Privacy Policy

Effective Date: August 29, 2026  |  Last Updated: August 30, 2026

1. Introduction

Luminor ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and safeguard information when you use the Luminor mobile application (the "App"). By using the App, you agree to the practices described in this policy.

2. Data We Collect

Luminor is a local-first application. We have designed it so that your personal data stays on your device whenever possible.

• Task Data: All tasks, notes, event dates, preparation checklists, and AI-generated content are stored exclusively on your local device using SQLite database. We do not have access to this data.
• Voice Recordings: Voice input is processed on-device using Apple's Speech framework. Audio is never transmitted to our servers or any third-party servers.
• App Settings: Preferences such as language, notification settings, and theme are stored locally on your device.
• Anonymous User ID: A randomly generated UUID is stored locally to support feedback emails. It is never transmitted to our servers.

3. AI-Generated Content & Third-Party Processing

When you request AI-generated preparation lists, the task title and event date are sent to our backend service (hosted on Cloudflare Workers), which forwards them to Groq (an AI inference provider) to generate content. No personally identifiable information is included in these requests. The generated content is then stored locally on your device.

This data processing is conducted under GDPR Article 6(1)(a) — your explicit consent, which you provide via the in-app consent dialog before using AI features.

4. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA) and United Kingdom (UK), we process data under the following legal bases:

• Consent (Article 6(1)(a)): AI feature usage requires your explicit, informed consent before any data is sent externally.
• Legitimate Interest (Article 6(1)(f)): Basic app functionality (task storage, notifications) operates entirely on your device without external data transmission.

5. Analytics & Crash Reporting

We currently do not use any third-party analytics or crash reporting services. Should this change in the future, we will update this Privacy Policy accordingly and notify users.

6. Push Notifications

If you enable push notifications, the App will schedule local notifications on your device to remind you of upcoming tasks. These notifications are generated and stored entirely on your device. No notification data is transmitted to external servers.

7. Data Sharing & Third Parties

We do not sell, trade, or share your personal data with third parties. The only external service interaction is the optional AI generation feature described in Section 3.

8. Your Rights (GDPR)

If you are in the EEA or UK, you have the following rights under the General Data Protection Regulation (GDPR):

• Right of Access (Article 15): Request a copy of the personal data we hold about you.
• Right to Rectification (Article 16): Request correction of inaccurate personal data.
• Right to Erasure (Article 17): Request deletion of your personal data.
• Right to Restrict Processing (Article 18): Request limitation of data processing.
• Right to Data Portability (Article 20): Receive your data in a structured, machine-readable format.
• Right to Object (Article 21): Object to processing based on legitimate interest.
• Right to Withdraw Consent (Article 7(3)): Withdraw consent at any time without affecting the lawfulness of processing before withdrawal.
• Right to Lodge a Complaint: File a complaint with your local supervisory authority.

To exercise these rights, contact us at privacy@neosparktech.io.

9. Data Security

We implement industry-standard security measures to protect data stored on your device. Since your data remains local, the primary security risks are physical device security and your device's operating system protections.

10. Children's Privacy

The App is not intended for children under the age of 13. We do not knowingly collect personal information from children.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be reflected on this page with an updated "Last Updated" date. Continued use of the App after changes constitutes acceptance of the updated policy.

12. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data rights, please contact us at:

privacy@neosparktech.io