Privacy Policy

1. The short version

• No Lume account: your planner and learning history are stored on your device; optional online features are explained below.
• No ads, no sale of personal data, no cross-app tracking and no third-party analytics SDKs in the app.
• Cloud AI in Lume Plus needs explicit consent; Apple Health and cycle data stay on your device.
• Billing is handled by Apple; RevenueCat checks subscription access. Music downloads also make network requests.
• The website has no cookies or analytics. You can export or erase local data in Settings and contact us about your rights.

Version 1.0 · Effective October 25, 2026. EN and RU describe the same practices. Mandatory rights under applicable law are preserved.

2. Who is responsible

Lume is operated by Surovtev Alexandr, individual entrepreneur, Republic of Moldova (“we” or “us”). We are the controller for personal data processed to operate Lume and its website. Contact: [email protected].

This policy covers the app, online features, website and support. Having no account does not make every network request anonymous: providers can receive technical identifiers and IP addresses.

3. Data and processing on your device

Tasks, habits, completion and change history, check-ins, energy and mood entries, focus history, the learning profile (“What Lume knows about me”), Moments and preferences are stored locally, using SwiftData and other local app storage. The learning engine identifies patterns on the device. Apple Foundation Models / Apple Intelligence can provide on-device assistance where supported; local processing does not require cloud AI consent.

There is no Lume account or Lume cloud sync. Ordinary app data may be included in iOS device backups you manage with Apple or on your computer. Lume’s dedicated Health and cycle stores are excluded from device backups and the general JSON export. Exported files and shared Moments become copies wherever you choose to save or send them; protect those copies separately.

4. Optional Apple permissions

• Notifications: local reminders scheduled on your device, with your permission.
• Calendar: EventKit reads selected calendars to show events and avoid scheduling conflicts. iOS calls the permission “Full Access”; Lume uses it for read-only import, not to edit your Apple calendars or upload their contents.
• Apple Health: read-only sleep analysis for Plus, and menstrual flow for free cycle-aware planning, each after you enable the feature and grant access. Lume does not write to Health. Health data and derived findings stay on the device; they are not sent to cloud AI or used for advertising, marketing or data brokerage.
• Screen Time / Family Controls: “No Distractions” uses Apple’s privacy-preserving app-selection tokens locally. Your app choices stay on the device; Apple does not share your app-usage data with us.
• Microphone: voice input in Quick Add / Ask Lume is transcribed on the device using Apple’s speech models. Required language models may be downloaded from Apple. Lume does not upload the recording for transcription. If you then submit the resulting text to cloud AI, the next section applies.

Change permissions in iOS Settings or, for Health, in the Health app. You can continue using the planner without these permissions; the related feature may be unavailable.

5. Wellbeing and sensitive information

Mood, energy, sleep, menstrual information, personal reflections and inferred patterns can reveal sensitive details about your health and daily life. These features are optional and support planning and self-reflection, not diagnosis. Cycle-aware planning does not provide fertility, ovulation or pregnancy advice.

Do not put health details, confidential information or unnecessary information about others into cloud messages or task titles you submit. Local Health integrations are excluded from cloud requests, but text you deliberately type can itself contain sensitive information.

6. Features that use a server

Cloud AI planning and Ask Lume (Plus). When available in your version and explicitly enabled by you, a request passes through an operator-controlled Lume server to OpenAI’s Responses API under our account. OpenAI processes it for the requested service. App Attest checks app integrity; pseudonymous installation and subscription identifiers, security proofs and usage counters protect access and enforce limits. The server and its infrastructure necessarily receive network metadata, including an IP address.

Planning sends compact derived scheduling data and temporary references, not the raw planner database. Ask Lume and task help can also send your message, limited recent conversation context, relevant task or habit titles, times, durations and existing step titles. We do not upload the whole learning profile, raw activity logs, task notes or Apple Health/cycle data. Sharing permitted behavioral findings requires a separate, off-by-default consent; it must not include Health-derived or reproductive information.

Consent must explain the recipient, purpose, fields and applicable retention before sending. You can decline or withdraw cloud consent in the app; local features remain available. Withdrawing consent stops future requests and does not undo completed processing. Cloud features may be unavailable while a release or region is not supported.

Focus music. Loading the catalogue or downloading audio contacts Lume’s server or its media host. These requests expose an IP address, request time, requested file and technical request metadata. No Lume account is required; catalogue and audio requests do not carry AI conversation content or require App Attest. Downloaded tracks can play offline.

