Lumio Privacy Policy

Last Updated: June 18, 2026

Effective Date: June 18, 2026

Thank you for using Lumio, an AI dream refiner for iOS (hereinafter referred to as “we”, “us”, “the App”, or “Lumio”). We attach great importance to the protection of your privacy. This Privacy Policy explains how we collect, use, store, and protect your information.

Please read this Privacy Policy carefully before using the App. If you do not agree with any part of this Policy, you should immediately stop using the App. Your continued use constitutes acceptance of this Policy.

1. Information We Collect

1.1 Information You Actively Provide

Dream & Plan Data

• The dreams and goals you share during AI conversations with Lumio
• Plan names, categories, and custom descriptions you create
• Action items within each plan, including action type, duration, and parameters

Action Execution Records

• Action completion status and timestamps
• Content you create during action execution (text notes, photos, voice memos, numeric inputs, slider ratings, location data, counter values)
• Timer-based action durations

AI Conversation Content

• Your responses during the dream refinement conversation with Lumio
• Preferences and clarifications you provide during plan generation

1.2 Automatically Collected Information

Device Information

• Device type (e.g., iPhone)
• Operating system version
• App version number

Usage & Diagnostics

• App feature usage patterns (analyzed locally)
• Crash logs and performance data (used to improve app stability)

1.3 Information We Do NOT Collect

We solemnly declare that Lumio does not collect:

• Personally Identifiable Information (PII) such as your real name, email address, phone number, or physical address
• Your precise geographic location (location data is only used for location-based action check-ins and stored locally)
• Contacts, calendars, or data from other apps on your device
• Financial information (all payments are securely processed by Apple)
• Biometric information (Face ID / Touch ID data is never accessed)

2. How We Use Your Information

2.1 Providing Core Functionality

• Generating personalized action plans based on your AI conversation with Lumio
• Tracking and displaying your daily action progress
• Calculating streaks, energy scores, and completion statistics
• Managing your personal galaxy of plan planets
• Enabling action execution with timers, photo capture, voice recording, and other action types

2.2 Improving User Experience

• Analyzing app usage patterns to optimize the user experience (analysis is performed locally on your device)
• Identifying and fixing technical issues through crash diagnostics
• Refining the AI conversation flow based on anonymized usage patterns

2.3 AI Processing

• AI conversations with Lumio are used solely to generate your personalized action plans
• AI conversation content is processed to extract plan structure (goals, actions, scheduling)
• No conversation data is retained on external servers for model training or other purposes

3. Data Storage

3.1 Local Storage (Primary)

All your data — including plans, actions, completion records, AI conversation history, and media files (photos, audio) — is stored primarily on your device using Apple’s SwiftData framework. You have full control over this data and can view, modify, or delete it within the App at any time.

3.2 iCloud Storage (Optional)

Lumio supports optional iCloud synchronization via SwiftData + CloudKit. When enabled, your plan data, action records, and preferences are synced across your Apple devices through your personal iCloud account.

Important Notes Regarding iCloud:

• Your iCloud data is hosted by Apple and governed by Apple’s Privacy Policy
• Data is encrypted both in transit and at rest
• iCloud data can only be accessed while signed into your Apple ID
• We do not have direct access to your iCloud data
• You can disable iCloud sync or delete synced data through your device’s iCloud settings at any time

3.3 Data Retention

• We retain your data only for as long as you use the App
• Deleting the App from your device removes all locally stored data
• iCloud data is managed according to Apple’s data retention policies

4. Information Sharing

4.1 We Do NOT Sell Your Information

We promise that we will never sell, rent, or trade your personal information to any third party.

4.2 Circumstances Where We May Share Information

With Your Consent

• We may share information with third parties only with your explicit consent

Service Providers

• Apple (iCloud storage, App Store payment processing)
• These providers process information only according to our instructions and are obligated to protect its security

Legal Requirements

• We may disclose information if required by law, regulation, or valid governmental request

Business Transfers

• In the event of a merger, acquisition, or asset sale, your information may be transferred. We will notify you if this occurs.

5. Information Security

We implement a variety of security measures to protect your information:

5.1 Technical Measures

• Industry-standard encryption (SSL/TLS) for data in transit
• iOS system-level encryption for local data
• Apple’s end-to-end encryption for iCloud data

5.2 Administrative Measures

• Restricted access to user data
• Regular security practice reviews

5.3 Security Disclaimer

While we employ reasonable security measures, no method of electronic storage or transmission is 100% secure. We cannot guarantee absolute security. If you discover any security vulnerabilities, please notify us immediately.

6. Your Rights

6.1 Access and Correction

You can view and modify your plans, actions, and preferences within the App at any time.

6.2 Deletion

You can delete your data by:

• Removing individual plans or actions within the App
• Deleting the App from your device (removes all local data)
• Managing or deleting synced data in your iCloud settings

6.3 Withdrawing Consent

You may withdraw consent at any time by deleting the App. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

6.4 Data Export

All data is stored locally on your device and in your personal iCloud account. You can view, manage, or export your data through in-app features or your device system. We cannot directly access or export your data on your behalf.

7. Children’s Privacy

Lumio is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If we discover that we have inadvertently collected such information, we will take immediate steps to delete it.

If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us immediately.

8. Third-Party Links and Services

The App may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We recommend reading the privacy policy of any third-party service before using it.

Apple Services Used:

• App Store (distribution and payment)
• iCloud / CloudKit (optional data sync)
• SwiftData (local data persistence)

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Updates will be posted on this page with a revised “Last Updated” date. For material changes, we will notify you through the App or App Store update notes.

You are advised to review this Policy periodically to stay informed about how we protect your information.

10. Contact Us

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

Email: hello@ninesouls.com

Website: https://9souls.com

We will respond to your request within 15 business days.

11. Governing Law

This Privacy Policy shall be governed by the laws of the developer’s location (People’s Republic of China), with reference to internationally recognized personal information protection standards (including GDPR, CCPA, PIPL, etc.). In the event of any conflict with the laws of your jurisdiction, we will apply the principle offering the most favorable protection to user privacy.

Any disputes arising from this Policy shall first be resolved through friendly negotiation. If no settlement is reached, the dispute shall be submitted to the competent court in the developer’s jurisdiction.

Appendix: Apple App Store Privacy Information Disclosure

In accordance with Apple App Store requirements, below is a summary of data types collected by Lumio:

Data Tracking: The App does not contain third-party advertising tracking or analytics tracking functionalities.

Data Linking: Collected data may be linked to your identity (via your Apple ID) but is not shared with third parties.

Lumio is committed to protecting your privacy. Thank you for trusting us with your dreams.