What Lumen knows, and nothing beyond it.
Lumen holds your goals, so this page starts with the summary rather
than burying it.
There are no analytics SDKs, no advertising identifiers, and no
third-party trackers in the app or on this site.
In effect 18 August 2026. Last updated 18 August 2026.
The privacy label.
Tracking means following you across other companies' apps and sites. Lumen does none of it. The column is there because the answer is no in every row, and that is the point of showing it.
The categories Lumen never asks for.
- Location, precise or coarse. Your time zone is a device setting used to time reminders, not a position, and it is never resolved to a place
- Contacts, photos, camera, or microphone
- Health, fitness, or biometric data
- Advertising identifiers
- Browsing history outside Lumen
- Card numbers or bank details
What we do with it, and on what basis.
| Data | Purpose | Legal basis |
|---|---|---|
| Email and account ID | Sign you in and keep your goals attached to you. | Performance of the contract |
| Goals and questionnaire answers | Store your plan, and generate or revise it when you ask. | Performance of the contract |
| Push token, device type, time zone | Send the reminders you switched on, to the right device at the right local hour. | Your consent, withdrawable at any time |
| Request and token counts | Rate limiting, abuse prevention, and cost control. | Legitimate interests |
| Server logs | Find and fix faults, and investigate abuse. | Legitimate interests |
| Subscription status | Know whether your plan is active. | Performance of the contract, and legal obligation for records |
What the AI receives.
When you ask Lumen to build or revise a plan, the text you wrote for that goal and the answers you gave to the five questions are sent to a language model provider. Your email address, your other goals, and your progress history are not part of that request.
The provider processes the request and returns the plan. It runs the model on our instruction, as a processor.
- OpenAI, United States. Builds the step-by-step plan from your questionnaire answers.
- DeepSeek, China. Handles the goal chat and short classification tasks.
Which provider sees your text depends on what you asked for, not on a single setting: the plan built from your questionnaire answers goes to OpenAI, while the goal chat goes to DeepSeek. That split holds in one direction only. Chat falls back to OpenAI when DeepSeek is unavailable, but nothing ever falls back the other way, so your questionnaire answers and the plans built from them never reach DeepSeek, even when OpenAI is failing.
Both providers sit outside the European Economic Area. OpenAI is in the United States, and that transfer is covered by the European Commission's standard contractual clauses in its data processing agreement with us. DeepSeek is in China, which the European Commission has not found to offer equivalent protection, so your legal remedies there are weaker than they are in the EU. Only goal chat uses DeepSeek: everything else, including the plan built from your five answers, runs on OpenAI. The full detail of how AI is used, and what it is allowed to decide, is set out on the transparency page.
Because of that, the China transfer happens only if you agree to it. The first time you open goal chat we explain where the message goes and ask; nothing is sent until you say yes. You can take that agreement back whenever you like, under Privacy on your account screen, which switches chat off again. Declining costs you goal chat and nothing else, because every other part of Lumen runs on OpenAI. Under the GDPR this is your explicit consent to a transfer to a country without an adequacy decision, and it is the sole basis for it.
Everything else stays put. Your account, your goals, and their steps are stored in the European Union (Google Cloud Firestore, eur3 multi-region), and only the goal text described above leaves it.
The full list of processors.
- Google Firebase. Authentication, database storage, and push delivery.
- Railway. Hosting for the application server and this site.
- OpenAI. Goal mapping, as described above.
- DeepSeek. Goal mapping, as described above.
- The payment provider or app store. Takes the payment and tells us only whether it succeeded.
That is the whole list. Nobody buys this data, because it is not for sale, and there is no advertising business attached to Lumen that would want it.
Kept while you use it, then gone.
A copy of the goals you have opened is also held on your own device, so the app can show them instantly without fetching them again. It stays in your browser or app storage until you sign out, which clears it. Nothing is written there for advertising or measurement, and there are no tracking cookies on this site or in the app.
Your goals stay while your account exists. If your subscription lapses, three goals of your choosing remain readable and the rest move to the archive; nothing is deleted for lapsing alone.
Delete your account and the goals, answers, and account record go with it, along with the step tree under each goal, your reminder settings, any device tokens registered for notifications, and the abuse counters described above. It is one action on our side and it is not reversible: there is no recycle bin and no backup we would restore you from. Ask at privacy@lumen-tracker.live if the app does not yet offer it directly. Server logs are kept only as long as they are useful for faults and abuse, and they are never assembled into a profile of you. The counters behind rate limiting expire on their own within hours of the window they belong to, so nothing accumulates there either.
Export it, correct it, or take it away.
- Access and export. Ask for a copy of everything held about you, in a portable format.
- Correction. Fix anything inaccurate, in the app or by asking.
- Erasure. Delete your account and its contents.
- Restriction and objection. Ask us to pause a use of your data, or object to one based on legitimate interests.
- Withdraw consent. Switch reminders off and the push token stops being used.
- Complain. Raise it with [national data protection authority], or the authority where you live.
Write to privacy@lumen-tracker.live and we answer within one month. There is no fee, and asking costs you nothing in the product.
One limit worth being straight about: a guest account has no email address, so there is nothing we can check a request against. If you use Lumen as a guest we cannot identify your data well enough to export or erase it on request, and signing out or clearing the app leaves it unreachable. Create an account if you want these rights to be usable.
The practical guarantees.
Traffic runs over TLS. Stored data is scoped per account, so one account cannot read another's goals. Access to production data is limited to the people who keep it running.
Lumen is not built for children. You need to be at least 16 to hold an account. No part of the product is directed at anyone younger.
The controller, and how to reach them.
[registered legal name], [registered address], is the controller for the data described here.
Privacy questions go to privacy@lumen-tracker.live. Anything else goes to contact@lumen-tracker.live.
If this policy changes in a way that matters, the date above changes and we say so in the app before the change takes effect.