Privacy Policy

1. Data controller and scope

LUMA is a health and family-care organization service. The data controller is ROGERIO WERNECK COSTA RODRIGUES FILHO, Brazilian company registry (CNPJ) 44.320.052/0001-10, located at SQN 311 Bloco D, nº 509, Asa Norte, Brasília/DF, CEP 70757-040. For privacy requests, contact help@myluma.com.br.

This policy applies to the LUMA app, myluma.life, the waitlist, support, and related communications. It covers patients, caregivers, invited people, and website visitors.

2. Data we may process

We process data related to the features you use:

Payments and trials: when purchasing is available, Stripe (web) or Google Play (Android) processes payment. LUMA does not receive or store full card numbers or security codes. It retains provider references, status, amounts and validity needed to authorize access, reconcile transactions and handle requests. A private record of the normalized email and first-use date identifies previous trial use, including after deletion; it is not used for advertising or exposed to other users.

• Account and profile: name, email, phone, language, time zone, LUMA ID, profile photo, and authentication data.
• Health and care routine: medication, dosage, form, instructions, schedule, treatment dates, prescriber, reason, notes, inventory, intake confirmations, and adherence history.
• Family and sharing: dependents, invitations, patient-caregiver relationships, roles, permissions, and shared-care actions.
• Communications: notification preferences and tokens, reminders, emails, WhatsApp messages, delivery confirmations, and replies sent to LUMA flows.
• AI-assisted features, when used: submitted text or file, context required to answer, generated output, model version, and technical quality and safety records.
• Technical and usage data: installation and session IDs, app version, device, operating system, IP address, browser agent, screens and controls used, timestamps, performance, errors, and diagnostics. The client blocks known sensitive fields such as passwords, tokens, and medication names from telemetry.
• Website and waitlist: email, interest profile, campaign parameters and, after consent, analytics cookie data.
• Support and security: support content, authentication and audit records, abuse prevention, and evidence needed to investigate incidents.

3. Why we use data

• Create and secure accounts and deliver requested features.
• Organize medication, schedules, inventory, reminders, and adherence records.
• Enable shared care only between linked people and within granted permissions.
• Send transactional communications and reminders through the app, push, email, or WhatsApp.
• Process AI requests and assess response quality and safety.
• Provide support, prevent fraud and abuse, and maintain security, availability, auditability, and operations.
• Measure use, fix errors, and improve the product using technical and, where possible, aggregated or anonymized data.
• Manage the waitlist and launch communications with consent.
• Comply with legal duties and valid authority requests.
• Offer analytics and campaign attribution are optional and start disabled. When authorized, they record offer views and plan selections without clinical content or free text. You may withdraw this choice; doing so does not disable records strictly necessary for security, access rights and payments.

4. Legal bases and sensitive data

Depending on the purpose, we rely on contract performance and pre-contract steps, consent, legal obligations, the exercise of legal rights, protection of life or physical safety, fraud prevention and security, and legitimate interests where permitted after considering individual rights.

Medication, treatment, and adherence information may be sensitive health data. Where Brazilian law requires it, we use specific and prominent consent or another lawful basis applicable to sensitive data. Withdrawing consent may prevent features that require that data.

5. Sharing and service providers

We do not sell personal data. We share the minimum necessary with providers supporting hosting, databases, authentication, storage, push notifications, transactional email, WhatsApp, audience analytics, and AI when the feature is used.

Services currently planned or integrated include Supabase, Expo and Firebase, Resend, LUMA's WhatsApp provider, Netlify, and AI model providers. Providers may change as the system evolves; we require limited purposes and safeguards appropriate to the data.

Data may also be shown to a patient or caregiver under an accepted invitation and valid permission. We may disclose data to authorities or third parties when required by law, to protect rights, or to comply with a valid order.

6. International transfers

Some providers may process data outside Brazil. We use mechanisms allowed by Brazilian law and contractual and technical measures designed to maintain protection consistent with this policy.

7. Family sharing and third-party data

Only add another person's information when you have authorization or another lawful basis. Care relationships use roles and permissions and can be revoked. Each participant must keep accessed information confidential and use it only for authorized care.

8. Automation and artificial intelligence

LUMA may use automation and AI to organize information, interpret requests, and assist interactions. These tools can be wrong and do not diagnose, prescribe, or make medical decisions. Confirm treatment decisions with a qualified professional.

You may request information about criteria used in automated decisions affecting your interests and ask for review where applicable under Brazilian law.

9. Retention

We retain identifiable data only as needed to provide the service, meet stated purposes, satisfy legal and security duties, and exercise legal rights. Technical activity events are scheduled for retention for up to 90 days; technical audit events for up to one year; and temporary public medication-list PDF links expire after three hours.

Waitlist data remains until launch, consent withdrawal, or it is no longer needed. Other periods depend on the record and legal obligations. At the end of the applicable period, data is deleted or anonymized.

Prior-trial records and minimum financial data serve separate purposes. Retention must be limited to a demonstrated need or applicable duty, with restricted access and a review of necessity; unlimited retention or advertising reuse is not authorized. You may request information, object or request deletion through the privacy contact, subject to lawful retention exceptions.

10. Account deletion

Account deletion is available inside the LUMA app itself, under Profile → Security, in the “Request account deletion” option. The request can also be started at myluma.life/excluir-conta. To prevent third-party requests, the person must enter the LUMA ID displayed in the profile, select a reason, and validate a unique link sent to the registered email. The request is subject to administrative control.

After email confirmation, the account becomes inactive and sign-in is blocked. You can cancel the deletion request using the secure link before 29 days have elapsed from confirmation. Processing begins at that deadline and deletion will be completed within 30 days. Account deletion differs from stopping renewal alone: account access is blocked. LUMA requests cancellation of future renewals with the provider before completing identity removal; a failure requires reconciliation and support assistance.

Removal deletes the identity, authentication account and personal data associated with use. Minimum records needed for payment reconciliation, legal duties and preventing repeated trials may remain separately with restricted access. These records are not represented as anonymous data. Records no longer needed must be deleted or effectively anonymized.

11. Security

We use risk-based safeguards including authentication, access rules, private storage, encryption in transit, administrative segregation, limited tokens, and operation logs. No system is infallible; if a relevant incident occurs, we will contain it and provide required notices.

Never send a password, access code, or secret to support. Contact help@myluma.com.br immediately if you suspect misuse.

12. Children and teenagers

Creating and controlling a LUMA account is limited to people aged 18 or older. A minor's information may only be added as a dependent managed by a responsible adult, in the minor's best interests and with required authorization. Minors must not create or operate their own account in this version.

13. Cookies and similar technologies

The website may use strictly necessary storage for operation and preferences. Audience and analytics cookies load only after acceptance in the cookie notice. You may decline non-essential cookies and continue browsing. In the app, technical identifiers and tokens support sessions, security, notifications, and diagnostics as described above.

14. Your rights

Under Brazilian data protection law, you may request, as applicable:

• confirmation and access; correction of incomplete, inaccurate, or outdated data;
• anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data;
• portability where regulated and applicable; information about sharing and consent choices;
• withdrawal of consent, deletion of consent-based data, and review of automated decisions;
• objection to unlawful processing and a petition to Brazil's Data Protection Authority.

15. Contact and changes

To exercise rights, report an incident, or ask a question, email help@myluma.com.br. We may request reasonable information to verify your identity and protect the account.

We may update this policy as the product, law, or providers change. The current version and update date will remain on this page, and material changes will be communicated through available channels.