Lumen.

Privacy Policy

Last updated: 30 September 2026

This Privacy Policy explains how Lumen ("Lumen", "we", "us") collects, uses, shares and protects personal data when you use the Lumen mobile and web applications and related services (the "Service"). Lumen is operated by Tiago Almeida, based in Portugal. We are the data controller for the personal data described below.

1. Data we collect

Information you provide

• Account information — when you sign in with Google or Apple, we receive your name, email address and a unique account identifier.
• Content you upload — photos, videos, voice notes, notes/captions, reactions and any moments/challenges you complete at an event.
• Voice notes and their transcripts — if you record a voice note, it is transcribed after upload so it can be read as well as heard, and the language spoken is detected automatically. Voice notes are visible only to you and the event's hosts. The audio, the resulting text and the detected language are stored with the event. See section 5 for who processes this.
• Event information — events you create or join, your role (host or guest), display name and join activity.

Information collected automatically

• Device & usage data — app version, device type, language, and basic interaction/diagnostic data used to operate and improve the Service.
• Push tokens — if you enable notifications, a device token so we can send event prompts and alerts.

Payments

• When you purchase a plan, the transaction is processed by the relevant app store (Apple App Store, Google Play) and/or our payments provider. We receive confirmation of purchase and entitlement details, but not your full card number.

2. How we use your data

• Provide and operate the Service — create events, host the shared album, and display content to the event's participants.
• Transcribe voice notes to text, so they can be read, searched and kept alongside the album.
• Send notifications you have opted into (e.g. "capture now" prompts).
• Process purchases and manage plan limits and album lifetime.
• Maintain safety, prevent abuse, and respond to content reports.
• Comply with legal obligations and enforce our Terms.

3. Legal bases (GDPR)

Where the EU/UK GDPR applies, we rely on:

• Performance of a contract — to provide the Service you request.
• Consent — for optional features such as push notifications. You may withdraw consent at any time.
• Legitimate interests — to secure, maintain and improve the Service and prevent abuse.
• Legal obligation — where we are required to retain or disclose data by law.

4. Sharing your content within an event

Lumen is a shared-album product. Content you upload to an event is visible to other members of that event according to the host's settings (for example, the gallery may be revealed live or after the event). You can also mark an individual photo, video or voice note as hosts only when you post it, or afterwards — it then stays visible to you and to the event's hosts, and is hidden from the other guests' galleries. Hosts and admins can moderate, remove or export event content, including hosts-only items. Please only upload content you are comfortable sharing with the event's participants.

5. Service providers & disclosures

We share data with trusted providers who process it on our behalf:

• Google Firebase / Google Cloud — authentication, database, file storage, hosting, push messaging and serverless functions.
• Google Cloud Speech-to-Text — converts uploaded voice notes to text and detects their language. The audio is sent to Google for processing in its EU region; no separate copy is kept.
• Apple — Sign in with Apple and push delivery (APNs).
• Payments providers — Apple, Google and/or RevenueCat and its payment processors to handle purchases.

We may also disclose data to comply with the law, enforce our Terms, or protect the rights and safety of our users. We do not sell your personal data.

6. International transfers

Our providers may process data on servers outside your country, including the United States. Where data is transferred outside the EEA, it is protected by appropriate safeguards such as the European Commission's Standard Contractual Clauses.

7. Retention & album lifetime

• Event albums are kept for a limited period (by default, around 12 months from the event), after which they may be deleted. Hosts may be offered the option to extend or download an album before it expires.
• Account data is retained while your account is active. When you delete your account, we delete or anonymise your personal data, except where we must keep it to meet legal obligations.
• Deleting your data — you can delete individual items you posted at any time, and delete your account from Profile → Delete account in the app. Deleting your account removes your profile, your notification tokens and your membership of every event. Content you already shared into an event stays in that event's album for the other participants, so delete those items first if you want them gone — or email support@tcreations.app and we will action the request within 30 days.

8. Your rights

Subject to applicable law, you may request to access, correct, delete, restrict or object to the processing of your personal data, and to receive a copy in a portable format. You can delete your account from within the app, or contact us using the details below. EU/EEA users have the right to lodge a complaint with their local supervisory authority — in Portugal, the Comissão Nacional de Proteção de Dados (CNPD).

9. Security

We use industry-standard measures, including encryption in transit and access controls, to protect your data. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

10. Children

Lumen is not directed to children under 16, and we do not knowingly collect personal data from them. If you believe a child has provided us data, please contact us so we can remove it.

11. Changes to this policy

We may update this Privacy Policy from time to time. We will post the updated version here and revise the "Last updated" date. Material changes will be communicated where appropriate.

12. Contact

Questions or requests about your privacy? Contact us at support@tcreations.app.