LUMMI

Privacy Policy

Last updated: September 15, 2026

Lummi is a personal journal for recording small moments of joy. This policy explains what happens to your data when you use it, who is responsible for it, and what rights you have over it.

The short version: Lummi does not collect, transmit, or have access to your journal entries. Everything stays on your device, or — if you turn on iCloud sync — in your own private iCloud account, which we cannot see, read, or export.

Scope: This policy applies only to the official Lummi app (App Store ID: 6811688422), built from the source at github.com/ekomarova/Lummi-iOS. Any other build, fork, or listing — regardless of the developer name shown — is not covered by this policy, and the party responsible for that build is solely liable for its own data handling and privacy disclosures.

1. Who is responsible for this app

AppLummi
DeveloperEvseniia Komarova, independent developer
Contactgithub.com/ekomarova/Lummi-iOS/issues

For the purposes of applicable data protection law, the developer above is the party responsible for the decisions made about Lummi's design — including the decision to store data locally and, optionally, in your own private iCloud account rather than on any server we operate.

2. What data Lummi processes

Your entries (the text you write and the date) are stored locally on your device using Apple's on-device storage framework. We do not operate any server that Lummi communicates with, so we never receive, view, or process this content ourselves.

Lummi does not ask for your name, email, or any account credentials, and does not generate an advertising identifier.

3. iCloud sync and Apple's role

If you enable sync in Settings, your entries are copied to your private iCloud database using Apple's CloudKit framework, so they can appear on your other devices signed into the same Apple ID. This is:

In this arrangement, Apple operates the iCloud infrastructure that stores your encrypted data on your behalf, under the terms of your own Apple ID and Apple's own privacy documentation. We do not instruct Apple on how to use this data beyond the standard CloudKit private-database mechanism, and we have no visibility into it. For details on how Apple itself handles iCloud data, see Apple's Privacy Policy.

4. Legal basis for processing

Where data protection law requires a stated legal basis (for example, under the EU/UK GDPR), the basis for any processing that occurs is your own action of enabling iCloud sync — an affirmative, opt-in choice you make and can reverse at any time. We do not process your journal content for any other purpose, such as advertising or analytics, so no other legal basis is relied upon.

5. International data transfers

Because your data, when synced, lives in your private iCloud account rather than on infrastructure we control, any international transfer of that data is governed by Apple's own iCloud data residency and transfer practices, not by us. We do not separately transfer your data anywhere.

6. Data retention and deletion

Entries are kept for as long as you keep them in the app. You're always in full control:

We hold no copy of your data ourselves, so there is nothing further for us to retain or delete on our end once you've removed it from your own device and iCloud account.

7. Your rights (EEA / UK — GDPR)

If you are located in the European Economic Area or the United Kingdom, data protection law gives you the following rights in relation to your data. Because we do not hold or process any copy of your journal content ourselves, most of these rights are exercised directly within the app or your device's iCloud settings, as described in Section 6:

  1. Access — you already have full, direct access to your data at all times within the app.
  2. Rectification — you can edit any entry directly in the app.
  3. Erasure — you can delete any entry, or all data, as described in Section 6.
  4. Restriction of processing — turning off iCloud sync stops any further processing beyond on-device storage.
  5. Data portability — since data is stored locally and in your own iCloud account, it is already under your direct control and not siloed in a system only we can export from.
  6. Objection — you may object to sync at any time simply by disabling it.
  7. Not to be subject to automated decision-making — Lummi does not perform any automated decision-making or profiling.

If you have a question we haven't answered here, you can reach us at the contact below.

8. Children's privacy

Lummi is not directed at children and does not knowingly collect any information from anyone, including children under 13 (as referenced by the U.S. Children's Online Privacy Protection Act, COPPA), since it does not collect information at all.

9. Security

Your entries are protected by the security of your own device (passcode, Face ID/Touch ID) and, if sync is enabled, by CloudKit's built-in encryption. We do not maintain any servers or databases of our own, which removes an entire category of risk — there is no central store of user data for us to secure or that could be breached on our end.

10. Third parties

The only third party involved in Lummi's operation is Apple Inc., acting as the provider of the on-device storage framework and, if you enable it, the iCloud/CloudKit infrastructure described in Section 3. Lummi does not integrate any analytics, advertising, or crash-reporting SDKs, and does not share data with any other company.

11. Cookies and tracking

Lummi is a native app, not a website, and does not use cookies. It does not use the AdSupport framework, does not generate or read an advertising identifier (IDFA), and does not track you across apps or websites owned by other companies.

12. Changes to this policy

If this policy ever changes — for example, if a future version of Lummi adds a feature that touches data handling — this page will be updated, and the date at the top will reflect the change. Material changes will also be reflected in the app's release notes.

13. Contact

Questions about this policy or how Lummi handles data can be raised by opening an issue at github.com/ekomarova/Lummi-iOS/issues. Since Lummi does not store or have access to any of your data, most privacy questions can be answered directly from this policy — but we're happy to clarify anything that isn't covered.