Lumen — Privacy Policy

Lumen — Privacy Policy

Last updated: 05 August 2026 | Effective: 15 August 2026

The short version

Lumen is a wellbeing app made by Atizan Studio LLC, a Massachusetts limited liability company. This policy explains what we collect, why, who sees it, and what you can do about it. In brief:

• Lumen is free. We do not collect payment information, and we have no advertising business.
• We do not sell your personal information, and we do not share it for targeted advertising. We never have.
• What you write in Lumen is yours. We do not use your journal entries, reflections, or session activity to train AI models, and we do not license them to anyone.
• You can delete everything, yourself, at any time — in the app under Settings → Account → Delete account.
• Some of what Lumen handles is sensitive. We treat it that way. Section 4 explains how.
• Group sessions are shared spaces. What you say there is seen by other participants, and we cannot control what they do with it.

This summary is for orientation only; the sections below are what actually governs.

1. Scope

This policy applies to the Lumen mobile applications for iOS and Android, the Lumen website, and related support channels (together, the “Services”). It is incorporated into the Lumen Terms of Use, and capitalized terms not defined here have the meaning given there.

It does not apply to third-party services you reach from Lumen, or to facilitators and partner organizations who handle your information under their own policies. Section 9 explains that boundary.

2. Information we collect

2.1 Information you give us

2.2 Information we collect automatically

We do not use third-party advertising SDKs, and we do not participate in cross-app tracking. We do not request Apple’s App Tracking Transparency permission because we do not track you across other companies’ apps and websites.

2.3 Information from other sources

• Sign-in providers. If you sign in with Apple or Google, we receive the identifier and email address that provider sends us. With Sign in with Apple you may choose to hide your real email; we work fine with the relay address.
• Partner organizations. If an employer, clinic, or community organization gives you access to a Lumen program, they may give us your email address or an access code so we can enroll you. Section 9 explains what flows back to them — which is far less than what flows in.

3. Device permissions

Lumen asks for permissions only when a feature needs them, and the app remains usable if you decline:

• Notifications — reminders and session alerts. Declining disables reminders only.
• Microphone — voice journaling and spoken participation in live sessions. Requested at the moment you start one.
• Camera — video participation in live sessions, and taking a profile photo.
• Photo library — attaching an image you choose. We receive only the images you pick.

You can change any of these at any time in your device settings.

4. Sensitive and health-related information

Lumen is a wellbeing and self-help tool, not a healthcare provider, and Lumen is not a covered entity under HIPAA — so HIPAA does not apply to what you enter here. That said, what you write in a journal entry or say in a group session can reveal a great deal about your mental and emotional state, and several U.S. laws — including Washington’s My Health My Data Act, the California Consumer Privacy Act, and the consumer health data provisions of the Connecticut, Nevada, and other state privacy laws — treat that as consumer health data or sensitive personal information.

We handle it accordingly:

• We collect it only with your consent, given when you create an account and affirm this policy, and again where a specific state law requires separate authorization.
• We use it only to provide the Services to you — never to profile you for advertising, never to infer conditions for anyone else’s benefit, never as an input to model training.
• We do not sell it, and we do not share it for cross-context behavioral advertising. We have never done either, and we will not begin without your separate, opt-in, revocable consent.
• Access inside our company is restricted to personnel who need it for a specific task — investigating a report you filed, responding to your support request, or resolving a technical fault — and that access is logged.
• We do not disclose it to law enforcement without valid legal process, and we will challenge processes we believe to be overbroad or improper. Section 8 covers the narrow safety exception.

5. How we use information

We use what we collect to:

1. Provide the Services — authenticate you, save your entries, track your progress, run group sessions, sync across your devices.
2. Personalize your experience — suggest relevant exercises, set reminders you asked for, remember where you left off. This is contextual personalization inside Lumen; it is not advertising profiling.
3. Communicate with you — operational messages about your account, sessions, and security, plus marketing messages if and only if you opted in.
4. Support you — answer questions, investigate problems, process appeals.
5. Keep Lumen safe — detect and act on violations of our content standards, prevent fraud and abuse, secure our infrastructure, and meet the moderation commitments in Section 13 of the Terms.
6. Improve the product — understand in aggregate which features get used and which do not, diagnose crashes, test changes.
7. Meet legal obligations — respond to lawful requests, keep required records, enforce our Terms, establish or defend legal claims.

