Privacy Policy

Overview

Lumenshore Limited (“Lumenshore”, “we”, “us”, or “our”), company number 09607326, registered at Windsor House, Troon Way Business Centre, Humberstone Lane, Leicester, England, LE4 9HA, operates the LumenLingo mobile application (the “App”) and the lumenlingo.com website (the “Website”). This Privacy Policy explains how we collect, use, store, and protect information when you use either platform.

LumenLingo uses a hybrid architecture. Learning data is stored locally by default. If you enable Cloud Sync, selected learning data and settings are encrypted on your device and replicated as ciphertext to Lumenshore’s cloud-backup service and your private CloudKit container. Rails and our service providers separately process the account, authentication, policy-acceptance, subscription, support, privacy-request, analytics, security and backup metadata needed to operate LumenLingo.

The sections below distinguish on-device learning data, optional encrypted Cloud Sync backups, and personal data processed by Lumenshore and its service providers across the App and Website.

Website Data Collection

When you visit lumenlingo.com, we may collect the following data:

• Email address — if you sign up for our newsletter or join the waitlist. We collect your email solely to send you product updates and launch notifications. You can unsubscribe at any time.
• Language preference — if you join the waitlist, we record which language you’re interested in to tailor future communications.
• Campaign attribution (UTM parameters) — we capture UTM parameters (source, medium, campaign) from URLs in your browser’s sessionStorage to understand which marketing channels are effective. This data is not tied to your identity and is cleared when you close your browser tab.
• Website analytics — with your consent, Vercel Analytics and PostHog process page views and interaction events. PostHog uses a pseudonymous identifier and localStorage/cookie persistence. The marketing Website has no account sign-in and does not attach this Website identifier to a LumenLingo account.
• Performance metrics — Vercel Speed Insights processes page-load and web-vital measurements to help us maintain the Website.
• Error data and session replays — we use Sentry for error monitoring. With your consent, Sentry may record session replays to help us diagnose and fix bugs. See the ‘Sentry Session Replay’ section below for full details.
• IP addresses and request metadata — hosting, CDN, security and API providers process IP addresses to deliver requests, prevent abuse and investigate incidents. When you accept a policy while signed in, Rails stores the IP address with the acceptance evidence for up to three years, then removes the IP while retaining the remaining legal record. Provider security logs follow their applicable retention settings.

Sentry Session Replay

We use Sentry (operated by Functional Software, Inc.) for error monitoring on our website. Sentry’s session replay feature records page interactions (clicks, scrolls, navigation) to help us reproduce and fix bugs.

Sampling rates: Session replays are captured for approximately 0.1% of normal browsing sessions. When an error occurs, the replay capture rate increases to 100% for that session only — this helps us understand exactly what led to the bug.

What is captured: Page navigation, clicks, scrolls, and screen content. All text inputs in forms (such as newsletter and waitlist fields) are masked to protect your privacy. Media content is blocked from capture.

What is sent: Replay data is transmitted to Sentry’s servers in the United States. It is retained according to Sentry’s data retention policy (typically 90 days).

Your control: Session replays are only active if you have given consent via our cookie consent banner. You can change your preference at any time.

Vercel Analytics & Speed Insights

We use Vercel Analytics and Vercel Speed Insights on our website. These services are privacy-focused by design:

• No cookies — Vercel Analytics does not set any cookies on your device.
• No personal data — no IP addresses, device fingerprints, or user identifiers are collected.
• Aggregate only — we see total page view counts and performance metrics, but we cannot identify individual visitors.

Both services are operated by Vercel Inc. Data is processed on Vercel’s infrastructure. See Vercel’s Privacy Policy for more details.

Custom Analytics Events

With analytics consent, Vercel Analytics and PostHog receive events about how the Website is used. Events can include a pseudonymous Website identifier, event properties and coarse device metadata; they do not include a signed-in account identifier, raw payment-card data or your learning data:

• app_store_click — when a visitor clicks an App Store download link (records link location on the page)
• pricing_view — when a visitor views the pricing page
• pricing_cta_click — when a visitor clicks a pricing call-to-action button (records which tier)
• blog_post_read — when a visitor reads most of a blog post (records the post slug and title)
• feature_section_view — when a visitor views a feature section on the homepage
• newsletter_signup — when a visitor signs up for the newsletter (records the page location, not the email)
• demo_started — when a visitor starts the interactive flashcard demo
• demo_completed — when a visitor completes the demo (records correct/total scores)
• demo_cta_click — when a visitor clicks a call-to-action after completing the demo
• page_not_found — when a visitor lands on a 404 page (records the path)
• error_page_view — when a visitor sees an error page (records the error message)

Offline Caching (Service Worker)

Our website uses a Service Worker to cache static assets (HTML pages, CSS stylesheets, JavaScript bundles, images, and fonts) on your device. This enables faster page loads on repeat visits and limited offline access.

The Service Worker cache is stored entirely on your device and contains no personal data. You can clear it at any time through your browser’s settings (Clear site data). No cached data is sent back to our servers.

iOS App Data Collection

The App stores learning data locally by default and uses online services for accounts, operation and optional Cloud Sync:

