Privacy Policy

Last updated: March 20, 2026

This Privacy Policy describes how Lumi ("the App", "we", "us", or "our") collects, uses, and protects information when you use the Service.

Interpretation and Definitions

Definitions

For the purposes of this Privacy Policy:

• Application means Lumi, the software application provided by us.
• Company means Lumi.
• Device means any device that can access the Service, such as a phone or tablet.
• Face Data means face images that you voluntarily upload or capture in the App, as well as face-related information derived from those images, such as facial landmarks, facial proportions, symmetry-related measurements, and analysis results.
• Personal Data means any information that relates to an identified or identifiable individual.
• Service means the Application.
• You means the individual using the Service.

Information We Collect

Personal Data

While using our Service, we may collect limited Personal Data such as:

• Email address, if you contact us directly
• Basic app usage information needed to maintain app functionality
• Purchase information related to subscriptions or in-app purchases, as provided through Apple

Photos and Face Data

Lumi provides appearance-related analysis features using photos that you voluntarily upload or capture in the App.

• Photo Upload: You may upload or capture selfies and other face photos for analysis within the App.
• Face Data Processed: The App may process facial landmarks, facial proportions, symmetry-related measurements, and analysis results derived from the photos you provide.
• On-Device Processing: Face data is processed locally on your device using Apple Vision framework.
• No Server Transmission: Face photos and related face analysis data are not transmitted to or stored on our servers.
• No Biometric Identification: We do not use face data to identify who you are, verify identity, or perform biometric authentication.

Usage Data

We may collect limited diagnostic and usage information necessary to maintain and improve the App, such as crash information, feature interaction, and general device-level diagnostics made available by Apple.

How We Use Your Information

We may use collected information for the following purposes:

• To provide the Service: including face analysis and personalized appearance-related insights inside the App.
• To process face photos locally on your device: Face data is used solely to generate the analysis results and coaching insights requested by you.
• To maintain app features: such as progress, settings, and user experience improvements.
• To communicate with you: if you contact us for support.
• To comply with legal obligations: where required by applicable law.

Camera and Photo Library Access

Lumi may request access to your device’s camera and photo library only so that you can:

• Take selfies for analysis
• Select existing photos from your library for analysis

We do not access your camera or photo library without your permission, and we do not access photos you have not selected.

Sharing of Data

We do not sell, rent, or share face data with third parties.

Face data is processed entirely on-device and is not transmitted to our servers.

We may disclose limited Personal Data if required to do so by law or in response to valid legal requests.

Retention of Data

Face photos and related analysis results used by Lumi may be stored locally on your device and are not stored on our servers. Such data remains on your device until you delete it or remove the App.

Any other Personal Data that we may receive, such as support emails, will be retained only for as long as reasonably necessary to respond to your request, comply with legal obligations, resolve disputes, or enforce agreements.

Delete Your Data

You may delete face photos and related analysis results stored by the App directly from your device by removing the content within the App, if such feature is available, or by deleting the App from your device.

If you contact us with a privacy request, we will do our best to assist you regarding any other Personal Data we may maintain, if applicable.

Security of Your Data

We take reasonable measures to protect Personal Data. Face photos and related face analysis data used by Lumi are processed locally on your device using Apple Vision framework and are not transmitted to our servers.

However, no method of electronic storage or transmission is completely secure, and we cannot guarantee absolute security.

Children's Privacy

Lumi is not intended for children under the age of 13. We do not knowingly collect Personal Data from children under 13. If you believe that a child has provided Personal Data to us, please contact us so we can take appropriate action.

Links to Other Websites

The Service may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated version on this page and update the "Last updated" date above.

Contact Us

If you have any questions about this Privacy Policy, you can contact us at:

• By email: dev.mehmetates@gmail.com