Like a specified post
• Comment: Leave a comment on a post
• Share Reward: Share the reward with friends
• Tag Business: Tag the business in a post
• Tag Creator: Tag the creator in a post

Requirements are set by the business or creator, not by Lucilla. Completing requirements does not guarantee reward availability — rewards are subject to quantity limits and budget constraints.

27. Grocery & Nutrition Features

• AI Grocery Lists: Lucilla provides AI-generated grocery lists based on your nutrition goals and preferences
• Nutrition Tracking: Track macronutrients (protein, carbs, fat) and calories from meals
• Grocery Store Integration: Browse deals and offers from participating grocery stores
• Nutrition advice is AI-generated and should not replace professional medical or dietary advice
• Grocery prices and availability are provided by third-party sources and may not be current

28. Creator Subscriptions

• Users may subscribe to creators for access to exclusive content
• Subscription fees are set by the creator and paid in USDC
• Lucilla deducts a platform fee from subscription payments
• Subscriptions auto-renew unless cancelled
• Refunds for subscriptions are handled on a case-by-case basis
• Creators are responsible for delivering the content promised to subscribers

29. Daily Free Step Matches

• Users receive up to 7 free step matches per day
• Free matches do not require USDC stakes
• Free match types include: 1v1, Free-for-All, Team, and Goal-Based
• Intraday matches (10-minute, 30-minute, 1-hour, 2-hour) are available for quick competitions
• Daily matches reset at midnight (user's local time)
• Free match results do not affect your USDC balance

30. Contact Information

For questions about these Terms:

• Email: s.borjas@lucilla.ca
• Website: lucilla.app