Privacy Policy

Last updated: 10 May 2026

1. Data Controller

Lumio is a personal clarity mapping service operated by: Mesut Tufan Güner

Offenbacher Landstraße 477

60599 Frankfurt am Main

Germany

Email: hello@lumio.company

2. What Personal Data We Collect

To provide our service, we collect the following data:

Identity & Contact Information:

- Full name

- Email address

- Age

- City and country

- Phone number (optional)

Sensitive Personal Data (from your intake form responses):

- Life experiences and personal milestones

- Strengths, frustrations, and goals

- Information about personal relationships

- Internal contradictions, fears, and private aspirations

We collect sensitive data only when you choose to share it in the intake form. This sharing is entirely under your control — you are not required to disclose information you do not wish to share.

3. How We Use Your Data

We use your data only for the following purposes:

- To prepare your personal clarity report

- To deliver the report to you

- To organize the optional follow-up call (if you opted in)

- To improve service quality (using anonymized feedback)

We do NOT use your data for:

- Marketing or advertising

- Sale to third parties

- Profiling

- Automated decision-making

4. Where Your Data Is Stored

Your data is stored encrypted across the following services:

- Form responses → Tally.so (EU servers, GDPR compliant)

- Analysis files → Proton Drive / Google Drive (EU/US, encrypted)

- AI analysis (temporary) → Anthropic Claude API (US — NOT used for model training)

5. Retention Period

Your data is retained for a maximum of 90 days from the date of report delivery. After 90 days, it is automatically deleted.

If you wish to have your data deleted earlier, send an email to hello@lumio.company. Your request will be processed within 30 days.

6. Transparency on AI Use

The Anthropic Claude AI model is used during the report preparation process. Important details:

- All AI-generated content is reviewed, edited, and approved by a human.

- Your data is NOT used by Anthropic for model training — this is guaranteed by Anthropic's API terms of service.

- Sensitive sections (blind spot analysis, contradiction zone) are written entirely by a human.

7. Your Rights (GDPR & KVKK)

You have the following rights:

- Right of access: You can learn what data is being processed about you

- Right to rectification: You can request correction of inaccurate data

- Right to erasure: You can request deletion of your data ("right to be forgotten")

- Right to object: You can object to data processing

- Right to data portability: You can request transfer of your data to another service

- Right to withdraw consent: You can withdraw your consent at any time

To exercise these rights, contact: hello@lumio.company

8. Cookies

This website uses only essential functional cookies. No marketing or analytics cookies are used.

9. Right to Complain

If you are not satisfied with our data processing, you may file a complaint with:

- Germany: Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI) — bfdi.bund.de

- Turkey: Personal Data Protection Authority — kvkk.gov.tr

10. Changes to This Policy

This Privacy Policy may be updated when necessary. Significant changes affecting existing customers will be communicated via email.