Privacy Policy
- Introduction
- Plain-English Summary
- App Store Privacy Label
- App Tracking Transparency (ATT)
- What We Do (and Don't) Receive
- Camera and Scan Content
- OCR Text Recognition
- Legal Basis for Processing (GDPR)
- Third-Party Services
- Data Retention
- Your Rights
- Deleting Your Data
- Children's Privacy
- International Data Transfers
- Security
- Changes to This Policy
- Contact Us
1. Introduction
This Privacy Policy describes how the Lumi iOS application ("Lumi", the "App", "we", "us", "our") handles information when you use the App. The App is published by TRY2APP LTD.
Lumi is built around a single principle: your scans never leave your iPhone. We don't run a backend that stores documents, we don't use AI providers, and we don't have user accounts. The only data that reaches us is what Apple needs to process your subscription purchase.
2. Plain-English Summary
In one paragraph: Lumi is a fully on-device document scanner. Camera frames are processed in-memory using Apple's Vision framework, the resulting JPEG is saved into your iPhone's private app sandbox, OCR runs locally, and PDF/image exports are generated locally. Lumi never uploads your scans, never sees your camera feed, and has no servers that hold your content. The only network calls Lumi makes are to Apple's StoreKit and RevenueCat — to verify and sync your subscription status. We do not track you, do not run ads, and do not sell data.
3. App Store Privacy Label (Apple Disclosure)
Apple requires every app on the App Store to disclose its data collection practices in the "App Privacy" label shown on each app's App Store listing. The information below mirrors the exact disclosures we make to Apple.
Category A — Data Used to Track You
None.
Lumi does not link any data collected from this app with data from third-party apps or websites for advertising or tracking purposes. We do not share any data with data brokers.
Category B — Data Linked to You
- Purchases — Purchase History. The product identifiers and subscription status of purchases made through Apple. Used for App Functionality (to unlock Premium features). Processed by Apple and RevenueCat, linked to your Apple ID for the purpose of restoring purchases on devices signed in to the same Apple ID.
Category C — Data Not Linked to You
- Identifiers — User ID. A random anonymous installation identifier generated by RevenueCat. Used for App Functionality only. Not linked to your real identity, email, or name. Stored on RevenueCat's servers solely so subscription status can be associated with this installation.
- Diagnostics — Crash Data. Standard iOS crash reports collected by Apple if you have enabled "Share with App Developers" in iOS Settings. Aggregated and anonymized by Apple before we see them. We do not run any third-party crash SDK.
What we do NOT collect
For full transparency, the following data categories Apple asks about are not collected by Lumi at all:
- Contact Info (email, name, phone number, physical address, other contact info)
- Health & Fitness
- Financial Info (payment, credit, other financial info — these stay with Apple)
- Location (precise or coarse)
- Sensitive Info (race, sexual orientation, religion, politics, etc.)
- Contacts
- Photo Library content — Lumi does not request access to your Photos library. If you choose to import an image via Apple's PhotosPicker (a secure system picker that runs in a separate process), only the images you explicitly tap are handed to Lumi; we cannot see your Photos library at large. Imported images stay on your device in the App sandbox, exactly like camera scans.
- User Content — your scans, OCR text, and PDF exports stay on your device and are never transmitted
- Browsing History
- Search History
- Identifiers — Device ID (IDFA or similar advertising identifier)
- Usage Data — Product Interaction, Advertising Data, Other Usage Data
4. App Tracking Transparency (ATT)
Apple's App Tracking Transparency framework requires apps to request user permission before tracking them across other apps and websites owned by different companies.
Lumi does not track you across other apps or websites. Because we do not engage in cross-app tracking, we do not present the ATT permission prompt. We do not access or use your Identifier for Advertisers (IDFA), and we do not share any data with advertisers or data brokers.
5. What We Do (and Don't) Receive
What Stays on Your iPhone
The following data is created and stored exclusively on your device, in the App's private sandbox. We do not receive it. It is not backed up to our servers (we have no servers for this).
- Every JPEG image you scan from the camera
- Any image you import via Apple's PhotosPicker (treated identically to a scan)
- The JSON index of your scan sessions (titles, page counts, timestamps)
- OCR text you generate
- PDF files when you export them
- The free-tier scan counter (stored in iOS UserDefaults)
- Your preferences (haptics on/off, default share format)
If iOS iCloud Backup is enabled on your device, iOS may back up the App's sandbox to your personal iCloud account as part of a standard iPhone backup. That backup is encrypted by Apple and accessible only to you. We have no access to it.
What Apple Receives
When you purchase a Premium subscription, Apple processes the transaction. Apple receives the information they normally receive for any in-app purchase — including your Apple ID, payment method, billing address, and the product identifier (lumi_weekly or lumi_yearly). Apple's privacy policy governs that processing.
What RevenueCat Receives
We use RevenueCat to verify subscription receipts and to keep the App in sync with your subscription state across devices. RevenueCat receives:
- An anonymous installation identifier generated by RevenueCat (a string like
$RCAnonymousID:...) that is not linked to your real identity - The Apple receipt for your subscription, which RevenueCat validates with Apple
- The product identifier you purchased and its current status (active, expired, in trial, refunded)
RevenueCat never receives your Apple ID, payment information, name, email, phone number, or any of your scans.
What Our Servers Receive
Nothing. Lumi does not call any server we operate. We do not run a backend for this App.
6. Camera and Scan Content
Lumi uses Apple's AVCaptureSession to stream camera frames in real time. Each frame is processed in-memory by Apple's Vision framework to detect document edges, and Apple's Core Image framework to perform perspective correction (dewarp).
