Privacy Policy

1. Who is responsible for your data

Lumina is operated from North Macedonia. For the personal data described in this policy, Lumina is the "data controller" (GDPR terminology) — the entity that decides why and how your data is processed. Our payment provider, Lemon Squeezy, acts as a merchant of record for the transaction itself (billing, tax collection, refunds), and separately as our data processor under a Data Processing Agreement for the billing data it handles on our behalf. Our other providers — Supabase and Anthropic — are also processors acting on our instructions, not independent controllers of your data.

2. Information we collect

• Account data: your email address and password. Authentication is handled by our provider, Supabase — we never see or store your raw password, only a salted hash it manages.
• Journal entries: the text you write, the Active Listener's replies, and, on the Paid plan, the values, recurring patterns, emotional tones, and growth milestones our AI extracts from your entries over time (the "Identity Board") and periodic cross-entry syntheses.
• Preferences: the onboarding choices you make about what you're journaling for, how you process things, and what tone you want from Lumina.
• Billing data, if you subscribe: Lemon Squeezy collects your payment details (card number, billing address) directly — we never receive or store them. We receive only your subscription status, renewal dates, and a customer/subscription identifier from them.
• Sandbox submissions: if you try the landing-page demo without an account, we process the text you enter to generate a one-off reflection, and store a hashed (non-reversible) version of your IP address purely to enforce a daily usage limit. The entry text itself is not saved.
• Feedback: if you submit an idea or bug report, we store the message, its type, which page you sent it from, and your account (if you're signed in).
• Automatically collected technical data: standard web request data generated by normal hosting — IP address, browser and device type, operating system, timestamps, and pages visited — used only for security, abuse prevention, and debugging. We do not use this data for advertising or behavioral profiling.

3. How we use your information

Depending on the data, we use it to:

• Send your journal entries to Anthropic's Claude API to generate each reflection and, on the Paid plan, extract patterns and values for your Identity Board and periodic synthesis. Your entries are not used to train Anthropic's models.
• Authenticate you and show you your own entries and Identity Board.
• Know which plan you're on and enforce its daily reflection limit.
• Respond to support requests and feedback you send us.
• Detect abuse, prevent fraud, and keep the service secure.
• Comply with legal obligations, such as responding to a lawful data request.

We do not sell your personal data, and we do not use your journal entries for advertising or share them with data brokers.

4. Legal bases for processing (GDPR/UK GDPR)

If you're in the EEA, UK, or a jurisdiction with similar law, we rely on:

• Contract: processing your account, journal entries, and billing data is necessary to provide the service you signed up for.
• Legitimate interests: securing the service, preventing abuse of the free sandbox, and improving Lumina based on feedback you send us, balanced against your rights.
• Consent: where we ask for it explicitly (for example, before sending non-essential email), which you can withdraw at any time.
• Legal obligation: where retention or disclosure is required by law, such as tax records Lemon Squeezy keeps as merchant of record.

5. Who we share it with

We share personal data only with the service providers ("sub-processors") needed to run Lumina, each bound by their own data protection terms with us:

• Supabase — database hosting and authentication. Stores your account, entries, and Identity Board data.
• Anthropic — generates the Active Listener's reflections and pattern extraction from the text you submit.
• Lemon Squeezy — billing, as merchant of record for subscriptions; handles payment collection, sales tax/VAT compliance, and processes refunds on our behalf.
• Railway (or our current hosting provider) — runs the application server and processes technical request data as described above.

We may also disclose data if required by law, subpoena, or other legal process, or to protect the rights, property, or safety of Lumina, our users, or the public. If Lumina is ever acquired or merges with another company, your data may transfer as part of that transaction, subject to this policy's commitments continuing to apply.

6. International data transfers

Lumina and its sub-processors operate infrastructure in the United States and other countries. If you're located in the EEA, UK, or another region with data transfer restrictions, your data may be transferred to and processed in a country that doesn't have the same data protection laws as yours. Where that happens, we and our providers rely on recognized safeguards — such as the European Commission's Standard Contractual Clauses or equivalent mechanisms — to protect your data in transit and at rest.

7. Data retention

We keep your account, journal entries, and Identity Board data for as long as your account is active, so you can keep using the service and building your history. If you delete your account (see "Your rights" below), we delete this data within 30 days, except where we're legally required to retain records for longer — for example, transaction records Lemon Squeezy keeps for tax purposes. Sandbox submissions are never stored beyond generating the one-off response; the IP hash used for rate-limiting is automatically superseded after 24 hours. Feedback submissions are kept until resolved and reviewed, after which we may retain an anonymized record for product history.

8. Your rights

You can update your preferences at any time from the Preferences page. Beyond that, depending on where you live, you have some or all of the following rights over your personal data. To exercise any of them, email support@luminajournal.app.

If you're in the EEA, UK, or a similar jurisdiction (GDPR/UK GDPR)

• Access — get a copy of the personal data we hold about you.
• Rectification — correct inaccurate or incomplete data.
• Erasure — request deletion of your account and associated data ("right to be forgotten").
• Restriction — ask us to limit how we use your data in certain circumstances.
• Portability — receive your journal entries and Identity Board data in a structured, machine-readable format.
• Objection — object to processing based on legitimate interests.
• Withdraw consent — where processing is based on consent, withdraw it at any time without affecting past lawful processing.
• Lodge a complaint — with your local data protection supervisory authority if you believe we've mishandled your data.

As we're based in North Macedonia, our own supervisory authority is the Agency for the Protection of Personal Data (azlp.mk). North Macedonia's Law on Personal Data Protection is closely aligned with the EU GDPR. You can complain to us, to azlp.mk, or to your own country's authority — whichever is easiest for you.

If you're a California resident (CCPA/CPRA)

• Right to know — what personal information we collect, use, and disclose, and why.
• Right to delete — request deletion of personal information we've collected from you.
• Right to correct — request correction of inaccurate personal information.
• Right to opt out of sale/sharing — we don't sell or share personal information for cross-context behavioral advertising, so there's nothing to opt out of, but you can still confirm this in writing at any time.
• Non-discrimination — we won't deny you service or charge you differently for exercising these rights.

We'll verify your identity (typically by confirming the request comes from the email on your account) and respond within the timeframe required by applicable law — generally 30 days for GDPR/UK GDPR requests and 45 days for CCPA/CPRA requests, with a possible extension for complex requests, which we'll notify you about.

9. Cookies and similar technologies

We use one strictly-necessary cookie, set by our authentication provider Supabase, to keep you signed in. It's required for the service to function and isn't covered by cookie-consent requirements, since it isn't used for tracking, analytics, or advertising. We don't use advertising cookies, cross-site tracking pixels, or third-party analytics scripts. Your browser lets you block or delete cookies at any time; doing so for the session cookie will sign you out.

10. Children's privacy

Lumina is not directed at, and we do not knowingly collect personal data from, anyone under 18. If you believe a child has provided us with personal data, contact us at support@luminajournal.app and we'll delete it.

11. Security

Data is encrypted in transit (TLS) and at rest by our infrastructure providers. Postgres row-level security ensures only your own authenticated session — and, for the minimum necessary processing, the AI and billing services above — can access your entries. No method of transmission or storage is 100% secure; if we become aware of a data breach affecting your personal data, we'll notify affected users and relevant authorities as required by applicable law.

12. Changes to this policy

We may update this policy as Lumina evolves. We'll update the "Last updated" date above, and for material changes, notify you by email or an in-app notice before they take effect.

13. Contact us

Questions about this policy, or to exercise any of the rights above: support@luminajournal.app. See also our Terms of Service.