Privacy Policy

Lumen · Effective date: 16 July 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 and in your private iCloud

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 or habits you are taking a break from, the start date of each period, an optional custom label, the daily cost and daily time you entered, and the end date of any previous period.
• Urge log entries you create, including timestamp, optional trigger note, and intensity level.
• Daily check-ins (the date and whether you marked the day as a hard one).
• Your signed commitment: the pledge date and either your drawn signature strokes or the name you typed.
• Savings goals you create (a title and target amount) and the personal reasons (“whys”) you write.
• App preferences and onboarding completion state (stored in UserDefaults).

This data syncs between your own devices through Apple’s CloudKit, into the private database of your personal iCloud account, with every field encrypted so that only your devices can read it. We have no server of our own, no access to your iCloud, and no way to read this data. If you use the Lumen watch app or home-screen widgets, a small progress snapshot (such as your day count) is shared between your devices using Apple’s frameworks; it never includes health data and never reaches us. 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. Apple Health (optional)

Lumen can, with your permission, read three types of data from Apple Health to show you evidence of your own recovery: resting heart rate, heart rate variability, and sleep. This is entirely optional; every other feature of the App works without it.

• Read-only. Lumen does not write anything to Apple Health.
• On-device only. Health data is read and processed in memory on your iPhone to compute comparisons such as “resting heart rate since you quit”. It is never stored in Lumen’s database, never synced to iCloud by Lumen, never shared with the watch app or widgets, and never transmitted to us or to any third party.
• Never used for advertising or disclosed to data brokers, in accordance with Apple’s App Store rules for HealthKit.
• You stay in control. You can grant or revoke Lumen’s read access at any time in iOS Settings under Privacy & Security → Health → Lumen. Revoking access does not affect any other feature.

4. 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.

5. 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, or location. Apple Health data is read only with your permission and only on your device, as described in section 3; it is never collected by us.
• We do not send marketing or re-engagement push notifications. Daily reminders, if you turn them on, are local notifications composed and scheduled entirely on your device. Apple may deliver silent background notifications to keep your private iCloud sync up to date; these contain no personal content and are not visible to you.

6. Apple App Privacy summary

For Apple’s App Store “Privacy Nutrition Label”, the App is declared as follows. Under Apple’s definitions, data counts as “collected” only when it is transmitted off your device in a way the developer can access; data that Lumen processes purely on your device (or that syncs only within your own iCloud account) is not collected.

7. How long we keep information

Data you create stays on your device, and in your private iCloud database, for as long as you keep using the App. You can delete everything at any time from Settings → Delete all data, which removes the iCloud copy, destroys the local database, and resets your preferences. Uninstalling the App removes all local data managed by Lumen; the copy in your private iCloud remains (so your history survives a new phone or a reinstall) until you use Delete all data or remove Lumen’s data from iCloud in iOS Settings. Subscription records held by Apple are retained according to Apple’s policies and applicable tax and accounting law.

8. 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, and you can export your data as a file from the App whenever you wish (data portability). 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.

9. 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.

10. 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.

11. 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. Data synced to your private iCloud is encrypted field by field so that only your devices can read it. If you enable Lumen’s optional app lock, unlocking uses Face ID, Touch ID, or your device passcode; biometric matching is performed entirely by iOS, and Lumen never sees or stores your biometric data. 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.

12. 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.

13. Contact

Questions, requests, or concerns about this policy or your information can be sent to:

Efe Budak
efebudakapps@gmail.com