Privacy Policy

LumaraRx (“Lumara,” “we,” “us,” or “our”) is operated by Astra Software Labs LLP. This Privacy Policy explains what information we collect, how we use, share, and protect it, and the choices you have. It applies to the Lumara mobile app, the Lumara clinic console, and the website at lumararx.com (together, the “Service”).

If you live in Washington, Nevada, or Connecticut, or another place with a consumer health data law, please also read our Consumer Health Data Privacy Policy, which explains how we handle health-related information under those laws.

1. Who we are

The Service is provided by Astra Software Labs LLP, a New Jersey limited liability partnership, which decides how and why the personal information described here is processed (it is the “controller” or “business”). Our mailing address is Astra Software Labs LLP (a New Jersey limited liability partnership), mailing address 1280 Lexington Ave FRNT 2, New York, NY 10028, United States. For questions about this policy or your data, email support@lumararx.com.

2. How HIPAA applies to Lumara

When you use Lumara on your own as a consumer, Lumara is not a healthcare provider or health plan, and HIPAA does not govern your information. Consumer privacy and consumer health data laws do, and this policy explains how we follow them.

Some clinics that use Lumara may be HIPAA “covered entities.” When Lumara provides services to a covered-entity clinic under a Business Associate Agreement with that clinic, Lumara acts as the clinic’s business associate for the protected health information it handles for the clinic, and that agreement governs that information alongside this policy. Whether such an agreement is in place is a matter between Lumara and each clinic; this policy does not state that one exists for any particular clinic.

Sharing a progress report with a clinic through Lumara (see “Sharing your progress report with a clinic” below) is something you direct as a consumer, and it is covered by this policy. It does not connect you to that clinic.

3. Where this policy applies

• Lumara mobile app — where you log medications, doses, schedules, lab values, symptoms, check-ins, and related information.
• Lumara clinic console — used by clinic staff to view information that patients have authorized, to manage protocols, and to open progress reports patients chose to share with them.
• Website (lumararx.com) — an informational site that does not ask for health information. It uses analytics and, on public pages, one advertising conversion tag, both only with your permission (see “Cookies, analytics, and advertising measurement”).

4. Key terms (plain English)

• Health information means information about your health that you enter or connect — medications, doses and schedules, injection sites, vials, symptoms, check-ins, lab values, weight, cycle information, notes, and data read from Apple Health or Health Connect. Some laws also treat the fact that a person uses a health app as health data; our Consumer Health Data Privacy Policy explains how we handle that.
• Service provider means a company that processes information on our behalf and under our instructions, under a contract that limits what it may do with the information.
• Third party means a company that receives information from us and uses it under its own terms — for example, an advertising platform.
• De-identified data means information that has been stripped of identifiers so that it cannot reasonably be linked to you. We do not try to re-identify it.

5. Information we collect

Information you give us

• Account information (required) — your email address, and if you sign in with Apple or Google, the identifier and email address they give us. We use it to create and secure your account and to send service messages. We never see your Apple or Google password.
• Profile information (optional) — a display name, date of birth, gender, goals, and similar details you choose to add.
• Health information (optional) — medications and supplements, doses, schedules, reminders, injection sites, vials, lab values, symptoms, daily check-ins (for example mood, energy, and sleep), weight, and notes. This powers tracking, reminders, and trends. You control what you enter.
• Cycle tracking (optional) — if you turn it on, the menstrual cycle information you log.
• Clinic connection information (optional) — if you join a clinic with an invite, the information needed to connect you, and the information you allow that clinic to see.
• Reports you share with a clinic (optional) — a snapshot of the report you previewed and approved, the name you asked us to show the clinic (shortened to first name and last initial), and when it was sent, opened, and withdrawn.
• Clinic details you give us (optional) — the clinic’s name, email address, phone number, city, state, and, if you picked it from our search, its National Provider Identifier (NPI). Because these details show who you share health information with, the copy attached to your account is kept private to you, like your health information.
• Support and feedback — what you send us when you contact support or use the in-app feedback form.
• Clinic staff information — if you use the clinic console, your name, work email, role, clinic details, and, for the account owner, billing details handled by Stripe.

