Privacy Policy

1. Introduction

LumaVoice ("we," "our," or "us") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application LumaVoice (the "App").

By using LumaVoice, you agree to the collection and use of information in accordance with this policy.

2. Information We Collect

2.1 Information Stored Locally on Your Device

The following data is stored only on your device and is never transmitted to our servers:

• Custom Tiles: Any custom communication tiles you create
• User Preferences: App settings, language preferences, tile size, color scheme
• Usage Statistics: Tile usage counts, session data, therapy progress (if therapy mode is enabled)
• Phrase History: Previously created sentences and phrases
• Therapy Data: Session notes, goals, and progress tracking (if therapy mode is enabled)
• Emotion Journal: Emotion tracking data and coping strategies

2.2 Information Transmitted to Our Servers

When you use the AI sentence polishing feature, the following minimal data is sent to our secure cloud backend:

• Sentence Text: The text you want to polish/enhance
• Request Metadata: Timestamp and basic request information for service operation

2.3 Information We Do NOT Collect

• Personal identification information (name, email, phone number)
• Location data
• Device identifiers for tracking purposes
• Contacts or photos
• Health information (beyond local therapy session data)
• Behavioral tracking across apps or websites

3. How We Use Your Information

3.1 Local Data Usage

Data stored on your device is used solely to:

• Provide core AAC communication functionality
• Remember your preferences and settings
• Track usage patterns for your personal insights
• Enable therapy mode features and progress tracking

3.2 Cloud-Processed Data Usage

Sentences sent to our backend for AI polishing are:

• Processed by OpenAI's GPT API to improve natural language output
• Used only for the immediate processing request
• Not stored, logged, or used for any other purpose
• Subject to OpenAI's data processing agreement (not used for model training)

4. Data Storage and Security

4.1 Local Storage

All user data is stored securely on your device using iOS's encrypted storage mechanisms. This data is protected by your device's security features (passcode, Face ID, Touch ID).

4.2 Cloud Security

Our backend infrastructure uses industry-standard security measures:

• HTTPS/TLS encryption for all data transmission
• Firebase Cloud Functions with secure environment variables
• No permanent storage of user sentences or requests
• OpenAI API key securely stored on server (never in app)

5. Data Sharing and Third Parties

5.1 Third-Party Services

LumaVoice uses the following third-party services:

• OpenAI (GPT API): For AI-powered sentence enhancement. OpenAI processes your sentences according to their Privacy Policy. Your data is not used to train their models.
• Firebase (Google Cloud): For backend hosting. No user data is stored in Firebase databases.
• Apple StoreKit: For in-app purchase processing. Handled entirely by Apple.

5.2 No Data Selling

6. Your Data Rights

6.1 Access and Control

You have complete control over your data:

• View: All your data is accessible within the app
• Export: Use the export features to save your data
• Delete: Delete custom tiles, phrase history, or therapy sessions at any time
• Reset: Reset all app data through Settings

6.2 Data Portability

You can export your data (usage reports, therapy session data) at any time through the app's export features.

6.3 Account Deletion

LumaVoice does not require an account. To delete all data:

1. Go to Settings → Advanced → Reset App Data
2. Or delete the app from your device

7. Children's Privacy

LumaVoice is designed for users of all ages, including children. We comply with the Children's Online Privacy Protection Act (COPPA):

• No personal information is collected from users of any age
• No accounts or registrations required
• All data stays on the device
• Parental controls available through iOS Screen Time

8. Data Retention

Local Data: Retained on your device until you delete it or uninstall the app.

Cloud-Processed Data: Sentences sent for AI processing are not retained. They are processed in real-time and immediately discarded.

9. International Data Transfers

LumaVoice's backend services are hosted in the United States (Firebase/Google Cloud, OpenAI). When you use the AI polishing feature, your sentence text is transmitted to servers in the US for processing. No personal information accompanies this data.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by:

• Posting the new Privacy Policy in the app
• Updating the "Last Updated" date
• Displaying an in-app notification for material changes

Continued use of the app after changes constitutes acceptance of the updated policy.

11. Legal Compliance

We may disclose information if required by law, such as to comply with a subpoena or similar legal process, or when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.

12. California Privacy Rights (CCPA)

If you are a California resident, you have the right to:

• Know what personal information we collect
• Request deletion of your personal information
• Opt-out of the sale of personal information (we don't sell data)

To exercise these rights, contact us at support@lumainnovations.com.

13. GDPR Compliance (EU Users)

If you are in the European Union, you have the right to:

• Access your personal data
• Rectify inaccurate data
• Erase your data ("right to be forgotten")
• Restrict processing of your data
• Data portability
• Object to processing

Since LumaVoice stores data locally on your device, you have complete control over your data at all times.

14. Contact Us

15. App Store Privacy Labels

For transparency, here's how LumaVoice's data collection is reported in the App Store:

• Data Used to Track You: None
• Data Linked to You: None
• Data Not Linked to You:
  • Usage Data (device-local only, not transmitted)
  • Identifiers (local app instance ID only)

© 2025 Luma Innovations LLC. All Rights Reserved.
LumaVoice is a registered trademark of Luma Innovations LLC.