Privacy Policy

LUMREN ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the LUMREN mobile application and website (collectively, the "Service"), and describes the rights available to you under applicable law, including the EU/UK General Data Protection Regulation ("GDPR") and the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA").

Please read this policy carefully. By using LUMREN you agree to the practices described here. LUMREN is not a healthcare provider and is not HIPAA-covered.

1. Information We Collect

Information you provide directly:

• Name and age representation (you must confirm you are 18 or older to use LUMREN)
• Email address, and Sign in with Apple / Google identifiers if you use those sign-in options
• Wellness intentions and personal goals
• Journal entries and mood logs
• Companion conversation messages
• Companion name and voice preferences

Biometric and health data:

• Heart rate (BPM) estimates, and how a reading compares to your own recent average
• Estimated breathing rate and perfusion index (perfusion index is used internally to judge signal quality and is not shown as a health score)
• A body state reading of settled, steady, or activated, derived from the above and your own optional mood input
• Signal quality of each read
• Scan history and timestamps

These measurements are computed on-device from your phone camera. Raw camera video is never stored or transmitted — only the computed values above are saved. Camera access is only active during an active scan in the foreground. LUMREN does not measure or report blood oxygen (SpO2), heart rate variability (HRV), stress, recovery, or arrhythmia; we removed these claims because a phone camera's sensors cannot reliably support them.

Mental health and emotional data:

• Journal entries, mood logs, and emotional state ratings
• AI companion conversation summaries and emotional pattern observations
• A personalised companion profile ("soul data") including emotional patterns, breakthroughs, and session history — built over time to personalise your experience

This data is stored on your device and optionally synced to our servers when you are signed in. You can delete it at any time from within the app.

Usage data:

• Session length and app interaction patterns
• Wellness tool usage (breathwork, sound, mudra, healing codes)
• Clarity streak and daily activity logs
• Device type, operating system version, and app version

2. Community Data

LUMREN includes an optional public Community feed. If you participate, we collect and process:

• Posts, replies and reactions: the text you write is stored on our servers and shown to other users in the Community feed. Posts are visible to anyone using LUMREN, in real time.
• Voice clips: if you attach a voice clip to a Post or announcement, the audio recording itself — not just a transcript — is uploaded to our cloud storage and made available at a public URL so that other users can play it back. This is different from the Talk companion feature (Section 5), where your voice is converted to text and the audio is discarded.
• Streak / tier badge: your clarity-streak tier (e.g. Waking, Aware, Lucid) is shown next to your Community activity.
• Device and account identifiers: a per-device identifier and your account ID are associated with your Posts so that reports, blocks, and "hide content I've reported" work correctly.
• Reports you file or that are filed against you: if you report a Post or user, we record the report for moderation review. If you are reported, the reported content and report details are retained for moderation purposes even if you later delete the content, for a limited period necessary to review the report.

Do not post anything in Community that you would not want visible to other users. We provide in-app tools to report content, block other users, and delete your own Posts; see our Terms of Service for the Community Guidelines.

3. How We Use Your Information

We use the information we collect to:

• Provide, personalise, and improve the LUMREN Service
• Power AI companion responses with context about your current state
• Generate personalised wellness recommendations based on your biometric data
• Operate the Community feed, including displaying your Posts to other users and enforcing our Community Guidelines
• Track your clarity streak, dimensional level, and progress over time
• Send push notifications when enabled (nudges, insights, reminders, and Community activity)
• Analyse aggregate usage to improve app features and performance
• Comply with legal obligations

We do not use your health or biometric data for advertising purposes, and we do not sell your personal data to third parties. We do not "sell" or "share" personal information for cross-context behavioural advertising as those terms are defined under the CCPA/CPRA.

4. Data Storage and Security

Your data is stored using the following systems:

• On-device storage: Most app state (preferences, recent scans, messages) is stored locally on your device using AsyncStorage and is not accessible to us unless you sign in and sync.
• Supabase (cloud): When you are signed in, the following may be synced to our secure Supabase database and storage for backup and cross-device access: completed heart scan data, journal entries, your personalised companion profile ("soul data"), and — if you choose to participate — your Community Posts, replies, reactions and voice clips. Data is encrypted in transit and at rest.

We implement industry-standard security measures including TLS encryption for all data in transit, access controls, and regular security reviews. However, no method of transmission or storage is 100% secure.

