Last updated: TO BE CONFIRMED

Privacy policy

What we collect, why, who helps us, and the choices you have.

DRAFT FOR REVIEW. This policy has not been checked by a lawyer yet and is not in force. Everything marked TO BE CONFIRMED still needs an answer before LumiNus launches.

The short version

  • We collect what LumiNus needs to work for the two of you, and nothing more.
  • What you write stays between you and your partner. Our analytics never include it.
  • We don't sell your personal data, and there are no ads in LumiNus.
  • The app's data is stored in the European Union (Ireland).
  • You can switch analytics and crash reports off in Settings at any time.
  • Deleting your account deletes your data, including the data you share as a couple.
  • LumiNus is for adults: you must be 18 or older.

1. Who we are

LumiNus is an app for couples, made by LoveLumiNus Limited, a company registered in Hong Kong (Business Registration No. 77431755; registered office: Unit 2406B, 24/F, Low Block, Grand Millennium Plaza, 181 Queen's Road Central, Sheung Wan, Hong Kong). In this policy, "we", "us" and "our" mean LoveLumiNus Limited.

We decide how and why your personal data is used, which makes us the "controller" under data protection law. You can contact us about anything in this policy at hello@loveluminus.com.

TO BE CONFIRMED (legal review): because we are based in Hong Kong and offer LumiNus to people in the EU and the UK, we may need to name a representative in the EU and in the UK (GDPR and UK GDPR, Article 27). Add their details here.

2. What we collect

Here is everything the LumiNus app collects, and why.

WhatExamplesWhy we need it
Your account Your email address, your password (our login provider only ever stores it in scrambled, hashed form), your name, and your confirmation that you are 18 or older. To create your account, sign you in and keep it secure.
Your profile Details you add about yourself, such as your gender, birthday, working status and diet preference. To suggest ideas that suit you, such as recipes that fit your diet.
Your couple Who you are paired with, your invite code, your shared time zone, and relationship details either of you adds, such as your relationship stage, wedding date, living situation and whether you have children. To pair you, to start your day at the right time, and to suggest ideas that fit your life together.
Your preferences Which kinds of ideas you turn on or off and which you like more, and the focus areas you choose. To decide which idea cards and missions you receive.
What you do in LumiNus Your likes and skips on idea cards, ideas you write yourselves, ideas you mark as done, challenges (title, notes, deadline and status), your answers to questions and quizzes, and the missions you complete. This is LumiNus itself: showing your matches, your challenges, your answers and your memories to the two of you.
Notifications If you allow notifications, a token that identifies your phone to Apple's or Google's notification service, and your notification setting. To send you reminders and updates from your partner, at most two a day and never at night.
Usage analytics (unless you switch them off) Events such as "app opened", "card swiped" or "challenge created", with a few details such as the category of a card or the number of days of a challenge. They are linked to a scrambled (hashed) ID, never to your name or email address. We never include what you write, and we don't store your IP address with them. To understand which parts of LumiNus help couples and which don't, so we can improve it.
Crash reports (unless you switch them off) Technical details when something goes wrong, such as the app version, your phone model and the error. No screenshots and no text you wrote. To find and fix bugs.
Messages you send us Your email address and whatever you write to us. To answer you.

TO BE CONFIRMED: once "Sign in with Apple" and "Sign in with Google" are added, list what we receive from them (usually your name and email address).

3. Sensitive information

Some of what you do in LumiNus can reveal something about your intimate life, for example if you turn on intimacy ideas and like some of them, or answer questions about intimacy. Data protection law treats this as especially sensitive, and so do we.

  • We use it only to run LumiNus for you and your partner.
  • It is only created if you choose to turn those ideas on. You can turn them off at any time in Settings, under Idea Card Focus.
  • We never send the content of an idea, question or answer to our analytics or crash reports.

TO BE CONFIRMED (legal review): (1) whether we must ask for separate, explicit consent before intimacy ideas are shown; (2) our analytics can include the category of a card you swiped, which may be "Intimacy", linked to a scrambled ID. Decide with a lawyer, especially for Germany, whether that is acceptable or whether this category should be left out of analytics.

4. What your partner can see

LumiNus is made for two, so some things are shared with your partner by design.

Your partner can see:

  • your name;
  • the ideas you have both liked (your matches);
  • your answer to a question or quiz, once you have both answered;
  • challenges you send each other, and what happened to them;
  • ideas you mark as done, and your shared memories;
  • the settings you share as a couple, such as your time zone, your relationship details and your idea categories.

Your partner can't see the ideas you skipped or a history of your swipes. One honest note: if your partner likes an idea and no match appears, they can work out that you passed on it.

5. Why we use it (our legal bases)

If you live in the EU or the UK, the law requires us to tell you the legal basis for each use of your data:

  • To provide LumiNus to you (performing our contract with you): your account, pairing, your daily ideas and missions, and keeping everything in step between you and your partner.
  • Our legitimate interests: usage analytics and crash reports to keep LumiNus working and to improve it. You can object at any time by switching them off in Settings.
  • Your consent: notifications, which you allow on your phone, and the sensitive information described above.
  • Legal obligations: when the law requires us to keep or share information.