• Learning data — flashcard mastery, practice scores, streaks, XP and session history are stored in SwiftData on your device. If you enable Cloud Sync, selected learning data is encrypted on your device and the encrypted backup is stored in Lumenshore’s cloud-backup service and your private CloudKit container so it can be restored across your devices. Rails stores the encrypted backup envelope, not a plaintext learning database.
• Learning preferences — language-pair choices remain on-device. Selected soundscape, appearance and account settings may be included in the same encrypted Cloud Sync backup.
• Account and authentication data — Clerk and Rails process your email address, LumenLingo/Clerk user identifier, display name, profile image reference, authentication/session metadata and account status so you can sign in, manage your account and see your profile. If you use Google Sign-In, the Google account identifier and any email, name and profile image imported through Google are described below; Clerk and Rails generate the remaining account and session fields.
• Policy acceptance — Rails stores which policy and version you accepted, when you accepted it, your locale and jurisdiction context, technical request evidence including IP address and user agent, and a client event identifier used to prevent duplicates.
• Subscription, entitlement and RevenueCat identity data — Apple is the merchant of record; RevenueCat and Rails process the LumenLingo/Clerk account identifier, purchase-receipt metadata, subscription state, entitlements and refunds to manage purchases. We do not receive raw payment-card details. Only after your analytics choice is remotely acknowledged may the App send RevenueCat bounded subscriber attributes — app and learning language, progress/activity measures, first-open time, device model, previous tier, and name/email where supplied — for product and acquisition analytics. These attributes are not sent merely because you accepted legal terms.
• Support and privacy requests — if you contact support, report a bug or make a data-rights request, we process the contact details, correspondence, attachments and case records needed to respond and retain accountability evidence.
• Device, coarse location and operational data — device/app version, push token and delivery metadata, request identifiers, security events and audit records may be processed to deliver notifications, secure accounts and operate the service. Rails and service providers may infer and store coarse city and country from IP addresses or trusted proxy headers, timezone, region or locale for security, service operation and consented analytics. The App does not request CoreLocation or precise GPS coordinates.
• Product analytics and feature flags — first-party Rails analytics and the bounded RevenueCat attributes listed above are processed only after your analytics choice is remotely acknowledged. The shipping production iOS build currently has no PostHog delivery endpoint configured. If a future production build enables App-side PostHog delivery, it may process App analytics only after the same consent. We do not use this data for cross-app tracking, advertising profiles or cross-context behavioural advertising.
• Error diagnostics — Sentry may receive crash, error, performance and request metadata. Session replay is used only where separately consented and configured.
• Optional bug-report screenshot — if you deliberately attach a screenshot in the in-app bug reporter, the App uploads that image with your report so Lumenshore can investigate. It is not collected unless you attach and submit it.
• Apple Search Ads attribution — only after your analytics choice is remotely acknowledged, the App may obtain an Apple AdServices attribution token and related campaign metadata and send them to Rails. Rails may combine that data with consent-gated RevenueCat subscription/product data and Apple first-party campaign reports for first-party or aggregate acquisition measurement. We do not access IDFA, request App Tracking Transparency permission, track across other companies’ apps or websites, build advertising profiles or use third-party ad networks.

Google Sign-In and Google User Data

Google Sign-In is optional. You can create and use a LumenLingo account with another available sign-in method. This section explains what Google user data is received through Clerk, how it is used and stored, when it is disclosed, and how to revoke the connection or delete your account.

What LumenLingo receives from Google

If you choose Google Sign-In, Clerk provides LumenLingo with the following basic identity data from your Google account:

• Google account identifier — the stable provider identifier Google issues for your account. Rails stores it in encrypted form and uses it to link the Google identity to the correct LumenLingo account and prevent duplicate or fraudulent account links.
• Email address — used to identify and secure your account, send service and security notices, manage subscription customer records, and respond to support or data-rights requests.
• Name — used to display and manage your profile, personalise service communications, and maintain subscription customer attributes. Marketing communications are sent only where the applicable consent or permission exists.
• Profile image — used to display your profile inside the App. The App and Rails use the image URL received through Clerk; Rails stores the URL reference rather than the image bytes.

How LumenLingo uses it

LumenLingo uses this information to create or link and authenticate your account, secure and manage it, display your profile, provide service and security communications, prevent fraud and abuse, and manage subscriptions and entitlements.

If you separately consent to product analytics and that choice is remotely acknowledged, first-party Rails analytics may use your LumenLingo/Clerk identifier and the account fields described here. The shipping production iOS build currently has no PostHog delivery endpoint configured; a future configured build could send the identifier, email address and first name to PostHog only after the same consent. The analytics identifier is not your Google account identifier, and consent can be withdrawn without losing App access.

Where it is stored and for how long

Clerk holds the authentication profile. Rails stores the LumenLingo/Clerk user identifier, encrypted Google account identifier, email address, display name and profile-image URL reference. RevenueCat always receives the LumenLingo/Clerk identifier and purchase/subscription status needed for entitlement management. Only after your analytics choice is remotely acknowledged may RevenueCat receive app and learning language, progress/activity measures, first-open time, device model, previous tier, and name/email where supplied for product and acquisition analytics; first-party Rails analytics may use the same consented account fields. The shipping production iOS build currently has no PostHog delivery endpoint configured. If a future production build enables App-side PostHog delivery, PostHog may receive the LumenLingo/Clerk identifier, email address, first name, App events and coarse device metadata only after the same consent. Postmark processes address, message and delivery data when we send email. Processing locations, transfer safeguards and retention rules for each provider are described below. Operational copies are generally retained while your account exists and are deleted or de-identified through account deletion, subject to the cancellation period and legal retention or hold requirements.

Who it is shared with

Google-derived profile data is disclosed only as described in this policy: to the processors listed below when necessary to provide authentication, account, subscription, communications, security and consented analytics services; when you direct us to disclose it; or when the law requires disclosure. Lumenshore does not sell personal data, disclose it to data brokers, or use it for advertising or advertising profiles.

Google data LumenLingo does not request

The Google Sign-In integration is limited to account authentication and basic profile and email data. LumenLingo does not use Google Workspace APIs to access Gmail, Google Drive, Google Contacts or Google Calendar data.

LumenLingo's use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

Google Sign-In itself does not upload your learning data. Learning data remains in SwiftData on your device unless you separately enable Cloud Sync. With Cloud Sync enabled, selected learning data is encrypted on your device and the encrypted backup is stored in Lumenshore’s cloud-backup service and your private CloudKit container; Rails stores the encrypted envelope, not a plaintext learning database.

How to disconnect Google Sign-In

You can revoke Google’s authorisation for the connection at any time from the third-party connections page of your Google Account. Revocation does not by itself close your LumenLingo account or erase data already retained for that account. To begin account deletion, use the in-App deletion control or contact legal@lumenlingo.com. After the 14-day cancellation period, a completed deletion removes or de-identifies Google identity and profile fields across the configured systems, subject to legal-hold and statutory-retention requirements.