7. Why we process information

Where data-protection law requires a legal basis, we rely on performance of our agreement for requested features and subscription access; consent for optional cloud processing and permissions where required; legitimate interests in service security, abuse prevention and responding to enquiries, balanced against your rights; and legal obligations where applicable. Processing sensitive data requires the additional basis required by your law, including explicit consent where applicable.

These principles apply under Moldovan personal-data law, the GDPR where applicable, and other applicable laws. You can withdraw consent without affecting earlier lawful processing. Lume’s suggestions do not determine your legal rights or make similarly significant decisions about you.

8. The website

The Lume website is static. It sets no cookies and uses no analytics, advertising trackers or tracking pixels. Hosting infrastructure may keep IP address, request time, path, user agent and security/error information to deliver and protect the site. Such logs are kept only for the short period needed for operations and security, or longer where an incident or law requires it; we do not promise a fixed deletion interval without the applicable hosting configuration.

Links to Apple and other services open sites with their own privacy practices. Sending support email uses your email provider and ours; it is not an anonymous website form.

Your theme choice is saved in your browser (local storage); it never leaves your device.

9. Providers and other disclosures

We do not receive full payment-card details. We do not sell personal data or share it for cross-context behavioral advertising. There is no third-party analytics SDK in the app and no App Tracking Transparency permission request. We may disclose necessary information when legally required or to protect rights and security, with applicable safeguards.

10. International transfers

The operator is in the Republic of Moldova. OpenAI and RevenueCat are US providers; Apple, email and hosting services may process data in other countries. Protection can differ from your country. Where required, transfers must use a lawful safeguard, such as applicable Standard Contractual Clauses and provider data-processing agreements. A provider offering those documents does not by itself establish that every transfer is covered. Contact us for information about the safeguards relevant to your request.

11. How long information is kept

Local records remain until you delete them or remove the app, subject to your device and backup settings. A learning reset starts learning afresh without deleting your tasks, habits or answers. Deleting Lume data does not remove copies you exported, Apple Health originals, Apple-managed backups or records held separately for purchases or support.

Cloud requests use OpenAI’s storage-disabled setting; this is not a guarantee of zero retention. OpenAI’s standard API controls can retain abuse-monitoring content for up to thirty days, or longer where legally required, unless approved stricter controls apply. API content is not used for model training by default. We do not opt in to training. See OpenAI’s data controls. Sharing behavioral findings requires verified zero-content-retention and no-training arrangements before activation.

Lume’s authenticated server is designed not to persist messages, task text or AI replies in its shared state or logs. It retains security, subscription-verification and quota metadata as needed to operate and protect the service. A single production retention interval for all such records is not established here. Purchase records follow applicable accounting, fraud-prevention and provider requirements. Support correspondence is kept only as needed to resolve the request, handle disputes and meet legal obligations. We can explain the applicable criteria when you contact us.

12. Your controls and rights

In Settings, use Privacy & data → Save a copy for a JSON copy, Account & subscription → Delete data from this iPhone for a full local erase, and the learning controls in What Lume knows about me to reset what Lume has noticed. You can also pause learning, correct supported profile information, disconnect Health features, change permissions and withdraw cloud consent. See Support for steps and limits.

Depending on applicable law, you have rights of access, rectification, erasure, restriction, portability, objection and withdrawal of consent. Email [email protected] with “Privacy request”, your country and what you need. We respond within the period required by your law, normally one month under the GDPR, and explain any lawful extension. We may request reasonable verification; do not send identity documents unless necessary and specifically requested. With no account and most data only on your device, we cannot retrieve local records remotely.

You may complain to your competent supervisory authority, including the National Centre for Personal Data Protection of the Republic of Moldova or the authority where you live or work where applicable.

13. Children and age

Lume is for people aged 13 and older, not children under 13. If local law requires parental consent for online services above age 13, that higher consent threshold applies. A parent or guardian must also agree where required to enter a contract. We do not knowingly collect personal data from children using Lume contrary to these rules. Contact us if this happens; we will take appropriate steps to delete data we hold and address the use. Health and cycle information remains particularly sensitive for younger users.

14. Security

We use iOS app isolation and data protection, protected local Health/cycle storage, encrypted transport for public online services, access controls and App Attest for authenticated AI access. These measures reduce risk but cannot guarantee absolute security. Keep your device protected and software updated, and share only the information needed for a request.

15. Changes to this policy

We publish changes here with a new effective date. For material changes, we provide a prominent website or in-app notice before they apply where practicable and as required by law. A policy update does not silently expand an existing consent: we request fresh consent when required.

16. Contact

Controller: Surovtev Alexandr, individual entrepreneur, Republic of Moldova. Email [email protected] for privacy questions or visit Support. Subscription and service rules are in the Terms of Use.