Lumen · Last updated 2026-08-23
23 August 2026. This Privacy Policy explains what Lumen collects, how we collect and use it, who receives it, how long it is kept, and the choices available to you.
We collect: (a) your email address and account identifier when you create or use an account; (b) answers you enter in the skin questionnaire, such as age range, skin type, sensitivity, acne frequency, pigmentation, skincare goal, routine and environment; (c) face data described below, only when you choose a photo and submit an assessment; (d) subscription status, product and transaction identifiers from Apple, Google, RevenueCat or Stripe; (e) referral activity if you use referrals; (f) records of your acceptance of our Terms, Privacy Policy and face-data consent; and (g) basic network and technical information, such as IP address, request time, device/platform information and error logs, generated when the app communicates with our service. We do not use third-party advertising trackers.
For this policy, "face data" means the selfie or other face photograph you deliberately select from your camera or photo library and the visible cosmetic skin information derived from it during analysis, such as apparent redness, breakouts, dryness or dehydration lines, oiliness and uneven tone. Lumen does not create a face template or faceprint, measure facial geometry, identify you, verify your identity, track you, or use face data for advertising. Camera and photo-library access is used only after you request it. A selected photo stays on your device until you submit it; when you submit, the app securely uploads the photo together with your questionnaire answers for the single analysis you requested.
We use face data only to inspect visible cosmetic skin characteristics for the assessment you request, combine those observations with your questionnaire answers, generate and return a personalised cosmetic skincare routine and product suggestions, keep the service secure and prevent prohibited or abusive use, and troubleshoot a specific request if it fails. Face data is not used to train Lumen or OpenAI models, for facial recognition, identity verification, advertising, marketing, user profiling unrelated to skincare, or sale to any person. The generated routine is saved locally on your device so you can view it later; the submitted face photo is not included in that saved routine.
When you expressly consent and submit an assessment, Lumen discloses your face photo and questionnaire answers to OpenAI, our AI processing provider, solely to generate the requested skin observations and routine and to maintain service safety. Lumen does not disclose face data to Clerk, RevenueCat, Stripe, Apple, Google, advertisers, data brokers or other third parties. We may disclose information if legally required, but would disclose face data only where the law requires it. We do not sell, rent or trade face data.
Lumen holds uploaded face-photo bytes only in encrypted transit and temporary server memory for the duration of the analysis request. We do not write them to our database, file system, backups or object storage. Lumen discards its in-memory copy immediately after the response, error or timeout, normally within 90 seconds. OpenAI may retain the submitted photo and associated request content in abuse-monitoring logs for up to 30 days, unless it must keep content longer for legal or safety reasons; OpenAI does not use API data to train its models unless the account holder explicitly opts in, and Lumen has not opted in. A photo you took or chose may separately remain in your device photo library under your control. Cosmetic observations and the generated routine are stored only on your device until you clear them, delete your account or uninstall the app.
You can remove a selected photo before submission by tapping its remove control. Because Lumen discards an uploaded photo immediately after processing, there is usually no Lumen-held photo to delete after an assessment. You can revoke consent for any future face-data collection or use at any time in About > Account > Revoke face data consent; after revocation, Lumen will not submit another photo unless you give fresh consent. Revocation does not undo an analysis already completed or processing required before the revocation reached us. You may also email hello@eaglettlabs.com to revoke consent or request deletion. We will delete data we control and instruct applicable processors to delete it where required and technically available. OpenAI abuse-monitoring content may remain until its retention period expires or longer where legally or safety-required.
We use Clerk for account authentication; RevenueCat and Apple or Google for mobile subscription status and purchases; Stripe for web billing where offered; hosting, database and email/support providers to operate the service; and OpenAI for the limited face-data processing described above. Each receives only information needed for its function. We require every third party with whom Lumen shares face data or other personal data to provide the same or equivalent protection described in this policy and required by applicable App Store rules, including limits on purpose, security, retention and deletion. We do not authorise our providers to sell your data or use face data for their own advertising.
We keep account, consent, referral and subscription records while your account is active. After account deletion, we delete or de-identify those records, subject to limited records that must be retained for fraud prevention, disputes, tax, accounting or other legal obligations. Such required records are kept only for the applicable legal period. Operational security logs are normally retained for no more than 30 days unless an incident or law requires longer retention. Billing providers and app stores retain transaction records under their own legal obligations. To delete your account and Lumen-controlled data, use About > Account > Delete account. If you cannot sign in, email hello@eaglettlabs.com from your account email; we will complete a verified request within 30 days. Deleting the account also clears the locally saved routine from the app, but does not delete an original photo from your device photo library or cancel an Apple/Google subscription, which you manage in store settings.
We use non-face information to create and secure your account, authenticate requests, generate your requested routine, remember it on your device, provide subscription access, process purchases and referrals, answer support requests, prevent fraud or misuse, diagnose errors, maintain and improve reliability, comply with law, and enforce our terms. We do not sell personal information or use it for third-party advertising.
Depending on where you live, you may have rights to access, correct, export, restrict, object to processing of, or delete your personal information, and to withdraw consent. Contact hello@eaglettlabs.com to exercise these rights. We use transport encryption, access controls and data-minimisation measures to protect information, but no transmission or storage method can be guaranteed completely secure.
Lumen is not intended for children under 16 or under the applicable age of digital consent in their country, and we do not knowingly collect their personal information or face data.
We may update this policy. If a change materially affects face-data collection, use, sharing or retention, we will update the effective date and request new consent before applying the change to future face-data processing. Questions, rights requests and face-data deletion or consent requests may be sent to Eaglett Ltd at hello@eaglettlabs.com.