What We Don’t Collect

We limit collection and want to be clear about information we do not intentionally collect or use:

• Rails and service providers may infer and store coarse city and country from IP addresses or trusted proxy headers, timezone, region or locale for security, service operation and consented analytics. The App does not request CoreLocation or precise GPS coordinates.
• No contacts or access to other apps on your device
• No raw payment-card or bank-account details (Apple handles App Store payment processing)
• No IDFA or other device-level cross-app advertising identifier, no App Tracking Transparency tracking, and no cross-app advertising profile
• No data sold or shared with third-party advertisers — ever
• No personal data shared with AI model training services
• No broad Photo Library access; the App receives only a screenshot you deliberately attach to a bug report

Legal Basis for Processing

Under GDPR and UK GDPR, we process personal data only when we have a lawful basis. Here is the legal basis for each type of data we handle:

Consent (GDPR Art. 6(1)(a))

• Newsletter signup — you actively provide your email and opt in to receive updates
• Waitlist signup — you actively provide your email and language preference
• Non-essential analytics and session replay — PostHog, Vercel Analytics and replay technologies are activated only after the applicable consent or preference permits them

Legitimate Interest (GDPR Art. 6(1)(f))

• Service security and fraud prevention — request metadata, IP addresses, audit events and account signals are used to secure the service and investigate abuse, balanced against data minimisation and retention controls
• Error monitoring and support — diagnostics and support records help us maintain reliability and answer requests; session replay remains consent-gated
• Service administration — limited account, entitlement and operational records are used to administer accounts, subscriptions and legal claims where those interests are not overridden by your rights

Contract Performance (GDPR Art. 6(1)(b))

• Account and authentication — identity and account records are necessary to provide signed-in services
• Subscription management — entitlement and purchase metadata are needed to provide paid features and handle refunds
• Support and service communications — contact details and request content are used when needed to provide requested support and transactional notices

Legal Obligation and Accountability (GDPR Arts. 6(1)(c), 5(2) and 7(1))

• Policy and consent evidence — we retain versioned acceptance and consent records to demonstrate compliance and establish, exercise or defend legal claims
• Privacy requests and regulatory records — DSAR, deletion, complaint and related audit records are processed to meet legal duties and prove that requests were handled

Whether Providing Data Is Obligatory

Under UK GDPR Article 13(2)(e), we must inform you whether the provision of personal data is a statutory or contractual requirement, and the possible consequences of failing to provide such data:

Contractual Requirements

• Account creation data (email address via Clerk authentication) — this is a contractual requirement. Without it, we cannot create your account or provide the Service.
• Subscription payment data (processed by Apple/RevenueCat) — this is a contractual requirement for premium features. Without it, we cannot process your payment or grant premium access.

Voluntary Provision

• Analytics and replay consent (PostHog, Vercel Analytics and consent-gated replay) — voluntary. Declining does not prevent core learning or account use, although some experiments or diagnostics will not run.
• Feedback and support emails — voluntary. If you do not provide contact details, we may be unable to respond to your query.

There is no statutory (legal) requirement to provide your personal data to us. All data provision is either contractual (necessary for the service) or voluntary.

UK Data Protection

Lumenshore Limited is a company incorporated in England and Wales (Company No. 09607326). As a UK-based data controller, we comply with the UK General Data Protection Regulation (UK GDPR) — retained from EU law via the European Union (Withdrawal) Act 2018 — and the Data Protection Act 2018 (DPA 2018). These laws govern how we collect, use, store, and protect your personal data.

Data Controller

The data controller responsible for your personal data is:

• Company: Lumenshore Limited
• Registered Address: Windsor House, Troon Way Business Centre, Humberstone Lane, Leicester, England, LE4 9HA
• Company Number: 09607326 (England and Wales)
• VAT Number: GB 270411929

Data Protection Lead

Although Lumenshore is not required to appoint a Data Protection Officer (DPO) under Article 37 UK GDPR (we are not a public authority, do not carry out large-scale monitoring, and do not process special category data at scale), we have designated a data protection lead to oversee compliance:

Data Protection Lead: The Director of Lumenshore Limited

You can contact our data protection lead at legal@lumenlingo.com for any questions about how we handle your personal data, to exercise your data rights, or to raise a data protection concern.

ICO Registration

As required by section 25 of the Data Protection Act 2018, Lumenshore Limited pays the annual data protection fee to the Information Commissioner’s Office (ICO), the UK’s independent supervisory authority for data protection.

The ICO maintains a public register of fee payers. You can verify our registration status on the ICO’s website.

Our ICO registration number is ZB718685. You can verify this on the ICO register.

International Data Transfer Adequacy

When personal data is transferred between the UK and the European Economic Area (EEA), it is protected by the UK–EU adequacy decision made under Article 45 UK GDPR. The European Commission granted adequacy to the UK in June 2021, recognising that UK data protection law provides an essentially equivalent level of protection to the EU GDPR.

For transfers to the United States, we rely on service providers certified under the EU–US Data Privacy Framework (DPF) and its UK Extension, which the UK government has recognised as providing adequate safeguards. Where a sub-processor is not DPF-certified, we ensure Standard Contractual Clauses (SCCs) approved by the ICO are in place.

For further details on international transfers and the specific safeguards we use, see the International Data Transfers section of this policy.

Special Category Data

LumenLingo does not collect or process any special category data as defined by Article 9 UK GDPR and section 10 of the DPA 2018. This includes: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life or sexual orientation, and criminal conviction data.

If our data processing activities change in the future to include any special category data, we will update this policy, conduct a Data Protection Impact Assessment (DPIA), and obtain explicit consent where required.

Your Right to Complain to the ICO

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). We would appreciate the opportunity to address your concerns first — please contact us at legal@lumenlingo.com and we will do our best to resolve the issue.

If you are not satisfied with our response, you can contact the ICO:

• Website: ico.org.uk/make-a-complaint
• Telephone: 0303 123 1113
• Post: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF

Electronic Communications (UK PECR)

The Privacy and Electronic Communications Regulations 2003 (PECR) set specific rules for electronic marketing and the use of cookies and similar technologies. As a UK company, Lumenshore Limited complies with PECR alongside the UK GDPR.

Cookies & Similar Technologies (Regulation 6)

PECR Regulation 6 requires your consent before we store or access information on your device, except where it is strictly necessary to provide a service you have requested. Our approach:

• Strictly necessary storage — consent preferences and language settings — is set without consent because it is essential for the website to function as you have requested.
• Non-essential storage — analytics tracking, error monitoring, and session replay — is only activated after you give explicit consent via our cookie banner.
• You can change your preferences at any time using the “Cookie Settings” link in the website footer.
• If your browser sends a Global Privacy Control (GPC) or Do Not Track (DNT) signal, all non-essential storage is automatically suppressed.

For full details of what we store and why, see our Cookie Policy.

Marketing Communications (Regulation 22)

We only send marketing emails to people who have given explicit, freely given consent by subscribing to our newsletter. We do not use pre-ticked boxes or bundle marketing consent with other agreements.

