Lumora Privacy Policy

Last Updated: August 2026

Lumora (“Lumora,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal information.

This Privacy Policy explains what information Lumora accesses and processes, how that information is used, whether it is shared, how long it is retained, and how you can withdraw consent or request deletion.

1. Camera and Face Data

Lumora uses your device’s camera to provide facial exercise, facial landmark tracking, facial tracking, and facial analysis features.

When you use these features, Lumora may process information including:

• Facial landmarks and landmark coordinates

• Facial measurements and proportions

• Face width and face height

• Facial shape measurements

• Jaw width and jaw angle

• Face ratio

• Facial symmetry measurements

• Facial movement and expression information

• Facial pressure-point locations used during exercises

• Other facial information required to provide the facial exercise and analysis features

For purposes of this Policy, this information is referred to as “Face Data.”

2. How Face Data Is Collected

Face Data is obtained through the device camera while you actively use Lumora’s facial exercise, facial tracking, or facial analysis features.

Lumora does not activate facial tracking without the appropriate camera permission from the user.

Camera access is controlled through the permission system provided by Apple.

3. How We Use Face Data

Lumora uses Face Data only to provide functionality directly related to the Lumora application.

This includes:

• Detecting facial landmarks.

• Tracking facial movements during exercises.

• Displaying facial pressure points.

• Guiding users during facial exercises.

• Checking facial movements during exercises.

• Measuring facial proportions.

• Measuring facial symmetry.

• Providing facial analysis results.

• Providing feedback about exercise performance.

• Improving the user’s interaction with Lumora’s facial exercise features.

Lumora does not use Face Data for:

• Advertising

• Marketing

• Authentication

• Identifying users

• Building advertising profiles

• Creating user profiles unrelated to Lumora’s functionality

• Selling or renting information

• Data mining for unrelated purposes

Apple’s requirements prohibit the use of Face Data for advertising, marketing, authentication, profiling, and other unrelated purposes. (Apple Developer)

4. Face Data Processing and Storage

Lumora is designed to process Face Data locally on the user’s device.

Lumora does not upload Face Data to Lumora’s servers.

Facial landmarks, facial tracking information, and other Face Data used during an active exercise or analysis session are processed on the device for the purpose of providing the requested functionality.

Lumora does not maintain a server-side database containing users’ Face Data.

5. Camera Images and Video

Lumora uses the camera’s live feed to perform facial tracking and analysis.

The camera feed is used to provide the application’s functionality and is not collected by Lumora for advertising, marketing, or unrelated purposes.

Lumora does not intentionally upload the user’s camera feed to its servers for facial analysis.

6. Hand Tracking

Some Lumora exercises use hand tracking to determine whether the user’s fingers are positioned correctly on the facial pressure points.

Hand-tracking information may include hand landmarks and finger positions.

Hand-tracking information is processed on the user’s device and is used only to provide exercise guidance and verify the user’s movements.

Lumora does not upload hand-tracking information to its servers.

7. Facial Analysis Results

Lumora may calculate facial measurements and analysis results on the device, including measurements relating to:

• Face Width

• Face Height

• Facial Shape

• Jaw Width

• Jaw Angle

• Face Ratio

• Facial Symmetry

These measurements are generated to provide the facial-analysis functionality of Lumora.

They are not used for advertising, marketing, authentication, or unrelated user profiling.

8. Face Data Sharing

Lumora does not sell, rent, or share Face Data with:

• Advertisers

• Advertising networks

• Data brokers

• Marketing companies

• Analytics providers

• Information resellers

• Other unrelated third parties

Lumora does not transfer Face Data off the user’s device.

If Lumora introduces a feature in the future that requires Face Data to be transferred to a third party, Lumora will clearly disclose the purpose of that transfer and obtain the required user consent before the transfer occurs.

Any third party with whom Lumora may share Face Data will be required to protect that Face Data with protections that are the same as or equal to those described in this Privacy Policy and required by applicable law and Apple’s requirements.

Apple’s current Developer Program terms specifically require equivalent protection when user/device data is shared with third parties. (Apple Developer)

9. Third-Party SDKs and Technologies

Lumora may use third-party software libraries and frameworks to provide application functionality, including technologies used for computer vision, facial landmark detection, and hand tracking.

These technologies may process information on the user’s device as part of providing Lumora’s functionality.

Lumora does not authorize third-party SDKs to use Face Data for advertising, marketing, profiling, or unrelated purposes.

Where Face Data is shared with a service provider in the future, that provider will be required to provide protections equal to those described in this Privacy Policy.

10. Face Data Retention

Lumora does not maintain a server-side copy of your Face Data.

Face Data used for live facial tracking and exercise functionality is retained only for as long as necessary to perform the relevant functionality during the active session.

When the relevant processing is complete, temporary Face Data is discarded from the active processing session.

If Lumora stores a facial measurement or analysis result locally on your device for a specific application feature, that information remains on the device until it is deleted through the applicable Lumora functionality, the operating system, or by deleting the Lumora application.

11. Face Data Deletion

Because Lumora does not maintain a server-side database of Face Data, there is no server-side Face Data account that requires deletion.

Temporary Face Data used during an active tracking session is discarded when it is no longer required.

If facial measurements or analysis results are stored locally on your device, you may delete them using any deletion functionality provided within Lumora or by deleting the Lumora application from your device.

12. Withdrawing Consent

You can refuse or withdraw camera permission at any time through your device’s privacy settings.

On iOS, you can manage Lumora’s camera permission through:

Settings → Privacy & Security → Camera → Lumora

If camera permission is withdrawn, features that require camera access, including facial tracking and facial exercises, will no longer function.

Because Lumora does not upload Face Data to its servers, withdrawing camera permission also prevents Lumora from accessing new camera-based Face Data.

13. Data Security

Lumora is designed to minimize the collection and transmission of personal information.

Face Data used for facial tracking and exercise functionality is processed locally on the user’s device and is not transmitted to Lumora’s servers.

We take reasonable technical and organizational measures to protect information used by Lumora.

However, no electronic system or method of transmission can be guaranteed to be completely secure.

For this reason, Lumora does not make an absolute guarantee that information is “100% secure.”

14. Data Used for Advertising and Marketing

Lumora does not use Face Data for advertising or marketing.

Face Data is not used to create advertising profiles or target users with advertisements.

Lumora does not sell Face Data to advertisers or advertising networks.

15. User Rights

Depending on your location and applicable law, you may have rights regarding your personal information, including the right to:

• Ask what personal information Lumora processes.

• Request deletion of personal information held by Lumora.

• Withdraw consent for camera access and Face Data processing.

• Ask questions about how your information is processed.

Because Face Data is processed locally and is not stored on Lumora’s servers, Lumora generally does not have a server-side copy of Face Data to provide or delete.

16. Children’s Privacy

Lumora is not intended to knowingly collect personal information from children in violation of applicable laws.

Lumora does not knowingly collect or store children’s Face Data on its servers.

If you believe that a child has provided personal information to Lumora that should not have been provided, please contact us.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to Lumora’s functionality, data practices, legal requirements, or privacy practices.

When we make material changes, we will update the “Last Updated” date at the top of this Policy and provide additional notice where required.

18. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or Lumora’s handling of Face Data, please contact us at:

Email: contact@atomicity.in

Company: DBQP ATomicity solutions PVT LTD

Website: www.Atomicity.in

Our Privacy Commitment

Lumora is designed around minimizing data collection.

Face Data stays on your device.

We do not sell Face Data.

We do not use Face Data for advertising or marketing.

We do not upload Face Data to our servers.

You control camera access through your device settings.