Privacy Policy
Last updated: November 14, 2026
In short. We collect what we need to run our apps: your email, your quiz answers and basic technical data. Card details are handled by our merchant of record (Paddle or Creem), not by us. We never send your quiz answers to advertising pixels, and we do not sell your personal information. You can ask us to see, correct or delete your data at any time.
1. Who is responsible
This policy explains how Hissa Kyrylo, individual entrepreneur (Ukraine), trading as Lumero Apps, 6 Klovskyi descent, apt. 16, Kyiv 01001, Ukraine (“we”, “us”) handles personal information. It applies to lumeroapps.com and to every web app we operate that links to this policy (each an “App”). We are the controller of the personal information described here. Contact: support@lumeroapps.com.
2. What we collect
Information you give us
- Email address, when you save a result, make a purchase or sign in.
- Quiz answers and other inputs, such as your preferences, habits, goals and, in some Apps, a first name or age range. Depending on the App, some answers may touch on sensitive topics; see section 4.
- Messages you send to our support.
Payment information
Payments are processed by our merchant of record, Paddle or Creem, depending on the App. They collect your card or other payment details and billing address under their own privacy policies. We never receive or store your full card number. From them we receive the information needed to provide your purchase: your name and email, country, the product and price, transaction and subscription status, and, in some cases, the card type and last 4 digits.
Information collected automatically
- Device and connection data: IP address, browser and device type, operating system, language and approximate location derived from the IP address.
- Usage data: pages viewed, quiz progress, the link or ad that brought you to the App, and timestamps.
- Cookies and similar technologies; see section 6.
3. Why we use it
| Purpose | Legal basis (GDPR) |
|---|---|
| Running the App, generating your result, report or plan, and saving it | Performance of a contract |
| Providing purchases and subscriptions, sending receipts, trial and renewal reminders and service notices | Performance of a contract; legal obligation |
| Answering support requests, handling refunds and cancellations | Performance of a contract; legitimate interests |
| Emails about our Apps and offers (you can unsubscribe at any time) | Consent, or legitimate interests for existing customers where the law allows |
| Understanding how the Apps are used and improving them | Legitimate interests; consent where required for cookies |
| Measuring our advertising (without your quiz answers) | Consent where required; otherwise legitimate interests |
| Preventing fraud and abuse, keeping the Apps secure | Legitimate interests |
| Keeping tax and accounting records, complying with the law | Legal obligation |
We do not make decisions that have legal or similarly significant effects on you based solely on automated processing. Quiz results are generated automatically, but only to give you the result you asked for.
4. Sensitive answers and advertising
Some quizzes ask about topics that can be sensitive, such as faith, emotional wellbeing, health or relationships. We use these answers only to generate your result and provide the App you are using.
- We never send quiz answers, or events that reveal them, to advertising pixels or conversion APIs (for example, Meta Pixel and Conversions API, TikTok Pixel or Google Ads).
- Advertising platforms may receive only standard events, such as a page view or a completed purchase, without your answers or results.
- We do not use sensitive information to infer characteristics about you for advertising, and we do not sell it or share it with data brokers.
5. Who we share it with
- Service providers that work for us under contract and only on our instructions: hosting and infrastructure (such as Cloudflare), email delivery, analytics and customer support tools.
- Merchants of record (Paddle or Creem), which process payments as independent controllers under their own privacy policies.
- Advertising platforms, limited to the standard events described in section 4, and only with your consent where the law requires it.
- Authorities or other parties when required by law, or to protect our rights, our users or the public.
- A buyer or successor if an App or our business is sold or transferred; this policy will continue to apply to your data.
We do not sell your personal information for money.
6. Cookies and similar technologies
We use essential cookies and local storage to make the Apps work, for example to keep your quiz progress and sign you in. With your consent where the law requires it, we also use analytics cookies to understand usage and advertising pixels to measure our ads. You can manage non-essential cookies in the cookie settings of an App, where available, and in your browser settings. We honor Global Privacy Control signals as an opt-out of sale and sharing.
7. How long we keep it
- Account data, quiz answers and results: while you use the App; deleted or anonymized within 24 months after your last activity, or sooner if you ask us to delete them.
- Purchase and transaction records: as long as tax and accounting laws require. The merchant of record keeps its own records.
- Support messages: up to 3 years after the last message.
- Server logs: usually no longer than 90 days, unless needed to investigate a security incident.
- If you unsubscribe from marketing emails, we keep your email on a suppression list so we do not email you again.
8. International transfers
We are based in Ukraine, and our service providers may process data in the United States, the European Union and other countries. Where the law requires it, we use appropriate safeguards for these transfers, such as the European Commission's Standard Contractual Clauses.
9. Your rights
Wherever you live, you can ask us to:
- tell you what personal information we hold about you and give you a copy (access and portability);
- correct inaccurate information;
- delete your information;
- stop or restrict certain uses, and object to processing based on legitimate interests;
- withdraw your consent at any time, without affecting earlier processing;
- stop sending you marketing emails (every email also has an unsubscribe link).
How to make a request. Email support@lumeroapps.com with the subject “Privacy request”, preferably from the address you used in the App. We may ask you to confirm that the address is yours before we act. Requests are free. We respond within one month (or 45 days where US state law applies), and we will tell you if we need more time, as the law allows.
EEA, UK and Switzerland (GDPR). You have the rights listed above, and you can lodge a complaint with the data protection authority in the country where you live or work. We would appreciate the chance to resolve your concern first.
Other US states. Residents of states with consumer privacy laws (for example Virginia, Colorado, Connecticut, Texas or Oregon) have similar rights. If we decline your request, you can appeal by replying to our answer. If you disagree with the outcome of the appeal, you can contact your state attorney general.
10. California residents (CCPA/CPRA)
If you live in California, you have the right to know what personal information we collect, use and disclose; to delete it; to correct it; to opt out of its sale or sharing; to limit the use of sensitive personal information; and not to be discriminated against for using these rights. You can use an authorized agent to make a request on your behalf.
In the last 12 months we collected these categories of personal information, for the purposes described in section 3:
- identifiers (email address, IP address, online identifiers);
- commercial information (products purchased, subscription status);
- internet or other electronic network activity (usage data);
- inferences (your quiz results);
- sensitive personal information, where quiz answers may reveal, for example, religious beliefs or health. We use it only to provide the App, as permitted by the CPRA, and not to infer characteristics about you.
Sale and sharing. We do not sell personal information. Some Apps use advertising cookies or pixels to measure ads; under California law this may count as “sharing” for cross-context behavioral advertising. Your quiz answers are never part of it. To opt out, turn on Global Privacy Control in your browser, use the cookie settings in the App where available, or email us with the subject “Do Not Sell or Share My Personal Information”. We do not knowingly sell or share the personal information of consumers under 16.
11. Children
Our Apps are not intended for children under 13, and we do not knowingly collect personal information from them. If you believe a child under 13 has given us personal information, contact us and we will delete it.
12. Security
We use reasonable technical and organizational measures to protect your information, including encrypted connections (HTTPS), access controls and working only with reputable service providers. No method of transmission or storage is completely secure, but we work to protect your data and will notify you and the authorities of a breach where the law requires.
13. Changes to this policy
We may update this policy from time to time. The date at the top shows the latest version. If we make material changes, we will notify you by email or in the App before they take effect.
14. Contact
Hissa Kyrylo, individual entrepreneur (Ukraine), trading as Lumero Apps
6 Klovskyi descent, apt. 16, Kyiv 01001, Ukraine
Email: support@lumeroapps.com