LUMO Privacy Policy

LUMO fitness and wellness app and coach marketplace

Effective date: November 2026

Website: https://www.lumoltd.com

Contents

1. Scope and who controls your data

2. Key terms and roles

3. Information we collect

4. How we collect information

5. How and why we use information

6. How Users and Coaches share information

7. Permissions and choices

8. Payments, subscriptions and coach payouts

9. Service providers and other disclosures

10. International transfers and data hosting

11. Legal bases where applicable

12. Retention and deletion of data

13. Security

14. Account deletion and privacy requests

15. Children’s privacy

16. Direct marketing and communications

17. Health and wellness disclaimer

18. Regional privacy rights

19. Changes to this Policy

20. Contact and complaints

This Privacy Policy explains how LUMO Ltd. ( “LUMO”, “we”, “us” or “our”) collects, uses, shares, protects and retains personal data when people use the LUMO fitness and wellness mobile app, coach marketplace, related website and support channels (together, the “Services”). Lumo Ltd. is the data controller, or equivalent responsible organisation, for the processing described here unless another party is identified as independently responsible.

LUMO is initially directed toward Hong Kong. Broader launch and distribution locations are Singapore, Australia and Southeast Asia countries. Regional provisions apply only where the relevant law covers a particular user, coach or processing activity.

This Policy covers personal data processed through the Services. It does not govern a coach’s independent handling of information outside LUMO, or third-party websites, apps and services that have their own privacy notices.

Controller: Lumo Ltd. Registered or principal business address: 2310 Dominion Centre, 43-59 Queen's Road East, Wanchai,Hong Kong . Privacy contact: lumoltd8@gmail.com

A “User” is a person who uses LUMO to track fitness or wellness information, discover or connect with coaches, communicate, share files or resources, book sessions or make eligible payments.

A “Coach” is a service provider who maintains a marketplace profile, communicates with Users, reviews client progress information that the User has permitted LUMO to make available, shares resources, manages bookings and may receive eligible payouts.

“Personal data” means information relating to an identified or reasonably identifiable person. Some wellness, health-related, location, identity and financial information may be considered sensitive or specially protected under applicable law. LUMO will handle such information with additional care and will seek consent where consent is legally required.

We collect only information that is reasonably necessary for stated purposes, taking account of the features a person chooses to use. If optional information is not provided, some related features may not work.

This includes name, email address, telephone number, username or account identifier, profile photo, preferences, settings and other profile details. If you choose to sign in with a third-party account (such as Apple or Google), we receive the identifiers and basic profile details (such as name and email address) that you authorise that provider to share.

Users may submit food logs, nutrition information, daily activity and exercise records, weight tracking, goals, progress entries, measurements, notes, images, documents and other fitness or wellness information. Depending on content and local law, this may be sensitive or health-related information. Food and activity data is stored in LUMO’s systems to provide progress history and insights and is not shared with third-party analytics services.

For Coaches, we collect the information a Coach chooses to add to their profile, such as professional biography, areas of expertise, qualifications, credentials, profile images, availability, service offerings and rates, together with payout information and records relating to bookings, complaints and compliance with our terms. Qualifications and credentials are self-reported by the Coach and shown on their profile. LUMO does not review or verify them, so Users should make their own checks before engaging a Coach.

We process in-app chat messages, message metadata, images, documents, resources and other files that Users and Coaches submit or exchange. Participants should not share information that is unnecessary for the coaching relationship. LUMO may access communications where reasonably necessary to deliver the feature, investigate safety or misuse, provide support, comply with law or enforce applicable terms.

We may process booking details, appointment times, service selections, cancellation status, payment status, transaction references, subscription level, renewal status, refunds and payout status. Payment and subscription data may be received from Stripe, Apple In-App Purchase and Google Play Billing, as applicable. Full card or bank-account details are handled by the relevant payment or platform provider and are not stored by LUMO.

This may include device type, operating system, app version, language, time zone, network information, device or app identifiers where applicable, feature interactions and security events. We use Firebase Crashlytics (provided by Google) to collect crash logs and diagnostic data, such as app version, device model, operating system, a Crashlytics installation identifier and the time and type of an error, so we can find and fix problems. This data does not include the content of food logs, activity records or chats.

If a person grants location permission, LUMO collects the device’s precise location (latitude and longitude) to power the nearby filter, which helps Users find Coaches near them and helps Coaches find nearby Users. Location is used to calculate distance; other people see an approximate distance or area, not your exact coordinates. Location permission is optional, can be turned off at any time in device settings, and the nearby filter may not work without it. Approximate location may also be inferred from an IP address for security or legal purposes.