Every marketing email we send:

• Identifies the sender as Lumenshore Limited
• Includes a working unsubscribe link
• Describes the types of content you will receive (product updates, language learning tips, and occasional offers)

We record your consent (including the version of the consent text shown, a timestamp, and a hashed identifier) for our accountability records.

Soft Opt-In

PECR Regulation 22(3) allows businesses to send marketing to existing customers for similar products without explicit consent (“soft opt-in”), provided an opt-out was offered at point of collection and in every subsequent message. Lumenshore does not currently rely on the soft opt-in exception — all marketing requires explicit consent.

Where Your Data Goes

Learning data and operational personal data follow different paths:

• Your device — learning content, progress, session history and learning preferences are stored locally using SwiftData.
• Optional Cloud Sync — selected learning data and settings are encrypted on your device, then replicated as ciphertext to your private CloudKit container and Lumenshore’s cloud-backup service. Rails does not receive plaintext learning records.
• Fly.io and PostgreSQL — Rails stores account, policy-acceptance, entitlement, support, privacy-request, device, security, audit and cloud-backup metadata. Encrypted backup envelopes are kept in private object storage; Rails does not store their plaintext contents.
• Clerk and RevenueCat — Clerk processes authentication and identity data. RevenueCat processes the account/subscription identifier and purchase/entitlement metadata needed to manage Royal. Only after remotely acknowledged analytics consent may it receive the bounded subscriber attributes described above for product and acquisition analytics.
• PostHog, Vercel and Sentry — PostHog processes consent-gated website analytics. The shipping production iOS build has no PostHog delivery endpoint configured; future App-side delivery would require a configured build and remotely acknowledged analytics consent. Vercel processes website delivery/performance and Sentry processes diagnostics and separately consented replay.
• Postmark and Help Scout — contact details, communications, delivery records and support cases are processed when we email you or handle support.
• Upstash — short-lived queue, rate-limit, idempotency and operational cache data supports Rails processing.
• Tigris Data — private object storage holds encrypted Cloud Sync backup envelopes and may also hold time-limited DSAR export archives and compliance evidence.
• Cloudflare — IP addresses and request/security metadata are processed at the edge for DNS, TLS, WAF and abuse protection.
• Apple attribution and Rails — only after remotely acknowledged analytics consent, the App may send an Apple AdServices attribution token and campaign metadata to Rails for first-party or aggregate acquisition measurement with consent-gated subscription/product data and Apple first-party campaign reports, without IDFA, ATT tracking or cross-app profiling.

We disclose data only as described in this policy, including to the providers in the Sub-Processors section, when you direct us to do so, or where law requires it. We do not use advertising networks or sell personal data.

How We Use Your Information

We use data only for the purposes described here:

• Provide learning and optional sync — the App uses your on-device learning history for scheduling, adaptation and progress views. If you enable Cloud Sync, selected data is encrypted on your device before backup and restoration through Lumenshore’s cloud-backup service and private CloudKit.
• Operate accounts — authenticate users, maintain account status and provide account-management controls.
• Manage subscriptions — validate purchases, provide entitlements and handle refunds or billing support.
• Record legal choices — prove which policy version and consent choices were presented and accepted.
• Handle support and privacy rights — respond to messages, bug reports, exports, corrections, objections and erasure requests.
• Secure and maintain services — prevent abuse, diagnose failures, deliver notifications and maintain audit trails.
• Improve the App and understand acquisition — use consent-gated first-party Rails analytics, bounded RevenueCat attributes, de-identified aggregates and Apple AdServices attribution. App-side PostHog delivery is not configured in the shipping production build. None of these paths uses IDFA, ATT tracking, cross-app tracking or advertising profiles.
• Communicate with you — send transactional messages and marketing only where permitted; every marketing message includes an opt-out.

Data Storage & Security

LumenLingo separates plaintext learning data on your device from the server systems used for accounts and encrypted Cloud Sync backups:

• On-device learning storage — learning data is stored in SwiftData and protected by device security.
• Optional encrypted Cloud Sync — selected learning data and settings are encrypted on your device and replicated as ciphertext to your private CloudKit container and Lumenshore’s cloud-backup service. Rails does not receive plaintext learning records.
• Rails service and cloud database — Fly.io-hosted Rails and PostgreSQL store the operational personal data and cloud-backup metadata described in this policy. Access is restricted, encrypted transport is used, and audit and retention controls are applied.
• Private object and cache services — Tigris stores encrypted Cloud Sync envelopes and restricted export/evidence objects; Upstash stores limited operational queue/cache data. Cloud Sync encryption keys are generated and protected by the Rails service and released only to an authenticated account under the service’s access controls.
• Website and edge security — Vercel and Cloudflare process requests using HTTPS, edge-security and abuse-prevention controls.

Third-Party Services

LumenLingo uses the following categories of third-party service providers. The detailed register below explains their roles and data:

• Apple — App distribution, payment processing, user-controlled iCloud sync and, only after remotely acknowledged analytics consent, privacy-preserving AdServices campaign attribution.
• Vercel and Cloudflare — Website hosting, delivery, performance and edge security.
• Clerk and RevenueCat — account authentication, account/subscription identity, subscription/entitlement management and, only after remotely acknowledged analytics consent, bounded product/acquisition analytics.
• PostHog and Sentry — PostHog processes consent-gated website analytics; App delivery is not configured in the shipping production iOS build and any future App use would require the same remote consent gate. Sentry provides diagnostics and separately consented replay.
• Fly.io, Upstash and Tigris Data — Rails/PostgreSQL hosting, operational queues/cache and private object storage.
• Postmark and Help Scout — email delivery and customer-support case management.

We do not use third-party advertising networks, access IDFA, request ATT tracking permission, track people across other companies’ apps or websites, sell personal data or share it for cross-context behavioural advertising.

Sub-Processors

The following providers process data for Lumenshore or provide platform services used to deliver LumenLingo. The exact role can depend on whether you use the App, Website, subscription, support or privacy-request features:

Data Processing and Transfer Protections

We maintain DPAs, platform terms or equivalent contractual protections as appropriate to each provider and processing role.

• Due diligence — providers are recorded in our internal sub-processor register with an owner and review date.
• Restricted transfers — we use an adequacy decision, Data Privacy Framework participation, Standard Contractual Clauses and/or the UK IDTA/Addendum as applicable.
• Data minimisation — provider integrations are scoped to the data needed for their stated purpose, with consent gates where required.
• Security controls — access restrictions, private storage, signed links, secret management and logging controls are applied according to the service.
• Ongoing review — provider locations and terms can change; we review the register and update this notice when a material change affects users.

