Terms of Service

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 — or older where your jurisdiction sets a higher minimum age for digital consent (14 in most of Latin America, 15 in France, 16 in Germany and most EU member states). Paid skill-based step matches additionally require you to be at least 18 years old, or older where local age-of-majority law requires it: 19+ in British Columbia, New Brunswick, Newfoundland & Labrador, Nova Scotia, Northwest Territories, Nunavut and Yukon (Canada) and in Alabama and Nebraska (US); 20+ in Thailand; 21+ in Honduras, Puerto Rico and Mississippi (US). By using the App, you represent and warrant that you meet the minimum age for your jurisdiction and have the legal capacity to enter into these Terms. Users under the age of majority may use the free matches, sponsored challenges, and social features, but may not enter paid matches.

2.1 Geographic Availability

Lucilla is distributed through two storefronts — the Apple App Store and the Google Play 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 § 2.1.3 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 § 2.1.3 below.

2.1.3 On-device geofence (applies to both 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
• Sub-national age gates (track local age of majority): Canada — 19+ in British Columbia, New Brunswick, Newfoundland & Labrador, Nova Scotia, Northwest Territories, Nunavut, Yukon (18+ in AB, MB, ON, QC, SK, PE); United States — 19+ in Alabama & Nebraska, 21+ in Mississippi & Puerto Rico; Thailand — 20+; Honduras — 21+; all other eligible regions 18+

This geofence applies only to paid Step Matches that involve a USDC stake. Free Step Matches, fitness tracking, social features, fully sponsored challenges, 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, fully sponsored challenges, 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 by province/territory (tracks age of majority): 19+ in British Columbia, New Brunswick, Newfoundland & Labrador, Nova Scotia, Northwest Territories, Nunavut, and Yukon; 18+ in Alberta, Manitoba, Ontario, Quebec, Saskatchewan, and Prince Edward Island. 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.
• United States — minimum age varies in a few states (tracks age of majority): 19+ in Alabama and Nebraska; 21+ in Mississippi and Puerto Rico; 18+ in all other available US states.
• Thailand — minimum age 20+: full contractual capacity ("sui juris") is reached at 20 under the Thai Civil and Commercial Code.
• Honduras — minimum age 21+: the age of majority / full contractual capacity is 21 under the Honduran Civil Code and Family Code.
• 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.

2.3 How Eligibility & Regional Rules Are Determined

Geographic availability, minimum-age thresholds, tax handling, and other jurisdiction-specific rules described in these Terms and in the Competition Rules are determined using a combination of automated location checks and good-faith legal research — including AI-assisted review of publicly available laws and regulations across the many jurisdictions in which Lucilla operates.

We make commercially reasonable efforts to keep this information accurate and current, and we update it as laws change or as we identify corrections. However, laws differ widely between (and within) countries, change frequently, and are open to interpretation, so this information may contain errors or omissions and is provided for general guidance only — it is not legal advice. You are responsible for ensuring that your participation, and in particular your participation in paid competitions, is lawful where you are located. Where we become aware of an error we will correct it; to the maximum extent permitted by law, Lucilla is not liable for losses arising from reliance on eligibility, age, or jurisdictional information that later proves inaccurate. If you believe any jurisdiction or age determination is incorrect, please contact legal@lucilla.ca.

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 and fitness tracking.
• Starter (formerly Creator): $30/month (USD, card via Stripe) — creator monetization tools, profile shop, and everything in Free.
• Business: $100/month (USD, card via Stripe) — everything in Starter, plus the business features described in the Ask Lucilla Terms.

Your plan belongs to your Lucilla account and applies in both Lucilla apps. Reward-campaign limits and reward fees for each plan are part of Ask Lucilla and are set out in the Ask Lucilla Terms of Service.

4.2 Pricing Tiers

Lucilla offers the following pricing tiers for individuals and businesses:

• Free: Basic features, standard support
• Starter: Creator monetization features, profile shop, lower platform fees
• Business: Everything in Starter plus business features in Ask Lucilla
• Enterprise: Business-grade features, dedicated support, custom integrations (see the Ask Lucilla Terms)

4.3 Billing

• Subscriptions automatically renew monthly unless canceled
• You will be charged by card via Stripe on lucilla.app. The fitness app does not sell subscriptions through the Apple App Store or Google Play; its plan screens link to lucilla.app/subscription
• Prices are subject to change with 30 days' notice
• Refunds are generally not provided for digital content already delivered

4.4 Cancellation

• Cancel anytime from your subscription on lucilla.app, or by contacting legal@lucilla.ca
• 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

Your Lucilla wallet is a non-custodial smart wallet that you create and control with a passkey on your device (Face ID, fingerprint or device PIN), using Circle's modular wallet infrastructure. It is the same wallet you use in the Ask Lucilla app.

