This Privacy Policy explains how your information is collected, used, and protected when you use the Luma Cleaner mobile application (the “App”).
01Data controller
The App is developed and operated by Klavdiia Guliaeva, an individual developer (“we”, “our”, or “us”). The developer name above corresponds to the developer listed on the Apple App Store.
Country of establishment: Kazakhstan.
For any privacy-related questions or to exercise your rights, contact us at [email protected].
02Information we collect
2.1 Personal information
Luma Cleaner does not require account creation. We do not directly collect personal information such as your name, postal address, or contact details.
2.2 Device and usage data
We automatically collect limited, non-identifying technical data so the App functions correctly and to improve its quality:
- Device type and operating system version
- App version
- Basic in-app usage events
- Crash, diagnostic, and performance data
2.3 Photos and media
Luma Cleaner requests access to your photo library solely to provide its core functionality (organizing and cleaning up media).
- All analysis of photos and videos is performed on your device.
- Photos and videos are not uploaded to our servers or any third party for processing.
- We do not store or access your photos outside of the App.
- You can grant or revoke photo access at any time in iOS Settings.
2.4 Advertising and attribution identifiers
To measure the effectiveness of our marketing campaigns, the App may use a mobile attribution identifier.
- On iOS, the App may ask for your permission through Apple's App Tracking Transparency (ATT) framework before accessing the Identifier for Advertisers (IDFA).
- If you grant permission, our attribution provider (AppsFlyer) may use the IDFA to attribute app installs to specific campaigns.
- If you decline, attribution is performed only through privacy-preserving, aggregated methods (such as Apple's SKAdNetwork), and the IDFA is not used.
03Legal bases for processing (GDPR)
Where the GDPR applies, we rely on the following legal bases:
| Purpose | Legal basis |
|---|---|
| Providing core App functionality (incl. photo access you initiate) | Performance of our agreement with you / your request (Art. 6(1)(b)) |
| Crash reporting, diagnostics, and stability | Our legitimate interest in a reliable, secure App (Art. 6(1)(f)) |
| Product analytics and usage measurement | Your consent, where required by local law (Art. 6(1)(a)); otherwise legitimate interest (Art. 6(1)(f)) |
| Marketing attribution / advertising identifiers | Your consent (Art. 6(1)(a)) |
| Refund and accounting data | Legitimate interest and legal obligations, e.g. tax (Art. 6(1)(f), 6(1)(c)) |
You may withdraw consent at any time (see Your rights). Withdrawal does not affect processing carried out before withdrawal.
04How we use data
We use the data described above to:
- Enable and maintain App functionality
- Improve performance, reliability, and quality
- Detect, diagnose, and fix technical issues
- Support and manage subscription features
- Measure the effectiveness of our marketing
We do not build advertising profiles about you, show personalized ads inside the App, or sell your personal data. Attribution data is used only to understand which marketing campaigns lead to installs.
05Purchases, subscriptions & refunds
All purchases, subscriptions, and refunds are processed by Apple through the App Store. We do not collect or store payment card information or Apple ID credentials.
Refunds
If you request a refund for an in-app purchase, Apple may share limited purchase-related information with us, such as:
- Purchase and usage history
- An anonymized account identifier
- Total spend
- Refund amounts
We use this information solely for accounting, fraud prevention, and improving the App, in accordance with Apple's policies.
06Third-party services (subprocessors)
The App uses the following services strictly for analytics, crash reporting, attribution, and subscription management. Each processes limited technical data under its own privacy policy:
| Service | Purpose | Indicative data | Privacy policy |
|---|---|---|---|
| Google Firebase | Analytics & performance monitoring | Device/usage data, app instance ID | firebase.google.com |
| Sentry | Crash & error reporting | Crash logs, device/diagnostic data | sentry.io |
| AppsFlyer | Marketing attribution analytics | Device data, attribution identifiers (incl. IDFA if permitted) | appsflyer.com |
| Apphud | Subscription & purchase management | Subscription status, transaction/device data | apphud.com |
These services are used in line with Apple App Store policies and applicable data protection laws.
07International data transfers
Some of our service providers are located outside your country, including in the United States and other jurisdictions. When personal data is transferred from the European Economic Area (EEA), the United Kingdom, or Switzerland, such transfers are protected by appropriate safeguards — such as the European Commission's Standard Contractual Clauses (SCCs) and/or, where applicable, an adequacy decision or the EU–U.S. Data Privacy Framework. You may contact us for more information about these safeguards.
08Data retention
We retain data only for as long as necessary to fulfil the purposes described in this Privacy Policy or as required by law (for example, retention of accounting records). When data is no longer needed, it is deleted or anonymized.
09Your rights
Depending on where you live, you may have some or all of the following rights:
GDPR — EEA, UK & Switzerland users
Access, rectification, erasure, restriction of processing, objection, data portability, and the right to withdraw consent at any time. You also have the right to lodge a complaint with your local data protection supervisory authority.
CCPA / CPRA — California residents
The right to know what personal information is collected, to request access or deletion, and to non-discrimination for exercising these rights. We do not sell your personal information.
To exercise any of these rights, contact us at [email protected]. To opt out of marketing attribution, you can decline tracking via the iOS ATT prompt at any time in iOS Settings.
10Children's privacy
The App is not directed to children. We do not knowingly collect personal data from children under the age of 16, or the applicable age of digital consent in your country (which may be as low as 13). If you believe a child has provided us with personal data, please contact us and we will delete it.
11Data security
We apply reasonable technical and organizational measures to protect data against unauthorized access, loss, or misuse. However, no method of electronic storage or transmission is completely secure, and we cannot guarantee absolute security.
12Changes to this policy
We may update this Privacy Policy from time to time. Material changes will be reflected by updating the “Last updated” date at the top. Your continued use of the App after an update constitutes acceptance of the revised Privacy Policy.
13Contact
For privacy-related questions or requests: