Privacy Policy — Lumea
Last updated: July 2, 2026
This Privacy Policy explains what personal data is processed when you use the Lumea mobile app ("Lumea", the "App", "we", "us"), why, and what rights you have. Lumea is a skincare companion offering AI-assisted skin analysis, a photo journal, routine and symptom tracking, and a food log.
Lumea is offered primarily in the United States and also in Germany. This policy is written to satisfy the EU General Data Protection Regulation (GDPR) and applicable US privacy law. A German version (Datenschutzerklärung) is available in the App; both describe the same processing.
1. Who Is Responsible (Data Controller)
The controller responsible for processing your personal data within the meaning of Art. 4(7) GDPR is:
Elena Frei Professor Bachofer Strasse 2 21509 Glinde Germany Email: frei.alex@gmx.de
Lumea is operated by a private individual, not a company. For any question about this policy or your data, contact the address above.
2. The Short Version
- Almost everything stays on your phone. Your journal photos, scan history and scores, routine, symptom check-ins, notes, food log, social handles you enter, and all settings are stored only on your device. We never upload them. Your skin profile is also stored on your device; when you run an AI analysis, a short profile summary travels with that request so the advice fits you (see Section 4.1).
- AI analysis is the one moment a photo leaves your device. When you run a skin, food, or product scan, that photo is sent — only with your prior explicit consent — through our server to Anthropic (USA) for analysis. It is processed transiently: our server stores nothing, and Anthropic does not use it to train AI models.
- An account is optional. The App works fully without one. If you create one, we store only your email address.
- No ads, no tracking, no selling data. We use no third-party advertising or analytics SDKs, and we do not track you across apps or websites.
- You are in control. You can withdraw AI consent, delete your photos and scan history, and delete your account — all inside the App.
The rest of this policy provides the full detail.
3. Data That Stays on Your Device
The following is stored only in the App's private storage on your device. It is never uploaded to or stored on our servers, and we have no access to it:
- Journal photos (progress selfies and other photos you save)
- Scan history and scores
- Your skincare routine and daily check-offs
- Symptom check-ins and notes
- Food log
- Skin profile and goals — stored only on your device; when you run an AI analysis, a short summary (e.g. skin type, age, allergies) is included in that request so the advice fits you (see Section 4.1)
- Social media handles you choose to enter (Snapchat, Instagram, TikTok usernames)
- All app settings
Deleting this data: You can delete your photos and scan history in the App under Profile → Privacy & data. Uninstalling the App removes all of its on-device data.
Camera and photo library: The App asks for permission to use your camera and photo library so you can take or select photos. You control these permissions in iOS Settings.
4. Data That Leaves Your Device
4.1 AI skin, food, and product analysis (photos → Anthropic)
When you run an AI analysis, the App sends the analysis photo to Anthropic PBC (USA), our AI processor, routed through our own server proxy (a Supabase Edge Function, hosted in the EU/US). This happens only with your prior explicit consent, which you give once through a consent screen before your first scan and can withdraw at any time under Profile → Privacy & data.
What happens to the photo:
- It is processed transiently, for that analysis only.
- Along with the photo, a short summary of your skin profile (e.g. skin type, age, allergies) is included so the analysis fits you. It is processed transiently in the same way and is never stored by our server.
- Our server stores nothing. The proxy is a pure pass-through and does not log or retain any photo or analysis content.
- Anthropic does not use API data to train its AI models. Anthropic retains inputs for at most about 30 days for abuse prevention, then deletes them.
- Your saved journal photos are never uploaded — only the photo you actively submit for a scan.
Legal basis: your consent (Art. 6(1)(a) GDPR) and, because skin analysis can reveal health-related information, your explicit consent (Art. 9(2)(a) GDPR).
4.2 Optional account
You can use Lumea fully without an account. If you choose to create one, you can sign up with:
- Email and password, managed by our authentication processor Supabase, Inc.; or
- Sign in with Apple.
We store only your email address. You can delete your account at any time in the App under Profile → Account; this triggers a server function that deletes your account data on our side.
Legal basis: performance of the user agreement (Art. 6(1)(b) GDPR).