• Ownership: The wallet and all USDC inside it belong to you. Lucilla never receives or stores your passkey and does not have the signing authority to move funds out of your wallet.
• Device signing key (optional): You can authorize a signing key that is created and kept on your device so that in-app payments — such as joining competitions, tipping and creator subscriptions — do not need a passkey prompt every time. The key never leaves your device, the authorization expires, and Lucilla's servers only submit the transactions it signs and pay the network fee.
• 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.
• Buying and selling USDC: handled by Coinbase under its own terms and verification requirements (Section 5.4).

5.1a How Money Moves

USDC moves on the Base blockchain between users' own wallets and Lucilla smart contracts. Apart from the flows below, Lucilla does not hold, transmit or exchange customers' funds on their behalf:

• Match escrow: USDC committed to a paid match is held by a Lucilla smart contract until the match settles; Lucilla's servers submit the settlement that pays the result. Lucilla's smart contracts are upgradeable and administered by a multi-signature wallet controlled by Lucilla, whose administrative functions can recover tokens held by the contracts.
• Referral earnings are paid from a wallet operated by Lucilla (Section 23).
• Sponsored challenge prizes may be paid by transfer from the sponsor's wallet; for enterprise businesses this is a Circle wallet Lucilla manages on the business's behalf.
• Network fees for supported in-app transactions are sponsored through Circle and billed to Lucilla.

5.2 Not a Financial Institution

Lucilla is not a bank 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 prize pools and certain transactions. Fee rates are configurable and vary by subscription tier and transaction 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 is controlled by your passkey through Circle's modular wallet infrastructure. Lucilla cannot 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: Match results 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
• You control your own wallet. Lucilla wallets are non-custodial and authorized by your own device passkey and biometrics. Lucilla cannot move your funds without your authorization and cannot reverse a transfer you authorize. Lucilla is not responsible for losses or funds stolen as a result of a compromised device, a lost or shared passkey or credentials, phishing, SIM-swap, or other unauthorized access to your device or accounts — safeguarding your device and credentials is your responsibility.
• Rigorously tested, but not defect-free. Our application and smart contracts are extensively tested and continuously monitored, but like all software they may contain bugs. We fix issues promptly as they are discovered. The platform is provided on an "as is" and "as available" basis, without warranties of any kind, to the maximum extent permitted by law.
• We continuously monitor 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

6.2A Skill-Based Design, Step Floor & Win Margin

Lucilla Step Matches are purely skill-based competitions: the result is determined entirely by each participant's own physical effort (verified steps taken during the match window), not by chance. This is the same legally recognized "commitment contract" model used by StepBet, HealthyWage, and DietBet. To keep results fair and resistant to measurement noise, every paid match applies the following safeguards:

• Minimum step floor: A result is only valid if the leading participant records at least a minimum number of verified steps. If the floor is not met, the match is voided and entry commitments are returned (less any non-refundable network or processing costs where applicable).
• Win margin / draw band: A winner is declared only when their verified step count exceeds the opponent's by more than a defined margin. If the final counts fall within that margin — a statistical tie given normal device variability — the match is declared a draw and each participant's entry commitment is returned. This margin exists specifically so that ordinary device inaccuracy (see Section 6A.5) cannot decide a paid match.
• Equal conditions: Both participants compete over the same time window, under the same rules, and within the same class of device-accuracy tolerance, so neither side is advantaged by the inherent error rate of step tracking.
• Exact step floors and win-margin thresholds may vary by match type and duration and may be adjusted over time to preserve fairness; the values that apply to your match are those in effect when the match is created.

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)

Tier 2 — Good (4-8% step-count error, all paid match types)

Tier 3 — Free Matches Only (bridge-sync delay or phone pedometer)

Tier 3 devices are NOT eligible for paid matches of any duration, and are not eligible for intraday matches (free or paid). They may only be used for free daily, weekly, or monthly matches.

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 delay varies significantly by manufacturer. Garmin Connect and Zepp (Amazfit) sync to Health Connect in 1–3 minutes and are eligible for all match types including intraday paid. Polar Flow, COROS, and Suunto sync in 15–60 minutes and are limited to free daily/weekly/monthly matches only.

Eligibility restrictions due to sync delay:

• Garmin and Amazfit: eligible for all match types including intraday paid matches.
• Polar, COROS, Suunto, and Xiaomi: eligible for free daily, weekly, and monthly matches only. Not eligible for intraday matches or any paid match of any duration.
• Huawei: not currently supported.