Aggregated and de-identified data. We may create statistics and insights that do not identify you or any individual — for example, how many people completed a given exercise in a month. We maintain de-identified data in de-identified form and do not attempt to re-identify it, except to test that the de-identification worked.

Research. If we ever want to use your content for research or publication, we will ask you first, separately, and you can say no without losing access to anything.

6. What we do not do

To state it plainly, because in this category the absences matter:

• We do not sell personal information, under any state law’s definition of “sell.”
• We do not share personal information for targeted or cross-context behavioral advertising.
• We do not show third-party ads in Lumen.
• We do not use your journal entries, reflections, session content, or messages to train machine-learning or AI models — ours or anyone else’s.
• We do not give partner organizations, employers, or insurers access to what you write.
• We do not collect precise location.
• We do not track you across other companies’ apps and websites.

7. Group sessions and shared spaces

Anything you post in a shared space, or say and show in a live facilitated session, is visible to the other participants and to the facilitator. We cannot control what they remember, repeat, or record. Confidentiality in these spaces is a shared expectation among participants, not a technical guarantee we can enforce — please share only what you are comfortable having heard.

Live sessions are transmitted through our video provider. [VERIFY: sessions are transmitted but not recorded or stored by us. If recording is enabled for any session type, describe here who can record, what notice participants get, where recordings are stored, and how long they are kept — this is the single most scrutinized paragraph in a policy like this.]

Deleting your account removes your posts from shared spaces or disassociates them from your identity, but other participants may retain their own record of what they saw.

8. When we share information

We share personal information only in these situations:

Service providers. Companies that run parts of the Services on our behalf, under contracts that limit them to our instructions and prohibit using your data for their own purposes:

Facilitators. A facilitator leading a session sees what you contribute to it, and your display name. Nothing else.

Partner organizations. Where a partner gave you program access, we may confirm eligibility and share aggregate, de-identified participation statistics — for example, that 40 of 100 enrolled employees attended at least one session. We never share individual journal content, individual session content, individual mood or progress data, or anything that identifies what any one person wrote or said. If a partner ever asks us for more, the answer is no.

Safety and legal. We may disclose information when we believe in good faith it is necessary to: comply with a law, subpoena, warrant, or court order; enforce our Terms; investigate suspected fraud or abuse; protect the rights, property, or safety of you, our users, or the public; or respond to an emergency involving a risk of death or serious physical injury. Where the law allows and it is not counterproductive, we will tell you before we disclose.

Business transfers. If Atizan Studio LLC is involved in a merger, acquisition, financing, or sale of assets, information may transfer as part of that transaction. We will give you notice, and your information will remain subject to this policy until you are told otherwise and given a chance to delete your account first.

With your direction. Anything else you explicitly ask us to share.

9. Third parties we do not control

Facilitators, partner organizations, and any external site you follow a link to have their own privacy practices. When a facilitator or partner collects information from you directly — through their own intake form, their own scheduling tool, their own email — that collection is theirs, not ours, and this policy does not cover it. Ask them for their policy.

10. How long we keep information

After you delete your account, see Section 11. Where we must keep something for a legal obligation, we keep only what the obligation requires, for only as long as it requires.

11. Deleting your account and your data

You can delete your account yourself, at any time, without contacting us and without explaining why:

In the app: Settings → Account → Delete account On the web: [ACCOUNT DELETION PAGE URL] By email: support@lumenly.net, from the address on your account

When you delete:

• Your profile, journal entries, reflections, session history, and progress data are removed from our production systems, ordinarily within 30 days.
• Content you posted in shared spaces is removed or disassociated from your identity.
• We retain only what law, dispute resolution, security, or abuse prevention requires — for example, a record that an account was permanently banned, so the ban can be enforced.
• Residual copies may persist in encrypted backups until they are overwritten on our normal backup cycle, ordinarily within [35] days. Backups are not used to restore deleted accounts.

Deletion is permanent. If you want a copy of your data first, export it from Settings → Export my data before you delete.