Information from your device and connected services

• Apple Health / Health Connect (optional) — with your permission, Lumara reads heart rate variability, resting heart rate, steps, weight, and sleep, read-only, to show trends in the app. We do not write to Apple Health or Health Connect. This data is never used for advertising, never shared with advertising partners, never used to decide your eligibility for anything, and never used to train AI models without your explicit consent. You can disconnect at any time.
• Notification tokens — if you allow notifications, a push token that lets us deliver reminders and alerts to your device. Dose reminders are scheduled on your device itself.
• Subscription status — from Apple, Google, and RevenueCat, whether you have an active subscription or trial and its renewal state. We do not receive your full payment card number.
• Technical information — device type, operating system and app version, IP address, and request and error logs our servers keep to run and secure the Service. We remove health information from these logs. The app does not include a crash-reporting tool. If you have chosen in your device settings to share diagnostics with app developers, Apple or Google may give us crash and performance reports.
• App interaction data — which app screens you open (as a fixed screen name) and events such as signing in, finishing onboarding, logging a dose, completing a check-in, or asking Ask Lumara a question. It is tied to a random identifier generated on your device and, once you sign in, to your account. It never includes what you logged — not which medication, not a dose, value, note, or question text. We keep it on our own servers. Only a small, non-health part of it is shared with Google Analytics (see section 19).
• How you found the app — once, when you first open the app, we record which advertising campaign (if any) led to your install, so we can tell which of our ads bring people who keep using Lumara. On Android this comes from the Google Play install referrer (the campaign name and source, and only whether an ad click identifier was present, never the identifier itself); on iPhone it comes from Apple’s privacy-preserving ad attribution (AdServices), which covers Apple Search Ads only and does not ask to track you or use your advertising identifier (IDFA). We keep this in our own database, tied to your account, and we do not send it to Google, Meta, or any other advertising partner. If app usage data is turned off for your account (section 19), we record only that the source is unknown.
• Approximate location at sign-up — when you create an account, our servers use the IP address of the connection to work out the approximate state or country it comes from. We use this only to decide whether the optional sign-up measurement event in section 19 may be sent. We do not collect your precise location.

Ask Lumara and the clinic help assistant

• Ask Lumara, in the app, runs entirely on your device. Your questions and the answers are worked out on your phone from data already in the app; they are not sent to us or to any AI provider. We record only that a question was asked, never its text.
• The clinic console help assistant sends what clinic staff type into it, with basic non-health context about the console page (for example, the page type and the user’s role), to an AI model provider, currently Anthropic, to generate an answer. It cannot read patient records. Staff are told not to type patient details. We do not store or log the text of these messages.

Information from the website

• Pages you visit, approximate location derived from IP address, browser and device type, and the page that referred you — through the analytics and advertising tools described in section 19, only to the extent your cookie choices allow.

6. Where information comes from

From you; from your device and the health platforms you connect; from Apple, Google, RevenueCat, and Stripe (subscription and payment status); from Google Play and Apple (which advertising campaign, if any, led to your install — see section 5); from a clinic that invites you (your invite and connection); from the clinic console when a clinic acts on your connected account (for example, assigning a protocol); and from the public NPI registry when you search for a clinic.

7. Legal bases for processing (EEA, UK, and Switzerland)

If data protection law in the European Economic Area, the United Kingdom, or Switzerland applies to you, we rely on: your explicit consent to process health information and to connect health platforms (you can withdraw it at any time); performance of a contract to provide the Service; legitimate interests to keep the Service secure, prevent abuse, fix problems, and understand use of the Service in a privacy-protective way; and legal obligations. The optional sign-up measurement event in section 19 is never sent for sign-ups from these places.