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)

Android

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
• Spurious or "phantom" steps: All accelerometer-based step counters can occasionally register steps not produced by walking — for example from arm movement, vibration, driving on rough roads, hand-washing, or clapping — and can conversely under-count (for example when pushing a stroller or holding a railing). These false positives and negatives are an inherent limitation of consumer pedometry, not a defect specific to Lucilla. Because both competitors in a match are subject to the same class of measurement error, and because outcomes are decided by a margin threshold and a minimum step floor (see Section 6.2A), small discrepancies do not determine results — counts within the margin are declared a draw and entry commitments are returned.
• Lucilla does not guarantee the accuracy of any wearable device, and step counts are used as reported by your device and the platform health service (Apple Health / Health Connect)
• 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 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.

7.5 Objectionable Content & Conduct — Zero Tolerance

Lucilla includes user-generated content and user-to-user interaction, and we maintain a zero-tolerance policy for objectionable content and abusive users. By using the App, you expressly agree to the following, which form part of these Terms (and constitute the End User License Agreement governing user content):

• You agree not to post, upload, transmit, or share any objectionable content — including but not limited to content that is unlawful, harassing, abusive, threatening, harmful, hateful, defamatory, obscene, sexually explicit, violent, bullying, discriminatory, or otherwise offensive — and you agree not to engage in abusive, harassing, or threatening behavior toward any other user.
• There is no tolerance for objectionable content or abusive users on Lucilla. Content that violates this policy and the Prohibited Conduct in Section 7.2 is prohibited regardless of context.
• Reporting and blocking are available to every user. You can flag objectionable content or abusive users directly in the App (see Section 7.3) and block any user so their content and messages no longer reach you. Every reported item is reviewed.
• We act on reports promptly. We aim to review reports and remove objectionable content within 24 hours, and we will remove the offending content and eject the user who provided it — including suspending or permanently terminating the accounts of users who post objectionable content or engage in abusive behavior.
• Enforcement does not require prior notice. Lucilla reserves the right, but is not obligated, to monitor, remove, or restrict access to any content at any time, and to suspend or terminate any account, in our sole discretion, in order to enforce this policy and protect our users.

By continuing to use the App, you acknowledge and accept this zero-tolerance policy. If you encounter objectionable content or an abusive user, please report it in the App or contact 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. Rewards, Deals & Business Campaigns

Geo and QR rewards, promo and cashback offers, event tickets, honeypot rewards, business reward campaigns, the enterprise business platform, and user data shared with businesses when claiming rewards are part of the separate Ask Lucilla app. They are governed by the Ask Lucilla Terms of Service, the Ask Lucilla Community Rules and the Ask Lucilla Privacy Policy, not by these Terms.

Sponsored and group step challenges remain part of the fitness app and are covered by Section 6.4 and the Step Match Official Rules.

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. The minimum age is 18+, except where local age of majority is higher: 19+ in Canada's BC, New Brunswick, Newfoundland & Labrador, Nova Scotia, Northwest Territories, Nunavut, and Yukon, and in US Alabama & Nebraska; 21+ in US Mississippi and Puerto Rico.

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, and social features. 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 trademarks of Lucilla, Inc.
• 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 step-verification, matchmaking or creator monetization systems
• 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, Health Connect, Google Fit, Google Health, Fitbit, Samsung Health, Circle, Firebase, Coinbase, LiveKit, Stripe). 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 additional age requirement beyond the minimum age in Section 2 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 involve binding financial contracts, which in most jurisdictions 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

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

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

• Requirements: Enhanced KYC + bank account verification or additional documentation
• Features:
• Unlimited withdrawals
• 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

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 lets you share your referral code and earn USDC when the people you refer play paid step matches.

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

How It Works

• Every Lucilla user can get a unique referral code and share it by QR code or link (https://lucilla.app/ref/YOURCODE)
• New users enter your code when they sign up

Earning

• Paid step matches carry a 5% platform fee. When someone you referred plays a paid match, you earn 4% of that match's prize pool (80% of the platform fee), and Lucilla keeps 1%
• You earn for 6 months from the referral (12 months for founding creators)
• Earnings are paid automatically to your Lucilla wallet when each match settles, from a wallet operated by Lucilla

Limits

• One referral code can be applied per account, and it cannot be changed once applied
• No self-referrals
• Referral earnings are non-transferable

Fraud & Abuse

We reserve the right to suspend or terminate accounts engaging in fraudulent referral activity (fake accounts, collusion, bots, stolen payment methods), to withhold or revoke earnings from suspicious referrals, and to modify or end the program at any time.