4.3 Anonymous usage analytics
To understand which features are used and keep the App working well, the App records simple usage events in our own Supabase database — no third-party analytics or advertising SDK is involved. Each event contains only:
- an event name (for example, "scan_completed"),
- a random per-install ID that is not linked to your identity, email, or account,
- platform, app language, and a timestamp.
No photos, no emails, no tracking across apps or websites, no advertising, no sale of data. The App does not use Apple's App Tracking Transparency framework because it performs no tracking.
Legal basis: our legitimate interest in understanding and improving the App (Art. 6(1)(f) GDPR).
4.4 Purchases and subscriptions
Lumea is free to download; premium features require a subscription purchased through Apple In-App Purchase:
- Yearly: $49.99/year (about $0.96/week), with a 3-day free trial
- Weekly: $6.99/week, cancel anytime
- Promotional offer (shown in-app, e.g. via the lucky wheel): the yearly plan at the same price of $49.99/year, but with a 7-day free trial instead of 3 days
Prices are shown in your local App Store currency. Subscriptions auto-renew until cancelled at least 24 hours before the end of the current period; billing, cancellation, and refunds are handled entirely by Apple (Settings → Subscriptions on your device).
To manage subscription entitlements, our processor RevenueCat, Inc. (USA) processes purchase receipts and entitlement status, identified only by a random app user ID — no name or email is needed or shared. Apple processes your payment as an independent controller under its own privacy policy; we never receive your payment card details.
Legal basis: performance of the user agreement (Art. 6(1)(b) GDPR).
4.5 Weather and UV (city you type — no location permission)
For local weather, UV, and air-quality information, you type a city name — the App never requests GPS or device-location permission. The coordinates of the chosen city are sent to Open-Meteo (an open weather API) to retrieve the data. No personal identifiers are transmitted.
Legal basis: performance of the user agreement (Art. 6(1)(b) GDPR).
4.6 Food barcodes
When you scan a food barcode, the barcode number is queried against Open Food Facts (an open food database). No personal identifiers are transmitted.
Legal basis: performance of the user agreement (Art. 6(1)(b) GDPR).
5. What We Do NOT Do
- No advertising and no advertising SDKs
- No third-party tracking; no tracking across apps or websites (no ATT prompt because there is nothing to track)
- No sale of personal data, and no sharing for targeted advertising
- No profiling for advertising purposes
- No social logins other than Sign in with Apple
6. Processors and Recipients
We share data only as described below and have data processing agreements (Art. 28 GDPR) in place with our processors.
| Recipient | Country | What they receive | Purpose | Role | Safeguard |
|---|---|---|---|---|---|
| Anthropic PBC | USA | The photo you submit for an AI scan (transient; no training use; deleted after at most ~30 days) | AI skin/food/product analysis | Processor | EU Standard Contractual Clauses (SCCs) under Anthropic's Data Processing Addendum; transfer also covered by your explicit consent (Art. 49(1)(a) GDPR) |
| Supabase, Inc. | EU/US hosting | Account email (if you create an account); anonymous usage events; AI requests pass through in transit only and are never stored | Authentication, our own database, server proxy | Processor | SCCs / EU–US Data Privacy Framework where applicable |
| RevenueCat, Inc. | USA | Random app user ID and purchase receipt/entitlement data (no name or email) | Subscription entitlement management | Processor | SCCs / EU–US Data Privacy Framework where applicable |
| Apple Inc. | Global | Purchase and billing data; Sign in with Apple identity token | App Store billing; Apple ID authentication | Independent controller | Apple's own privacy policy and terms |
| Open-Meteo | Open API | Coordinates of the city you typed (no personal identifiers) | Weather/UV/air-quality data | Independent data source | No personal data transmitted |
| Open Food Facts | Open database | Barcode numbers (no personal identifiers) | Food product lookup | Independent data source | No personal data transmitted |
7. International Data Transfers
Some of our processors are located in the United States (Anthropic, RevenueCat; Supabase uses EU/US hosting). Where personal data is transferred to the US, the transfer is protected by the EU Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914) agreed in the respective data processing agreement, and/or the EU–US Data Privacy Framework where the provider is certified. The AI-analysis transfer additionally rests on your explicit consent. You can request more information about these safeguards using the contact details in Section 1.