8. How we use information

We use information to: provide and operate the Service; create and secure your account; deliver reminders and notifications you turn on; show trends and calculations; connect you with a clinic you choose; provide support; process subscriptions; understand how the Service is used and improve it; measure whether our ads lead to sign-ups (only as described in section 19); prevent fraud and abuse; and comply with law.

We do not use your health information for advertising, to build advertising or marketing profiles, or to decide your eligibility for any product, insurance, or service, and we do not sell it. Calculations and trends are observational and educational; they are never medical advice.

Contacting clinics about Lumara. When patients share reports with a clinic, we keep a business record about that clinic: its name, NPI, email address, phone number, city and state, how many patients have shared reports with it, and whether it has opened a report, created a clinic account, or subscribed. We use it to contact the clinic about Lumara, and a small number of authorized Lumara staff can see it. It never contains your name, anything that identifies you, or your health information, and when we contact a clinic this way we do not tell it who shared. A clinic can stop our report emails with the link in any of them, or ask us at support@lumararx.com not to contact it.

9. De-identified and aggregated data

We may create de-identified or aggregated data and use it to run, understand, and improve the Service, or to publish general statistics. We keep it in de-identified form, do not attempt to re-identify it, and require anyone we share it with not to re-identify it.

10. How we protect information

• Encryption in transit (TLS 1.2 or higher) and at rest.
• On-device encryption of the app’s local database (SQLCipher), with sign-in tokens kept in the device’s secure storage.
• App lock — a Face ID or fingerprint lock (your passcode is the fallback), on by default, that locks the app automatically whenever it goes to the background. You can turn it off in the app’s settings; it applies when Face ID or a fingerprint is set up on your device.
• Row-Level Security in our database, so each person’s data is isolated from every other account and each clinic sees only its own connected patients.
• Health information kept out of logs, notifications, and analytics.

No method of transmission or storage is completely secure. We work to protect information with recognized practices, but we cannot guarantee absolute security.

11. How long we keep information

• While your account is open, we keep your information to provide the Service.
• When you delete your account (in the app under More → Account → Delete account, or by emailing support@lumararx.com), we permanently erase your health information from our live systems right away: your medications, doses, schedules, vials, check-ins, symptoms, lab results, weight, cycle entries, health-platform readings, trips, alerts, any notes or feedback you typed, the app-usage records tied to you, and the record of which advertising campaign led to your install. At the same time we remove your email address, name, date of birth, gender, goals, settings, and sign-in link; remove you from every clinic’s patient list and end its access; delete progress reports you shared; disconnect health platforms; and cancel messages waiting to be sent.
• What we keep after you delete your account. Only records that contain no health information: billing records of your app-store subscription events (for example, the plan and the date), the security records described below, a note that a message was sent with its contents removed, and the one-way code described next. If anything reaches a deleted account afterwards (for example, from a phone that was offline), we erase it automatically within a day.
• Preventing re-registration of a deleted account. We keep a one-way, scrambled code (a cryptographic hash) made from your sign-in identifier, so that a still-valid sign-in for the deleted account cannot silently create a new one. It cannot be turned back into your identifier or email address.
• Backups. Our database is backed up automatically to encrypted backups. Backups are kept for a limited rolling period of no more than 30 days and then overwritten, so erased information can remain in a backup until it rolls off — no more than 30 days after you delete your account. We do not restore deleted accounts from backups except to recover from a disaster, and if we do, we re-apply deletions.
• Security records. Records of actions taken on accounts (for example, which kind of action was taken and when — never the content of your health entries) are kept for at least six years for security and compliance, including after you delete your account.
• Clinics. Deleting your account removes your information from every clinic’s view in Lumara. A clinic you connected to or shared a report with is responsible for anything it copied into its own records (for example, a downloaded report or a note in its own system). Those are the clinic’s own records, kept under its own legal obligations; deleting your Lumara account does not delete them.
• Advertising and analytics partners. Copies held by Google or Meta (section 19) are kept under their own retention policies. We send them no health information.
• Shared reports. We delete a report you shared as soon as you withdraw it, or after 30 days if no clinic opens it. A report a clinic has opened stays available to that clinic until you withdraw it or delete your account. The clinic business record in section 8 contains nothing about you.
• Legal holds. We may keep information longer where the law requires it or to establish, exercise, or defend legal claims.

