Privacy Policy

a) When Visiting Our Website (Server Log Files)

When you access our website, our hosting provider automatically collects and stores information in server log files, which your browser transmits to us. This includes:

• Browser type and version
• Operating system used
• Referrer URL (the previously visited page)
• Hostname of the accessing computer
• Time of the server request
• IP address and request metadata (which can be personal data)

Request metadata can be correlated with security and error events to investigate incidents. The basis for this data processing is our legitimate interest (Art. 6(1)(f) GDPR) in ensuring the security, stability, and error-free operation of our website.

b) Cookies

Our website uses cookies. Cookies are small text files that are stored on your device.

• Essential Cookies: We use technically necessary cookies to make our website user-friendly and functional (e.g., for login sessions). The legal basis is our legitimate interest (Art. 6(1)(f) GDPR) and, where applicable, § 25(2) TDDDG.
• Non-Essential Cookies: Other cookies (e.g., for analytics, marketing) are only used with your explicit consent, which we obtain via a cookie consent banner. The legal basis for this is your consent (Art. 6(1)(a) GDPR and § 25(1) TDDDG). You can withdraw your consent at any time through the cookie settings on our website.

c) Contacting Us (Email or Contact Form)

If you contact us via email or a contact form, the information you provide (e.g., name, email address, your message) will be stored by us to process your request and for any follow-up questions. We process this data based on Art. 6(1)(b) GDPR if your request is related to the fulfillment of a contract or for pre-contractual measures. In all other cases, the processing is based on our legitimate interest (Art. 6(1)(f) GDPR) in effectively handling the inquiries addressed to us.

d) Account Registration and Use of Services

To use our online programs or the LuminaOS app, you must register an account. We collect data such as your name, email address, and a password. This data is necessary to provide and manage your account and deliver the services you have purchased. The legal basis is the performance of a contract (Art. 6(1)(b) GDPR).

e) Data Processing within the LuminaOS Application

The LuminaOS web and mobile applications are designed for personal growth and involve the processing of highly personal data you provide. This includes:

• Profile Information: Your name and email address.
• User-Generated Content: Goals, journal entries, daily notes, habit tracking data, reflections, OBS categories, Prime Time scheduling data, and other text, images, audio, or files you input into the app.
• People, Team, and Community Data: People/contact records, relationship notes, accountability-group participation, team or community content, and other collaboration data you choose to create or share.
• AI Coach and AI-Assisted Features: The prompts you enter, the responses generated by AI Coach, and text, audio, images, files, or context you choose to submit for AI-assisted journaling, reflection, coaching, transcription, or extraction features.
• Google Integrations: Data synchronized with Google services that you choose to connect, such as Google Tasks, Google Calendar, Google Contacts / Google People, and Google Docs backup.
• Optional Wearable Integrations: If you explicitly connect a supported wearable provider such as Oura, we process the health and wellness records you authorize the provider to share. Depending on the permissions you grant, this may include sleep, readiness, activity, recovery and stress indicators, oxygen saturation, temperature deviation, heart-rate variability, resting heart rate, respiratory rate, and workout summaries. LuminaOS does not request detailed heart-rate time-series data for the initial Oura integration.
• Export and Backup Data: Data included when you use export, backup, or connected-document features made available in the Services.

We process account and app data to deliver the functions you request (Art. 6(1)(b) GDPR). Security and abuse prevention rely on Art. 6(1)(f) GDPR. Optional analytics rely on consent. Health data requires an additional exception under Art. 9 GDPR, described below; contractual necessity alone does not authorize processing special-category data.

Apple Health / HealthKit and health-data choices

On a supported iPhone, you can choose Apple Health data types and grant HealthKit read permissions. Depending on your selection and available records, these include sleep; heart rate, resting and walking heart rate, heart-rate recovery and variability; breathing rate, blood oxygen, body and wrist temperature, and aerobic fitness; steps, distance, energy, exercise, move and stand time, and flights climbed; height, weight, BMI, body fat, lean mass and waist circumference; workouts and mindfulness sessions.

The app uploads selected records and daily summaries to your LuminaOS account. These include values, units, dates, time zones, source-app and device metadata, and identifiers needed to reconcile duplicates and deletions. We normalize these records into health history, daily summaries and related activity or habit views. HealthKit may include records written by other apps or devices; importing them through Apple Health does not mean you connected that provider directly to LuminaOS.

Synchronization can run when you request it or when the operating system permits background updates. Imported history is stored in LuminaOS, rather than remaining only in Apple Health. Disconnecting can either retain normalized history or delete the imported Apple Health data, according to the option you choose. Both disconnect options clear raw synchronization records; retaining history keeps normalized records and summaries. Neither option deletes your original HealthKit records. Revoking permission in Apple Health stops future reads but does not erase data already imported.