8. How Long We Keep Data
- On-device data: stays on your device under your control until you delete it in the App (Profile → Privacy & data) or uninstall the App. We have no remote access to it.
- AI scan photos: stored by no one on our side; Anthropic retains them for at most about 30 days for abuse prevention, then deletes them.
- Account data (email): kept until you delete your account in the App (Profile → Account) or ask us to delete it.
- Anonymous usage events: kept only in anonymous form, never linked to your identity, and only as long as needed for App improvement.
- Purchase data: processed by Apple and RevenueCat under their retention rules; we retain records only as long as legally required.
9. Deleting Your Data and Withdrawing Consent
Everything below works directly in the App — no email needed:
- Withdraw AI consent: Profile → Privacy & data. Withdrawal stops all future AI uploads and does not affect the lawfulness of past processing.
- Delete photos and scan history: Profile → Privacy & data.
- Delete your account: Profile → Account. This deletes your server-side account via our deletion function.
- Delete everything on the device: uninstall the App.
For anything you cannot do in-app, email frei.alex@gmx.de.
10. Your Rights (GDPR)
Subject to the conditions of the GDPR, you have the right to:
- Access your data (Art. 15) and receive a copy;
- Rectification of inaccurate data (Art. 16);
- Erasure (Art. 17);
- Restriction of processing (Art. 18);
- Data portability (Art. 20);
- Object to processing based on legitimate interests (Art. 21);
- Withdraw consent at any time (Art. 7(3)), without affecting past processing — for AI analysis, directly in the App (Section 9).
To exercise any right, contact frei.alex@gmx.de. We respond within the legal time limits (generally one month).
Right to complain (Art. 77 GDPR): You may lodge a complaint with a data protection supervisory authority, in particular in the EU/EEA member state of your residence or workplace. Our competent supervisory authority is:
Unabhängiges Landeszentrum für Datenschutz Schleswig-Holstein (ULD) Holstenstraße 98, 24103 Kiel, Germany https://www.datenschutzzentrum.de
11. Note for Users in the United States
We do not sell personal information, do not share it for cross-context behavioral advertising, and do not use it for targeted advertising. The App performs no tracking as defined by Apple's App Tracking Transparency framework. If your US state's privacy law grants you rights of access, deletion, or correction, you can exercise them through the in-app controls described in Section 9 or by emailing frei.alex@gmx.de — we honor such requests regardless of formal applicability thresholds.
12. Children
Lumea is intended for users aged 13 and older. We do not knowingly collect personal data from children under 13. If you believe a child under 13 has provided personal data, contact us (Section 1) and we will delete it.
13. Health Data and "Not Medical Advice"
Lumea provides non-medical, wellness-oriented skincare guidance only. It is not a medical device and does not provide medical advice, diagnoses, or treatment recommendations. Always consult a qualified healthcare professional — such as a dermatologist — for persistent or severe skin symptoms or any medical question.
Because facial photos and skin-related self-reports can reveal health-related information, they are treated as special-category data under Art. 9 GDPR. We process such data for AI analysis only with your explicit consent (Art. 9(2)(a) GDPR); everything else stays on your device (Section 3).
14. Security
We take appropriate technical and organizational measures to protect your data, including:
- On-device storage in the App's private, sandboxed area, protected by iOS security;
- Encryption in transit (HTTPS/TLS) for all network communication;
- A no-storage server proxy for AI requests: the API key is held server-side, never in the App, and no analysis content is logged or retained;
- Data minimization: only the data described in this policy leaves your device, and identifiers are random and unlinked to your identity wherever possible.
No method of transmission or storage is completely secure, but we work continuously to protect your data.
15. Changes to This Policy
We may update this policy when the App, our processors, or the law changes. We will update the "Last updated" date above and, for material changes, provide a more prominent notice in the App.
16. Contact
For any privacy question or to exercise your rights:
Elena Frei Professor Bachofer Strasse 2, 21509 Glinde, Germany Email: frei.alex@gmx.de