Privacy Policy — Lumira

Last updated: May 8, 2026 Effective date: May 8, 2026 Version: 1.0

1. Introduction

This Privacy Policy (the "Policy") describes how personal data of users of the Lumira mobile application (the "App" or the "Service") is collected, used, shared and protected.

It has been drafted in accordance with the General Data Protection Regulation (EU) 2016/679 (GDPR), the French Data Protection Act of 6 January 1978 (as amended), as well as other applicable regulations (notably ePrivacy and CCPA for California residents).

By using the App, you acknowledge that you have read this Policy.

2. Core principle: everything stays on your device

Lumira is designed to process the maximum amount of data locally, on your device:

No user account is ever created. No sign-up, no email, no password.
Your birth data (date, time, place) and your onboarding answers are stored only in your device's local database. They are never transmitted to the Publisher or to any third party.
Your daily readings are computed and stored locally.
Uninstalling the App permanently and irreversibly deletes that data.

The App does, however, rely on a limited set of third-party services — Google Firebase and Google AdMob for analytics, crash diagnostics and ad serving, and Nominatim (OpenStreetMap Foundation) for birth-place lookup during onboarding. These services may process certain technical data described below.

3. Data controller

The controller of your personal data is:

Identity: Emilie Collin
Address: 13 rue de la Grange aux Belles, 75010 Paris, France
Privacy contact email: lumira.app.contact@gmail.com

The processing does not require the appointment of a Data Protection Officer (DPO) under Article 37 GDPR. You may nonetheless contact the controller at any time at the above address for any data-related question.

4. Categories of data

Lumira applies the data minimization principle: only the data strictly necessary is collected.

4.1 Data stored only on your device (never transmitted)

Category	Data
Birth data	Date, time (optional), place of birth, associated latitude/longitude
Life context	Onboarding answers (themed tags: career, relationships, etc.)
Preferences	Language, notification time, time zone
Reading history	Readings opened (kept for 7 days by default)

This data lives in the App's local SQLite database (Drift) and local preferences (SharedPreferences). It does not leave your device. The Publisher has no access to it.

4.2 Technical data processed by third-party services

Category	Data	Third-party service involved
Firebase install identifier	Pseudonymous identifier tied to the App install	Firebase Analytics, Crashlytics
Advertising identifier	AAID (Android) — only with consent	Google AdMob
Technical data	Device model, OS and version, language, approximate country, carrier	Firebase Analytics, Crashlytics, AdMob
Usage events	Anonymous events: onboarding started and completed, daily reading opened, save tapped, tarot card drawn, voluntary rewarded-ad view to unlock an extra draw, cosmos tradition viewed, language changed	Firebase Analytics
Crash data	Stack trace, app state at crash, device type	Firebase Crashlytics
IP address	Connection IP (automatically collected server-side by Google)	Firebase, AdMob
Ad consent status	Your choice in the UMP dialog	Google User Messaging Platform
Geocoding query	When you manually type your birth place, the search term and your IP address are sent to the Nominatim server. The response (latitude / longitude / city name) is used locally and is not reused for tracking.	Nominatim (OpenStreetMap Foundation)

4.3 Data Lumira never collects

No name, first name, email or authentication identifier (the App does not offer accounts).
No payment data (the App is free and processes no payment).
No medical health data.
No biometric data.
No background location data; place of birth is entered manually and stays on your device.
No content from your contacts, photos or other apps.

5. Purposes and legal bases

In accordance with Article 6 GDPR, each processing operation relies on a specific legal basis.

Purpose	Legal basis	Data involved
Computing the natal chart and providing personalized readings	Performance of the Service requested by the User (Art. 6.1.b)	Birth data, life context (processed locally only)
Sending daily notifications	Consent (Android system permission)	Time preference, time zone
Audience measurement and product analytics (Firebase Analytics)	Legitimate interest (Service improvement) — opt-out available	Install identifier, events
Bug diagnosis and fix (Firebase Crashlytics)	Legitimate interest (security and stability) — opt-out available	Crash reports
Personalized ad serving (AdMob)	Consent collected via Google UMP	Advertising identifiers, display context
Non-personalized ad serving	Legitimate interest when consent is denied	Non-identifying contextual data
Legal obligations	Legal obligation (Art. 6.1.c)	As required

You may withdraw your consent at any time when processing relies on it, without affecting the lawfulness of prior processing.

6. Recipients of the data

Your data is never sold. It may be communicated to the following recipients, strictly within the described purposes:

6.1 Technical processors (Article 28 GDPR)

Processor	Service used	Country / Region
Google Ireland Limited / Google LLC — Firebase	Analytics, Crashlytics	EU (primary) + transfers to United States
Google Ireland Limited / Google LLC — AdMob	Ad serving	EU + United States
Google Ireland Limited / Google LLC — User Messaging Platform	Ad consent collection and storage	EU + United States
Google Play (Google Ireland Limited)	Android distribution	EU + United States
OpenStreetMap Foundation — Nominatim	Geocoding service queried when searching a birth place (one-off transmission of the typed term + IP address)	United Kingdom + Germany

6.2 International transfers safeguards

Some transfers occur to the United States. They are framed by:

Standard Contractual Clauses (SCCs) of the European Commission (Decision 2021/914);
the EU-US Data Privacy Framework adequacy decision where applicable to the relevant processor;
additional technical safeguards implemented by the processors (encryption in transit and at rest).

6.3 Public authorities

Data may be transmitted to administrative or judicial authorities under a duly issued legal request (court order, statutory obligation).