You can also delete individual journal entries or posts at any time without deleting your account.

12. Your privacy rights

Depending on where you live, you may have some or all of the following rights. We extend all of them to every Lumen user in the United States, regardless of state, because drawing lines between users on this seemed like the wrong thing to do:

• Know and access — what we hold about you, where it came from, why we have it, and who we shared it with.
• Correct — fix inaccurate personal information.
• Delete — as described in Section 11.
• Portability — receive a copy in a portable, machine-readable format.
• Opt out of sale or targeted advertising — we do neither, so there is nothing to opt out of, but the right stands.
• Limit use of sensitive personal information — we already limit it to providing the Services, which is the standard the CCPA sets.
• Withdraw consent — for consumer health data processing, at any time, by emailing privacy@lumenly.net or deleting your account. Withdrawal is not retroactive but stops future processing.
• Non-discrimination — exercising any of these rights costs you nothing and changes nothing about your access to Lumen.
• Appeal — if we decline a request, we will tell you why, and you can appeal by replying to our response. We will decide the appeal within 45 days and explain the outcome in writing.

Making a request. Use the in-app tools where they exist — they are faster and require no identity verification beyond being logged in. Otherwise email privacy@lumenly.net. We respond within 45 days, extendable once by another 45 where the request is complex, and we will tell you if we need the extension.

Verification. We verify requests by confirming control of the account email. We may ask for additional information if the request is unusual or the stakes are high — we will not use anything you send for verification for any other purpose, and we delete it afterward.

Authorized agents. An agent may submit a request on your behalf with written, signed permission; we may still contact you to confirm.

California residents. In the twelve months before this policy’s effective date, we collected the categories described in Section 2, for the purposes in Section 5, from the sources in Section 2, and disclosed them for a business purpose to the service providers in Section 8. We did not sell or share personal information, including sensitive personal information, and we have no actual knowledge of selling or sharing the personal information of anyone under 16. California residents may also request the “Shine the Light” disclosure at privacy@lumenly.net.

Nevada residents. Nevada law lets you tell us not to sell certain information. We do not sell it, but you may submit the direction to privacy@lumenly.net.

13. Security

We protect your information with encryption in transit (TLS) and at rest, access controls and least-privilege permissions for our personnel, logged administrative access, multi-factor authentication on our internal systems, and regular dependency and vulnerability review.

No system is perfectly secure, and we cannot promise that yours will never be compromised. If a breach affects your personal information, we will notify you and the relevant authorities as the law requires, and we will tell you what happened rather than the minimum we can get away with.

Please help: use a strong, unique password, keep your device locked, and tell us at security@lumenly.net if you find a vulnerability. We do not pursue legal action against good-faith security researchers who report responsibly and do not access other users’ data.

14. Children

Lumen is for adults. You must be at least 18 to use it. We do not knowingly collect personal information from anyone under 18, and we do not direct any part of Lumen to children. If we learn that an account belongs to someone under 18, we delete the account and its data. If you believe a minor has an account, email support@lumenly.net and we will act promptly.

15. Where your information is held

We operate from the United States and store information on servers located in the United States. If you use Lumen from outside the United States, your information is transferred to and processed in the United States, where privacy laws may differ from those where you live. Lumen is designed for use in the United States; we do not target other markets.

16. Cookies and similar technologies

The Lumen mobile app does not use cookies or third-party advertising trackers. It stores a session token and your preferences locally on your device so you stay logged in.

The Lumen website uses strictly necessary cookies to run the site and remember your choices, and we do not use advertising cookies. Where required, we present a consent banner before setting anything non-essential, and we honor Global Privacy Control signals as a valid opt-out.

17. Changes to this policy

We may update this policy. If a change is material — a new category of data, a new purpose, a new class of recipient — we will tell you in the app or by email before it takes effect, and where the law requires consent for the new use, we will ask for it rather than assume it.

18. Contact us

Privacy questions and rights requests: privacy@lumenly.net General support and reports: support@lumenly.net Security reports: security@lumenly.net Legal notices: legal@lumenly.net

Atizan Studio LLC [MAILING ADDRESS] Massachusetts, United States