Privacy Policy

Section 1

Who we are and what this covers

Lumi is made by Nowl Labs [CONFIRM: owner: registered legal-entity suffix (for example Private Limited), from the MCA certificate], based in India. For the Digital Personal Data Protection Act, 2023 we are the “Data Fiduciary”: we decide why and how your personal data is used. “You” means the person using Lumi, the “Data Principal”.

This policy covers the Lumi app for Android and iPhone and the Lumi website. It explains what we collect, why, who helps us process it, how long we keep it, and the rights you have.

Section 2

What we collect and why

Each row below is a kind of data, what it includes, why we use it, and where it is kept. We only ask for what a feature needs.

Notification reminders are scheduled on your phone. We do not collect a push token or send notifications from a server.

Section 3

Face photos

Face photos are the most sensitive thing Lumi handles, so they have their own rules. We treat them as sensitive personal data under the Information Technology Rules, 2011, even though Lumi does not use them to identify you.

Consent first, and only for adults

Nothing is captured until you have agreed on the Face scanning screen. Face scanning is only for people aged 18 and over, because the DPDP Act 2023 treats anyone younger as a child. Lumi as a whole is intended for people aged 18 and over (section 13). We rely on the age you give us and do not verify it.

What happens during a scan

• Framing, lighting and face-position checks run on your phone.
• When you ask for a report, the photos and your skin profile are sent once, over an encrypted (HTTPS) connection, to our analysis service, which uses an AI model to read them. What comes back is a written report. [CONFIRM: name the AI provider used by the analysis service, and confirm it does not keep the photos]
• The temporary files made during the scan are deleted from your phone after they are sent.
• No face-recognition template or biometric identifier is created, and your photos are never used to recognise you.

Where the photos are kept afterwards

By default, on your phone only. A copy of your latest scan's photos is kept in Lumi's private app storage so your report can show them. A new scan replaces it.

Private cloud storage is optional and off until you turn it on. It is a separate choice on the Face scanning screen, and it needs a signed-in account. When it is on, the photos of your latest scan are stored in Google Firebase Storage in an area only your account can read, so your report keeps its photos on a new phone. Only the latest scan is kept; the previous one is deleted when a new one is saved. Turning it off deletes the photos stored there.

What we never do with them

• We never sell them or share them with advertisers or data brokers.
• We never use them to train AI models.
• We never make them public or show them to other users.

Withdrawing consent

Withdrawing is as easy as giving consent. Open Profile › Face scanning (in the Lumi app) and turn it off. Face scanning stops and the face photos on your phone are deleted. Your written reports stay, because they contain no photos. Withdrawing consent does not delete your account; that is a separate step (section 12).

Section 4

Lumi chat and voice calls

Lumi's replies are generated by AI. To answer well, Lumi is given a short summary of your profile: your first name, skin type, concerns, latest score, routine and recent product scans. It is not given your face photos.

• Typed chat is handled by ElevenLabs' conversational AI service. If that is unavailable, our own Lumi server answers using Google's Gemini models on Google Cloud (in Mumbai). Our server keeps a memory of your conversations and ratings, linked to your account, so Lumi can remember context.
• Voice calls only start when you tap Call and allow the microphone. Your voice is streamed to ElevenLabs for the length of the call so Lumi can hear and answer you. [CONFIRM: ElevenLabs retention settings for transcripts and audio]
• Read aloud uses your phone's own text-to-speech; nothing is sent for it.
• Ratings: if you rate a reply, the rating and any note you add are stored with that conversation so we can improve Lumi.
• Reporting a reply: every Lumi reply has a “Report this reply” option. A report sends us the reason you picked, any note you add, and the text of the reply you reported, linked to your account, so our team can review it and fix the problem. Reports are kept only as long as we need to deal with them.

Please do not share things in chat you would not want stored, such as passwords, bank details or other people's health information.

Section 5

Location

• During onboarding you can pick your city, or tap to use your location. If you do, Lumi asks your phone for an approximate location only, uses it to find your city, and saves its coordinates in your profile rounded to about 1 kilometre, to look up your local climate. Lumi never asks for your precise location.
• The home screen's weather card uses a low-accuracy location, rounded to about 1 kilometre, and sends it to Open-Meteo, a weather service, to get UV, temperature, humidity and air quality.
• Location is only read while you are using the app, never in the background. You can refuse or turn it off in your phone's settings and type a city instead.

Section 6

Analytics

We use Mixpanel, hosted in the European Union, to see how Lumi is used. It receives app events (for example “report viewed”), your device platform and app version. When you sign in, those events are linked to your account ID, and your name, email address and sign-in method are added to your Mixpanel profile so your activity is counted once across devices.

• Analytics never receives your photos, the text of your chats or searches, or the answers you give in onboarding.
• Scores are mostly sent in broad bands rather than exact numbers.
• Lumi does not record your screen for analytics.
• We do not use analytics for advertising, and there are no ads in Lumi.
• As a safeguard, if a profile on your phone says you are under 18, Lumi switches analytics off on that phone: no events are sent to Mixpanel and you are not linked to a Mixpanel profile. It switches back on only if the age is corrected to 18 or over.

