Lumio Privacy Policy
Operator
Business name: iahtti
Representative: Junyoung Lee
Business registration number: 261-76-00594
Lumio (the “Service”) values users’ personal information and complies with applicable privacy laws, including Korea’s Personal Information Protection Act. This Policy applies to the iOS app Lumio and connected server services.
1. Personal information we collect and how
A. Information provided by users
| Item | Collection method | Required? |
|---|---|---|
| Apple user identifier (sub) | Sign in with Apple | Required when signing in |
| Name | Display name provided by Apple at Sign in with Apple | Optional |
| Purchase history (product ID, transaction ID, amount) | Via Apple and the app at in-app purchase | When purchasing |
B. Information generated or collected during use
| Item | Details | Storage location |
|---|---|---|
| OCR / PDF / text extraction results | Temporarily transmitted for AI card generation | Not stored on the server after generation completes |
| Credit balance, expiration, transaction ledger | Purchase, usage, and reward history | Server |
| Funnel and usage analytics events | Event names, numbers, and flags only (e.g., onboarding complete, generation attempt/success, purchase screen entry, review complete) | Server |
| Crash summaries | Non-identifying summaries such as OS version, build number, exception type | Server |
| Decks, cards, review records (FSRS) | Learning content | User device and iCloud (Apple) — not stored on the server by default |
| Shared template submissions, reports, likes | When using community features | Server |
C. Automatic collection
- App Attest device attestation data (to prevent request forgery for payment, generation, and balance queries)
- Service access logs and IP addresses (standard web server logs)
2. Purposes of collection and use
| Purpose | Details |
|---|---|
| Member identification and account management | User distinction via Sign in with Apple, name display, account deletion |
| AI card generation | Sending uploaded, captured, or entered text to AI to create flashcards |
| Payments and credit operations | In-app purchase verification, credit accrual/deduction/expiration, refunds and disputes |
| Service improvement and stability | Funnel analytics, crash summary analysis, incident response |
| Notifications | Review reminders and credit expiration notices (per user settings and consent) |
| Community and safety | Shared template operations, report handling, abuse prevention |
3. Retention and use period
| Data | Retention period |
|---|---|
| Account information (identifier, name, credits) | Until membership withdrawal (account deletion) — destroyed without undue delay upon deletion request |
| Payment and credit transaction ledger | Period required by law and for dispute handling (including e-commerce related laws) |
| AI generation request body | Not stored after generation processing completes |
| Analytics events | For operations and statistics — kept in non-identifiable form after account deletion, or destroyed |
| Deck, card, and review data | User device and iCloud — local reset upon app deletion, iCloud data deletion, or account deletion |
4. Provision to third parties
In principle, the Service does not sell or provide users’ personal information externally. However, the following processors and integrations are used to provide the Service.
| Recipient | Purpose | Items provided |
|---|---|---|
| Apple Inc. | Sign-in, in-app purchase, iCloud sync, App Attest | Per Apple’s policies |
| Cloudflare, Inc. | API and database hosting | Request data, account and transaction information |
| AI model providers (e.g., MiniMax via Cloudflare Workers AI) | Card generation | Text and template metadata included in generation requests (not retained after generation) |
We do not provide personal information to third parties for marketing, and we do not sell it for advertising tracking purposes.
5. Entrustment of processing
Not applicable.
6. User rights
Users may exercise the following rights at any time.
- Access, correction, and deletion: App Settings → Delete Account to request deletion of server account and linked data
- Withdraw consent: Disconnect Sign in with Apple (Apple ID settings); disable notification permissions (device settings)
- Learning data management: Delete decks and cards in-app; manage iCloud via Apple ID settings
7. Destruction procedures and methods
- Upon account deletion: Delete linked server data such as user records, credit ledgers, and shared templates/snapshots (where applicable)
- Device data: Reset local SwiftData, caches, widgets, and Watch shared data during in-app account deletion
- Electronic files: Deleted in a manner that makes recovery impractical
8. Measures to ensure security
- Sign in with Apple, App Store payment verification, and App Attest-based request authentication
- API access control via shared secrets and admin tokens between app and server
- Rate limiting on sensitive APIs such as AI generation and payments
- Avoiding long-term server storage of learning card body text (not stored after generation)
9. Children’s personal information
The Service is not directed to children under 14, and we do not knowingly collect children’s personal information.
10. Privacy officer
| Item | Details |
|---|---|
| Name | Junyoung Lee |
| Contact | [email protected] |
11. Changes to this Privacy Policy
This Policy may be revised when laws or the Service change. Changes will be announced via the app or website.
12. International transfers
Server (Cloudflare) and AI processing infrastructure may be located outside the user’s country, and information may be transferred to those countries when using the Service.