Legal
Privacy Policy
Last updated: 25 April 2026
We built this studio the way we'd want our own data handled: we don't collect what we don't need, we don't run servers we can't avoid, and we don't share anything we've taken. This policy explains that in full — plainly, without legalese where plain words work.
Who we are
This site and all Lumen Labs apps are operated by NOVA-LUMEN LABS LLP, a Limited Liability Partnership incorporated in India on 2 April 2026.
- Trading name: Lumen Labs
- LLPIN: ACW-8836
- Registered office: Plot No 10/A, Rail Nagar, Belgaum, Karnataka 590001, India
- Contact: [email protected]
For the purposes of the GDPR and India's Digital Personal Data Protection Act 2023, NOVA-LUMEN LABS LLP is the data controller / data fiduciary for personal data processed through our apps and this website.
What data we collect
By default, nothing.Our apps do not collect personal data out of the box. We don't run analytics pixels, we don't embed third-party tracking SDKs, and we don't require user accounts unless a specific app genuinely needs one. Where an app does need an account or any personal data, that collection is disclosed in-app at the point of collection, in plain language, before you hand anything over.
The website itself does not use advertising cookies, tracking pixels, or third-party analytics. Minimal functional cookies may be used for things like remembering a theme preference or keeping a form session intact; nothing that identifies you personally.
HealthKit data
Any app that reads from HealthKit processes that data entirely on your device. We do not transmit HealthKit data off your device. We do not store it on servers. We do not process it on servers. We have no servers — the architectural reason we can make this claim confidently.
Per Apple's HealthKit terms, we never use HealthKit data for advertising, data-mining, or any purpose other than providing the feature you're using in the app at that moment.
Payments
In-app purchases are handled by Apple (StoreKit on iOS) and Google (Play Billing on Android). Subscription management is run by those platforms.
We use RevenueCat to receive anonymised purchase-state confirmations — essentially, "this anonymous user-ID is entitled to Pro". We never see credit card numbers, billing addresses, tax IDs, or payment identifiers. We could not leak payment data if we tried, because we never receive it.
Children
Our apps are not directed at children under 13. We do not knowingly collect personal information from children under 13. If you believe a child has provided us with data, email [email protected] and we will delete it.
Your rights under GDPR (EU/UK)
If you're in the EU, UK, or anywhere else GDPR-equivalent rights apply, you have the right to:
- access the personal data we hold about you;
- request correction of inaccurate data;
- request erasure ("right to be forgotten");
- request a portable copy of your data;
- object to processing, or restrict it.
Email [email protected] to exercise any of these rights. We aim to respond within 30 days.
Your rights under CCPA (California)
If you're a California resident, you have the right to know what personal information we hold, to request deletion, and to opt out of the sale of personal information.
We do not sell personal data. We don't share it with data brokers, ad networks, or analytics partners. There is nothing to opt out of — but you can still email [email protected] to exercise any CCPA right.
India — DPDP Act 2023 compliance
For users in India, NOVA-LUMEN LABS LLP acts as a Data Fiduciary under the Digital Personal Data Protection Act 2023. You have the right to access, correct, and erase your personal data, the right to grievance redressal, and the right to nominate another person to exercise your rights in the event of death or incapacity.
Grievances should be directed to our Grievance Officer at [email protected]. We will acknowledge receipt within 72 hours and aim to resolve within 30 days.
Data retention
We retain only the minimal data required to provide a feature, to comply with applicable law, or for reasonable fraud-prevention. When retention is no longer justified, we delete. If you request deletion and no overriding legal obligation applies, we honour it.
Changes to this policy
If we change this policy, we'll update the "Last updated" date above and note material changes on the site. We don't make changes retroactively damaging to your rights.
Governing law
This policy is governed by the laws of India. Any dispute arising out of or in connection with it falls within the exclusive jurisdiction of the courts of Karnataka, India.