- The camera stream is never recorded as a video file.
- Individual frames are never written to disk, except for the final JPEG that is created when the App auto-captures a stable document or you tap the manual shutter button.
- That final JPEG is saved into the App's private sandbox on your iPhone — it does not appear in your Photos library unless you explicitly share it there.
- No frame, no preview image, and no JPEG ever leaves your device through any network call we make.
The camera permission you grant on first launch (NSCameraUsageDescription) is the only permission Lumi needs to do its job.
Importing Images from Your Photos
Lumi includes a button in the bottom toolbar that lets you import an existing image — for example, to convert a screenshot or an old photo of a receipt into a PDF. This uses Apple's PhotosPicker, which is a secure system picker that runs in a separate process. The picker hands Lumi only the images you explicitly tap; Lumi does not get access to your Photos library as a whole, and we therefore do not request the standard photo-library permission (NSPhotoLibraryUsageDescription).
Once an image reaches Lumi via the picker, it is treated exactly like a camera scan: optional auto-dewarp via Vision and Core Image, saved as JPEG inside the App's sandbox. Nothing about the imported image is transmitted off your device.
7. OCR Text Recognition
Same on-device privacy guarantee applies to imported images and camera scans alike.
Premium subscribers can extract text from any scan. OCR runs entirely on your iPhone using Apple's VNRecognizeTextRequest API. The recognized text is stored alongside the corresponding scan, also on your device. No text and no image is sent to any server during OCR. This applies equally to printed text, handwriting, and any other content you scan.
8. Legal Basis for Processing (GDPR)
If you are in the European Union, United Kingdom, or another jurisdiction with comparable law, we process the very limited data we receive under the following legal bases:
- Performance of a contract (Art. 6(1)(b) GDPR) — processing necessary to provide the App and fulfill purchases (anonymous installation ID for RevenueCat, purchase data).
- Legitimate interests (Art. 6(1)(f) GDPR) — processing for App stability and fraud prevention, balanced against your rights and freedoms.
- Legal obligation (Art. 6(1)(c) GDPR) — retention of purchase records for tax and accounting.
9. Third-Party Services
The App's external surface is intentionally minimal. The only two parties that ever receive data are listed here.
Apple
Purpose: App Store distribution, StoreKit billing, system services (Vision framework, Core Image, AVCaptureSession run on-device via Apple's frameworks but do not communicate with Apple's servers about your content). Apple processes all payments directly; we never see your payment instrument.
Privacy policy: https://www.apple.com/legal/privacy/
RevenueCat
Purpose: subscription receipt validation and entitlement sync. Data: anonymous installation ID, Apple receipt, subscription state. Operator: RevenueCat, Inc.
Privacy policy: https://www.revenuecat.com/privacy
That's the complete list. There is no analytics SDK, no AI provider, no crash reporting SDK, no advertising network, no usage tracking, and no account database.
10. Data Retention
- Scans, OCR text, exported PDFs: stored on your device until you delete them in the App or uninstall the App. We hold no copy.
- Free-tier counter and preferences: stored on your device. Removed when you uninstall (unless restored via iOS backup).
- Anonymous installation ID, subscription state at RevenueCat: retained while your installation is active. Deleted on request (see Section 12).
- Subscription records at Apple: governed by Apple's policies and applicable tax/accounting law (typically up to 7 years).
11. Your Rights
Depending on where you live, you may have rights regarding your personal data, including:
- Right of access — to ask what data we hold about you
- Right to rectification — to correct inaccurate data
- Right to erasure — to delete your data (see Section 12)
- Right to restrict processing — to limit how we use your data
- Right to data portability — to receive your data in a portable format
- Right to object — to object to certain processing
- Right to withdraw consent — for processing based on consent
- Right to lodge a complaint — with your local data protection authority
Because the only data we have about you is the anonymous RevenueCat installation ID and your subscription status, in practice most rights can be exercised simply by emailing us with the details below, or by deleting the App.
12. Deleting Your Data
To delete your scans and on-device preferences, uninstall the App from your iPhone. iOS will remove the App's sandbox, including all scans, OCR text, PDFs, and preferences. This action is irreversible.
To request deletion of any data RevenueCat holds about your installation, email [email protected] with the subject "Lumi — Data Deletion Request". We will forward the request to RevenueCat and confirm completion within 7 business days. Note: doing so may make it harder to restore your subscription on future installs.
13. Children's Privacy
The App is not directed to children under 13. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided us with personal information, please contact us and we will take steps to delete it.
14. International Data Transfers
RevenueCat is based in the United States and may process data in the U.S. and other countries. For users in the EU, UK, or Switzerland, RevenueCat relies on Standard Contractual Clauses (SCCs) as the lawful mechanism for data transfers. See RevenueCat's privacy policy for details.
15. Security
All data processed by the App stays inside the iOS app sandbox, which is sandboxed and encrypted by iOS. Network calls to Apple's StoreKit and RevenueCat use TLS. We follow industry best practices, but no transmission or storage system is perfectly secure. Please keep your iPhone passcode strong and enable Face ID / Touch ID to keep your device-local scans private.
16. Changes to This Policy
We may update this Policy from time to time. When we make material changes, we will notify you via in-app message or update the "Effective date" at the top. Continued use of the App after changes are posted constitutes acceptance of the revised Policy.
17. Contact Us
If you have any questions about this Privacy Policy or our data practices, please email us:
Email: [email protected]
Subject: Lumi — Privacy Inquiry
Publisher: TRY2APP LTD