Sub-Processor Changes

If we add or change a sub-processor that handles personal data, we will update this page and note the change in the Version History section of this Privacy Policy. For material changes, we will provide at least 30 days' notice before the new sub-processor begins processing data.

International Data Transfers

Lumenshore Limited is based in the United Kingdom. Some providers process personal data outside the UK/EEA or through global networks. Provider locations can change, so the Sub-Processors table and provider notices should be read with these transfer safeguards:

• Apple — App Store and iCloud data can be processed through Apple’s global infrastructure.
• Vercel and Cloudflare — Website requests and security metadata can be processed through global edge networks, including outside the UK/EEA.
• Clerk, RevenueCat, PostHog and Sentry — identity, entitlement, analytics and diagnostics may be processed in the United States and/or European Union according to the configured service and plan.
• Fly.io, Upstash and Tigris Data — operational databases, queues/cache and private objects are placed according to our configured deployment regions but provider operations may involve international access.
• Postmark and Help Scout — email and support data may be processed in the United States and other provider locations.

Transfer Safeguards

For all international data transfers, we ensure at least one of the following safeguards is in place:

• Standard Contractual Clauses (SCCs) — EU Commission-approved contractual clauses that bind the data importer to protect your data to GDPR standards.
• EU-US Data Privacy Framework — where the recipient is certified under the framework, providing an adequacy basis for transfers to the US.
• UK International Data Transfer Agreement (IDTA) — the UK equivalent of SCCs, approved by the ICO for transfers from the UK.
• Adequacy decisions — where the European Commission or UK Government has determined that the destination country provides adequate data protection.

You may request a copy of the relevant transfer safeguards by contacting us at legal@lumenlingo.com.

Aggregated and De-identified Data

We may collect, aggregate, and de-identify personal data so that it can no longer reasonably identify any individual. Once de-identified, such data is no longer personal data under GDPR, UK GDPR, CCPA, or any applicable data protection law.

We may use, disclose, and publish de-identified and aggregated data for any purpose, including but not limited to:

• Product improvement and feature development
• Research and analytics
• Marketing materials and case studies
• Benchmarking and public reports
• Investor and stakeholder reporting

De-identification Standards

Our de-identification process meets the following legal standards:

• GDPR Recital 26 — data cannot be singled out, linked, or inferred to identify any individual, taking into account all means reasonably likely to be used.
• CCPA § 1798.140(m) — information that cannot reasonably be used to infer information about, or otherwise be linked to, a particular consumer or household. We maintain a commitment not to attempt to re-identify de-identified data.

Examples of Aggregate Data

Examples of the types of aggregate data we may derive and publish include:

• Total users or subscriptions by coarse market or plan
• Aggregate App or Website feature-use counts from consented events
• Service reliability, delivery and error-rate statistics
• Support-volume and privacy-request completion statistics
• Aggregate conversion and retention statistics that do not reveal an individual

No individual user can be identified from any published aggregate data.

Our right to retain and use Aggregate Data survives account deletion and service termination. After you delete your account, we may retain Aggregate Data that was derived from your use of the Service.

Children’s Privacy

LumenLingo is designed for users aged 13 and older. In accordance with GDPR Article 8 and DPA 2018 section 9, we do not knowingly collect personal information from children under 13 (or the applicable minimum age in your jurisdiction, which may be higher — for example, 16 in Germany and the Netherlands).

The App uses accounts and online operational services. Learning data is stored locally by default; if Cloud Sync is enabled, selected data is encrypted on the device and backed up as ciphertext as described above. We do not knowingly permit a child below the applicable digital-consent age to provide personal data without valid parent or guardian authorisation where the law requires it.

Parents and guardians can manage or delete the app and its data at any time through standard iOS device management. If you believe a child has provided personal data to us, please contact us at legal@lumenlingo.com and we will delete it promptly.

COPPA Compliance

LumenLingo complies with the Children’s Online Privacy Protection Act (COPPA). We do not knowingly collect, use, or disclose personal information from children under 13 without verifiable parental consent. Our service is not directed at children under 13, and we do not target advertising to children.

All website forms that collect personal information (such as email addresses) include an age-confirmation step requiring users to confirm they are at least 13 years old, or that they have parental or guardian consent if under 18.

Parental Rights

Under COPPA and similar laws, parents and guardians have the right to:

• Review any personal information we may have inadvertently collected from their child
• Request deletion of their child’s personal information from our systems
• Refuse further collection or use of their child’s information
• Manage or remove the app and its locally stored data through standard iOS device management

To exercise any of these rights, please contact us at legal@lumenlingo.com. If we discover that we have collected personal information from a child under 13 without proper parental consent, we will delete that information within 72 hours of discovery.

Educational Use & FERPA

LumenLingo is not administered by or on behalf of educational institutions. If a school or educational organisation chooses to recommend LumenLingo to students, it does so independently. The institution is responsible for ensuring compliance with the Family Educational Rights and Privacy Act (FERPA) and for obtaining any required parental consent before directing students under 13 to use the service.

Age of Digital Consent — Multi-Jurisdiction

The age at which a person can give valid consent for data processing varies by jurisdiction. As a language-learning service likely used by younger learners, we apply locale-aware age requirements.

Age of Consent by Jurisdiction

The following table summarises the minimum digital consent age in each jurisdiction where we operate:

• United Kingdom: 13 (UK GDPR / ICO guidance)
• United States: 13 (COPPA)
• Spain: 14 (LOPDGDD)
• Italy: 14 (D.Lgs 101/2018)
• China: 14 (PIPL Art. 31 — under-14 classified as sensitive personal information)
• South Korea: 14 (PIPA — parental consent for under-14)
• France: 15 (Loi Informatique et Libertés)
• Germany: 16 (BDSG)
• Netherlands: 16 (UAVG)
• Poland: 16 (GDPR national implementation)
• Ireland: 16 (Data Protection Act 2018)
• Japan: 16 (APPI — case-by-case for minors; we apply 16 as a conservative default)
• UAE: 18 (UAE PDPL — minors require guardian consent)
• Saudi Arabia: 18 (PDPL — minors require guardian consent)
• India: 18 (DPDPA 2023 — children defined as under 18; verifiable parental consent required)
• Brazil: 12/18 (LGPD Art. 14 — children under 12 require parental consent; 12–17 processed in their best interest)
• Canada: 13 (PIPEDA; Quebec: 14 under provincial law)
• Australia: capacity-based (Privacy Act 1988 — no fixed age; assessed by individual capacity)

Our Approach

We apply the age and parental-consent rules required for the user’s jurisdiction to account registration and personal-data collection. Where we cannot establish valid consent or another lawful basis for a child’s data, we do not permit the collection and will remove data discovered to have been collected improperly.