Section 7

Who we share data with

We do not sell or rent your personal data. We share it only with providers that help us run Lumi, only for that purpose, under their own security and privacy terms:

Each provider's own privacy terms: Google, Firebase, ElevenLabs, Mixpanel, Open-Meteo and Cloudflare.

When you open a product in a shop from Lumi, the shop's page loads in Lumi's in-app browser. That shop receives what any website receives from a visitor and handles it under its own privacy policy. Lumi does not pass it your profile or scans.

We may also disclose data where Indian law requires it, for example to a court or a government agency with legal authority, or to protect someone's safety. If Lumi or our company is ever sold or merged, your data would move under this policy and we would tell you first.

Section 8

Where your data is processed

Our Lumi chat server runs in Mumbai. Some of our providers process data in other countries: Mixpanel in the European Union, and Google, ElevenLabs and Cloudflare in their global data centres. We only transfer data outside India as the DPDP Act 2023 allows. [CONFIRM: Firestore and Storage region for project lumi-509007]

Section 9

How long we keep it

• On your phone: until you delete it, withdraw consent, sign out of an account that is erased, or uninstall Lumi. Scan history keeps your 40 most recent scans.
• In your account: your profile, reports, history and routine are kept while your account is open, and deleted when you delete your account.
• Private cloud photos: only your latest scan, until you turn cloud storage off or delete your account.
• Lumi chat memory: while your account is open. [CONFIRM: deletion of chat memory on the Lumi server when an account is deleted]
• Analytics: kept by Mixpanel for as long as our Mixpanel project retains it. [CONFIRM: Mixpanel retention period and deletion on account deletion]
• Emails and feedback: as long as needed to deal with what you raised.

We may keep a limited record for longer where the law requires it, for example to resolve a dispute or respond to a legal request. [CONFIRM: fixed retention period for saved reports (the earlier 12-month rule is not yet automated)]

Section 10

How we protect it

• All traffic between the app and our services is encrypted in transit (HTTPS/TLS).
• Our cloud database and photo storage are locked so each account can read and write only its own records.
• Face photos are never sent to analytics or to Lumi chat.
• Access to our systems is limited to the people who need it to run Lumi.

No system is perfectly secure. If a personal data breach affects you, we will tell you and the Data Protection Board of India as the DPDP Act 2023 requires, with what happened and what you can do.

Section 11

Your rights

Under the DPDP Act 2023 you have these rights, and most of them are one tap away:

• Know and access: see your profile in Profile (in the Lumi app) and your scans in Skin journey (in the Lumi app). For a summary of what we hold and who we shared it with, email us.
• Correct and update: edit your profile at any time.
• Erase: delete a scan, turn off cloud photo storage, withdraw face-scanning consent, or delete your account (section 12).
• Withdraw consent: at Profile › Face scanning (in the Lumi app). Withdrawing does not undo processing that already happened.
• Nominate: name someone to exercise your rights if you die or cannot act. Email us and we will record it.
• Complain: to our Grievance Officer first (section 16). If you are not satisfied, you can complain to the Data Protection Board of India.

We may need to confirm it is really you before acting on an emailed request. We aim to acknowledge a request within 48 hours.

Section 12

Deleting your account

Open Profile (in the Lumi app) and tap Delete my account. If you no longer have the app, follow the steps on our account deletion page or email us from the address on your account.

Deleting your account removes your sign-in, profile, reports, history, routine and private cloud photos, and erases what Lumi kept on that phone. It cannot be undone. Withdrawing face-scanning consent is narrower: it only removes face photos. [CONFIRM: server-side deletion covers the account database, photo storage, sign-in record and chat memory]

Section 13

Children

Lumi is intended for people aged 18 and over. The DPDP Act 2023 treats anyone under 18 as a child, and we do not knowingly collect or process children's personal data.

• If we learn that we hold personal data of someone under 18, we delete it, and close the account if there is one.
• If you think a child is using Lumi, or you are a parent or guardian who wants a child's data deleted, email [email protected] and we will act on it.
• There are no ads in Lumi, and we never target advertising at anyone.

Section 14

Phone permissions

Lumi only asks for a permission when you use the feature that needs it, and you can say no:

• Camera: face scans, label scans and your profile picture.
• Photos: to choose a picture instead of taking one.
• Microphone: voice calls with Lumi.
• Location: your city and local weather (section 5).
• Notifications: routine reminders you set up.

Section 15

Changes to this policy

If we change this policy, we will update the date at the top. If a change affects how we use your data in a significant way, we will tell you in the app first, and where the change needs your consent we will ask for it again.

Section 16

Contact and Grievance Officer

Questions, requests or complaints about your data: write to [email protected].

• Grievance Officer: Aniket Kumar
• Company: Nowl Labs [CONFIRM: owner: registered legal-entity suffix, from the MCA certificate]
• Postal address: [[STREET_AND_PIN — NOT YET SET]], Bengaluru, Karnataka, India
• Email: [email protected]

We acknowledge complaints within 48 hours and aim to resolve them within 30 days. Your right to complain to the Data Protection Board of India is unaffected.