12. How we share information

• With service providers who host, store, and run the Service for us under contracts that limit their use of the information. They are listed in section 13.
• With clinics, at your direction — the information you authorize when you choose to connect to a clinic, and a report you choose to share.
• With the U.S. NPI registry — when you search for a clinic, the clinic name, city, and state you typed go to the public National Provider Identifier registry run by the U.S. Centers for Medicare & Medicaid Services. Nothing that identifies you is sent.
• With analytics and advertising partners, as limited in section 19: Google Analytics receives a narrow, non-health set of app sign-up and purchase steps; Google (Firebase) and Meta receive one sign-up event only if you opt in; and website analytics and ad-measurement tags run only if you allow them. None of these receives your health information.
• For legal reasons — to comply with law, a subpoena, or valid legal process; to enforce our terms; or to protect the rights, safety, and security of our users, the public, or Lumara. Where the law allows, we will tell you about a demand for your information.
• In a corporate transaction — if we are involved in a merger, acquisition, financing, or sale of assets, information may transfer as part of that transaction, subject to this policy, with notice where required.

We do not share your information with data brokers, and we do not share health information with any advertising or analytics partner.

Sharing your progress report with a clinic

On any plan, including the free one, you can share a basic progress report with a clinic through Lumara:

• What the report contains. The last 30 days: the medications you track, with their dose and how consistently you took each; your overall count of doses taken, missed, and skipped; your latest weight and how it changed; and the symptoms you logged most. You see the whole report before you send it, and what you preview is what the clinic sees.
• What the email to the clinic says. We email the address you give us that you (by first name and last initial) want to share your progress report. The email contains no health information, and its link does not open the report by itself.
• When the clinic can see it. Only after someone at the clinic signs in to a Lumara clinic account and enters a one-time code we send to that same email address. The first practice to do that is the only one that can open it. If none does within 30 days, the share expires and we delete the report.
• It is a snapshot. It does not update, it does not connect you to the clinic, and it shows the clinic nothing else in your account.
• Withdrawing it. You can withdraw a shared report at any time in the app. We delete it straight away and the clinic can no longer open it. We cannot recall anything the clinic copied, printed, or recorded before you withdrew it; that is governed by the clinic’s own obligations to you.
• What we keep afterwards. A record that the share happened — the clinic details you gave us, and when it was sent, opened, and withdrawn — so you can see your sharing history in the app.
• Clinics can opt out. A clinic can ask us to stop sending these emails to its address. If you try to share with an address that has opted out, we will tell you.

13. Service providers and third parties we use

This is the list of companies that receive personal information through the Service, what they do, and what they receive. We update it when it changes.

Service providers (they act on our instructions)

Company	What it does for us	Information involved
Supabase	Sign-in and account security; database hosting	Account information and everything stored in your account, including health information
Vercel	Hosting for our servers, website, and clinic console; cookieless website page counts	All information passing through our servers, IP address, technical logs
RevenueCat	Managing in-app subscriptions	A pseudonymous app user code, subscription and purchase history, device identifier
Apple (App Store) and Google (Google Play)	App distribution, in-app purchases, and billing	Purchase and subscription information (they handle your payment details)
Stripe	Billing for clinic plans	Clinic billing contact and payment details; no patient health information
Bird	Sending account, security, and service emails	Email address and the content of the email
Expo, Apple Push Notification service, and Firebase Cloud Messaging	Delivering push notifications; Expo also delivers app updates	Push token, notification content (which never includes health details), device and app version
Apple and Google sign-in	Signing in with Apple or Google, if you choose to	The identifier and email address they share with us
Anthropic	AI model for the clinic console help assistant	What clinic staff type into the assistant, with basic non-health page context
Sanity	Content management for the website and blog, including image delivery	IP address and browser details when your browser loads website images
Google Fonts	Delivering the fonts the website uses	IP address and browser details