Tax Implications

• Referral earnings may be 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

24. Fraud Prevention, Sanctions & Compliance

Lucilla works to prevent fraud and financial crime and to comply with applicable law, including economic sanctions.

Transaction Screening

Transactions in the app are automatically screened for:

• Sanctions: transactions involving sanctioned persons, entities or jurisdictions
• Transaction Velocity: unusual transaction patterns and frequencies
• Geographic Anomalies: unusual location patterns
• Risk Assessment: automated risk scoring (0-100 scale)

Transaction Limits

• 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

Identity Verification

Identity verification is required for:

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

Verification uses a government-issued photo ID and a selfie. Failure to complete verification when required will result in transaction blocking.

Our Rights & Actions

• Block Transactions: prevent transactions that appear suspicious or violate limits
• Restrict Accounts: temporarily restrict accounts pending review
• Request Documentation: require additional identity verification or transaction documentation
• Cooperate with Authorities: share information with law enforcement or regulators pursuant to valid legal process or where applicable law requires
• Terminate Accounts: permanently terminate accounts involved in illegal activity

User Responsibilities & Prohibited Transactions

• Provide accurate and truthful identity information
• Do not use Lucilla for money laundering, terrorism financing, sanctions evasion, fraud, or proceeds of illegal activity
• Do not transact with sanctioned individuals, entities, or countries
• Do not structure transactions or create multiple accounts to get around limits
• Do not enter prohibited competitions in restricted jurisdictions

Data Retention

Transaction records, wallet addresses, geographic data, risk scores and identity-verification documents are retained for as long as applicable law requires.

Consequences of Violations

• Transaction blocking
• Account suspension or termination
• Reporting to law enforcement where appropriate

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)
• Lucilla may feature or promote videos at its discretion

26. Reward Claim Requirements

Requirements that businesses attach to rewards (polls, reviews, follows, photo proof and similar) are part of Ask Lucilla and are described in the Ask Lucilla Terms of Service, Section 6.3.

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. Jurisdictional Restrictions on Paid Step Matches

The paid step-match feature ("Skill-Based Competition") is a contest of physical fitness skill, not gambling. However, certain jurisdictions classify any paid-entry prize contest as gambling regardless of the skill-vs-chance test. To comply with local laws, the paid step-match feature is NOT available in:

Countries

Afghanistan, Belarus, Brazil, Cuba, Gabon, Iran, Iraq, Libya, Maldives, Morocco, Myanmar, North Korea, Russia, Saudi Arabia, Syria, United Arab Emirates, Venezuela, Vietnam.

United States

Hawaii, Utah, Washington, Idaho, Montana, Florida, Nevada, Arizona, Arkansas, Connecticut, Delaware, Louisiana, South Dakota, Tennessee.

Users in these regions may still use the free features of Lucilla — walking rewards, free step challenges, daily check-ins, social features, and wallet functionality. Only the paid step-match feature is geo-restricted.

Detection method: real-time GPS location at match entry. Account registration location (from KYC) is used as a secondary check. Spoofing the geolocation to bypass these restrictions is a violation of these Terms.

Lucilla reserves the right to update this list as laws change or new jurisdictions clarify their position on skill-based prize contests.

31. SMS / Text Messaging Program

The Lucilla fitness app uses your mobile number to verify your account and send security codes; it does not enroll you in marketing texts. Lucilla's conversational text-message service at +1 (314) 237-4046 (SMS and WhatsApp) is part of Ask Lucilla, and its full terms are in the Ask Lucilla Terms of Service, Section 5. By texting that number, texting START, or opting in at lucilla.app/sms, you agree to receive text messages from Lucilla related to that service, including conversational replies to messages you send us, codes, reward and ticket confirmations, and offers you have opted into.

• Message frequency varies.
• Message and data rates may apply.
• To opt out at any time, reply STOP — you will receive a confirmation and no further messages.
• For help, reply HELP, or contact us at legal@lucilla.ca.
• Carriers are not liable for delayed or undelivered messages.

Your mobile information and messaging consent will not be shared with third parties or affiliates for marketing or promotional purposes. See the Ask Lucilla Privacy Policy for how the text-message service handles your information.

32. Contact Information

For questions about these Terms (for the Ask Lucilla app, see lucilla.app/legal/rewards):

• Email: legal@lucilla.ca
• Website: lucilla.app
• Legal notices: Lucilla, Inc., c/o Sebastian Borjas, s.borjas@lucilla.ca