Privacy policy for Lumi

Last updated: 11 November 2026

1. What this is about

This privacy policy applies to Lumi, the AI assistant for businesses, in the browser and in the apps for iPhone, iPad, Mac, Android and Windows. It says which personal data Lumi processes, for what, where, for how long and who receives it, and which rights you have. It follows the Swiss Federal Act on Data Protection (FADP) and, where it applies, the EU General Data Protection Regulation (GDPR).

The website getlumina.org and the landing pages have their own privacy policy. Lumi’s terms (AGB) also apply to the use of Lumi.

2. Who is responsible

The controller is Lumina Technologies, Binzallee 7, 8055 Zürich, Switzerland (“Lumina”). Send questions about privacy and requests about your data to theodore@getlumina.org.

3. What Lumina is responsible for and what the business is

Lumi is used by businesses such as restaurants, bars and cafés. Lumina is responsible for the data of the people who use Lumi with their own login (owners and staff) and for running the service.

Lumina processes the data a business brings into Lumi or connects to it on behalf of that business: e-mails, reservations, reviews, receipts, documents, appointments and everything in them about guests, suppliers or staff. The business is the controller of this data; Lumina is its processor (Art. 9 FADP, Art. 28 GDPR) and processes it only to carry out the business’s tasks. The business makes sure it may have this data processed in this way and informs its guests (terms, section 5.1). Guests and other people whose data reaches Lumi this way contact the business with questions and requests; Lumina supports the business with them.

Where Lumina looks at a business’s content, or has an AI evaluate it within the business’s instance, to improve Lumi (section 7), it does so for a purpose of its own and is itself responsible for that. A person only looks in if the business allows it; the business can turn off the evaluation by the AI (section 7).

4. Which data Lumi processes

Account and sign-in: name, e-mail address, role in the business, date of creation and the version of the terms in force when the account was created. Lumi stores your password only as a hash (scrypt), never in plain text. If you sign in with Google or Apple, Lumi stores the ID of your account with that provider, the e-mail address it confirms and the name if it sends one. An account is created through an invitation; an invitation link is valid for 14 days.

Sessions: signing in creates a random key. The server stores it only as a hash, with the app’s device name (such as “Lumi · iPhone”) and its expiry: 30 days, extended while you use Lumi. To slow down password guessing, the server keeps the IP address of failed sign-ins in memory for 15 minutes, not in the database. The web server in front of Lumi also keeps an access log: time, IP address, the address requested and whether the request succeeded, without content and without cookies. It serves to detect and trace attacks and is deleted after 30 days.

Content: what you and the agents write in the chat, including what you say by voice (as text), reactions, attached photos and documents, what the agents remember (memory, knowledge, skills), routines, reminders, calls (time, reason, duration, status), approvals and tasks with their trace, that is which tools an agent called with which details and what came back. Also the documents Lumi creates, such as invoices and quotes as PDF.

Details about the business: during setup, Lumi reads the business’s website and public information from the web (opening hours, address, offering, reviews) and saves it as the team’s knowledge. On top of this come the business’s settings, such as language, approvals, call rules, call hours and monthly limit.

Connected services: if you connect Google (Gmail and Calendar; Docs, Sheets, Slides and Drive with a consent of their own, and then only the files Lumi creates there or that you show it; for connections made before 29 October 2026 all of Drive), Microsoft 365 (Outlook, Calendar, OneDrive, SharePoint, Word and Excel) or another app, Lumi reads there what the agents need for their tasks, such as e-mails with sender, recipients, subject, content and attachments, appointments and files. Lumi only asks for the permissions its tools need: read e-mail, create and send drafts, only read calendar events, read files and, if you connect Docs, Sheets, Word or Excel, create and fill in documents and spreadsheets there, and for Google, once available, reply to reviews of the Business Profile. The access keys are stored encrypted (AES-256-GCM) on the server; the agents never see them. If you disconnect a service, Lumi deletes the access keys and revokes the access where the provider allows it (Google and many apps). For Microsoft, you can also remove the permission in your Microsoft account.

New e-mails: when a mailbox is connected, Lumi checks for new e-mails in the inbox about once a minute (for Gmail without the Promotions and Social tabs). For each new e-mail, an AI checks from the sender, subject and a short excerpt whether the business needs to know about it or decide something, at most 200 times a day. Only then does the Manager work on the e-mail further. E-mails and replies to reviews go out only as the business’s approvals allow; by default, Lumi asks before anything is sent.

Getting to know the mailbox: shortly after you connect a mailbox for the first time, Lumi reads a small selection of the last six weeks once: mostly e-mails you sent yourself (some of them in full, without attachments) and an overview of incoming ones (sender, subject, a short excerpt). From these, an AI notes how you write (greeting, sign-off, signature, languages), which requests are typical and which suppliers and partners you deal with, so that drafts sound like you. These notes are kept in your business’s knowledge; you see them with the Manager under “What I remember” and can delete any of them. Lumi does not store the e-mails it read for this.