Learning data is stored locally by default; optional Cloud Sync transmits an encrypted backup, while signed-in use transmits account, consent, subscription and operational metadata to the providers described in this policy. These safeguards do not remove the need for appropriate age and parental-consent controls.

Parental Consent for Underage Users

If you are between 13 and your jurisdiction’s consent age, you cannot submit personal information through our website without parental consent. Our forms require a self-declaration confirming you meet the age threshold for your jurisdiction.

For users under the applicable age: we display an age-appropriate notice explaining our data collection practices. Essential service functionality (such as browsing the website) remains available without consent-based data collection.

China PIPL — Special Protections for Under-14

Under China’s Personal Information Protection Law (PIPL Art. 31), personal information of individuals under 14 is classified as “sensitive personal information.” Processing requires separate consent from a parent or guardian, and we must conduct a Personal Information Protection Impact Assessment for any such processing.

We do not knowingly collect personal information from Chinese users under 14. If we discover such data has been collected, we will delete it promptly and notify the parent or guardian.

Children’s Enhanced Privacy Protections

As a language-learning service likely used by younger learners, we apply enhanced privacy protections for users under 18. These protections exceed baseline regulatory requirements and reflect our commitment to child safety.

Data Minimisation for Minors

We collect only data strictly necessary for service delivery from all users, with additional restrictions for verified minors:

• No marketing communications are sent to verified minor users.
• No session-replay or behavioural-analytics tracking is applied to minor users.
• Analytics is limited to essential error monitoring to maintain service quality.
• No third-party advertising trackers are loaded for minor users.

Parental Controls

Where parental or guardian consent has been provided:

• Parents or guardians may review the data we hold about their child by emailing legal@lumenlingo.com.
• Parents or guardians may revoke consent at any time, and we will cease processing the child’s personal data within 30 days.
• Upon parental request, we will delete all of the minor’s personal data, subject to any legal retention obligations.

Age-Appropriate Privacy Notices

For users aged 13–17, we aim to provide privacy information that is:

• Written in clear, plain language appropriate for a younger audience.
• Concise and focused on what matters most: what data we collect, why, and how to control it.
• Presented in a visual, accessible format rather than dense legal text wherever possible.

UK Children’s Code Compliance

The UK Information Commissioner's Office (ICO) Age Appropriate Design Code applies to online services likely to be accessed by children under 18. As a language-learning service, LumenLingo falls within scope. We have assessed our service against all 15 standards of the Code:

• Best interests of the child: data practices prioritise children's wellbeing over commercial interests.
• Data protection impact assessments: we conduct DPIAs for features likely to be accessed by children.
• Age-appropriate application: we apply age-appropriate protections by default; where precise age is unknown, we treat all users as potentially under 18 for privacy purposes.
• Transparency: privacy information is provided in clear, age-appropriate language.
• Detrimental use of data: we do not use children's data in ways that have been shown to be detrimental to their wellbeing.
• Policies and community standards: our published terms uphold the Code's standards.
• Default settings: high-privacy defaults are applied for all users, ensuring children receive maximum protection without needing to adjust settings.
• Data minimisation: only data essential for the learning service is processed.
• Data sharing: we do not share children's personal data with third parties for marketing or advertising purposes.
• Geolocation: we do not collect or use precise geolocation data.
• Parental controls: not applicable — LumenLingo does not currently provide parental control features. If introduced, they will be designed to provide an appropriate level of monitoring without excessive surveillance.
• Profiling: children are not profiled for marketing or behavioural targeting. Our spaced-repetition algorithm is purely pedagogical and does not constitute profiling under the Code.
• Nudge techniques: we do not use design techniques that encourage children to provide unnecessary personal data or weaken their privacy protections.
• Connected toys and devices: not applicable — LumenLingo is a software application and does not interact with connected toys or IoT devices.
• Online tools: we provide accessible tools for users to exercise their data rights, including account deletion and data export.

App Store Age Rating

LumenLingo is rated 4+ for the nature of its App Store content. That content rating is not an age-verification or data-consent mechanism. Account and online-service use remain subject to the age and parental-consent rules described above. Learning data is stored locally by default; optional Cloud Sync stores selected data as an encrypted backup as described in this policy.

For website services that collect personal data (newsletter, waitlist), the minimum age is enforced according to the user’s jurisdiction as described in our Age of Digital Consent section above.

Data Retention & Deletion

We keep each category only for as long as needed for the purpose, legal duties, security or legal claims, then delete or anonymise it under the applicable retention rule:

Website Data

• Newsletter/waitlist emails — retained until you unsubscribe, plus up to 30 days to process your removal.
• Sentry error logs — retained by Sentry for 90 days, then automatically deleted.
• Sentry session replays — retained by Sentry for 90 days, then automatically deleted.
• Consent-gated analytics and attribution — retained according to configured website PostHog, RevenueCat, Apple and Sentry settings. Rails-side product and Apple AdServices acquisition events are aggregated or anonymised after 90 days. The shipping production iOS build has no PostHog delivery endpoint configured.
• Policy and consent evidence — the acceptance event is retained as legal accountability evidence. Its exact IP address is removed after no more than three years, and direct technical identifiers are removed on verified erasure where permitted.
• Privacy-request records — completed DSAR identity details are anonymised after three years; non-identifying event evidence can be retained to demonstrate handling. Export archives are time-limited and access-controlled.

iOS App Data

• Account deletion — after the 14-day cancellation period, the deletion flow deletes or de-identifies active account data and requests deletion from applicable providers, subject to legal holds and limited records retained for legal duties, fraud prevention or claims. Use the App and Apple controls to remove local and private-CloudKit copies; Lumenshore deletes the server-side encrypted Cloud Sync envelope through the account-erasure process.
• Delete the app — uninstalling LumenLingo removes all locally stored data.
• iCloud data — you can manage iCloud storage through your device’s Settings → Apple ID → iCloud → Manage Storage.
• Subscription cancellation — cancellation stops future renewal but does not delete your account. Entitlement, purchase/refund and accounting evidence is retained only as needed for service, tax/accounting, fraud prevention and legal claims; use account deletion or a rights request to request erasure.

Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the Information Commissioner's Office (ICO) without undue delay and, where feasible, within 72 hours of becoming aware of the breach, in accordance with UK GDPR Article 33. Where notification to the ICO is not made within 72 hours, it shall be accompanied by reasons for the delay.

If the breach is likely to result in a high risk to your rights and freedoms, we will also notify you directly without undue delay, in accordance with UK GDPR Article 34. We will communicate to you in clear and plain language:

• The nature of the personal data breach, including where possible the categories and approximate number of data subjects and records concerned
• The name and contact details of our data protection lead from whom you can obtain more information
• The likely consequences of the breach
• The measures taken or proposed to address the breach, including, where appropriate, measures to mitigate its possible adverse effects

We maintain internal breach response procedures, including a breach register, to ensure we can detect, report, and investigate personal data breaches effectively. For questions about our breach notification procedures, contact us at legal@lumenlingo.com.

Law Enforcement and Government Requests

Lumenshore will only disclose personal data to law enforcement authorities or government bodies when legally compelled to do so — for example, pursuant to a court order, warrant, or statutory obligation under the Data Protection Act 2018, section 7.

Where we receive a valid legal demand for personal data, we will notify the affected user unless we are legally prohibited from doing so (for example, by a non-disclosure order attached to the demand).

We will resist any request that we consider to be overbroad, disproportionate, or lacking a proper legal basis. We do not voluntarily provide personal data to any government body, and we do not participate in mass surveillance programmes.

If you have questions about our approach to law enforcement requests, please contact us at legal@lumenlingo.com.

Automated Decision-Making and Profiling

We do not use your personal data for automated decision-making that produces legal effects or similarly significant effects on you, as defined by UK GDPR Article 22.

Our app uses a spaced-repetition algorithm to optimise your learning schedule. This is pedagogical optimisation only — it determines when to show you a flashcard, not any decision with legal or similarly significant effects on you.

If we ever introduce automated decision-making with legal or significant effects in the future, we will update this policy and ensure you have the right to: (a) obtain human intervention, (b) express your point of view, and (c) contest the decision, as required by UK GDPR Article 22(3).

California Notice at Collection (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA) require that we disclose the categories of personal information we collect, the purposes for collection, and whether such information is sold or shared. This notice is provided at or before the point of collection.

Do Not Sell or Share My Personal Information

Lumenshore does not sell your personal information to third parties. We do not share your personal information for cross-context behavioural advertising. Because we do not engage in these practices, there is no need to opt out — but we provide this disclosure as required by the CCPA/CPRA.

If our practices ever change, we will update this policy and provide a mechanism for you to opt out before any sale or sharing begins.

California residents may also use the Global Privacy Control (GPC) browser signal to communicate their opt-out preference. We honour GPC as a valid opt-out request under the CPRA.

Your Rights

Depending on your location, you may have additional rights regarding your data:

Under GDPR (European Economic Area & UK)

• Right to access — export local learning data from the App and request an authenticated export of account, consent, subscription, support and other server-side personal data.
• Right to rectification — edit available account/app fields or contact us to correct inaccurate server records, subject to preserving immutable legal evidence.
• Right to erasure — use in-app account deletion or make a data request; after the 14-day cancellation period, active server data and the server-side encrypted backup are deleted or de-identified, subject to legal holds and permitted retention. Local and private-CloudKit copies can be removed through the App and Apple settings.
• Right to data portability — use the App’s JSON export for local learning data and request a machine-readable DSAR export for eligible server-side personal data.
• Right to object — withdraw analytics consent in settings or object to processing based on legitimate interests through a data request.
• Right to restrict processing — contact us to request that we limit how we process your data.
• Right to lodge a complaint — you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by calling 0303 123 1113, or with your local supervisory authority if you are outside the UK.
• Right to withdraw consent — where we rely on consent as a legal basis (e.g., analytics), you may withdraw your consent at any time by adjusting your cookie preferences or contacting us at legal@lumenlingo.com. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

Under CCPA/CPRA (California)

• Right to know — you may request that we disclose the categories and specific pieces of personal information we have collected about you. See the Notice at Collection section above.
• Right to delete — you may request deletion of your personal information. Use the in-app Delete Account feature, delete the app, or contact us to remove website data.
• Right to correct — you may request correction of inaccurate personal information. App data can be edited directly; for website data, contact us.
• Right to opt out of sale or sharing — we do not sell or share personal information for cross-context behavioural advertising. No opt-out action is required.
• Right to limit use of sensitive personal information — we do not collect sensitive personal information as defined by the CCPA/CPRA.
• Non-discrimination — we will not deny you services, charge different prices, or provide a different quality of service because you exercised your privacy rights.

For California residents, we will acknowledge your request within 10 business days and respond substantively within 45 calendar days. If more time is needed, we may extend by an additional 45 days with notice. We may verify your identity by matching information you provide with data we have on file.

Under US State Privacy Laws (Virginia, Colorado, Connecticut & Others)

If you reside in Virginia, Colorado, Connecticut, Utah, or other US states with comprehensive privacy laws, you hold similar rights to those described under CCPA/CPRA above. These laws include the Virginia Consumer Data Protection Act (VCDPA), Colorado Privacy Act (CPA), and Connecticut Data Privacy Act (CTDPA).

• Right to access — you may confirm whether we process your personal data and request a copy.
• Right to correct — you may request correction of inaccurate personal data.
• Right to delete — you may request deletion of your personal data.
• Right to data portability — you may obtain your data in a portable, readily usable format.
• Right to opt out — you may opt out of targeted advertising, the sale of personal data, and profiling. Lumenshore does not engage in any of these practices.

If we decline your request, you may appeal by contacting us at legal@lumenlingo.com. We will respond to appeals within 60 days. If you are unsatisfied with the outcome, you may contact your state attorney general's office.

Colorado and Connecticut require us to honour universal opt-out signals such as Global Privacy Control (GPC). We honour GPC across all jurisdictions.

Verification & Response Process

To protect your data, we will verify your identity before processing a rights request. We may ask you to confirm the email address associated with your account or subscription, or to provide other identifying details that match our records.

You may designate an authorised agent to make a request on your behalf. We will require proof of the agent's authority (such as a signed authorisation or power of attorney) and may still verify your identity directly.

