1. Introduction

Lumio Copilot is a personal assistant for iPhone, made by Lumo Studios LLC, a California limited liability company (“Lumo Studios,” “we,” “us,” or “our”). This Privacy Policy describes how we handle information in connection with the Lumio Copilot iOS application (the “App”) and the marketing website at lumio.lumo-studios.com (the “Site”). This policy is specific to the Lumio Copilot product. Other products and services offered by Lumo Studios LLC are governed by their own policies.

Lumio Copilot is designed to run on-device by default. The assistant's intelligence, memory, and indexed content live on your iPhone. We have intentionally built the product so that we cannot see your assistant data, even if we wanted to.

2. Plain-language summary

This summary is written in plain English to give you the gist. The full sections below are the legally operative text.

We do not collect your assistant data.
Calendar, mail, reminders, notes, photos, contacts — all read locally on your iPhone.
Your memory index lives on your phone.
No third-party analytics. No advertising SDKs. No behavioral profiling.
Crash reports scrub user content before being sent.
Cloud features (e.g., web search) are opt-in per feature; when on, your provider sees the query, not us.
Your data is never used to train models.

3. Data categories

3.1 Data accessed on-device only (not transmitted to us)

With your permission, the App reads the following on your iPhone in order to assist you. This data is processed locally and is not transmitted to Lumo Studios LLC servers:

Calendar events
Reminders
Mail — Apple Mail at v1.0; Gmail and Outlook integrations are deferred to v1.1
Notes
Photos metadata (e.g., dates, locations) when granted
Contacts
Focus state
Health (read-only, opt-in)
Location (when granted)

You control each permission through standard iOS permission prompts and Settings. Revoking a permission stops the App from accessing that category going forward.

3.2 Data we do not collect

For clarity, the following are not collected by us:

Voice recordings
Dictated text
Calendar, mail, or reminder content
Draft replies
Memory contents
Search queries (unless you opt in to a cloud feature — see Section 4)
Advertising identifiers (e.g., IDFA)
Behavioral profile or cross-app activity

3.3 Data we receive only if you contact us

If you email us at lumio@lumo-studios.com, we receive your email address, the body of your message, and any attachments or details you choose to include. We retain support correspondence for as long as needed to assist you and to comply with legal obligations.

3.4 Crash report data

To improve stability, the App may submit crash reports through Apple's standard crash reporting infrastructure. Crash reports include anonymized stack frames, OS version, device model, and App version. User-generated content (memory entries, drafts, queries, voice, transcripts) is stripped before submission. You can disable crash reporting in iOS Settings under Privacy & Security → Analytics & Improvements.

4. Cloud features (opt-in only)

Some features can optionally route a request to a third-party service (for example, a web-search query). These features are off by default and must be enabled per feature in App Settings.

When you enable a cloud feature:

The third-party processor receives only the data necessary to fulfill that specific request.
We do not log, store, or proxy the request or response on our servers.
Each cloud-touched response is visibly indicated in the App so you can tell what left your device.
The third party's own privacy policy and terms govern their handling of the request.

Default state: all cloud features are off. You can disable any cloud feature at any time.

5. Apple's role

The App is distributed exclusively through the Apple App Store. Apple processes any payment (note: at v1.0, the App is free and has no in-app purchases), provides crash reporting infrastructure, and may collect aggregated install and usage metrics under its own policies, which we do not control.

For information about how Apple handles your data, please review Apple's Privacy Policy.

6. No tracking, no advertising

Lumio Copilot contains no advertising or tracking software. Specifically, the App does not include:

Google Analytics, Firebase Analytics, or Google Ads SDKs
Mixpanel, Amplitude, Heap, or PostHog
Segment or any customer-data platform SDK
Facebook / Meta SDK
AppsFlyer, Adjust, Branch, or other attribution SDKs
Any third-party advertising network

We do not participate in cross-app or cross-site tracking. We do not sell, rent, or share your personal information for advertising or marketing purposes.

7. Children's privacy

Lumio Copilot is not directed at children under 13, and we do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe your child has provided personal information to us, please contact us at lumio@lumo-studios.com and we will take steps to delete it.

8. Your rights (GDPR / CCPA / general)

Because the App stores assistant data locally on your iPhone, you already have direct access to and control over the substantive data we would otherwise be obligated to give you under data protection laws. You can view, edit, export, or delete your memory and other local data from in-App Settings at any time.

With respect to information you have shared with us through support correspondence (which is functionally the only personal information we hold about you), you have the right to request:

Access — a copy of the personal information we hold about you.
Correction — correction of inaccurate or incomplete information.
Deletion — deletion of your personal information, subject to legal retention requirements.
Portability / export — a copy in a commonly used format.
Objection / restriction — objection to or restriction of certain processing.

To exercise these rights, email lumio@lumo-studios.com. We may need to verify your identity before responding.

EU/UK users: You have the right to lodge a complaint with a supervisory authority in your country of residence.

California residents (CCPA / CPRA): California residents have specific rights under the California Consumer Privacy Act, including rights to know, delete, correct, and limit the use of sensitive personal information. We do not sell or share personal information for cross-context behavioral advertising. We do not use sensitive personal information for any purpose beyond providing the App.

9. International users & data location

Lumo Studios LLC is a California, USA company. Local assistant data lives on your iPhone in the country where you use it. If you opt in to a cloud feature, the corresponding request may be routed through US-based or other third-party providers and processed in those jurisdictions.

EU/UK users are responsible for ensuring they have a lawful basis under the GDPR or UK GDPR for any opt-in cloud feature they choose to enable.

10. Security

Local data lives in the iOS application sandbox and is protected by iOS data-protection mechanisms tied to your device passcode or biometric authentication. If you enable iCloud backup of the App's data, that backup is encrypted by Apple under Apple's standard practices.

We do not operate servers that store user assistant data. We do, however, take reasonable administrative, technical, and organizational measures to protect any limited information you send us through support correspondence. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

11. Memory & data control

The memory index is yours. From in-App Settings you can:

View every memory entry the assistant holds.
Edit any entry directly.
Export your memory in plain text or JSON.
Delete individual entries or wipe the entire memory.

Deletion is immediate and irreversible. Uninstalling the App removes all local data, including the memory index, indexed content, and any cached results.

12. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date at the top of this page. Material changes will also be communicated via in-App notice. Your continued use of the App after a change indicates your acceptance of the revised policy.

13. Contact

For questions about this Privacy Policy or our handling of your information, contact:

Lumo Studios LLC
Email: lumio@lumo-studios.com
Mailing address: California, United States (specific address available on request)