Website logins: logins for websites the agents should sign in to (such as a reservation tool or a supplier’s shop) are stored encrypted on the server and in Anthropic’s vault (section 6). The password is only inserted into requests to the website it belongs to; the AI itself never sees it. Lumi does not store one-time codes.

Voice: for dictation, the app sends the recording to the server, which passes it on to OpenAI to turn it into text; the server does not store the recording. Where the server cannot transcribe, the app recognises speech with the device’s speech recognition (on Apple devices on the device where supported; on Android with the service the device has set up for it, usually from Google). In voice chats and calls from Lumi, the audio runs encrypted (WebRTC) directly between your device and OpenAI; Lumi’s server receives no audio. For this, the voice AI gets the latest messages of the chat. What you and the agent say in the conversation is then in its chat as text (OpenAI provides the transcript), and so are its answers; that way the agent also knows later what you talked about. For troubleshooting, the server stores technical details about a conversation’s connection (duration, type of network, sound quality).

Notifications: so that answers, approvals and calls arrive while the app is closed, the app registers its device with the server, with the push token from Apple (Apple Push Notification service, on iPhone also PushKit for calls) or from Google (Firebase Cloud Messaging), the platform and the app’s language, linked to your session. Once you sign out, the device receives nothing more. A notification contains the agent’s name and the beginning of its message; for an approval, for example, the recipient and subject of an e-mail or the name and party size of a reservation; for a call, the reason. It travels encrypted through Apple’s or Google’s servers, but is not end-to-end encrypted.

Usage and billing: the AI usage per task, voice chat and dictation, the credits and their bookings (payments, gifts with giver and reason), plan and trial week. Payments go through Stripe, on Stripe’s payment page in the browser. Lumina receives from Stripe the e-mail address, business name, name and billing address, a customer number, the status of the subscription and the amounts, and issues the receipts with them; you enter card and other payment details only with Stripe. The apps don’t sell anything.

Log: the server keeps a log of events in the business, such as a task’s errors, new connections, undelivered notifications and every look by Lumina (section 7).

Permissions on the device: camera (photos, for example of delivery notes), microphone (dictation, voice chat, calls), notifications, and Face ID, Touch ID or fingerprint to unlock and confirm. The app only asks when you use the feature. The device does the biometric check; Lumi receives no biometric data.

On your devices: the apps for iPhone, iPad and Mac store the session key in the device’s keychain and a copy of your workspace (chats, drafts, messages not yet sent, attachments) so they open quickly and also work offline. The Android app encrypts the session key with a key from the Android Keystore and excludes its data from backups. The Windows app keeps the session as a cookie in its own encrypted storage. In the browser, Lumi only sets a technically necessary session cookie and stores a few settings such as the language locally. When you sign out, the apps delete the session key from the device.

No advertising, no tracking: Lumi contains no advertising or analytics services and doesn’t track you across other apps or websites.

5. Why and on what basis

Lumina processes the data to provide Lumi and carry out the business’s tasks (contract; Art. 6(1)(b) GDPR), to help when something doesn’t work, find errors, prevent misuse and improve Lumi (legitimate interest; Art. 6(1)(f) GDPR), and to bill and meet legal obligations such as keeping accounting records (Art. 6(1)(c) GDPR). Lumi only uses sign-in with Google or Apple, notifications, the microphone and the camera if you choose or allow them.

Lumina doesn’t sell data, doesn’t use it for advertising and doesn’t build profiles for advertising. Lumina makes no automated individual decisions about you with Lumi within the meaning of Art. 21 FADP and Art. 22 GDPR; what the agents do on behalf of the business is steered by the business with its approvals.

Data from Google services: Lumi’s use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy) and the Google Workspace API User Data and Developer Policy (https://developers.google.com/workspace/workspace-api-user-data-developer-policy), including the Limited Use requirements. Lumi uses e-mails, calendar events and files from Google only for features you see and use in Lumi: checking and reporting new e-mails, learning how you write when a mailbox is first connected, drafting replies and sending them once you approve, and looking up events and files when you or an agent asks. For the reply time to guests (section 7) Lumi reads only the times and labels of e-mails from Gmail, never their contents; Lumina sees only the summarised number. The weekly AI analysis of the chats (section 7) reads the chats with Lumi within the business’s instance, not the mailbox. Content from Google that appears in them leaves the instance only as anonymous, aggregated findings without names and without the wording of e-mails; Lumina uses them to improve the features you see and use in Lumi and trains no AI model with them. Lumi passes this data, with your consent, only to the service providers in section 6, as far as these features need it, and never for advertising, to data brokers or to assess creditworthiness. Neither Lumina nor the AI providers use it to create, train or improve AI or machine-learning models. People at Lumina read such data only with your explicit agreement, which Lumina records (during the pilot phase before you connect Google, for the access in section 7, which you can turn off at any time; otherwise for specific content with the support access), when it is needed for security (for example to investigate abuse), or when the law requires it.

