# Privacy Policy
**App name:** Lumi — Smart Budget Tracker
**Last updated:** June 11, 2026
**Contact:** graveris.ints@gmail.com
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## 1. Introduction
Welcome to **Lumi** ("we", "our", or "us"). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains what information we collect, how we use it, and what rights you have in relation to it.
By downloading and using the Lumi app, you agree to the terms of this Privacy Policy. If you do not agree, please do not use the app.
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## 2. Information We Collect
### 2.1 Information You Provide Directly
- **Financial transactions** — expense and income records, amounts, categories, dates, and notes that you manually enter in the app.
- **Budget and goal data** — monthly budgets, spending limits, savings goal names and targets, and contribution amounts.
- **Recurring expenses** — titles, amounts, categories, and schedules for recurring payments you set up.
- **Currency preference** — your selected home currency.
- **Onboarding responses** — answers to setup questions (financial goal, spending challenge) used to personalise your experience.
### 2.2 Information Collected Automatically
- **Device location (optional)** — if you grant permission, approximate city and country are collected once during onboarding to provide localised context for the AI coach. We do not continuously track your location.
- **App usage data** — anonymous crash reports and performance metrics to help us improve the app. This data does not identify you personally.
### 2.3 Information We Do NOT Collect
- Bank account or card numbers
- Login credentials or passwords
- Social security numbers or government IDs
- Any financial data from your bank or financial institution (Lumi is 100% manual entry)
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## 3. How We Use Your Information
We use the information you provide solely to operate and improve the Lumi app:
| Purpose | Data used |
|---------|-----------|
| Display your financial dashboard | Transactions, budgets, goals |
| Generate AI-powered spending insights | Anonymised transaction data sent to Gemini API |
| Subscription detection | Pattern analysis on your manually logged transactions |
| Personalise the AI coach | Anonymised spending summaries |
| Send budget alerts (if enabled) | Budget limits and spending totals |
| Improve the app | Crash reports and anonymous usage metrics |
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## 4. AI Features & Third-Party AI Services
Lumi uses **Google Gemini API** to power its AI Budget Coach and Smart Insights features.
- When you interact with the AI Coach or request insights, a **summary of your anonymised financial data** (spending totals by category, budget limits, goal names) is sent to the Gemini API.
- **No personally identifiable information** (name, email, device ID) is included in these requests.
- Data sent to Gemini is subject to [Google's Privacy Policy](https://policies.google.com/privacy).
- You can use Lumi without using AI features. AI insights are only generated when you explicitly request them.
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## 5. Data Storage
### 5.1 On-Device Storage
All your financial data (transactions, budgets, goals, recurring payments) is stored **locally on your device** using encrypted persistent storage (AsyncStorage with Redux Persist). We do not operate servers that store your personal financial data.
### 5.2 No Cloud Backup by Lumi
Lumi does not back up your data to any Lumi-operated cloud service. If you delete the app or reset your device, your data will be lost unless you use your device's own backup solution (e.g. iCloud backup on iOS).
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## 6. In-App Purchases & Subscriptions
Lumi offers optional premium subscriptions (weekly and yearly plans) processed through the **Apple App Store** via RevenueCat.
- Purchase transactions are handled entirely by Apple. We do not receive or store your payment card information.
- Subscription status is verified via RevenueCat's SDK.
- RevenueCat may collect anonymised app usage data. See [RevenueCat's Privacy Policy](https://www.revenuecat.com/privacy).
- To manage or cancel your subscription, go to **Settings → Apple ID → Subscriptions** on your device.
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## 7. Location Data
Location access is requested **once** during onboarding to determine your approximate city and country. This is used solely to provide localised suggestions in the AI coach (e.g. local spending context).
- Location data is stored only on your device.
- It is never shared with third parties beyond the anonymised AI requests described in Section 4.
- You can deny location permission and the app will function fully without it.
- You can revoke location permission at any time in your device settings.
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## 8. Push Notifications
If you enable Budget Alerts, Lumi will send local push notifications when you approach or exceed a budget limit.
- Notifications are generated and delivered entirely on your device.
- No notification data is sent to external servers.
- You can disable notifications at any time in the app (Settings → Budget Alerts) or in your device's notification settings.
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## 9. Children's Privacy
Lumi is not directed at children under the age of 13. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided us with personal information, please contact us at **graveris.ints@gmail.com** and we will delete it promptly.
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## 10. Data Sharing
We do not sell, trade, or rent your personal information to third parties.
We may share anonymised, non-identifiable data with:
- **Google Gemini API** — for AI features (see Section 4)
- **RevenueCat** — for subscription management (see Section 6)
- **Crash reporting services** — anonymous error reports only
We will disclose your information if required to do so by law or in response to valid legal requests.
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## 11. Your Rights
Depending on your location, you may have the following rights regarding your data:
- **Access** — request a copy of the data we hold about you
- **Correction** — request correction of inaccurate data
- **Deletion** — request deletion of your data
- **Portability** — request your data in a portable format
- **Objection** — object to certain processing of your data
Since all financial data is stored locally on your device, you can exercise most of these rights directly by editing or deleting data within the app, or by uninstalling the app.
For any requests, contact us at **graveris.ints@gmail.com**.
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## 12. Data Security
We implement appropriate technical safeguards to protect your data:
- All on-device data is stored in encrypted AsyncStorage
- Network requests to AI APIs use HTTPS/TLS encryption
- We do not transmit raw financial records — only anonymised summaries
No method of storage or transmission is 100% secure, and we cannot guarantee absolute security.
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## 13. Retention
Your financial data is stored on your device for as long as you use the app. You can delete individual transactions, budgets, or goals at any time within the app. Uninstalling Lumi will remove all locally stored data.
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## 14. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of significant changes by updating the "Last updated" date at the top of this document. Continued use of the app after changes constitutes acceptance of the updated policy.
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## 15. Contact Us
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us:
**Email:** graveris.ints@gmail.com
**App:** Lumi — Smart Budget Tracker
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*This Privacy Policy was prepared for the Lumi app and is effective as of June 11, 2026.*