Draft. This text is under legal review; the final version will be published at this address. Details in square brackets are not final yet.
Privacy Policy
Applies to: people who use the Lumentor app ("you").
Version: Draft 1 · 27 October 2026 · Pending legal review
This policy explains what personal data Lumentor collects, why, who receives it and what your rights are. Health-related data is processed only with your explicit consent, which we ask for separately.
1. Who we are
[Legal entity name], [Address]. Contact for privacy questions: [privacy@getlumentor.com].
2. What we collect
Account and contact
- Your email address, the one-time sign-in code, your app language.
- Optional: your name and phone number.
Profile
- Age, sex, height, weight; optionally body fat and waist.
- Training experience, goals, training and cardio days, time zone, units, your gym's weight increments, your chosen coach.
- Your answers to your coach's setup questions: goals, equipment, session length, daily activity level, supplements.
Health-related data (with your consent, see section 4)
- Screening answers at setup: heart disease or high blood pressure, chest pain, fainting, chronic illness, regular medication, a doctor's advice to exercise only under supervision, pregnancy. These answers are used only to decide whether a doctor's clearance is needed and are not stored. We keep only your clearance declaration and any restriction you type in.
- Injured body areas, pain or injuries you mention during sessions, and the related notes to your coach.
- Body measurements: weight, body fat; waist, chest, arm, hip, thigh and neck.
- Supplements you take.
Training and nutrition records
- Sessions, sets (reps, weight, duration), warm-up and cardio, exercise changes and their reasons, your program.
- Nutrition goals, meals and their calorie and macro estimates, saved meals.
Voice and conversation
- Your voice: during a session, audio from your microphone is sent to our servers to be transcribed. Audio is not stored; we keep only the transcript.
- Conversation transcripts: what you, your coach and the app say, and the cards shown on screen.
- Photos and files you share in chat (for example a photo of your meal).
Subscription and usage
- Subscription status, billing periods, country, currency and price, transaction IDs, add-on packs. Payment is taken by Apple; we never receive your card details.
- How much AI usage you consume and its cost, to apply your weekly allowance.
- A few in-app milestones: opening a coach profile, starting setup, opening the Pro screen, purchase result, finishing a workout. Used to improve the product, never for advertising.
Security
- Session data (in your device's secure keychain), error reports, system logs.
- IP address: used for security and abuse prevention; not written to our database; kept in our hosting provider's request logs for [30] days.
We do not use advertising, the advertising identifier (IDFA) or third-party analytics SDKs.
3. Why we use it and our legal bases
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Create your account and sign you in | Contract (6(1)(b)) |
| Provide voice coaching: understand you, reply, keep your records, run your program | Contract (6(1)(b)) |
| Personalise and update your program | Contract (6(1)(b)) |
| Share with your coach (only if you turn sharing on) | Contract; explicit consent for health data |
| Manage your subscription and allowance | Contract (6(1)(b)) |
| Answer support requests | Contract; legitimate interests (6(1)(f)) |
| Security, abuse prevention, debugging | Legitimate interests (6(1)(f)) |
| Measure and improve quality | Legitimate interests (6(1)(f)) |
| Comply with the law (tax, consumer law, lawful requests) | Legal obligation (6(1)(c)) |
4. Health-related data
Health data is a special category of personal data. We process it only with your explicit consent (GDPR Art. 9(2)(a); KVKK Art. 6). You can use the app without giving it, and you can withdraw it at any time in Settings → Privacy. Without it we do not ask health questions, and we do not store your injury or pain information or share it with your coach.
5. Who receives your data
Your coach. Sharing with your coach is off by default; you control it, and every change is logged.
- With sharing on, your coach sees: your name, phone, age, height, weight, sex, experience, training days, injuries, setup answers (health questions excluded), sessions, progress, the last 42 days of meals, supplements, measurements and your program.
- With sharing off, your coach sees only counts, plus pain or injury notes sent without your name.
- Your conversation transcripts are never shared with your coach.
Service providers (processors). They process data only on our instructions.
| Provider | Purpose | Data | Location |
|---|---|---|---|
| Google Cloud | Servers, file storage, AI (Gemini) | Audio for transcription, conversations, photos, program, records | Germany (Frankfurt); AI processing [EU] |
| Supabase Inc. | Database, sign-in, file storage | Account, profile and all records | [Germany (Frankfurt)] |
| Fish Audio [entity] | Speech in your coach's voice | Text of what the coach will say to you (may include your name and figures from your records) | [Country] |
| Apple | App distribution, payment | Purchase data (under Apple's own policy) | [US / EU] |
| RevenueCat Inc. | Subscription status | A random user ID and purchase records only; not your email | United States |
| Amazon Web Services | Sign-in code email | Your email address | [Germany (Frankfurt)] |
| Cloudflare Inc. | Domain and email forwarding | Emails you send us | [Global] |
Authorities, when the law requires it.
We do not sell your personal data.
6. International transfers
Your data is processed outside your country, including in Germany and the countries listed above. We rely on the European Commission's Standard Contractual Clauses (and, for Turkey, the KVKK standard contracts) for these transfers.
7. How long we keep it
- While your account is open: profile, records, conversations and photos. You can delete a single conversation or all of them at any time; health notes and files in a deleted conversation are deleted with it.
- When you delete your account (Settings → Delete account): profile, records, conversations, photos and your sign-in account are deleted right away. Links to you are removed from earnings records we keep for accounting. Apple and RevenueCat keep purchase records under their own policies.
- System and error logs: [30] days. Backups: deleted from backups within [7] days.
- Records we must keep by law (for example for tax) are kept for the required period.
8. AI and automated processing
Your sessions are run by an AI assistant, and your program may be generated by AI from your coach's rules. The voice you hear is synthetic, generated from your coach's voice with their permission. You can ask for human review of any automated outcome that affects you; your coach can always adjust your program.
9. Your rights
Depending on where you live, you can ask to access, correct, delete or export your data, to restrict or object to processing, and to withdraw consent at any time. You can also complain to your data protection authority. Write to [privacy@getlumentor.com] from the email address on your account; we reply within 30 days. You can view, correct and delete most records directly in the app.
10. Security
We encrypt data in transit, limit access to authorised people and log administrator access. Your session is stored in your device's secure keychain.
11. Children
Lumentor is not for people under 18. If we learn we hold data of someone under 18, we delete it.
12. Changes
We will publish updates in the app and on getlumentor.com and notify you of material changes.