Response Timeframes

• CCPA/CPRA (California) — acknowledgement within 10 business days; substantive response within 45 calendar days (extendable by an additional 45 days with notice).
• VCDPA (Virginia) — response within 45 days (extendable by an additional 45 days with notice).
• CPA (Colorado) — response within 45 days (extendable by an additional 45 days when reasonably necessary).
• CTDPA (Connecticut) — response within 45 days (extendable by an additional 45 days with notice).
• GDPR (EEA & UK) — response within one calendar month (extendable by two further months for complex requests).

To exercise these rights, use the authenticated in-app privacy controls, email us at legal@lumenlingo.com, or submit a request through our Data Request page. We verify identity and respond within the applicable statutory timeframe.

Your California Privacy Rights

Under California Civil Code § 1798.83 ("Shine the Light"), California residents may request information about the disclosure of personal information to third parties for direct marketing purposes. Lumenshore does not disclose personal information to third parties for their direct marketing purposes.

To exercise any California privacy right — including rights under the CCPA/CPRA — email us at legal@lumenlingo.com with the subject line "California Privacy Rights" or submit a request through our Data Request page.

Global Privacy Control & Do Not Track

We honour the Global Privacy Control (GPC) signal. When your browser sends a GPC signal (via the Sec-GPC HTTP header or the navigator.globalPrivacyControl JavaScript API), we treat it as a valid opt-out request for non-essential data processing.

Under the California Privacy Rights Act (CPRA), GPC constitutes a valid opt-out of the sale or sharing of personal information. Under the Colorado Privacy Act and Connecticut Data Privacy Act, we are required to honour universal opt-out mechanisms including GPC.

When a GPC signal is detected, we automatically suppress all non-essential tracking on our website — including analytics events and session replay — regardless of any prior cookie consent preferences.

We also honour the Do Not Track (DNT) browser signal. Although DNT has been deprecated by the W3C, we treat it identically to GPC for consistency and as a demonstration of our commitment to privacy.

Policy Updates

We may update this Privacy Policy from time to time, typically to reflect changes in our services or legal requirements. When we make significant changes, we’ll update the “Last updated” date and version number at the top of this page.

For material changes, we provide an appropriate notice and request a new acknowledgement or consent where required. Continued use alone is not treated as consent where the law requires an affirmative choice.

Version History

• v2.6 (30 July 2026) — Disclosed optional bug-report screenshots and corrected the California visual-information category; clarified coarse-location sources, RevenueCat’s consent-gated attributes and consent-gated Apple AdServices attribution with no IDFA, ATT tracking or cross-app profiling; and recorded that App-side PostHog delivery is not configured in the shipping production build.
• v2.5 (26 July 2026) — Clarified Google Sign-In data handling and corrected the description of optional, device-encrypted Cloud Sync and its storage providers.
• v2.4 (14 July 2026) — Corrected the description of LumenLingo’s hybrid local/server architecture; disclosed account, consent, subscription, support, analytics, security and DSAR processing; corrected IP and retention statements; expanded the provider register; and added immutable content-hash evidence for legal versions.
• v2.3 (27 March 2026) — Phase 3 legal fortification: added limitation of liability cross-reference to Terms, added dispute resolution section referencing Terms for non-GDPR disputes with GDPR Art. 79 carve-out, standardised all contact email addresses to legal@lumenlingo.com.
• v2.2 (26 March 2026) — Phase 2 legal hardening: standardised company name to Lumenshore Limited throughout; added GDPR Art. 77 ICO complaint right and contact details; added processor sub-processor register; enhanced international transfer safeguards; added regional privacy frameworks (Japan APPI, China PIPL, Brazil LGPD, Germany BDSG, Australia Privacy Act, India DPDP, Canada PIPEDA, South Korea PIPA, Switzerland FADP); improved electronic communications and PECR compliance disclosures.
• v2.1 (26 March 2026) — Reorganised sections: moved commercial/regulatory compliance disclosures (VAT treatment, EU VAT, international tax, pricing compliance, sanctions, encryption export controls) to Terms of Service. Added cross-reference to Terms. Consolidated trademark attribution to shared Legal namespace. No content was removed.
• v2.0 (23 March 2026) — Extended policy to cover lumenlingo.com website data collection, added Sentry session replay disclosure, Vercel Analytics disclosure, legal basis for processing, data flow section, and service worker caching details.
• v1.0 (22 March 2026) — Initial privacy policy covering the LumenLingo iOS app.

Limitation of Liability

For details on our liability limitations, please refer to the Limitation of Liability section in our Terms of Service.

Dispute Resolution

For disputes not relating to data protection, the dispute resolution provisions of our Terms of Service apply, including informal resolution, mediation, and court proceedings governed by the laws of England and Wales.

For data protection disputes, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) or to seek a judicial remedy under GDPR Article 79 and the Data Protection Act 2018 section 167, without prejudice to any other administrative or non-judicial remedy available to you.

EU Representative (GDPR Art. 27)

Lumenshore Limited is incorporated in England and Wales and is therefore established outside the European Economic Area (EEA). Where Lumenshore offers its Service to individuals in the EEA or monitors their behaviour within the EEA, it may be subject to the obligation under GDPR Art. 27 to designate a representative in the EU.

LumenLingo processes minimal personal data and does not systematically monitor the behaviour of EU-based individuals. The app's learning algorithms operate locally on users' devices and do not involve server-side profiling or tracking.

Lumenshore Limited, legal@lumenlingo.com

Lumenshore will review this assessment periodically and will formally appoint an EU representative under GDPR Art. 27 if required by changes in processing activities, applicable guidance, or regulatory requirements.

EU-based individuals have the right to lodge a complaint with their local data protection supervisory authority. A list of EEA supervisory authorities is available on the European Data Protection Board website.

If Lumenshore formally appoints an EU representative in the future, the representative's details will be published in this Privacy Policy and communicated to the relevant supervisory authority in accordance with GDPR Art. 27(4).

Contact Us

If you have questions about this Privacy Policy, your data, or want to exercise your rights, please reach out:

• Email: legal@lumenlingo.com
• Company: Lumenshore Limited, Windsor House, Troon Way Business Centre, Humberstone Lane, Leicester, England, LE4 9HA
• Company Number: 09607326 (England and Wales)
• VAT Number: GB 270411929

Formal data rights requests follow the statutory response timelines.