5. Device Permissions

LUMREN requests the following device permissions. Each is optional unless noted, and can be revoked at any time in your device Settings.

• Camera: Used solely during a heart scan to read subtle colour changes in your fingertip via the rear camera and torch. No images or video are recorded, stored, or transmitted. Camera is only active during an active foreground scan session.
• Microphone: Used in two distinct ways. (1) In the Talk screen, for voice conversations with your AI companion — audio is processed in real time (speech converted to text on-device or via a secure API call), then sent as text to generate a response; raw audio from Talk is never stored or sent to third parties. (2) In Community, if you choose to record a voice clip to attach to a Post or announcement, that recording is uploaded to cloud storage and made available to other users as described in Section 2 — this only happens when you actively record and post one.
• Notifications: Used to send daily check-in reminders, wellness nudges, insight updates, and Community activity alerts. You can enable or disable notifications at any time from device Settings. We do not send marketing emails or third-party promotional notifications.
• Screen Time / Family Controls (iOS): Used by the optional Digital Reset feature to temporarily block selected apps. Requires explicit setup by you — never enabled automatically. See Section 6 for full details.
• Accessibility Service (Android): Used by the optional Digital Reset feature to detect when a blocked app comes to the foreground, so the reset screen can appear. This service does not read, capture, or transmit the on-screen content of any app — it only observes which app package is currently in the foreground. It is never enabled automatically; you must turn it on manually in Android Settings, and can turn it off at any time. See Section 6 for full details.
• Usage Access (Android): Used by the optional Digital Reset feature to verify permission status, and separately to power in-app screen-time insights you can view. Never used to log or transmit your general app usage to our servers. See Section 6 for full details.
• Display Over Other Apps / SYSTEM_ALERT_WINDOW (Android): Used solely so the reset screen can appear on top of a blocked app. See Section 6 for full details.

6. Digital Reset — App Blocking (iOS and Android)

LUMREN offers an optional Digital Reset feature that temporarily blocks apps you choose for a short reset period before allowing access. This feature is entirely voluntary and requires explicit setup by you.

iOS (Family Controls):

• Digital Reset on iOS uses Apple's Family Controls framework. You select which apps to block using Apple's native app picker — this selection is processed entirely by Apple's system and is never transmitted to LUMREN's servers.
• LUMREN does not know, record, or store which apps you choose to block. App selection data stays on your device inside Apple's secure Family Controls container.
• When a blocked app is opened, a shield screen appears powered by Apple's ManagedSettings framework. LUMREN does not monitor your app usage outside of the shield interaction itself.
• Your most recent body state reading, latest heart rate estimate, and self-reported mental state are written to a shared on-device container so the shield screen can suggest a relevant reset tool. This data never leaves your device.

Android (Accessibility Service + Usage Access):

• Digital Reset on Android is powered by an Accessibility Service, which detects when the app you're currently viewing changes to one on your blocked list, so the reset screen can appear. This service does not read, capture, log, or transmit the on-screen content of any app — it only observes which app package is in the foreground, and only acts on apps you have explicitly chosen to block.
• The feature also uses Usage Access permission (Android's UsageStatsManager) and the ability to display over other apps (SYSTEM_ALERT_WINDOW) to support the reset screen and permission checks. All three permissions are optional and must be granted by you manually in Android Settings — none are enabled automatically, and each can be revoked at any time.
• We do not log, transmit, or analyse your general app usage patterns to our servers through any of these permissions.
• The list of apps you choose to block is stored locally on your device. It is never transmitted to LUMREN's servers.
• After your reset completes, a cooldown period (set by you) prevents the reset screen from appearing again for that app until the cooldown expires.

The Digital Reset feature collects no data that is transmitted off your device beyond what is already described in this policy. It is a tool for your personal wellness and attention management — not a monitoring system.

7. AI Services and Data

LUMREN uses two third-party AI services:

• Anthropic (Claude): Processes conversation text to generate your AI companion responses. To personalise these responses, we also send anonymised summaries of your recent scan results (e.g. whether your body state read settled or activated, and whether your heart rate was above or below your usual) along with mood and journal context. We do not send raw biometric numbers or camera data. Anthropic does not use your data to train AI models under our agreement.
• ElevenLabs: Converts text to speech for your companion's voice responses. Only the text of the AI reply is sent — no user audio, no health data. ElevenLabs does not receive your voice recordings from the Talk feature. (Separately, if you post a voice clip to Community, that recording is stored by Supabase as described in Section 2 — it is not sent to Anthropic or ElevenLabs.)