6. Who receives the data

Lumina passes on personal data only as far as Lumi needs it. These service providers process it on Lumina’s behalf:

OVHcloud: servers in Zurich, Switzerland. This is where each business’s database, attachments and encrypted access keys are stored, in its own separate instance, together with the daily backups.

Anthropic (USA): Claude runs the agents. For a task, Anthropic receives what the agent needs for it: messages, attachments, e-mails and files from connected services, the business’s knowledge and memory, and the results of the tools. The agents run on Anthropic’s platform in an isolated environment with a browser, web search and access to websites; the history of their sessions, uploaded files and the vault with the website passwords are also kept there. Claude researches the business on the web during setup and answers short checks when OpenAI can’t be reached.

OpenAI (USA): voice chat and calls, dictation and short checks: how detailed an agent’s answer to your message should be (for this, the text of the message), whether a new e-mail is important (sender, subject, excerpt), whether an action needs an approval and whether a call is warranted. For voice chats, OpenAI receives a pseudonymous ID of your login (a hash) so it can attribute misuse.

Under their terms for business customers, Anthropic and OpenAI don’t use the data to train their models and keep it only for a limited time, for example to monitor misuse.

Stripe (Ireland and USA): payments for plans and extra usage. Stripe also processes payment data for its own purposes, such as fighting fraud and meeting legal obligations, under its own privacy policy.

Apple: notifications and calls on iPhone, iPad and Mac, “Sign in with Apple” and speech recognition as a fallback for dictation.

Google: notifications and calls on Android (Firebase Cloud Messaging) and “Sign in with Google”.

Services the business connects itself (such as Google, Microsoft, aleno, SumUp, Planday or WhatsApp Business), and websites the agents operate on its behalf, receive what the task requires. The contracts and privacy policies the business has with them apply.

Authorities only receive data if the law requires it.

7. Lumina’s access

Lumina can look at a business’s chats, the questions to the agents, the tasks with their trace, the usage, the logins (e-mail address, last sign-in, devices), the connections and the errors, to help, find errors, prevent misuse and improve Lumi (terms, section 5.3). Lumina doesn’t see passwords or access keys, and of attachments only the name. The interface for this can only be reached on the server itself, not over the internet.

Every look at chats, questions and tasks needs a reason and is logged with the business, with time, name, reason and whether it was a support case. The business sees the log in Lumi in the browser and in the Windows app under Settings → Privacy → “Looks by Lumi”, as well as every change Lumina makes to its skills, every gift of credits, every invitation link, every suggestion and every question Lumina has Lumi pass on to it, every run of the AI analysis and what the business itself passed on to the Lumi team.

Lumina looks into chats, questions and tasks with a reason, to help and to improve Lumi. The business can turn this off at any time in the same place with the switch “Allow access to improve Lumi” (terms section 5.3); Lumina then only looks in during a support case. The business allows a support case itself, there or with a tap on the card Lumina sends in the chat to ask for it (“Support access”, for one week or until it ends it); the permission is logged with time and name. Its instance refuses every other look. With a connected Google account the same applies while Lumi is in its pilot phase: before connecting, the business agrees to this access, this is logged, and the switch stays. After the pilot phase Lumina only looks in with Google during a support case allowed this way; the switch does not exist then (section 5).

Under the same conditions Lumina can view the app the way a person of the business sees it: read only, for one hour, logged with time, name and reason. If the business ends the support access, this view ends too.

Without any access, Lumina sees whether the pilot helps the business, as numbers only and never with contents: how often the business approves, changes or rejects Lumi’s drafts, how many approvals wait longer than two days and how fast guests get an answer. For the reply time, Lumi reads only when the e-mails of a conversation arrived and left in the connected mailbox (times and folders, no senders, subjects or texts): once for the four weeks before the mailbox was connected, as the comparison, and then daily for the last four weeks. Only the number of replies and the median reply time in minutes are stored. In addition there are weekly usage numbers, also without contents: how many tasks Lumi handled in the chat and how long they took, how many failed or were stopped, how often someone followed up right after an answer, how many answers got a 👎, how often each tool and each general guide was used and how often that didn’t work (self-written guides only as a number, without their name), on how many days each role used Lumi, how many calls with how many minutes, and how many wishes and answers to questions were passed on.

