Privacy Policy

Lumi360 is a family organisation platform operated from South Africa. In this Privacy Policy, “Lumi360”, “we”, “us” or “our” refers to the Lumi360 service and its operator.

If you have questions about this Privacy Policy or how your information is handled, you can contact us at hello@lumi360.io.

Depending on how you use Lumi360, you may provide information such as:

Account information

• Your name
• Email address
• Phone number
• Login and authentication information
• Account creation information
• Subscription and account status information

Family information

You may choose to add information about members of your family, such as:

• Names
• Relationships
• Birthdays
• Activities
• Sports
• Dance, music or other extracurricular activities
• School information
• Classes, groups or teams
• Preferences and interests
• Family notes
• Other information you choose to store in your family workspace

Content you create or upload

You may also choose to provide:

• Voice commands
• Written notes
• Photos
• Screenshots
• School newsletters
• School notices
• Forms
• Documents
• Images of documents
• Meal information
• Shopping information
• Calendar information
• Other family-related content you choose to add to Lumi360

This information is provided by you for the purpose of helping Lumi360 organise and manage your family's information.

Lumi360 allows you to upload screenshots, photographs, documents or other images containing information that you want Lumi to understand or organise.

For example, you may upload a screenshot of:

• A school message
• A school notice
• An activity schedule
• A competition announcement
• A form
• A WhatsApp message
• A calendar entry
• Another piece of information relevant to your family

Lumi360 may process the information contained in these uploads so that it can help you organise, understand or retrieve that information.

Uploaded files are privately stored.

Access to an uploaded document or file is controlled according to the permissions associated with that file. Depending on the file and the user's relationship to the family, access may be available to the person who uploaded it, an authorised adult or administrator, or another family member who has been explicitly permitted to access that document.

One family cannot access another family's uploaded files.

Uploaded documents and screenshots may remain stored in your family's document or information area so that you can access them later.

You should only upload information that you are authorised to provide to Lumi360.

Your family workspace is intended to be a private area for you and your family.

Lumi360 has no staff interface for opening or browsing a family's private content, and staff do not review family content in the normal operation of the service.

Lumi360 staff do not have a normal application interface through which they can open another family's:

• Family profiles
• Calendar or events
• Activities
• School information
• Documents
• Screenshots or uploaded images
• Notes
• Meals
• Shopping information
• Lumi conversation content
• Voice-derived text
• Other private family workspace content

For account administration and service operation, authorised Lumi360 personnel may have access to limited account-level information such as:

• Account holder name
• Email address
• Phone number
• Plan and account status
• Relevant usage counts
• Relevant dates and timestamps

This information may be used for account administration, service operation, support, security and related business purposes.

As with any hosted technology service, authorised personnel with infrastructure-level responsibility could technically reach stored information where necessary to operate, secure, maintain or support the service. Such access is restricted to what is reasonably necessary and is subject to appropriate security and confidentiality controls.

Lumi360 does not provide routine staff access to browse or review your family's private workspace.

We use information provided to Lumi360 to operate and provide the service. This may include:

• Creating and managing your account
• Maintaining your family workspace
• Storing information you choose to save
• Organising family information
• Creating calendar events and reminders at your request
• Helping you manage activities and schedules
• Organising school information
• Processing documents and screenshots
• Helping you find previously stored information
• Responding to your voice or written requests
• Providing Lumi AI functionality
• Processing payments and subscriptions
• Providing customer support
• Maintaining service security
• Detecting and preventing misuse
• Troubleshooting technical problems
• Improving the reliability and functionality of Lumi360

We do not use your family information simply because it exists in your account. Its use is connected to providing, securing and improving the Lumi360 service.

Lumi360 includes an AI assistant called Lumi. When you ask Lumi to do something, information necessary to understand and carry out your request may be processed by AI or other technology providers used by Lumi360.

For example, if you say:

“Remind me that Alyah has dance tomorrow.”

Lumi may process that request to understand the person, activity, date and intended action. Lumi may also use information already stored in your family workspace when that information is necessary to correctly understand your request.

Information sent to an AI provider is sent only as needed to process your request and provide the functionality you have asked for.

Lumi360 does not use your family content to train public AI models.

Lumi360 is designed so that important information is stored as structured data rather than relying solely on a conversation or temporary AI context.

AI processing is used to provide the functionality you request. It is not intended to provide Lumi360 staff with routine access to browse your family's private information.

Lumi360 includes voice functionality that allows you to speak naturally to Lumi.

Lumi360 does not store the original voice recording. When you use voice functionality, the audio is sent to a transcription provider so that it can be converted into text. The original audio is then discarded.

Only the resulting text may be stored where applicable, such as when you ask Lumi to save something or when text is required to complete the requested functionality.

Voice input may contain personal or family information if you choose to speak that information.

We use voice information only as necessary to provide the relevant functionality, maintain the service, address security or technical issues, and comply with applicable legal obligations.

Information stored within a Lumi360 family workspace is associated with that family's account. Access to the workspace is controlled through account authentication and the permissions available within the service.

Family information is protected through database-level access controls and family membership permissions.

