Privacy Policy – LUMA

Privacy Policy – LUMAEffective date: 4 August 2026LUMA helps international students prepare for studying in the UK. This policy explains
what personal data we collect, why, and the control you have over it.We are the data controller for the data described here.### What we collectAccount — your first name, last name, email address, and password. If you sign in
with Apple or Google, the identifier and email they return.Age — your date of birth, to confirm you are old enough to use LUMA. If you are
under 18, we also collect a parent or guardian's name and email to record their consent.Your student profile — nationality, country of prior education, first language,
English level and qualifications, institutions of interest, programme, subject, level,
intended start, offer status, funding and sponsor, arrival date, accommodation and visa
status, whether you have a UK bank account, SIM or GP, interests, dietary requirements,
faith, and your self-rated confidence.Some of this is special category data under UK GDPR — your faith, dietary requirements,
health-related answers, and immigration status. We collect it only with your explicit
consent, and you can leave any of these blank.Check-ins — your answers to wellbeing and progress check-ins, including any comments
you write.Conversations — your chats with your personal assistant are private to your account.
Conversations with university and course agents can be reviewed by the team that runs
that agent, to improve its answers.Memory — facts and extracts LUMA keeps from your profile and conversations so it
doesn't ask you the same thing twice.Documents — files you upload to your wallet, such as your passport, CAS, visa or BRP,
and offer letter. Your assistant can read these when answering your questions.Map pin — if you choose to appear on the student map, your pin shows your country,
university, programme and start term. Your name, age, home town and contact handle are
each separately optional and stay on your device unless you switch them on.Reminders and notifications — reminders you create, your notification preferences,
and a push token for your device.Usage — which screens you view and for how long, app sessions, a few feature actions,
your platform and app version. Nothing you type is included, and identifiers are stripped
from screen addresses.Diagnostics — the app keeps a short log of recent errors on your device. It is only
sent to us if you file a feedback report and tick the box to attach it.Device permissions — Face ID, Touch ID or fingerprint to unlock the app (this never
leaves your device); location for the campus map; camera and photos only for attaching a
screenshot to a bug report.We do not track you across other companies' apps or websites, and we do not run
advertising.Why we use itTo create and run your account and give you tailored pre-arrival guidance (to perform our
contract with you); to provide wellbeing support, share data with your university or
sponsor if you agree, show your map pin, and send notifications (with your consent); to
improve the app and keep it secure (our legitimate interests). Special category data is
processed only on your explicit consent.You can withdraw consent at any time. This does not affect processing that already
happened.Who we share it withWe do not sell or rent your personal data.Your university — if you agree to institutional data sharing, or connect a university
email, your institution can see certain engagement and wellbeing data. This is optional;
you can decline, and we ask again when you connect.Your sponsor — if you are sponsored, we ask you separately, and only when it becomes
relevant, before sharing any progress information.We may also disclose data where the law requires it.How long we keep itWe keep your data for as long as your account exists. When you delete your account, we
erase it — including your profile, memory, conversations, documents and map pin. Usage
data is reported only in aggregate.Your rightsYou can ask us to give you a copy of your data, correct it, delete it, restrict or object
to how we use it, or provide it in a portable form. You can also withdraw any consent.Much of this you can do yourself in the app: edit your profile, view, edit or wipe your
memory, remove your map pin, change notification preferences, and delete your account.For anything else, contact us at [email protected]. We respond within one month. If you
are unhappy with our response, you can complain to the Information Commissioner's Office.LUMA's assistant gives guidance, not decisions. Nothing in the app decides your
application, place or funding.Deleting your accountGo to Settings, then Account, then Delete account. This permanently erases your LUMA
account and all associated data, including your profile, memory, conversations, documents
and map pin. It cannot be undone.If you can no longer sign in, email [email protected] from the address on your account
and we will delete it for you.SecuritySensitive data on your device is stored in the iOS Keychain or Android Keystore. All
traffic to our servers uses TLS. You can turn on a biometric app lock so Face ID, Touch ID
or a fingerprint is needed to open the app. Access to production data within our team is
limited to those who need it.Under 18sLUMA is for students aged 16 and over. If you are under 18, we require a parent or
guardian's consent before your account is created. We do not knowingly collect data from
children under 13; if you believe we have, contact us and we will delete it.ChangesIf we make a material change we will post it here with a new effective date and ask you to
review and accept the updated notice in the app.Contact[email protected]