Privacy Policy

Last updated: June 9, 2026

Introduction

Lumi Software builds apps including Photo Cleaner, Imposter Game!, Finger Chooser, and Dice Roller. Some apps are ad supported and/or offer optional premium subscriptions. This page explains how we collect, use, share, and protect your personal data when you use our apps and services.

Lumi Software B.V., based in the Netherlands, is the data controller responsible for the personal data described in this policy. You can reach us at hello@lumisoftware.io.

Information We Collect

  • Device and usage information (such as device model, OS, crash data).
  • Purchase history and subscription status (through Apple and RevenueCat).
  • Advertising identifiers (for serving ads, with your consent, unless you upgrade to Premium).
  • Log data and analytics to improve app performance.

How We Use Your Information

  • Provide and maintain app functionality.
  • Process and manage subscriptions (via Apple's App Store and RevenueCat).
  • Serve advertising in free versions of our apps.
  • Communicate with you about updates or issues.
  • Detect and prevent fraud or misuse of the service.

Legal Basis for Processing

Under the GDPR, we process personal data on the following legal bases:
  • Performance of a contract — to provide app functionality and to process and manage your subscriptions.
  • Consent — to serve personalised advertising and to use advertising identifiers. You may withdraw your consent at any time.
  • Legitimate interests — to maintain and improve app performance through crash and usage analytics, and to detect and prevent fraud or misuse, where these interests are not overridden by your rights.
  • Legal obligation — to retain certain records (for example, transaction records) where required by law.

Subscriptions and Payments

All payments and subscriptions are processed securely by Apple via the App Store. We do not have access to or store your payment information. Subscription status and entitlements are managed with the help of RevenueCat. Premium users enjoy additional features and an ad-free experience.

Advertising and Tracking

Free versions of our apps may display ads through Google Mobile Ads (AdMob). Serving personalised ads, and using advertising identifiers such as Apple's IDFA, requires your consent.
  • In the European Economic Area and the UK, we ask for your consent through a consent prompt provided by a Google-certified consent management platform before showing personalised ads. If you do not consent, you will see non-personalised ads instead.
  • On iOS, we also present Apple's App Tracking Transparency prompt before any cross-app tracking.
  • You can change or withdraw your advertising choices at any time in your device settings or by reopening the consent prompt.
  • Users below the applicable digital age of consent are served only non-personalised ads.
  • Premium subscribers do not see ads.

How We Share Your Information

We only share information with third parties as described in this Privacy Policy. This includes:

We do not sell your personal information.

International Data Transfers

Some of our service providers, including Apple, Google, and RevenueCat, may process your personal data outside the European Economic Area, including in the United States. Where this happens, the transfer is protected by appropriate safeguards such as the European Commission's Standard Contractual Clauses and/or the EU-US Data Privacy Framework.

Data Retention

We keep personal data only for as long as necessary for the purposes described in this policy. Crash, analytics, and log data are retained for a limited period and then deleted or anonymised. Records relating to purchases and subscriptions may be retained longer where necessary to comply with legal and tax obligations.

Cookies and Similar Technologies

Our apps themselves do not use cookies. However, third-party SDKs such as Google Mobile Ads may use technologies like cookies or similar identifiers to provide their services.

Your Rights

Depending on your location, you have rights under applicable privacy laws (such as the GDPR and CCPA), including the right to:
  • access the personal data we hold about you;
  • request correction of inaccurate data;
  • request deletion of your data;
  • restrict or object to certain processing;
  • request data portability;
  • withdraw consent at any time, without affecting processing carried out before withdrawal.

To exercise these rights, contact us at hello@lumisoftware.io. You also have the right to lodge a complaint with your local data protection authority. In the Netherlands, this is the Autoriteit Persoonsgegevens.

Children's Privacy

Our apps are general-audience apps and are not directed to children. We do not knowingly collect personal data from children for the purpose of advertising personalisation. In the European Economic Area, the digital age of consent varies by country and is 16 in the Netherlands. Where we identify, or have reason to believe, that a user is below the applicable digital age of consent, we serve only non-personalised ads and do not use advertising identifiers for that user without verifiable parental consent. If you are a parent or guardian and believe your child has provided us with personal information, please contact us so we can delete it.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. You are advised to review this page periodically for any changes. Changes are effective immediately after they are posted on this page.

Contact Us

Lumi Software B.V. is the controller responsible for your personal data. Lumi Software B.V. is registered with the Dutch Chamber of Commerce (KvK) under number 42084955. If you have any questions or suggestions about this Privacy Policy, do not hesitate to contact us at hello@lumisoftware.io.