Legal basis and consent: Providing the optional integration uses Art. 6(1)(b) GDPR; processing health data additionally requires your explicit consent under Art. 9(2)(a) GDPR. Device permission controls access to HealthKit; it does not by itself establish explicit consent to every subsequent server-side use. Accepting the Terms or reading this notice is not health-data consent. Consent must cover the specified purposes and can be withdrawn at any time, without affecting processing that was lawful before withdrawal. You can stop synchronization, revoke device permissions, and request deletion at info@bright-minds.io. The rest of LuminaOS remains available without a health connection.

Imported Apple Health records are processed by LuminaOS and its hosting providers for the health and activity features. Records and summaries are account-scoped. Do not assume that text you independently put into an AI prompt, journal, shared activity or connected tool remains outside that feature: it follows that feature's processing rules. Apple Health permission is not permission to use health data for advertising or public-model training.

f) Google API Services User Data

Google sign-in and each Google productivity integration are optional. LuminaOS asks for access only when you start the corresponding connection and uses the resulting Google user data as follows:

• Google account identity: Your email address identifies and displays the Google account connected to a LuminaOS integration.
• Google Calendar: Read-only calendar-list metadata populates and validates the writable-calendar selector. Event access reads, creates, updates, and deletes Prime Time events in the calendar you select. App-created-calendar access lets LuminaOS create and manage its dedicated fallback calendar.
• Google Tasks: Task lists and tasks are read and written to provide user-initiated and background synchronization of titles, notes, due dates, completion state, priority markers, categories, and remote links.
• Google Contacts: Contact data is read only for the import screen. LuminaOS stores only the contacts you explicitly select for import and does not write changes back to Google Contacts.
• Google Drive and Google Docs backup: The limited drive.file permission lets LuminaOS create and update only its app-managed backup folders and documents. LuminaOS does not request general access to all files in your Google Drive.

LuminaOS stores OAuth credentials and the minimum identifiers, mappings, timestamps, and user-selected or synchronized records needed to operate these features. Production data is transmitted over encrypted connections and stored in access-controlled systems with encryption at rest. Google user data is used only to provide or improve the user-facing integration you selected. It is not sold, used for advertising, or used to train generalized or non-personalized AI or machine-learning models.

We do not transfer or disclose Google user data except to infrastructure processors needed to provide the selected feature, for security purposes, when required by law, or with your explicit consent. Human access is prohibited except with your affirmative permission for specific data, when necessary for security, when required by law, or for appropriately aggregated internal operations.

Disconnecting a Google integration removes its stored authorization credentials. Records already imported into LuminaOS and files, tasks, or events already created in Google may remain until you delete them in the relevant service or use the applicable LuminaOS deletion controls. Google user data otherwise follows the account, retention, export, and deletion rules described in this policy.

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

g) AI-Powered Features

Our AI Coach currently uses OpenAI-powered services to provide responses and related AI-assisted functionality. When you use these features, the data you submit, including prompts and any supported text, image, file, audio, or voice content, may be sent to those AI service providers for processing.

• OpenAI processes API content under its applicable business and data-processing terms, rather than the settings of a personal ChatGPT account.
• OpenAI states that API content is not used to train its models by default. Abuse-monitoring and feature-specific retention can still apply; this is not a promise of zero retention.
• AI Coach conversations, tool activity, and related context may be stored in LuminaOS systems so that the service can provide continuity, auditability, and user-controlled memory.
• Where enabled, AI Coach may use OpenAI response-state continuation and optional rich context profiles to improve coaching continuity. The LuminaOS database remains the primary record for user-accessible export and deletion workflows.
• AI Coach Voice Mode may process live microphone audio, final user and assistant transcripts, tool activity, call identifiers, quota metadata, and diagnostic metadata needed to operate the realtime voice session. Raw live voice audio is not intended to be stored as a canonical chat record.
• Composer dictation and reflection features may temporarily process audio recordings, transcripts, OBS category context, timelines, and draft reflection content to produce text, structured reflection updates, or other app content requested by you.
• We urge you not to enter any sensitive personal data (e.g., health information, financial details, government IDs) that you would not want a third party to process.

The legal basis for the requested AI function is Art. 6(1)(b) GDPR. This is not a blanket legal basis for health or other special-category data. Such data requires an applicable Art. 9 GDPR exception; do not submit it without the relevant explicit consent or another applicable legal basis.