Different family roles may have different levels of access to information. For example, certain information may be restricted to authorised adults, administrators or explicitly permitted family members.

You are responsible for keeping your account credentials secure and for ensuring that people you allow to access your account are authorised to do so.

If you believe that someone has gained unauthorised access to your account, please contact us as soon as possible at support@lumi360.io.

Lumi360 is designed for family use and may contain information relating to children. This may include:

• Names
• Ages or dates of birth
• School information
• Activities
• Sports
• Dance or music activities
• Schedules
• Preferences
• Notes
• Documents
• Other information provided by a parent or authorised family member

We recognise that information relating to children requires particular care.

Parents or guardians should only provide children's information where they are authorised to do so.

We process children's information for the purposes of providing the Lumi360 family service and in accordance with applicable privacy laws.

If you purchase a Lumi360 subscription or other paid service, payment information may be processed by our payment service provider.

Lumi360 does not need to store your full bank card details in order to provide your subscription.

Payment providers may process information such as:

• Payment details
• Transaction amount
• Currency
• Transaction status
• Payment date
• Refund information
• Information necessary to identify and manage your subscription

Payment processing is subject to the payment provider's own terms and privacy policy. For billing questions, contact us at billing@lumi360.io.

Lumi360 may use trusted third-party service providers to operate parts of the service. These may include providers supporting:

• Hosting and database infrastructure
• Authentication
• AI processing
• Voice transcription
• File and document storage
• Payment processing
• Email or communications
• Security
• Technical monitoring
• Website and application infrastructure

Where third parties process personal information on behalf of Lumi360, we take reasonable steps to ensure that they are subject to appropriate confidentiality, security and data-processing requirements.

Third-party providers only receive or process information where reasonably necessary for the service or the specific functionality being provided.

Some technology and service providers used by Lumi360 may operate infrastructure or process information outside South Africa.

Where personal information is transferred to or processed in another country, Lumi360 will take reasonable steps to comply with applicable requirements under POPIA, including requirements relating to cross-border transfers of personal information.

Where required by law, appropriate safeguards or permissions will be implemented.

We take reasonable technical and organisational measures designed to protect personal information against:

• Loss
• Damage
• Unauthorised access
• Unauthorised disclosure
• Unauthorised modification
• Unlawful processing

These measures include appropriate authentication, access controls, database-level security policies, secure storage controls, restricted administrative access and secure transmission technologies.

Family data is separated through database-level access controls so that one family cannot access another family's information.

Uploaded files are stored in private storage and access is controlled according to the applicable family and document permissions.

No online service can guarantee absolute security. However, Lumi360 is designed to limit access to personal information to what is reasonably necessary to operate and protect the service.

If a security compromise occurs that requires notification under applicable law, Lumi360 will follow the applicable legal requirements for responding to and notifying affected parties and/or the Information Regulator.

We retain information for as long as reasonably necessary to:

• Provide the Lumi360 service
• Maintain your account
• Provide access to information you have chosen to store
• Meet contractual obligations
• Resolve disputes
• Maintain appropriate business and transaction records
• Meet legal or regulatory requirements
• Protect the security and integrity of the service

When information is no longer reasonably required, it may be deleted, anonymised or securely disposed of in accordance with applicable requirements.

Under applicable privacy laws, including POPIA, you may have rights relating to your personal information. These may include the right to:

• Request access to personal information we hold about you
• Request correction of inaccurate or incomplete information
• Request deletion where legally permitted
• Object to certain processing
• Request information about how your personal information is processed
• Withdraw consent where processing is based on consent
• Lodge a complaint concerning the processing of your personal information

Lumi360 does not currently provide a self-service data export or deletion button.

If you wish to exercise a privacy right, including a request for access, correction or deletion, please contact Lumi360 at support@lumi360.io.

We will handle requests within a reasonable timeframe and subject to applicable legal requirements.

Some rights may be subject to legal limitations or other applicable requirements.

Lumi360 is committed to complying with applicable requirements of the Protection of Personal Information Act, 2013 (POPIA).

We aim to process personal information lawfully, fairly and transparently and only for appropriate purposes connected to the operation of the Lumi360 service.

Where applicable, Lumi360 will take reasonable steps to ensure that personal information is:

• Collected for a specific and lawful purpose
• Relevant and not excessive for that purpose
• Kept reasonably accurate
• Protected against unauthorised access or processing
• Retained only for as long as reasonably necessary
• Handled in accordance with applicable data-subject rights

Lumi360 also recognises that information relating to children may receive additional protection under applicable law.

We may update this Privacy Policy from time to time to reflect:

• Changes to Lumi360
• Changes to our services
• Changes in technology
• Changes in applicable law
• Changes to our privacy practices

When we make material changes, we will take reasonable steps to make the updated policy available to users.

The “Last updated” date at the top of this Privacy Policy indicates when it was most recently updated.

If you have questions about this Privacy Policy, want to exercise a privacy right, or have a concern about how your personal information is being handled, please contact Lumi360:

• General and privacy questions: hello@lumi360.io
• Privacy rights and support requests: support@lumi360.io
• Billing and subscription questions: billing@lumi360.io

Lumi360

South Africa

Website: lumi360.io