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Privacy Policy

Last Updated: November 3, 2026

This English version is the official and legally binding version of this Privacy Policy. Translations are provided for convenience only, and if they differ, the English version prevails.

1. Who we are

This policy covers the LumoTravel app, the website lumoapps.org and its journal. The data controller is Vladimir Maslov, an individual developer based in Moldova. Contact: support@lumoapps.org.

2. Using the app without an account

You can use the app without giving your email. The app then creates an anonymous account, and your travel data stays on your device. Cloud sync starts only after you add an email.

The app is free for up to 5 trips, and you never have to buy anything. A subscription and its 7-day free trial start only if you choose them in the App Store.

3. Data we process

CategoryDataStored encrypted on our server
AccountEmail, password in hashed form, language, account datesNo, needed to run the account
SubscriptionStatus, expiry date, product, transaction ID, price, RevenueCat IDNo
Profile (optional)Name, date of birth, nationalities and passport expiry dates, phone, target countries, residence permit expiry dateYes
Travel (optional)Countries, entry and exit dates, trip purpose, comments, visas and their stay rulesYes
Documents (optional)Tickets, visa photos, insurance and hotel bookings you uploadYes
ReportsPDF reports you generateYes
NotificationsPush notification tokenNo
SupportYour email and message when you contact us or report a ruleNo
App usageActions in the interface, app version, device and system type, internal user IDHandled by PostHog
Website usagePages, clicks, referring site, campaign tags, browser language, device type, browser details, country derived from IPNo, see section 5

We do not ask for your passport number, tax ID or home address in the app. Do not write them in comments. Documents you upload may contain them, and they are stored encrypted.

4. Location

If you allow it, the app uses your device location to detect which country you are in, including in the background when you turn this on. Exact coordinates are processed on your device and are not sent to our servers. Only the resulting country and trip dates may be synced.

The app first tries to find the country offline. When you are online, coordinates may be sent to Apple's location service to confirm the country and city. You can turn location access off at any time in your device settings.

5. Website analytics and cookies

Our own website analytics works without cookies. It keeps a random session ID in your browser for the visit. We read your IP address only to derive your country and store it as a hash, so we do not keep the address itself.

Google Analytics, loaded through Google Tag Manager, runs only if you press Accept in the cookie banner. It sets Google cookies and sends data to Google. If you press Reject, it does not load. You can change your choice at any time with Cookie settings in the website footer. Your choice is stored in your browser.

Fonts are served from our own server, so viewing the site does not send your data to a font provider.

6. Why we use data and our legal bases

PurposeLegal basis (GDPR)
Providing the app, sync, calculations, reports and notificationsContract
Storing documents and other optional data you addConsent, which you can withdraw by deleting them
Detecting your country from locationConsent through the device permission
Managing subscriptions and purchasesContract and legal obligations
Support and rule reportsContract and legitimate interests
App analytics and our own website analytics, to improve the serviceLegitimate interests
Google AnalyticsConsent
Security and abuse preventionLegitimate interests

We do not sell your data, show ads or use your data for advertising. Calculations in the app are informational. We do not make automated decisions with legal effects on you.

7. Who receives data

ProviderPurposeDataLocation
HetznerServer hostingAll data stored on our serverGermany
AppleApp Store payments, push delivery, location lookupPurchase data, push token, coordinates when used for lookupUnited States and others
RevenueCatSubscription managementInternal user ID, subscription and purchase statusUnited States
PostHogApp analyticsUsage events, internal user ID, device dataEuropean Union
GoogleWebsite analytics, only after consentCookies, pages visited, device data, IP addressUnited States and others
ResendSending emailsYour email and the messageUnited States
ExpoDelivering push notificationsPush token and notification textUnited States

Pinterest. We use the Pinterest API only to publish our own journal articles to our own Pinterest business account. We do not receive, store or process Pinterest data of website visitors or app users. The access tokens for our own account are stored encrypted on our server and are used only to create and update our Pins.

App versions released before November 2026 also send your account email to PostHog, and the country and day count when you tap a country on the home screen. Updating the app stops this.

We may also disclose data when the law requires it.

When data leaves the European Economic Area, we rely on the safeguards offered by these providers, such as Standard Contractual Clauses.

8. How long we keep data

  • Account, profile, travel data, documents and reports: until you delete them or your account.
  • Records you delete in the app: removed from the server within 30 days.
  • Deleting your account: your data and files are removed from our active systems. Database backups made for maintenance are replaced over time.
  • Detailed website analytics: 90 days. After that we keep only daily totals with no personal data.
  • Support messages and rule reports: as long as needed to handle them. They are stored separately and are not removed automatically with your account, so email us if you want them deleted.
  • Purchase records: removed from our server with your account. Apple and RevenueCat keep their own records.

9. Security

Data between the app and our server travels over HTTPS. On our server, the fields marked in section 3 and all uploaded files are encrypted, and access is restricted. We can technically decrypt this data for legal obligations, support you ask for, or system security.

On your device, the app does not add its own encryption. Your data there is protected by your device security, such as your passcode. Saved documents are excluded from device backups, while other app data may be included in them. Face ID is handled by your device, and we never receive it.

10. Your rights

Depending on where you live, you may have the right to:

  • access your data and get a copy;
  • correct inaccurate data;
  • delete your data;
  • restrict or object to processing;
  • receive your data in a portable format;
  • withdraw consent at any time;
  • complain to your data protection authority.

To delete your account, open Profile and choose Delete Account. For any other request, email support@lumoapps.org. Deleting the app does not cancel a subscription. Manage it in your Apple ID settings.

11. Children

LumoTravel is not intended for children under 13, and we do not knowingly collect their data. If you think a child gave us data, contact us and we will delete it.

12. Changes

We will update the date above when this policy changes. We will tell you about important changes in the app or by email.