Analytics and advertising partners (third parties, under their own terms)

Company	Purpose	Information involved	When
Google Analytics	Our analytics for the website and the app’s sign-up and purchase funnel. For the app data our servers forward, Google processes it for us under its data-processing terms, with Google Signals off and no Google Ads link	Website: pages visited, device and browser, approximate location. App: the non-health event names listed in section 19, with platform, app version, and pseudonymous identifiers	Website: if you allow analytics cookies (otherwise cookieless measurement only). App: forwarded by our servers unless app usage data is turned off for your account
Google (Firebase Analytics)	Measuring whether our Google ads lead to sign-ups	That this device created an account and the sign-in method; device and app identifiers and IP address	Only if you tick the optional box at sign-up, and never from the excluded places in section 19
Meta (Facebook)	Measuring whether our Meta ads lead to sign-ups	That this device created an account and the sign-in method; device and app details and IP address	Same as Firebase above
OpenAI	Measuring whether our ads on ChatGPT lead to sign-ups from the website	That a website visit led to an account being created; browser and device details and IP address	Only on public website pages, and only if you allow advertising measurement

14. Selling, sharing, and targeted advertising

• We do not sell personal information for money or anything else of value, and we have not done so in the past 12 months.
• We never share health information for advertising, and we do not use it to target ads.
• What counts as “sharing” for advertising. California and some other state laws treat giving information to an advertising platform to measure ads as “sharing for cross-context behavioral advertising” or “targeted advertising,” even when the platform receives no health information. Under that broad reading, two things we do count: (1) the optional app sign-up event sent to Google and Meta, only if you opt in; and (2) the website analytics and advertising-measurement tags, only if you allow them in the cookie banner. We disclose both as sharing so that you can control them.
• How to opt out. In the app, turn off “Share sign-up with ad partners” in Privacy & safety (or simply do not tick the box at sign-up). On the website, use Do Not Sell or Share My Personal Information or “Cookie settings.” We honor Global Privacy Control signals on the website automatically. Opting out never affects your use of Lumara.

15. Your privacy rights

Wherever you live, you can ask us to: tell you what personal information we hold about you and give you a copy; correct it; delete it; withdraw any consent you gave; stop the optional advertising measurement described above; and stop non-essential messages. You can do much of this yourself in the app — export data, edit entries, withdraw a shared report, disconnect a clinic or health platform, turn off the ad-partner switch, or delete your account (More → Account → Delete account). Depending on where you live, you may also have the right to data portability, to object to or restrict certain processing, and to complain to a data protection authority.

How to make a request

Email support@lumararx.com with the subject “Privacy request,” or write to us at Astra Software Labs LLP (a New Jersey limited liability partnership), mailing address 1280 Lexington Ave FRNT 2, New York, NY 10028, United States. We will verify your identity before acting, usually by confirming control of the email address on your account; we will not ask for more information than we need. We respond within the time the law that applies to you requires — generally within 45 days, or within one month for requests under the GDPR or UK GDPR — and where the law allows us to extend that, we will tell you why.

Authorized agents

You may ask someone else to make a request for you. We will ask the agent for your signed permission (or a valid power of attorney) and may ask you to confirm your identity with us directly, unless the law does not allow us to.

Appeals

If we decline your request in whole or in part, we will explain why. You can appeal by replying to our decision, or by emailing support@lumararx.com with the subject “Privacy appeal,” within 60 days of our decision. Someone who did not make the original decision will review it, and we will tell you the outcome in writing within 45 days of receiving your appeal, or within any shorter period your state requires (we may extend this by up to 60 more days where the law allows, and will tell you if we do). If we deny your appeal, we will tell you how to contact your state attorney general or other regulator.

