Privacy Policy

Last updated: February 8, 2025

Lumis Light App, a subsidiary of TLOP ("we," "our," or "us") operates the Lumis mobile application (the "App"). This Privacy Policy explains how we collect, use, and protect your information when you use our App.

We are committed to protecting your privacy. Lumis was designed with a privacy-first approach, and we believe your personal reflections and values should remain yours alone.

1. Information We Collect

1.1 Information You Provide

When you use Lumis, you may provide the following information:

• Personal values and preferences: The values, goals, and preferences you input to personalize your affirmations experience.
• App settings: Your notification preferences, widget configurations, and display preferences.

1.2 Information We Do NOT Collect

Lumis is designed to keep your data private. We do not collect:

• Your name, email address, or other personal identifiers
• Location data
• Contacts or address book information
• Photos, camera, or microphone data
• Browsing history
• Financial or payment information (payments are processed entirely by Apple through the App Store)

1.3 Automatically Collected Information

We may collect limited, anonymized technical data to ensure the App functions correctly, including:

• Device type and operating system version
• App version
• Crash logs and performance data

This data is collected in aggregate and cannot be used to identify you personally.

2. How Your Data Is Stored

All personal data you enter into Lumis (your values, preferences, and affirmation settings) is stored exclusively on your device. We do not transmit, upload, or store your personal data on any external servers or cloud services.

This means:

• Your data stays on your device at all times
• If you delete the App, your data is permanently removed
• We cannot access, view, or recover your personal data
• Your data is not shared with any third parties

3. How We Use Information

The limited information we may collect is used solely to:

• Provide and maintain the App's functionality
• Diagnose and fix bugs or technical issues
• Improve App performance and user experience
• Comply with legal obligations

4. Third-Party Services

4.1 Apple App Store

Lumis is distributed through the Apple App Store. Any purchases, subscriptions, or transactions are processed entirely by Apple and are subject to Apple's Privacy Policy. We do not have access to your payment information.

4.2 Analytics

We may use anonymized, privacy-respecting analytics tools to understand general usage patterns (e.g., which features are most used). These tools do not collect personally identifiable information and comply with Apple's App Tracking Transparency framework.

4.3 No Advertising

Lumis does not display advertisements. We do not share any data with advertising networks or data brokers.

5. Data Security

Since your personal data is stored only on your device, it benefits from the security measures built into your iOS device, including:

• Device encryption
• Passcode/biometric protection
• iOS sandboxing (apps cannot access each other's data)

We recommend keeping your device's operating system up to date and using a strong passcode or biometric authentication to protect your data.

6. Children's Privacy

Lumis is not directed at children under the age of 13 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will take steps to delete such information.

7. Your Rights

Depending on your location, you may have certain rights regarding your data, including:

• Access: Since all data is stored on your device, you have full access to it at all times through the App.
• Deletion: You can delete all your data at any time by deleting the App from your device.
• Portability: Your data resides on your device and is under your control.
• Opt-out: You can disable any optional data collection through your device's privacy settings.

7.1 For European Users (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR), including the right to access, rectify, erase, restrict processing, and object to processing of your personal data. Since Lumis stores all personal data on your device and does not collect personally identifiable information, most of these rights are inherently satisfied by our architecture.

7.2 For California Users (CCPA/CPRA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). We do not sell or share your personal information. Since we do not collect personally identifiable information, the provisions of these laws are inherently addressed by our privacy-first design.

8. International Data Transfers

Since your personal data is stored exclusively on your device, no international data transfers of personal data occur through our App.

9. Data Retention

Your personal data remains on your device for as long as you use the App. When you delete the App, all associated data is permanently removed from your device. Anonymized crash and performance data may be retained for up to 12 months for analytical purposes.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy within the App and updating the "Last updated" date. Your continued use of the App after changes are posted constitutes your acceptance of the updated policy.

11. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:

Lumis Light App
A subsidiary of TLOP
Email: lumisapp@outlook.com