If a User chooses to connect them, LUMO can read activity, exercise and other health data from Apple Health (on iOS) and from Health Connect, Google Fit or Samsung Health (on Android), limited to the data types the User approves in the permission screen. LUMO may also use the camera, photo library and notification services when the related feature is used. We request access in context and limit collection to what is needed for the selected feature. Data from health platforms is handled under each platform’s rules, is not used for advertising and is not shown to Coaches.

When a person contacts us or reports an issue, we may collect the request, correspondence, attachments and related account or device details. We may also create records concerning fraud prevention, safety incidents, policy enforcement, disputes, complaints, consent, data requests and legal compliance.

We collect information directly through registration and profile forms, food logs, activity tracking, settings, booking and payment flows, chat, support requests, and other forms. We collect files or images when a person uploads them or authorises camera or photo-library access.

We collect some device, usage, permission and security information automatically when the Services are used. Device permissions are requested in context and can generally be changed in device settings.

We receive limited information from integrated providers, including payment and app-store platforms. Our hosting, push-notification and diagnostics providers, and any health-platform integration a person chooses to enable, may also process information as described in this Policy and in their own notices.

The table below summarises our main data uses. A particular use may involve more than one category, and recipients receive only the information reasonably needed for their role.

Category

Main purposes

Typical recipients

Retention

Account   and profile

Create and   secure accounts; authenticate; personalise profiles; deliver Services

Lumo staff   and contractors; hosting or authentication providers; Users or Coaches where   a profile is shown

Until the   account is deleted

Fitness, wellness and progress

Store history; provide insights; support coaching and   permitted progress review

Lumo service and support teams; the selected Coach only   where permitted by app controls

Until the account is deleted

Coach   profile and credentials

Publish   marketplace profile; show self-reported credentials; handle complaints

Users   viewing the marketplace; hosting providers; professional advisers where   needed

Until the   Coach deletes the account

Chat, files and resources

Enable communication and resource sharing; safety,   support and dispute handling

Message participants; cloud storage; authorised support   or safety personnel

Until the account is deleted

Bookings   and session records

Schedule   sessions; send reminders; manage cancellations, service delivery and disputes

The booking   User and Coach; notification providers (Apple and Google)

Kept after   account deletion for the other participant and legal records (see section 12)

Transactions, subscriptions and payouts

Process eligible payments or payouts; reconcile   accounts; prevent fraud; meet tax and legal duties

Stripe, Apple, Google and relevant payout or banking   providers; advisers and authorities where required

Kept after account deletion; generally 7 years (see   section 12)

Device,   diagnostics and security

Maintain   compatibility; troubleshoot; protect accounts; improve reliability

AWS; Google   (Firebase Crashlytics); authorised technical personnel

Until the   account is deleted; Crashlytics reports are deleted after 90 days

Location and optional integrations

Power the nearby filter; provide the requested   health-platform, camera, photo or notification feature

Relevant device, platform or health-app provider when   enabled; other Users or Coaches see approximate distance only

Until permission is withdrawn or the account is deleted

Support,   safety and legal records

Answer   requests; investigate misuse; enforce terms; establish or defend claims;   comply with law

Support and   safety teams; professional advisers; law enforcement or regulators where   lawful

Until the   account is deleted, or longer where needed for a legal claim

We use information to create and manage accounts, provide profiles and marketplace features, connect Users with Coaches, store progress history, generate or display fitness and wellness insights, enable chat and file sharing, manage bookings, process eligible payments or payouts, and maintain the Services.

We use account, device, transaction, communication and support information to protect Users and Coaches, verify activity, detect fraud or abuse, investigate incidents, resolve disputes and respond to support requests. We use appropriately limited technical information, such as crash logs and performance data, to understand reliability and improve the Services. We do not give third-party analytics services access to food or activity logs.

We may use information to keep business and transaction records, respond to lawful requests, exercise or defend legal claims and meet tax, accounting, consumer-protection, privacy and other legal duties. LUMO does not currently use personal data for direct marketing (see section 16).

LUMO is designed to let Users and Coaches interact. When a User views or connects with a Coach, relevant Coach profile information, credentials, services, availability and rates may be visible to the User. When a booking or coaching relationship is created, the User’s and Coach’s names, profile details, booking information and communications may be visible to the other participant.

Chat messages, files and resources are visible to the intended conversation participants. When a User connects with a Coach, that Coach can see the User’s food log, weight tracking and exercise log. Coaches cannot see data that LUMO reads from a User’s connected health apps (such as Apple Health, Health Connect, Google Fit or Samsung Health). When the coaching connection ends, the Coach can no longer view the User’s food, weight or exercise logs in LUMO, although messages and files already exchanged remain visible to both participants.

Users and Coaches are responsible for considering what they share with each other. A recipient may keep information after it has been shared, for example in a message, downloaded file or independent record. LUMO’s in-app controls cannot guarantee deletion from a recipient’s separate systems.

