1. Who is responsible for your data?
Lumora is operated by Moritz Affolter, Lohngasse, Port BE, Switzerland ("Lumora," "we," "us," or "our"). Moritz Affolter is the controller of the personal data described in this Privacy Policy.
Privacy questions and requests may be sent to moritz@moritscls.com. General support is available at support@asklumora.com.
2. What this policy covers
This policy applies when you visit asklumora.com, create or use a Lumora account, upload a photo for a skin analysis, purchase a subscription or scan credits, use a referral code, request product recommendations, or contact us. Lumora is operated from Switzerland and offered primarily to consumers in the United States.
Lumora provides cosmetic skincare information. It is not a medical service and does not diagnose or treat disease.
3. Data we collect
Depending on how you use Lumora, we collect:
- Account data: email address, account identifier, authentication records, subscription status, settings, and referral information.
- Scan content: the facial photo you choose to upload, technical image metadata, and the resulting skin-analysis scores, observations, routines, and recommendations.
- Preferences: whether you have affirmatively chosen to save scan photos, cookie choices, budget preferences, and other settings.
- Transaction data: the plan or credit pack purchased, amount, currency, payment status, Stripe customer and transaction identifiers, and billing-period information. Lumora does not receive or store your complete payment-card number.
- Usage and device data: pages viewed, interactions, approximate location derived from an IP address, browser and device information, referral URLs, campaign parameters, experiment assignment, and diagnostic logs.
- Support data: your name, email address, message, and related correspondence when you contact us.
We obtain data directly from you, automatically from your browser or device, from Stripe about transactions, and by generating inferences from the photo and information you submit. Skin observations, scores, routines, and similar inferences may be treated as consumer health data or sensitive personal data under some US state laws even though Lumora is a cosmetic, not medical, service.
Please upload only a photo of yourself. Do not upload another person's photo or any image you are not entitled to use.
4. How we use personal data and why
We process personal data for the following purposes:
| Purpose | Data involved | Legal basis where the GDPR applies |
|---|---|---|
| Provide an account, scans, results, routines, recommendations, credits, and subscriptions | Account data, scan content, preferences, transaction data | Performance of our contract; steps requested before entering a contract |
| Analyze the voluntarily submitted facial photo and produce skin-related observations | Scan content | Your explicit consent where required for sensitive data; otherwise performance of the service you requested |
| Save scan photos for before-and-after and trend features | Scan photos and account preference | Your affirmative consent |
| Secure the service, prevent fraud and abuse, enforce scan limits, and troubleshoot failures | Account, transaction, usage, device, and diagnostic data | Legitimate interests in security, reliability, and preventing misuse; legal obligations where applicable |
| Process payments, cancellations, and refunds | Account and transaction data | Performance of our contract; legal obligations |
| Respond to support requests | Account and support data | Performance of our contract; legitimate interests in customer support |
| Measure and improve Lumora | Consent-based analytics and experiment data | Consent where required; otherwise legitimate interests where permitted |
| Measure advertising performance | Campaign and conversion data | Consent |
| Maintain financial, tax, legal, and compliance records | Transaction, account, and communication data | Legal obligations and establishment, exercise, or defence of legal claims |
You may withdraw consent at any time. Withdrawal does not affect processing that occurred before withdrawal. Some processing is necessary to provide a feature you request; without the relevant data, that feature may not work.
5. How photo analysis works
Lumora sends the photo you submit to an AI service to generate cosmetic observations about visible skin characteristics. The output may include estimates relating to texture, pores, redness, hydration, oil balance, tone, and a suggested skincare routine. Before starting a scan, Lumora presents a clear request to process your photo and generate these inferences. AI results can be incomplete or inaccurate and must not be treated as a medical diagnosis.
Lumora does not use face geometry to identify you and does not use your photo for facial recognition. We do not sell scan photos or use them for advertising profiles.
OpenAI processes the submitted image and associated instructions as a service provider. Lumora uses the OpenAI API with storage disabled for the request. OpenAI states that API inputs and outputs are not used to train its models by default unless the customer opts in, and that standard abuse-monitoring logs may be retained for up to 30 days unless longer retention is legally required. See OpenAI's business data information and API data controls.
