Privacy Policy

Last updated: June 2026

I. Introduction

LUMI UNI (“we”, “us”, “our”) respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, and process information when you access or use the mobile application (the “App”).

For the purposes of this Privacy Policy, “personal data” means any information relating to an identified or identifiable individual, directly or indirectly.

This Privacy Policy applies to all users of the App (“Users”).

Please read this document carefully. By using the App, you confirm that you have read, understood, and agreed to this Privacy Policy.

We do not sell your personal data to third parties.

II. Information We Collect

We may process different categories of information depending on how you use the App.

1. Information You Provide

We collect information that you voluntarily provide when using the App, including:

• Personal data such as your age, skin type, skin concerns, and facial yoga goals, if you choose to provide such data during onboarding or profile setup.
• Progress data such as photos taken within the App for transformation tracking, if you choose to use this feature.
• Contact information, including your email address and any content you provide when contacting support.

This information is used to personalize your experience and deliver the App’s core features.

In most cases, this data is stored locally on your device and is not transmitted to our servers unless necessary (e.g. support requests). You can modify or delete this data at any time, and it will be removed upon uninstalling the App.

2. Functional Information

To enable core App features, we may process:

• Data related to App usage, completed exercises, and skin care routines;
• Reminder and notification preferences;
• Streak and progress history.

If you choose to use the transformation photo feature, photos are stored only on your device and are not uploaded to our servers without your explicit consent.

3. Automatically Collected Information

When you use the App, certain data may be collected automatically. This data is typically aggregated and does not directly identify you.

We may collect:

• Device information: device type, operating system, model, screen characteristics, memory usage;
• Connection data: IP address, network provider, connection type, session duration;
• Location-related data: approximate location derived from IP, language, time zone;
• Identifiers: advertising IDs or similar device identifiers;
• Usage data: interactions with the App, session times, feature usage;
• Log data: technical logs related to App performance;
• Advertising data: information about ads displayed and interactions with them.

We may use third-party analytics and advertising services that process such data automatically, including profiling to better understand user behavior and preferences.

We do not control how third-party providers process data collected through their own technologies. For more information, please refer to Section IV.

4. Camera Access

The App may request access to your device’s camera solely for the transformation tracking feature (taking before/after photos). Camera access is used only when you actively initiate this feature. No camera data is processed in the background or transmitted without your action.

5. Payment Information

In-app purchases and subscriptions are processed by third-party platforms (e.g. Apple App Store).

We do not collect or store your payment details such as credit card information.

III. Purposes of Data Processing

We process your information for the following purposes:

• To provide the App functionality and deliver requested services;
• To personalize your facial yoga programs, skin care routines, and reminders based on your profile;
• To improve and optimize the App, including performance monitoring and troubleshooting;
• To personalize content and advertising, where applicable;
• To communicate with you, including responding to inquiries and sending updates;
• To ensure security, prevent fraud, and enforce our Terms of Use.

If we introduce new purposes for processing, we will update this Privacy Policy accordingly.

IV. Sharing of Information

We may share your information only as described below:

• With service providers and partners (e.g. analytics or advertising providers) that support the operation of the App;
• When required by law or legal process;
• To protect our rights, safety, or property, or that of our users or others;
• In connection with a business transfer, such as a merger or acquisition.

We do not sell or rent your personal data.

While we carefully select partners that apply appropriate data protection measures, we are not responsible for their independent data processing practices.

The App may contain links to third-party services. We are not responsible for their privacy practices.

V. International Data Transfers

Your information may be transferred to and processed in countries outside your place of residence.

These jurisdictions may have different data protection laws. By using the App, you consent to such transfers.

We take reasonable steps to ensure that your data is protected in accordance with applicable laws, including using secure storage providers and, where possible, encryption.

VI. Data Retention

We retain your personal data only for as long as necessary:

• to provide the App’s functionality;
• to comply with legal obligations;
• to resolve disputes and enforce agreements.

You may request deletion of your data where applicable.

Some data may be retained for a limited period where required for legal, security, or backup purposes.

VII. Your Rights

Depending on your location, you may have the following rights:

• Access your personal data;
• Correct or update inaccurate data;
• Request deletion of your data;
• Restrict or object to certain processing activities;
• Request data portability.

To exercise these rights, please contact us using the details provided below.

For data processed by third-party services, you may need to contact those providers directly.

VIII. Your Choices (Opt-Out)

Advertising Preferences

You can limit personalized advertising by adjusting your device settings:

• On iOS: enable “Limit Ad Tracking” in your device settings.

You may still receive non-personalized ads.

Notifications and Reminders

You can manage or disable push notifications and daily reminders at any time through your device’s notification settings or within the App.

Camera Access

You can revoke camera access at any time through your device settings. This will disable the transformation photo feature.

IX. Data Security

We implement appropriate technical and organizational measures to protect your data from unauthorized access, loss, or misuse.

These measures include data minimization and, where possible, encryption.

However, no system is completely secure. While we strive to protect your data, we cannot guarantee absolute security.

In the event of a data breach, we will notify you as required by applicable law.

X. Minors

We do not knowingly collect personal data from minors without parental consent. If we become aware that such data has been collected without appropriate consent, we will delete it promptly.

If you believe a minor has provided personal data without appropriate consent, please contact us.

XI. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

Any changes will be reflected by updating the “Last updated” date. Continued use of the App after changes indicates your acceptance of the updated policy.

XII. Contact Information

If you have any questions about this Privacy Policy or your data, please contact us at info.support@lumiuni.pro