Scope and our role
This policy explains how Luma processes information when you use the mobile application, website, support channels, and related services. The mobile application is designed for adults who choose to organize their own personal health information.
Before public release, this policy must identify the operating legal entity, its address, applicable representative, and the countries where the service is offered.
Information you provide
We process information you choose to submit so the requested features can work.
- Account information, such as email address and authentication credentials.
- Profile information, including display name, date of birth or age, biological sex selection, height, weight, measurement system, time zone, and language.
- Sensitive health information, including laboratory reports, biomarker values, units, laboratory ranges and flags, notes, reminders, and optional menstrual-cycle entries.
- Documents, images, and PDFs you choose to scan or upload.
- An optional doctor referral code used to record who introduced you to Luma.
- Messages and attachments you send to support.
Doctor referrals
If you open a participating doctor’s referral link or voluntarily enter the doctor’s code during account creation, Luma may record an aggregate link visit, the referring partner, and the attribution date. This supports referral measurement and future commission accounting.
Referral attribution does not give a doctor access to your identity, account, uploaded reports, results, cycle entries, medications, Apple Health information, or other health data. Doctors receive aggregate referral and subscription counts only. The current beta has no active subscription charges or commission payments.
Information generated through use
The service creates limited operational information needed to keep accounts secure and features reliable.
- Session and device records, notification identifiers, consent history, and important account activity.
- Technical error information, request timing, coarse device characteristics, and security signals. We do not include behavioral advertising trackers.
- Deterministic comparisons and estimates derived from your entries, such as value changes, percentage changes, reminder dates, and estimated cycle dates.
Optional Apple Health connection
On supported Apple devices, you can choose to connect Apple Health. Luma requests read-only access to today’s step count, walking and running distance, active energy, and the latest height and weight values so it can display or refresh those details in your private profile. Apple presents and controls the permission request.
Apple Health values are processed and stored locally by the mobile app and are not uploaded to Luma’s server by this feature. Luma does not write to Apple Health, use Health data for advertising or data brokerage, or access any Health category you did not authorize. You can change Health permissions at any time in Apple Health or device Settings.
Why we process information
We use information only for defined purposes and an appropriate legal basis.
- Provide the features you request and maintain your account.
- Store, retrieve, and export information supported by the current beta.
- Schedule one-time notifications you enable.
- Protect accounts, enforce user-level access, prevent abuse, and investigate security incidents.
- Respond to support requests and comply with applicable legal obligations.
- Process sensitive health information with explicit consent where required. You can withdraw optional consent, although some features will then stop working.
Document review and automated extraction
When you choose a camera image, photo, or PDF, Luma sends that selected copy over encrypted transport to Luma’s server for optical character recognition. The server uses self-hosted OCR to propose biomarker names, values, units, and reference ranges, then discards its temporary extraction copies after the request completes. The app saves a report only after you review the structured result sheet and confirm at least one result.
OCR can be incomplete or wrong. You must compare every proposed field with the source report. Luma does not send these reports to an external generative-AI provider for extraction in the current beta, and manual correction remains available.
Sharing and service providers
We do not sell personal or health information, use it for behavioral advertising, or share it with data brokers. Carefully selected providers may process limited information under contract for hosting, private document storage, email delivery, security, customer support, or user-approved document processing.
A completed production policy must list or link to the actual provider categories, processing locations, and international-transfer safeguards. We may disclose information when legally required or necessary to protect users, the service, or others, subject to applicable law.
Storage, security, and retention
The current beta uses encrypted transport, secure password hashing, account-scoped API queries, secure mobile token storage, rate limiting, audit events, a database not exposed to the public internet, and an optional biometric app lock. No service can guarantee absolute security.
Some beta health entries are stored locally on the device. When you use in-app account deletion, Luma deletes the account and linked server-side profile and health records, clears local Luma state, and cancels reminders scheduled by the app. Limited infrastructure backups may persist temporarily until their normal rotation completes; final backup and retention periods must be disclosed before public release.
Your controls and rights
Depending on where you live, you may have rights to access, correct, export, restrict, object to, or delete personal information and to withdraw consent. Current in-product controls are listed below.
- Edit or remove cycle entries.
- Open original blood-test images or PDFs, export a verified result sheet, compare reports, and delete a report together with its locally stored source files.
- Completely hide cycle tracking while keeping its entries on the device.
- Connect Apple Health voluntarily and change that permission in Apple Health or device Settings.
- Enable an optional biometric app lock.
- Export locally stored app information through the device share sheet.
- Sign out of the current account.
- Permanently delete your account and linked server-side health data from Profile after entering an explicit confirmation.
Notifications, children, and changes
Push notifications are used only when you enable reminders. You can disable them in Luma or device settings. The service is intended for adults and is not knowingly offered to children below the minimum age required in the launch country.
We will post an updated date and provide appropriate notice before material policy changes. Continued use will not replace fresh consent where the law requires it.
Contact and complaints
Privacy contact placeholder: privacy@example.com. Replace this with a monitored address, the controller’s legal name and mailing address, and any required data-protection representative before release. You may also have the right to complain to your local data-protection authority.
This policy is a product-ready draft, not legal advice. It must be reviewed against the real company, vendors, hosting regions, launch markets, and data flows before accepting users.