6. Your scan-photo choice
The default is not to save your scan photo.
- If you do not affirmatively select Save my scan photos, Lumora deletes the photo from its own storage promptly after the analysis finishes or fails. Technical cleanup removes an abandoned upload within 24 hours. Lumora may retain the scores, routine, and other non-image analysis results so that the service, scan limit, and result history can function.
- If you affirmatively select Save my scan photos, Lumora keeps the photos in private storage so that features such as before-and-after comparisons and skin trends can work. You may change this setting at any time. Switching to automatic deletion deletes previously saved scan photos and causes future scan photos to be deleted after processing.
- Deleting a Lumora photo does not necessarily delete a short-lived copy already processed by a service provider; that provider's limited retention is described above.
The save choice is optional and does not affect access to the basic analysis. You can manage it under Settings → Privacy.
7. Retention
We keep personal data only as long as needed for the purposes described above:
| Data | Typical retention |
|---|---|
| Scan photos when saving was not selected | Deleted after a completed or failed analysis; abandoned uploads deleted within 24 hours |
| Scan photos deliberately saved by an account holder | Until you delete them, switch to automatic deletion, or delete your account |
| Analysis results, routines, scores, and scan history | Until account deletion; guest records may be retained in pseudonymous form to provide results and enforce usage limits |
| Account and preference data | While the account is active and for a short period needed to complete deletion, security, and backup processes |
| Payment and accounting records | For the period required by tax, accounting, payment, and other applicable laws |
| Support messages | Up to 24 months after the request is closed, unless longer retention is needed for a dispute or legal obligation |
| Consent and security records | For as long as needed to demonstrate choices, protect the service, and establish or defend legal claims |
| Consent-based analytics data | No longer than 12 months in identifiable or pseudonymous form, followed by deletion or aggregation |
Backups and provider systems may take a limited additional period to complete deletion. We may retain anonymized statistics that no longer identify an individual.
8. Service providers and recipients
We disclose data only as needed to operate Lumora, comply with law, or protect the service. Current categories include:
- Lovable for application development and hosting infrastructure;
- Supabase for authentication, database, and private file storage;
- OpenAI for AI-assisted photo analysis and recommendation generation;
- Stripe for checkout, subscriptions, billing portal, payment processing, and fraud prevention;
- PostHog for consent-based product analytics and experiment measurement;
- OpenAI advertising measurement for consent-based campaign and conversion measurement; and
- professional advisers, authorities, or transaction counterparties where required by law or a corporate reorganization.
These providers may process technical and personal data under their own security and privacy terms. We do not sell personal data.
9. US Consumer Health Data Privacy Notice
This section supplements the rest of this policy for residents of US states with consumer-health privacy laws, including Washington and Nevada. It is intended to serve as Lumora's Consumer Health Data Privacy Policy.
Categories of consumer health data
Lumora may collect and generate:
- a voluntarily uploaded facial image and associated image metadata;
- visible skin observations and estimates, including texture, pores, redness, hydration, oil balance, tone, and similar characteristics;
- skin scores, concerns, routines, progress history, comparisons, and product recommendations inferred from scans; and
- information showing that a person requested or used Lumora's skin-analysis service.
Lumora does not collect medical records, prescriptions, insurance information, genetic data, or precise location for the purpose of identifying a visit to a healthcare facility. Lumora does not use facial images for identity recognition.
Sources and purposes
We obtain consumer health data directly from the photo and choices you submit and through automated inferences generated to provide the requested analysis. We use it only to deliver scans, results, routines, saved-photo comparisons when selected, progress features, product recommendations, customer support, security, and legally required compliance. We do not use consumer health data for targeted advertising or to build advertising profiles.
Collection, use, and disclosure
We collect and use consumer health data with your affirmative choice or to the extent necessary to provide the analysis or feature you request. Where separate consent is required before disclosure, Lumora requests it separately unless the disclosure is necessary to provide the requested service.