No discrimination

We will not deny you the Service, charge you a different price, or give you a different level of service because you exercised a privacy right.

16. California privacy rights (CCPA / CPRA)

In the past 12 months we have collected these categories of personal information, for the purposes in section 8, from the sources in section 6: identifiers (email address, account and device identifiers, IP address); customer records (name, and for clinic staff, business contact details); commercial information (subscription and purchase history); internet or electronic activity (app interaction and website usage); approximate geolocation (from IP address); sensitive personal information (health information, including cycle information, and account sign-in credentials); and inferences we draw only to show you your own trends. We disclose these categories to the service providers in section 13 for business purposes. We “share” identifiers and internet activity with the advertising partners in section 13 only as described in section 14. We do not sell any category, and we do not sell or share the personal information of anyone we know to be under 16.

We use sensitive personal information only to provide the Service you request and for the other purposes California law permits, so the “right to limit” does not apply. California residents can exercise the rights in section 15 — to know, delete, correct, opt out of sharing, and not be discriminated against — using the methods there, including through an authorized agent.

17. Other U.S. state privacy rights

Residents of states with comprehensive privacy laws (for example Colorado, Connecticut, Virginia, Oregon, Texas, and others) have rights to confirm, access, correct, delete, and obtain a copy of their personal data; to opt out of targeted advertising, sale, and profiling with legal or similarly significant effects; and to appeal. We process sensitive data, including health information, only with your consent where those laws require it. Use section 15 to make a request or an appeal. For consumer health data rights in Washington, Nevada, Connecticut, and similar laws, see our Consumer Health Data Privacy Policy.

18. International data transfers

We are based in the United States, and our service providers may process information in the United States and other countries. Where the law requires it, we use recognized safeguards, such as the European Commission’s Standard Contractual Clauses, for transfers out of the EEA, the UK, or Switzerland.

19. Cookies, analytics, and advertising measurement

Website and clinic console cookie choices. On lumararx.com and in the clinic console, a cookie banner asks before we use any cookie that is not essential, and nothing optional runs until you choose. You can accept or reject everything, or choose by category: essential (always on: keeping you signed in to the console and remembering your choice), analytics (Google Analytics on lumararx.com), and advertising measurement (the tag described below). Your choice is stored for one year, applies to lumararx.com and the clinic console together, and can be changed at any time from “Cookie settings” in either site’s footer. Before you choose, and if you reject analytics, Google Analytics runs in a cookieless mode that sets no cookies. We also use Vercel Web Analytics, which counts page views without cookies. Some links we email you carry an invite code, your email address, or a sign-in token in the page address; our pages remove those before any analytics loads. The clinic console uses no analytics or advertising cookies.

App usage analytics (mobile app). The app sends the app interaction data in section 5 to our own servers. Our servers forward a small, non-health part of it to Google Analytics, server to server. What we forward, by event name only: opening the app; the consent and sign-in screens being shown; consent being accepted; starting and completing sign-in or sign-up; your account being set up; finishing onboarding steps (that a step was finished, never your answers); allowing notifications; and paywall, plan selection, trial, and purchase steps (including a failed purchase) — plus a single milestone named “activated,” sent once, which does not say how it was reached. Each event carries only your device platform, app version, and a session identifier, together with a random per-install identifier and, once you sign in, a pseudonymous code derived from your account with a secret key that never leaves our servers. What we never forward: the name of any screen you open; your name or email; joining or connecting to a clinic; any medication, dose, schedule, symptom, check-in, cycle, lab, weight, Apple Health or Health Connect event or value; reports you share; Ask Lumara questions; and calculator warnings. Google Signals is off for this data and it is not linked to any Google Ads account. To have app usage data turned off for your account — after which our servers neither record nor forward it — use the “App usage data” setting in Privacy & safety where your app version offers it, or email support@lumararx.com.