Wishes to the Lumi team: If something doesn’t work yet or goes wrong, Lumi can offer to pass it on to the Lumi team. Lumi shows you the text first and passes it on only once you say yes, in general words, without names of guests, staff or suppliers and without contents from e-mails. Lumina receives the text with its kind (wish, problem or answer to a question), your role in the business (not your name) and the time. The business sees everything that was passed on in the same place under “Passed on to the Lumi team”.

Questions from the Lumi team: Lumina can ask the businesses through Lumi whether something that doesn’t exist yet would be useful. A question doesn’t wake Lumi and comes without a notification. Lumi asks it in a conversation you start yourself, when it fits, and at most once; after two conversations or its deadline (usually one week) it is over. Each business has at most one open. If you answer, Lumi passes your answer on like a wish, with your yes. Every question is logged like a suggestion.

Learning from the chats: Once a week an AI (Claude by Anthropic, section 6) reads the chats of the last seven days within the business’s instance: what the people write and what Lumi and the agents answer, without the own chats of staff and without the work on e-mails in the background. It leaves out lines with an e-mail address or phone number beforehand. In general words it notes where Lumi didn’t help and what the business wishes for, without names, guest data or amounts. Only these anonymous findings leave the instance; no person reads chats for this. This applies to all businesses, also with a connected Google account, and is on until the business turns it off: in the onboarding at the step “Feedback straight through Lumi” and under Settings → Privacy (“Learn from our chats”). Every run and every collection of the findings is logged. Lumina bears the costs, not the business’s credits.

At present, only Lumi’s operator has this access. What the operator reads at a business can end up in the chat of the operator’s own Lumi instance, which also works with Claude. There it is deleted after 90 days, and that instance’s log after one year. The operator collects the wishes, answers to questions, numbers and findings once a week and evaluates them with Claude Code (also Claude by Anthropic) on the operator’s computer; in what comes of it, businesses appear only under a pseudonym.

8. Transfers abroad

The businesses’ data is stored in Switzerland. Anthropic, OpenAI, Stripe, Apple and Google also process data in the USA and other countries. For companies in the USA certified under the Data Privacy Framework, protection is deemed adequate under Swiss and EU law. Otherwise Lumina bases the transfer on the European Commission’s standard contractual clauses, which the Swiss Federal Data Protection and Information Commissioner (FDPIC) also recognises, with the adjustments needed for Switzerland.

9. How long

Lumina keeps a business’s data for as long as it uses Lumi. The business can delete or disconnect memory entries, routines and reminders, website logins and connections in the app at any time.

Sessions end 30 days after they were last extended, or when you sign out. The server doesn’t store dictation recordings. Backups are made daily and deleted after 14 days.

If a business closes its account (section 10), Lumina deletes its data within 30 days; it disappears from the backups no later than 14 days after that. Lumina keeps payment records for as long as the law requires, in Switzerland ten years (Art. 958f of the Swiss Code of Obligations). Anthropic, OpenAI and Stripe keep data according to their own periods.

10. Deleting your account and data

In the app: Settings → General → Delete account, in the browser and in the apps for iPhone, iPad, Mac, Android and Windows. Your login is deleted right away, along with your sessions, your personal settings and the devices that receive notifications.

If you are the last person with access to the business, Lumina closes the business in Lumi: all work stops, Google, Microsoft and the connected apps lose their access, a booked plan ends with the current month, and Lumina deletes the instance with all its data within 30 days. It disappears from the backups 14 days later. Only payment records are kept, as far as the law requires.

Without the app: write to theodore@getlumina.org from your account’s e-mail address and give the address of your business (such as muster.getlumina.org). Lumina deletes your account and confirms it to you. If the whole business should be deleted, say so.

Guests and other people whose data appears in e-mails, reservations or reviews contact the business (section 3).

11. Security

Each business has its own instance with its own database and its own address. Connections are encrypted with HTTPS, passwords are stored only as hashes, access keys and website logins encrypted. Every look by Lumina at content is logged. No system is completely secure; if you report a vulnerability to theodore@getlumina.org, Lumina takes care of it right away.

12. Your rights

You can ask for information about your data, have it corrected, deleted or restricted, object to processing, receive your data in a common format and withdraw consent at any time, within the FADP and, where it applies, the GDPR. Write to theodore@getlumina.org; Lumina answers within 30 days and may ask you to show that it is your account.

You can also complain to the Swiss Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern, or to the data protection authority of your country in the EU.

13. Children

Lumi is made for businesses, not for children. A login is meant for adults and staff of a business.

14. Changes

Lumina updates this privacy policy when Lumi or the law changes. The current version is at /datenschutz on your business’s address; Lumina informs you about significant changes in the app or by e-mail. This policy exists in German, English, French and Italian; the German version governs.