1. Our promises
To summarize: your information is used to help you start things — nothing else.
- We do not sell your personal information.
- We do not show ads, and we do not share your information for advertising.
- We do not use your conversations to train AI models.
- We do not keep recordings of your voice calls.
- You can see what Lumer remembers about you, turn memory off, and delete it at any time, inside the app.
- You can decline optional permissions. Features that need a permission, such as voice calls requiring microphone access, will be unavailable without it.
2. Who we are
To summarize: Lumer is run by ORBITECH PTE. LTD., a company in Singapore.
Lumer (the “App”), its website and related services (together, the “Services”) are provided by ORBITECH PTE. LTD., a company incorporated in Singapore (UEN 202335826D), with its registered office at 120 Lower Delta Road, #07-14 Cendex Centre, Singapore 169208 (“Lumer”, “we”, “us”). We are the organisation responsible for your personal data (the “controller” under the EU and UK GDPR).
This policy explains how we handle personal data under the Singapore Personal Data Protection Act 2012 (PDPA), the EU and UK General Data Protection Regulation (GDPR), and other laws that apply where you live.
3. What we collect
To summarize: what you tell us, what you do with Lumer, and a little technical information to keep the App working.
Information you give us
- Account details. When you sign in with Apple or Google, we receive your name and email address. If you use Apple’s “Hide My Email”, we receive a relay address instead.
- Profile. The name you give your companion, the name you want to be called, your pronouns and, if you choose to add it, your birthday.
- Onboarding answers. Your answers to a few short questions — for example what you want help with, and, if you choose to answer, whether you identify as neurodivergent (such as ADHD). These answers are optional. See Sensitive information.
- Tasks and plans. Task names, notes, dates, times, reminders, repeat settings and the first steps you set up with Lumer.
- Conversations. Messages you type in chat, and what you say during voice calls and focus sessions.
- Support messages. Anything you send us when you contact us.
Information created when you use Lumer
- Memory. If Memory is on, Lumer creates memory notes from your conversations, including inferred preferences, triggers, helpful interventions and context — for example what tends to help you get started, and where you left off — so you don’t have to repeat yourself.
- Call transcripts and summaries. We store full call transcripts and AI-generated summaries, including the task you worked on, the next step you agreed on, friction points, emotional tone and unresolved topics.
- Usage information. Which features you use and when — for example whether a scheduled call was answered or declined, and whether a focus session started. We use this to make Lumer work and to improve it.
- Device and technical information. Device model, operating system, app version, language, time zone, crash reports and push-notification tokens.
- Purchase information. Subscription status and transaction IDs from Apple or Google. We never receive your card details.
Transcripts, summaries and memory notes may reveal information about ADHD, mental health or wellbeing, including information you did not expressly state. AI inferences may be wrong. See Sensitive information.
Device permissions
Lumer asks for permissions only when a feature needs them, and you can change them in your device settings at any time:
- Microphone — for voice calls and voice input. Lumer listens only while a call or voice input is active.
- Notifications and calls — so Lumer can reach you at the times you set.
Connected services
If you connect Apple Music or Spotify to play music during focus sessions, we receive only what is needed to play music for you (such as an access token and playback information). We do not read your listening history for any other purpose.
4. How Lumer’s AI works
To summarize: Lumer shows up only when you’ve agreed, uses only what it needs, and you can switch things off at any time.
Why Lumer shows up
Lumer calls or notifies you only at times you set up together, for tasks you create or confirm. You can decline any call with one tap. Declining has no consequence and Lumer won’t follow up about it.
What information the AI uses
To respond to you, the AI uses your nickname and pronouns, your onboarding answers, today’s tasks, the current conversation and, if Memory is on, your memory notes. From your conversations, Lumer also generates call summaries (including emotional tone and friction points) and, if Memory is on, inferred memory notes such as preferences and triggers. These may reveal information about ADHD, mental health or wellbeing, including things you did not expressly say, and they may be wrong.
What happens to your voice
During a call, your voice is processed in real time and converted to text so Lumer can respond. The audio is not recorded and is discarded when the call ends. We keep the text transcript and summary of the call and, if Memory is on, any memory notes.
Who processes it
We use third-party AI and speech providers to generate responses and convert speech to and from text: OpenAI (conversation), Deepgram (speech-to-text), Cartesia (text-to-speech) and LiveKit (real-time voice calls). We may also use ElevenLabs or Google for text-to-speech.
How to turn it off
- Turn off or delete memory in Settings › Personal Intelligence.
- Change or turn off calls and reminders for any task, or in Settings › Notifications.
- Withdraw microphone or notification permissions in your device settings.
AI responses can be wrong. Please see our Terms of Service for more.
5. How we use information
To summarize: to run Lumer, personalise it for you, keep it safe and make it better.
| Purpose | Legal basis (GDPR) |
|---|---|
| Provide the Services — your account, tasks, calls, chat and focus sessions | Performance of our contract with you |
| Personalise how Lumer talks to you, including Memory | Your consent, which you can withdraw at any time |
| Process health-related information — neurodivergence information you share and health-related inferences from your conversations (such as emotional tone, friction points and triggers) | Your consent (Art. 6(1)(a)) and your explicit consent (Art. 9(2)(a)) |
| Manage subscriptions and restore purchases | Performance of our contract |
| Fix bugs, keep the Services secure and prevent abuse | Our legitimate interests |
| Measure how the App is used with Google Firebase Analytics, which collects individual usage events before reports are aggregated | Our legitimate interests |
| Send product updates, if you turn them on | Your consent |
| Comply with law and respond to lawful requests | Legal obligation |
Under the PDPA, we rely on your consent (including deemed consent) and on the exceptions the PDPA allows, such as legitimate interests.
