Privacy Policy
Lumen · Effective date: 29 May 2026
1. Who we are
Lumen (the “App”) is published by Efe Budak (“we”, “us”, “our”), based in the Republic of Ireland. The App is distributed through the Apple App Store under the bundle identifier com.efebudak.Lumen. For the purposes of the EU General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018, Efe Budak is the data controller for the limited information processed in connection with the App. If you have any question about this policy or your data, you can reach us at efebudakapps@gmail.com.
2. Information stored on your device
The following information is created by you, stored locally on your iPhone using Apple’s on-device Core Data framework, and is not transmitted to us or to any third party:
- The habit you are taking a break from, the start date of your current period, an optional custom label, the daily cost you entered, and the end date of any previous period.
- Urge log entries you create, including timestamp, optional trigger note, and intensity level.
- App preferences and onboarding completion state (stored in UserDefaults).
Lumen does not use iCloud sync, does not back up your data to our servers, and does not include any custom backend. Standard iOS device backups (iCloud Backup or encrypted local backups) are managed entirely by Apple and your device settings; we have no access to them.
3. Information processed for subscriptions
Lumen requires an active “Lumen Pro” subscription to use its features. Subscriptions are handled entirely through Apple’s StoreKit; the App does not integrate any third-party subscription SDK or service. When you open the paywall, make a purchase, or restore a purchase, Apple processes your Apple ID and payment information to complete the transaction and returns a StoreKit transaction record to the App, including the product identifier, purchase date, expiration date, and renewal/refund status. This record is used on your device to verify your entitlement to Lumen Pro and to power restore-purchase functionality.
We never see your payment details, and Lumen does not transmit this information to us or to any third party. Apple’s handling of your purchase is described in Apple’s privacy policy.
4. What we do not collect
- We do not collect your name, email address, phone number, or account credentials. Lumen has no sign-in.
- We do not use analytics SDKs, crash-reporting SDKs, or advertising SDKs.
- We do not track you across other apps or websites, and we do not share data with data brokers.
- We do not access your contacts, photos, microphone, camera, location, health data, or HealthKit.
- We do not send push notifications.
5. Apple App Privacy summary
For Apple’s App Store “Privacy Nutrition Label”, the App is declared as follows:
| Data category | Collected? | Linked to you? | Used for tracking? |
|---|---|---|---|
| Purchases (subscription status) | Yes, by Apple | No | No |
| Identifiers | No | — | — |
| Diagnostics (crash & performance) | Only Apple’s standard, opt-in TestFlight/App Store diagnostics | No | No |
| Health & Fitness, Contacts, Location, Photos, Browsing, Search, Messages, Audio, User Content | No | — | — |
6. How long we keep information
Data you create stays on your device for as long as you keep the App installed. You can delete it at any time from Settings → Delete all data, which destroys the local database and resets your preferences. Uninstalling the App removes all local data managed by Lumen. Subscription records held by Apple are retained according to Apple’s policies and applicable tax and accounting law.
7. Your rights
Because Lumen does not maintain a server-side account, the most effective way to exercise your rights is directly within the App: you can view, edit, or delete your sobriety record, urge log, and preferences at any time. If you live in the European Economic Area, the United Kingdom, California, or another region that grants statutory privacy rights, you also have the right to access, rectify, erase, restrict, port, or object to the processing of any limited information held about you, and to withdraw consent where processing is based on consent. You can exercise these rights by contacting us at efebudakapps@gmail.com. We will respond within the time frame required by applicable law.
If you are located in the European Union or the European Economic Area and believe that our processing of your information infringes the GDPR, you have the right to lodge a complaint with a supervisory authority. Our lead supervisory authority is the Irish Data Protection Commission (www.dataprotection.ie); you may also complain to the supervisory authority in your country of residence.
8. Children
Lumen is not directed to children under 18 (or the equivalent minimum age in your jurisdiction), and we do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us and we will take appropriate steps to remove it.
9. International users and data transfers
The App can be downloaded worldwide via the Apple App Store. We are based in the Republic of Ireland. Information processed by Apple in connection with your subscription may be handled on servers located outside your country of residence, including in the United States. Where personal data is transferred from the European Economic Area, the United Kingdom, or Switzerland to a country that has not been deemed to provide an adequate level of protection, those transfers are governed by appropriate safeguards (such as the European Commission’s Standard Contractual Clauses and, where applicable, the UK Addendum), as described in Apple’s privacy policy.
10. Security
Information stored locally is protected by the iOS sandbox and by your device’s passcode, Face ID, or Touch ID where you have enabled them. Network traffic to Apple is transmitted over TLS. No method of electronic storage or transmission is perfectly secure; we use reasonable measures consistent with the App’s on-device design.
11. Changes to this policy
We may update this policy from time to time. When we do, we will revise the “Effective date” at the top of the page and, where the change is material, we will surface a notice inside the App before the change takes effect. Continued use of the App after the effective date constitutes acceptance of the updated policy.
12. Contact
Questions, requests, or concerns about this policy or your information can be sent to:
Efe Budak
efebudakapps@gmail.com