Optional sign-up measurement for our ads (mobile app). This never includes any health or medication information, and it is off unless you turn it on. On the first screen of the app there is a separate, optional checkbox, “Help measure Lumara’s ads (optional)”, which is not ticked unless you tick it and is separate from accepting our terms. If you tick it, when your new account is created we tell Google (Firebase Analytics) and Meta (Facebook) — one event each — that this device created a Lumara account and how you signed in (Apple, Google, or email), so we can see whether our ads lead to sign-ups.

• Where it is never sent. It is never sent for a sign-up whose connection appears to come from Washington, Nevada, or Connecticut, or from the European Union / European Economic Area, the United Kingdom, or Switzerland — even if the box is ticked — and it is not sent when we cannot tell where the connection comes from. We decide this from the approximate location of the connection at sign-up.
• What it never includes. Your medications, doses, schedules, symptoms, check-ins, lab values, Apple Health or Health Connect data, or any other health information; your name, email address, or account ID; or whether or which clinic invited you.
• What Google and Meta can see. Like any app that measures its ads, the event shows Google and Meta that this device created a Lumara account. Each attaches an identifier for the app on your device and receives the device’s IP address, model, and operating-system version; on Android, Firebase also uses your device’s advertising ID (the app switches Meta’s own advertising-ID collection off). On iPhone the app does not access the advertising identifier (IDFA) and does not ask to track you; Meta measures through Apple’s privacy-preserving ad attribution and its own aggregated measurement. We send Meta nothing else — no app opens, purchases, name, email, or other details for matching. Ad personalization is turned off for the Firebase data.
• Afterwards. After the sign-up event, Firebase may record basic app-usage signals from that device (such as that the app was opened, never which screens) until you turn the switch off, connect to a clinic, or sign out — at which point the app turns Firebase off and stops anything further going to Meta.
• Changing your mind. Turn off “Share sign-up with ad partners” in Privacy & safety at any time; this withdraws your consent and stops Firebase and Meta collection on that device. It cannot recall an event already sent; Google and Meta keep it under their own policies. On Android you can also reset or delete your advertising ID in your device settings. Versions of the app released before this checkbox existed do not send the event.

Website advertising measurement. Our public website pages include a conversion-measurement tag from OpenAI, which tells us when a visit that began with one of our ads led to someone creating an account. It does not receive your name, email address, or any health information. It is never present in the app, in the clinic console, or on password-reset, clinic-invite, or account pages that carry a link from your email. It loads only if you allow advertising measurement in the cookie banner, and you can turn it off at any time from “Cookie settings” or Do Not Sell or Share My Personal Information. We honor Global Privacy Control automatically.

20. Children’s privacy

Lumara is intended for adults 18 and older. We do not knowingly collect personal information from anyone under 18. If we learn that we have, we will delete it.

21. Payments

Subscriptions bought in the app are processed by the Apple App Store or Google Play, and clinic plans by Stripe. Lumara does not receive or store your full payment card details. Purchases are also subject to the applicable store’s or processor’s terms and privacy practices.

22. Medical disclaimer

Lumara is a tracking and education tool. It is not a medical device and does not provide medical advice, diagnosis, or treatment. Calculators show how a value is derived from what you enter; insights are observational, never prescriptive. Always follow your licensed healthcare provider’s instructions.

23. Changes to this policy

We may update this policy. When we do, we will change the “Last updated” date above and, for material changes, give notice in the app or by email before the change takes effect. We will ask for your consent where the law requires it, for example before using health information in a materially different way. The current version is always at lumararx.com/privacy.

24. Contact us

Lumara is operated by Astra Software Labs LLP. For privacy questions or requests, email support@lumararx.com or write to Astra Software Labs LLP (a New Jersey limited liability partnership), mailing address 1280 Lexington Ave FRNT 2, New York, NY 10028, United States.