Privacy Policy

Effective date: 2026-05-18
Last updated: 2026-05-18

LumaCard is a children's language-learning app built by Zhi (contact: zhiii0x@gmail.com). We designed LumaCard to be private by default. This page explains, in plain language, exactly what that means.

TL;DR

• We do not collect any personal information.
• We do not use any analytics, advertising, or tracking SDKs.
• We do not send any data to our servers, because we don't have any.
• Everything you do in the app stays on your device.
• The app works fully offline.

If that's all you wanted to know, you can stop reading. The rest of this page is the longer, regulator-friendly version.

1. Information we do not collect

We do not collect, store on our servers, or share with any third party:

• Names, email addresses, phone numbers, or any other contact details.
• Account credentials (the app has no login).
• Location data.
• Microphone, camera, photos, or contacts data.
• Advertising identifiers (IDFA), device fingerprints, or behavioral profiles.
• Crash reports, usage analytics, or telemetry.

We do not display advertising of any kind, and we do not link to social networks.

2. Information stored only on your device

To make the app work, LumaCard stores the following locally on your device. This data never leaves the device unless you explicitly use Apple's iCloud Backup or Device Migration features (which are controlled by Apple, not by us).

• Learner profiles you create in the app (a display name and an avatar emoji you pick).
• Progress data: which cards you've studied, your Leitner spaced-repetition state, tracing scores, puzzle results, and sticker collection.
• Preferences: chosen language, audio settings, daily reminder time.

You can delete all of this at any time by:

• Using the "Reset Progress" controls inside Settings, or
• Deleting the app, which removes all locally stored data.

3. Permissions the app asks for

LumaCard only asks for one permission, and only if you opt in:

• Local Notifications — used solely to send the daily study reminder you set in Settings. We send these on-device; no notification ever passes through our servers. You can disable them in iOS Settings → Notifications → LumaCard at any time.

LumaCard does not request microphone, camera, photo library, location, contacts, Bluetooth, or HealthKit access.

4. Audio in the app

LumaCard plays back pre-recorded audio files bundled inside the app. Audio playback does not require any permission, does not record sound, and does not transmit anything off the device. The on-device text-to-speech (Apple's AVSpeechSynthesizer) is also used and is processed entirely on-device by iOS.

5. Children's privacy (COPPA / GDPR-K)

LumaCard is designed for children and falls under the App Store's "Made for Kids" category guidelines.

• We comply with the U.S. Children's Online Privacy Protection Act (COPPA) by not collecting any personal information from anyone, including children under 13.
• We comply with the EU GDPR-K (Article 8) by the same mechanism: there is no data processing of children's personal data because there is no data processing at all.
• The app contains no behavioral advertising, no third-party SDKs that profile users, no social features, and no in-app purchases targeted at children.
• External links inside the app (privacy policy, contact email) are gated behind a parent-verification step.

6. Third parties

LumaCard does not integrate any third-party SDKs that collect data, including (non-exhaustive list): Google Analytics, Firebase Analytics, Facebook SDK, AppsFlyer, Adjust, Branch, Amplitude, Mixpanel, Segment, Sentry, Crashlytics. We rely solely on Apple's built-in frameworks (SwiftUI, SwiftData, AVFoundation, UserNotifications), which run on-device.

The only Apple service that could process data on our behalf is App Store Connect's built-in crash and engagement metrics, which are aggregated, anonymous, and controlled by Apple's own privacy policy. You can disable Apple-level diagnostics in iOS Settings → Privacy & Security → Analytics & Improvements.

7. Your rights

Because we do not hold any personal data about you, there is no data to access, export, correct, or delete on our end. To delete all your data, delete the app from your device.

If you live in a jurisdiction that grants you specific privacy rights (EU/EEA, UK, California, etc.) and you want to confirm in writing that we hold no personal data about you, email zhiii0x@gmail.com and we will respond within 30 days.

8. Changes to this policy

If we ever change how the app handles data, we will update this page and bump the "Last updated" date at the top. If the change is material (e.g., we add an optional account system), we will surface the change inside the app before the new behavior takes effect.

9. Contact

Questions, concerns, or parental requests:

Email: zhiii0x@gmail.com
Suggested subject: "LumaCard Privacy"

We typically respond within 3 business days.