7. Retention periods

Data category	Period
Local data on the device (profile, answers, preferences)	Until App uninstall or manual reset from Settings
Local reading history	Rolling 7 days (automatic purge)
Aggregated analytics data (Firebase Analytics)	14 months max (Firebase default)
Crash reports (Crashlytics)	90 days
Ad consent status (UMP)	Until you revoke or reset
Advertising identifier (AAID)	Under your control in your phone's system settings (resettable at any time)
Data needed for litigation	Until limitation periods expire

After these periods, data is irreversibly deleted or anonymized by the processors.

8. Your rights

Under Articles 15 to 22 GDPR, you have the following rights:

Right of access — confirmation that data concerning you is processed and a copy thereof. Note: most data (natal profile, answers, history) is already directly accessible inside your App ("Profile" and "History" screens).
Right of rectification — edit your natal data from the "Edit profile" screen of the App.
Right to erasure ("right to be forgotten") — uninstalling the App immediately and irrevocably deletes all local data (natal profile, history, preferences). For data processed by third-party services (Firebase Analytics, Crashlytics, AdMob), contact lumira.app.contact@gmail.com providing your advertising identifier if you wish to use it as the key.
Right to restriction of processing — suspend certain processing operations while your contestation is verified.
Right to data portability — receive your data in a structured, commonly used, machine-readable format.
Right to object — for legitimate reasons, in particular when processing relies on legitimate interest (analytics, crash reporting).
Right to withdraw consent at any time (personalized ads via UMP, notifications via system settings).
Right to issue post-mortem directives about the fate of your data after death, in accordance with Article 85 of the French Data Protection Act.
Right not to be subject to automated individual decisions — Lumira makes no automated decision producing legal or significantly similar effects on you.

How to exercise your rights

In the App: "Settings" section (edit profile, manage ad consent via UMP, opt out of analytics, manage notifications). Uninstalling the App immediately deletes all local data.
In your phone's system settings: reset or delete the advertising identifier, manage notification permissions.
By email: lumira.app.contact@gmail.com, stating the subject of your request. Because Lumira holds no account identifier on its side, our ability to locate your data in some processing operations may be limited; if so, we will tell you what technical elements (e.g., advertising identifier) are needed.

The Publisher will respond within one month, extendable by two months in case of complexity.

Complaint with a supervisory authority

If you believe your rights are not respected, you may lodge a complaint with the French Data Protection Authority (CNIL):

3, place de Fontenoy — TSA 80715 — 75334 Paris Cedex 07, France
Phone: +33 1 53 73 22 22
Website: www.cnil.fr

You also have the right to lodge a complaint with the supervisory authority of your country of residence within the EEA.

9. Third-party SDKs

The App does not use HTTP cookies in the classic sense (it is not accessed via a web browser). It does, however, integrate third-party software development kits (SDKs) that may read or write information on your device:

SDK	Function	Type of information
Firebase Analytics	Audience measurement	Install identifier, events
Firebase Crashlytics	Diagnostics	Crash reports
Google AdMob	Advertising	Advertising identifier (AAID)
Google User Messaging Platform (UMP)	Ad consent collection	Local consent status

On first launch in the European Economic Area, the United Kingdom, Switzerland and certain U.S. states, an ad-consent screen (Google UMP) is presented, compliant with GDPR and IAB TCF v2 requirements. You may revisit your choices at any time from "Settings → Ad preferences" in the App.

10. Data security

The Publisher implements appropriate technical and organizational measures:

Sandboxed local storage — your sensitive data (natal profile, answers) stays on your device in a SQLite database isolated by the operating system's sandbox (Android).
Encryption in transit — all communications with Firebase and AdMob servers use TLS 1.2+.
Encryption at rest by processors — Google encrypts all server-side data (AES-256).
Environment isolation — separation of dev / staging / prod Firebase projects; AdMob test keys on non-production environments.
Security updates — regular application of security patches to Flutter and Firebase dependencies.

No system being infallible, in case of a security incident affecting your data, the Publisher is committed to meeting its notification obligations (CNIL and affected users) within the timeframes set by GDPR.

11. Protection of minors

The Service is forbidden to persons:

under 15 in France (Article 8 of the French Data Protection Act);
under 16 in the EEA;
under 13 in the United States (COPPA).

Users below these thresholds may only use the Service with the express consent of their legal representatives. The Publisher does not knowingly collect any data from minors without such consent. Given the absence of a user account, the Publisher relies on the User's commitment at first launch and invites any parent observing unauthorized use to report it to lumira.app.contact@gmail.com so that any associated analytics data can be purged.

12. Automated decisions and profiling

Lumira personalizes content based on your natal chart and onboarding answers. This processing consists of a deterministic selection of pre-written texts from an internal library; it uses no generative AI model at runtime, runs entirely on your device, and produces no legal or similarly significant effect on you. You retain control over your input data at all times (editable or deletable from the App).

13. Specific rights for California residents (CCPA / CPRA)

If you are a California resident, you also have the following rights:

right to know the categories of personal data collected and the purposes;
right to request deletion of your data;
right to correct inaccurate data;
right to non-discrimination for exercising these rights;
right to opt out of the "sale" or "sharing" of your data — Lumira does not sell or share your personal data within the meaning of CCPA / CPRA.

To exercise these rights: lumira.app.contact@gmail.com.

14. Changes to the Policy

The Publisher may amend this Policy to keep up with changes in the Service or in applicable law. Material changes will be notified:

by in-app notification;
at least 30 days before they take effect when the change reduces your rights or expands the purposes.

The date of the latest update appears at the top of this document.

15. Contact

For any question relating to this Policy or to the processing of your personal data:

Email: lumira.app.contact@gmail.com
Data controller: Emilie Collin

End of Privacy Policy — Lumira v1.0 — May 8, 2026