Neither AI service uses your data to train their models under our agreements. This is disclosed in the app on the paywall and Talk screens.

8. Third-Party Services

We use the following third-party services:

• Anthropic (Claude API): AI language model for companion responses
• ElevenLabs: Text-to-speech voice synthesis (text-to-speech only; no audio recordings sent)
• Supabase: Cloud database, file storage (including Community voice clips), and authentication
• RevenueCat: In-app subscription and purchase management
• PostHog: Product analytics (screen views, feature usage, session events — no health data, no email address collected)
• Sentry: Crash reporting and error monitoring (crash logs and stack traces only; no personal health data is sent to Sentry)
• Expo / React Native: App framework and push notification infrastructure
• Apple / Google: Sign-in, subscription billing, and — for Digital Reset — Family Controls (iOS) or Accessibility Service (Android)

Each third party processes data under their own privacy policies. We encourage you to review those policies.

9. International Data Transfers

LUMREN and the third-party providers listed in Section 8 may process and store your information on servers located outside your country of residence, including in the United States. Where we transfer personal data out of the EEA, UK, or Switzerland, we rely on appropriate safeguards recognised under GDPR, such as Standard Contractual Clauses, or the transfer mechanisms our providers make available, to protect your information.

10. Children's Privacy

LUMREN is intended for adults 18 and older and is not directed at or intended for use by minors, including children under 13 within the meaning of the U.S. Children's Online Privacy Protection Act (COPPA). We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us with personal information, please contact us immediately at privacy@lumren.app and we will investigate and delete it promptly.

11. Your Rights — GDPR / UK GDPR

If you are located in the EEA, UK, or Switzerland, LUMREN acts as the data controller for the personal data described in this policy. Our legal bases for processing include: performance of our contract with you (providing the Service you've subscribed to), your consent (e.g. enabling optional features like Digital Reset, microphone use, or posting to Community), our legitimate interests (e.g. securing the Service, preventing abuse, improving features), and compliance with legal obligations.

Subject to applicable law, you have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of your data ("right to be forgotten")
• Object to or restrict processing of your data
• Data portability
• Withdraw consent at any time, without affecting processing carried out before withdrawal
• Lodge a complaint with your local data protection supervisory authority

To exercise these rights, contact us at privacy@lumren.app. We will respond within 30 days, or the shorter period required by applicable law.

12. Your Rights — California (CCPA/CPRA)

If you are a California resident, the categories of personal information described in Sections 1 and 2 fall within the following CCPA/CPRA categories: identifiers (email, account ID, device ID); characteristics protected under California or federal law (age representation); internet or network activity (usage data); audio and sensory data (Talk and Community voice recordings, as described above); and sensitive personal information (health and biometric estimates, precise information about your mental/emotional state, and account log-in credentials).

In the preceding 12 months we have not sold or shared (as those terms are defined by the CCPA/CPRA) any personal information, and we do not use or disclose sensitive personal information for purposes beyond providing the Service. You have the right to:

• Know what personal information we collect, use, and disclose about you
• Access and request a copy of your personal information
• Correct inaccurate personal information
• Delete your personal information (available immediately in-app via Settings → Delete Everything)
• Limit the use of sensitive personal information to what's necessary to provide the Service (which is already how we operate)
• Opt out of the sale or sharing of personal information — not applicable, as we do not sell or share personal information
• Not be discriminated against for exercising any of these rights
• Designate an authorised agent to make a request on your behalf

To exercise these rights, contact privacy@lumren.app. We may need to verify your identity before completing certain requests.

13. Data Retention

We retain your data for as long as your account is active or as needed to provide the Service. You can delete all your data immediately at any time via Settings → Delete Everything in the app — this performs immediate erasure of your account and data, including Community content, from both your device and our servers. If you request deletion by email, we will complete it within 30 days, except where retention is required by law or, for a limited period, where content is subject to an active moderation report as described in Section 2.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes via in-app notice or email. Continued use of the Service after changes constitutes acceptance of the updated policy.

15. Contact Us

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

• Email: privacy@lumren.app
• Website: lumren.app