TO BE CONFIRMED (legal review): confirm each legal basis, including the Hong Kong Personal Data (Privacy) Ordinance.

6. Who helps us

We use a small number of service providers to run LumiNus. They may only use your data to provide their service to us, and never for their own purposes.

ProviderWhat they do for usWhere
SupabaseThe app's database, sign-in and back endEU (Ireland)
PostHogUsage analytics, only if analytics are onEU
SentryCrash reports, only if analytics are onEU (Germany)
ExpoSending push notifications to Apple and GoogleTO BE CONFIRMED
Apple and GoogleThe app stores and push notifications; sign-in, if you choose to sign in with themUnder their own privacy policies
Our email sending serviceSign-up and sign-in emailsTO BE CONFIRMED
CloudflareThis website, and forwarding emails sent to our addressesWorldwide network
Google (Gmail)The mailbox where we read and answer your emailsTO BE CONFIRMED

We may also share information if the law requires it, or with a buyer if LoveLumiNus Limited is ever sold, in which case this policy would continue to protect your data.

7. Where your data is stored

The app's data is stored in the European Union, in Ireland. Our team is based in Hong Kong and may access it from there, and some of our providers may process data in other countries. When data leaves the EU or the UK, we rely on recognised safeguards, such as the European Commission's standard contractual clauses.

TO BE CONFIRMED (legal review): the safeguards for each transfer, including access from Hong Kong.

8. How long we keep it

  • Your account and everything in it: for as long as your account exists.
  • When you delete your account: we delete your data and your couple's shared data from our live database straight away. Copies in our backups disappear within TO BE CONFIRMED: number of days.
  • Usage analytics: kept for TO BE CONFIRMED. They are linked only to a scrambled ID.
  • Crash reports: kept for TO BE CONFIRMED.
  • Emails you send us: for as long as we need them to help you, and no longer than TO BE CONFIRMED.

9. Deleting your account, and why shared data goes too

Everything in a LumiNus couple is shared by design. An answered question holds both of your answers, and a memory records something the two of you did together. There is no version of that data that belongs to just one of you.

So when either partner deletes their account, the couple's shared record is deleted with it, and neither of you can keep a copy of the other's part. The same happens if you unlink from your partner: your shared content is deleted, and we keep only a minimal record, with no content, that the couple existed.

You will be able to delete your account in the app, in Settings. TO BE CONFIRMED: account deletion arrives in the app before launch. Until then, email hello@loveluminus.com from the address you signed up with.

10. Your rights

Depending on where you live, you have the right to:

  • ask for a copy of your personal data;
  • ask us to correct it;
  • ask us to delete it;
  • ask us to restrict how we use it, or object to it (for analytics, you can simply switch them off);
  • receive your data in a portable format;
  • withdraw your consent at any time, without affecting what we did before;
  • complain to a data protection authority.

LumiNus doesn't have a button to download your data yet. Email us and we will send you a copy by hand. We reply to requests within one month.

If you want to complain, you can contact the data protection authority where you live: in the EU, your local authority (in Germany, the authority for your federal state); in the UK, the Information Commissioner's Office (ico.org.uk); in Hong Kong, the Office of the Privacy Commissioner for Personal Data (pcpd.org.hk). We'd appreciate the chance to put things right first, so please get in touch with us too.

11. Your choices in the app

  • Analytics and crash reports: Settings, then Analytics. When it's off, nothing is sent, and crash reports stop too.
  • Notifications: Settings, then Notification, or your phone's settings.
  • Which ideas you receive: Settings, then Idea Card Focus.

TO BE CONFIRMED (legal review): the Analytics switch in the app says "Share anonymous usage with LumiNus". Because the data is linked to a scrambled ID, it is pseudonymous rather than anonymous. Consider changing the app's wording.

12. Age

LumiNus is for adults. You must be 18 or older to use it, and we ask you to confirm this when you sign up. If we learn that someone under 18 has an account, we will delete it.

13. Security

We protect your data with encryption between your phone and our servers, passwords stored only in hashed form, and database rules that stop anyone outside your couple from seeing your couple's data. No system is perfectly secure. If something happens that puts your data at risk, we will tell you and the authorities as the law requires.

14. This website

loveluminus.com sets no cookies and uses no analytics or advertising trackers. Our fonts are served from this website, not from a third party. Cloudflare, which hosts the website, processes technical information such as IP addresses to deliver it and keep it safe. If you email us, see "Messages you send us" above.

15. Changes to this policy

If we change this policy, we will update the date at the top. If the change is important, we will also tell you in the app before it takes effect.

16. Contact us

LoveLumiNus Limited
Unit 2406B, 24/F, Low Block, Grand Millennium Plaza
181 Queen's Road Central, Sheung Wan
Hong Kong
hello@loveluminus.com

TO BE CONFIRMED: whether to use a separate address for privacy requests, such as privacy@loveluminus.com.