We disclose consumer health data only to the following processors as necessary to provide Lumora:
- Supabase: authentication, database, and private image storage (privacy information);
- OpenAI: AI processing of the submitted image and generation of the requested output (privacy information); and
- Lovable and its hosting infrastructure providers: operation and delivery of the application (privacy information).
Stripe receives transaction and account information but not scan photos or skin-analysis results. PostHog and advertising-measurement providers must not receive photos, skin observations, scores, routines, or scan-failure details. Lumora does not permit third parties to collect consumer health data over time across unrelated websites or services when you use Lumora.
We do not sell consumer health data. If that practice ever changes, Lumora will first provide the separate authorization and other protections required by law; a general acceptance of this policy would not constitute authorization.
Your US consumer-health rights
Subject to applicable law, you may:
- confirm whether Lumora collects, shares, or sells your consumer health data;
- access that data and receive a list of the third parties and affiliates with whom it was disclosed;
- correct inaccurate data where correction is available;
- withdraw consent from future collection or disclosure;
- request deletion of consumer health data, including notification to relevant processors; and
- appeal a refusal to act on your request.
Submit a secure request or appeal through Settings → Privacy or email moritz@moritscls.com with the subject Consumer Health Data Request or Privacy Appeal. We will verify the request without asking for more data than reasonably needed. We ordinarily respond within 45 days, or sooner where required, and explain any permitted extension. If we deny an appeal, we will provide the reason and the relevant state regulator's contact information.
You will not be discriminated against for exercising a privacy right. Withdrawal may prevent Lumora from providing a future scan or feature that necessarily requires the relevant data.
California and other US state rights
If Lumora is subject to a comprehensive state privacy law applicable to you, you may also have rights to know, access, correct, delete, or obtain a portable copy of personal data; to opt out of a sale, targeted advertising, or qualifying sharing; and to limit certain uses of sensitive personal data. Lumora does not sell personal data and does not use consumer health data for targeted advertising. We extend the core access, correction, and deletion request process described above even when a particular statutory business threshold may not apply.
10. International transfers
Our providers may process data in Switzerland, the European Economic Area, the United States, and other countries. Where required, we use recognized safeguards for international transfers, such as adequacy decisions and approved standard contractual clauses. You may contact us for information about the safeguards relevant to your data.
11. Cookies and similar technologies
Lumora uses local storage, first-party cookies, and provider technologies for authentication, security, preferences, referrals, analytics, experiments, payments, and advertising measurement. Non-essential analytics and advertising technologies are used only after consent where required. You can accept, decline, or later change your choice. Details appear in the Cookie Policy.
12. Security
We use reasonable technical and organizational safeguards, including encrypted connections, access controls, private file storage, and separation of payment-card processing. No online service is completely secure, so we cannot guarantee absolute security.
13. Your rights
Subject to applicable law, you may request:
- access to your personal data;
- correction of inaccurate data;
- deletion of data;
- restriction of or objection to certain processing;
- a portable copy of data you provided;
- withdrawal of consent; and
- information about international-transfer safeguards.
You may also complain to a competent supervisory authority. In Switzerland, this is the Federal Data Protection and Information Commissioner. EEA and UK residents may contact the authority where they live or work.
To exercise a right, email moritz@moritscls.com. We may need to verify your identity. Mandatory retention obligations may limit deletion in some cases.
14. Automated processing
Lumora uses automated systems to generate cosmetic observations and recommendations. These outputs do not produce legal or similarly significant effects. You choose whether to act on them and should consult a qualified healthcare professional about medical concerns.
15. Children
Lumora is not intended for children under 16. If you are under 16, do not use the service or upload a photo. Users aged 16 or 17 should use Lumora only when permitted by local law and, where required, with a parent or guardian's permission. Contact us if you believe a child under 16 has provided data.
16. Changes to this policy
We may update this policy when Lumora or the law changes. We will post the revised version with a new update date and provide additional notice if a change materially affects your rights.
17. Contact
Moritz Affolter
Lohngasse, Port BE, Switzerland
Email: moritz@moritscls.com
Support: support@asklumora.com