6. Sensitive information
To summarize: ADHD and wellbeing information — including what Lumer infers from your conversations — is sensitive. Features that process it require your separate, explicit consent.
Information about whether you identify as neurodivergent, things you share about your mood or wellbeing, and what Lumer infers from your conversations (such as emotional tone, friction points and triggers) may be considered health information or “special category” data. We treat it with extra care:
- Features that process health-related information or create health-related inferences require your separate, explicit consent. We will ask for it before that processing begins, and explain the information, purposes and providers involved.
- You can leave onboarding questions unanswered, but that does not by itself prevent health-related inferences from your conversations.
- We use this information only to provide and personalise the Services for you. We never use it for advertising and never sell or share it for marketing.
- You can withdraw consent at any time in the app settings or by emailing [email protected]. We then stop the consent-based processing and delete the related information unless a specific legal obligation requires us to keep it.
- If you are under 18, processing of your health-related information requires the consent of a parent or guardian.
Lumer is not a medical service, and we do not diagnose or treat any condition.
8. How long we keep information
To summarize: we do not store call audio. We store full call transcripts, summaries and memory notes separately from the daily chat view. Their retention periods are set out below.
| Information | How long |
|---|---|
| Chat messages | The chat view clears at midnight (your local time) every day. Server-side copies of chat messages are kept with your account and deleted when your account is deleted. |
| Voice audio from calls | Not stored. Processed in real time and discarded when the call ends. |
| Call transcripts and summaries | Kept while your account is active, so Lumer can follow up on your calls. Deleted when you delete your account. |
| Memory notes | Until you delete them, turn off and clear Memory, or delete your account. |
| Tasks and reminders | Until you delete them or delete your account. |
| Account and profile | While your account is active. |
| Deleting your account | You can request deletion in the App (where available) or by emailing [email protected]. We verify requests using information reasonably necessary to protect your account; if you use Apple’s “Hide My Email” or no longer have access to your email address, we will offer another way to verify. We delete your account and associated personal data within 30 days, or sooner where applicable law requires. Any information retained to meet a legal obligation is restricted to that purpose. Deleting your account does not cancel an Apple or Google subscription. |
| Server logs | Kept for a limited period needed for security and debugging, then deleted or anonymised. |
| Purchase records | As long as required by tax and accounting law. |
9. Your choices and rights
To summarize: most things you can do yourself in the App. For anything else, just email us.
In the App
- View, update or delete your memory: Settings › Personal Intelligence.
- Turn each type of notification on or off: Settings › Notifications.
- Delete your account and data: request deletion in the App (where available) or by emailing [email protected] — see How long we keep information. Deleting your account does not cancel a subscription bought through Apple or Google — please cancel it in your store account.
Your rights
Depending on where you live, you may have the right to access, correct, delete or receive a copy of your personal data, to object to or restrict certain processing, and to withdraw consent at any time without affecting earlier processing. To make a request, email us at [email protected]. We respond within the period required by the law applicable to your request, including the shorter deadlines for access requests in Brazil, Taiwan and Indonesia. Where an extension is legally permitted, we will explain the reason and the revised deadline. If we refuse a request, we will explain why and tell you about available complaint or appeal routes.
You also have the right to complain to a data protection authority — in Singapore, the Personal Data Protection Commission; in the EU or UK, your local supervisory authority.
10. Security
To summarize: we protect your data carefully, though no system is perfect.
We use technical and organisational measures designed to protect personal data, and we limit access to people who need it to provide the Services. If a data breach affects you, we will notify you and the authorities as required by law.
11. International transfers
To summarize: your data is hosted in the United States and may also be processed in other countries.
Our primary hosting and database are in Oregon, United States (Amazon Web Services). Our service providers may also process information in other countries. Where the law requires it, we use appropriate safeguards for international transfers; contact us at [email protected] for details.
12. Age requirement
To summarize: you need to be 13 or older. If you’re under 18, a parent or guardian needs to be OK with it.
You must be at least 13 years old to use Lumer. If you are under 18 (or the age of majority where you live), you may use Lumer only with the permission of a parent or guardian. Where local law sets a higher age for consenting to the processing of personal data (for example, up to 16 in some EU countries), a parent or guardian must give that consent for you. If you are under 18, processing of your health-related information (see Sensitive information) requires the consent of a parent or guardian.
We do not knowingly collect personal data from children under 13. If you believe a child under 13 has given us their information, please contact us and we will delete it.
13. Changes to this policy
To summarize: if something important changes, we’ll tell you first.
We will post updates on this page and change the “last updated” date. If a change materially affects how we use your information, we will notify you in the App before it takes effect, and ask for your consent where the law requires.
14. Contact us
ORBITECH PTE. LTD., 120 Lower Delta Road, #07-14 Cendex Centre, Singapore 169208
Email: [email protected]