Where we offer user controls for AI memory, rich context profiles, or related AI settings, you can adjust those controls in the app settings. Some operational records may remain where required for security, billing, abuse prevention, legal compliance, or deletion-job auditability.

h) Optional ChatGPT and Codex MCP Connection

You can optionally connect your LuminaOS account to ChatGPT or Codex through our MCP integration. Before the connection is approved, the LuminaOS authorization screen identifies the requesting client, lists its requested permissions, and prominently explains the data categories that the connection may process.

• Data categories: Depending on the tool you request, the returned result may contain goals, habits, actions, timelines, daily or weekly reflections, and profile or personalization fields you chose to save, including emotional, spiritual, wellbeing, or health-related context.
• Purpose and minimization: From LuminaOS to OpenAI, only the result needed for the requested tool call is shared so ChatGPT or Codex can show information or carry out the action you requested. The MCP connection does not provide OpenAI with a general copy of your LuminaOS account, database, or full conversation history.
• Recipients: OpenAI processes the requested result to operate ChatGPT or Codex. Bright Minds and our hosting and security processors process the connection data needed to authenticate the request, execute the tool, secure the service, and return the result.
• Oura exclusion: Imported Oura wearable data remains account-scoped in LuminaOS and is not returned through the ChatGPT or Codex MCP connection.
• Retention and controls: The source records in LuminaOS continue to follow the retention rules in section 5. OpenAI may retain tool results within its service under your ChatGPT or Codex plan, workspace settings, data controls, and OpenAI policies; Bright Minds does not control those copies. You can disconnect or remove the LuminaOS app in ChatGPT or Codex to revoke future tool access, use LuminaOS settings to edit or delete source records or request account deletion, and use OpenAI's chat and data controls for results already shared. Revocation does not undo actions already completed or automatically erase results already included in the OpenAI service.

This optional processing is based on your explicit authorization of the connection and the performance of the service you request. Where a profile field contains data that is treated as sensitive or special-category data under applicable law, the authorization screen provides the disclosure before you choose whether to allow the connection.

i) Launch Campaign, Promotions, and Verification Emails

If you submit a LuminaOS launch campaign or promotional request, we process the data required to review and administer that request. This may include your email address, optional phone number, WhatsApp/mobile campaign group preference, confirmation statements, selected enrollment mode, source URL, referrer, UTM campaign parameters, IP address, user agent, verification status, grant status, and related admin review notes.

For automatic enrollment, we send a verification email and store only a hashed verification token with an expiry timestamp. Premium access is not activated through the public form alone; it is activated only after email verification or manual admin review, depending on the option you choose.

The legal basis is pre-contractual or contractual processing (Art. 6(1)(b) GDPR) and our legitimate interest (Art. 6(1)(f) GDPR) in fraud prevention, campaign administration, and abuse monitoring.

j) Newsletter

If you subscribe to our newsletter, we require your email address. We use a "double opt-in" procedure to verify that you are the owner of the email address and consent to receiving the newsletter. You can revoke your consent and unsubscribe from the newsletter at any time, for example, via the "unsubscribe" link in the newsletter. The data processing is based on your consent (Art. 6(1)(a) GDPR).

In-App Account Deletion

You can start the account-removal flow in the app settings:

https://luminaos.app/settings/app

To do so, open the settings page and click the account deletion button. Once confirmed, your access is removed, active login identifiers are disabled or tombstoned, and the old account is not restored if you later sign up again with the same email. In the web app, this is currently an archive-first deletion flow. In supported mobile self-service flows, deletion may start a backend-owned permanent deletion job that deletes, anonymizes, or restricts data depending on ownership conflicts and legal retention obligations. Archiving an account is not permanent erasure of its content. To request permanent erasure, use the email route below. Account removal does not by itself cancel a paid subscription; use the separate cancellation control.

Deletion Request via Email

If you prefer, you can also request deletion by email.

Verification and Processing

• We may ask for additional information to verify that the request is made by the account holder.
• We respond without undue delay and normally within one month. If the GDPR permits an extension because of complexity or the number of requests, we inform you within that first month, explain why, and state the extended period (up to two additional months).
• If certain data must be retained due to legal obligations, we will restrict processing of that data and retain it only for the required period.

Mobile App Local Storage and Offline Use

On supported mobile devices, the LuminaOS app may store certain data locally on your device to support secure sign-in, offline use, draft recovery, queued synchronization, and backup safety mechanisms.

• Authentication or session-related credentials may be stored in secure device storage such as the iOS Keychain or Android secure storage facilities.
• Drafts, pending operations, offline metadata, and local backup files may be stored temporarily on device and synchronized or cleared later depending on your actions and app state.
• Where you use connected contact, journaling, or backup features, local caching may occur to support performance, recovery, and offline continuity.