Camera and photo library access are optional and used only when a person chooses to capture or upload an image or file. Notification permission is optional, although disabling it may prevent reminders, booking updates or message alerts. Location permission is optional and is used only for the nearby filter described in section 3.7.

Connections to Apple Health, Health Connect, Google Fit and Samsung Health are off by default. You choose which data types to share in the system permission screen and can turn access off at any time in the relevant health app or device settings. Data received from these platforms is used only to show your activity and progress in LUMO; it is not used for advertising, marketing or data mining, and it is not sold or disclosed to third parties. Sign in with Apple or Google is used only if you choose it. Permissions can generally be changed or withdrawn in device or platform settings, but withdrawing permission may stop the related feature from working.

Users may edit supported profile, food and activity records in the app. Coaches may edit supported profile, availability and service information.

Purchases of LUMO subscriptions and other digital features within the app are processed by Apple In-App Purchase on iOS or Google Play Billing on Android. Payments for coaching sessions and services provided by Coaches are processed by Stripe. Those providers process payment credentials under their own terms and privacy notices. LUMO receives payment status, transaction references, subscription information and limited fraud or refund information, not full card details.

Coach payouts are processed by Stripe (Stripe Connect). Coaches provide identity, tax and bank or payout details directly to Stripe during payout onboarding, and Stripe verifies them under its own terms and privacy notice. LUMO does not store full bank-account numbers; we receive payout status, verification status and limited account details (such as the last four digits of a bank account) needed to manage payouts.

We use service providers to operate LUMO, including Amazon Web Services (AWS) for cloud hosting, databases and file storage; Stripe for coaching payments and Coach payouts; Apple for App Store distribution, In-App Purchase, Sign in with Apple and push notifications (Apple Push Notification service); and Google for Google Play distribution, Google Play Billing, Google Sign-In, push notifications (Firebase Cloud Messaging) and crash reporting (Firebase Crashlytics). If a User connects Apple Health, Health Connect, Google Fit or Samsung Health, data is exchanged with that platform under its own terms. If we add a provider that processes personal data in a materially different way, we will update this Policy.

Providers may process personal data only for authorised purposes and under appropriate contractual, confidentiality and security requirements. Some providers, such as Apple, Google, Stripe or a Coach acting independently outside LUMO, may also determine their own purposes and provide separate privacy notices.

We may disclose information when reasonably necessary to comply with law or legal process; protect rights, safety and security; investigate fraud or misuse; enforce agreements; or establish, exercise or defend legal claims. We may also transfer information in connection with a proposed or completed merger, financing, reorganisation, sale of assets or similar transaction, subject to appropriate protections and notice where required.

LUMO does not sell personal data. We do not use advertising SDKs or advertising identifiers (such as Apple’s IDFA or Google’s Advertising ID), do not disclose personal data to data brokers and do not share personal data for cross-context behavioural or targeted advertising.

The Services, LUMO personnel and providers may process information in more than one country. LUMO’s primary data is hosted on Amazon Web Services (AWS) in its Asia Pacific (Hong Kong) region. Some providers, including Apple, Google and Stripe, may process information in other countries, such as the United States, Singapore or Ireland, under their own safeguards. Where applicable law requires protection for cross-border transfers, we use recognised safeguards, such as our providers’ data processing terms and standard contractual clauses, or another lawful transfer mechanism, and can provide further information on request.

The legal basis for processing depends on where a person is located and the activity involved. We may process information as necessary to perform a contract or take requested steps before a contract; with consent, including where sensitive information or device permissions require it; for legitimate interests such as operating, securing and improving the Services, preventing fraud and supporting Users and Coaches, where those interests are not overridden by individual rights; or to comply with legal obligations.

If consent is the basis, it may be withdrawn for future processing, subject to legal or operational limits. If processing is required to provide a requested feature or complete a booking or payment, declining the necessary information may mean that feature cannot be provided.

We keep personal data while an account is active. When a User or Coach deletes their account, we delete their profile and personal information, except for the limited records described below that we need to keep for the other participant or to meet legal obligations.

Data category

Practical retention rule

Retention period

Account   and profile (including Coach profiles)

Kept while   the account is active

Deleted when the account is   deleted

Food, activity and wellness records

Kept while the account is active, including data   imported from connected health apps

Deleted when the account is   deleted

Chat   messages and uploads

Kept while   the account is active

Deleted when the account is   deleted

Booking, transaction, subscription and payout   records

Kept after a User or Coach deletes their account,   because the other participant needs a record of past sessions and payments,   and to meet tax, accounting and legal duties. The deleted person’s profile   details are removed and the record is linked only to an internal reference ID

Generally 7 years after the   transaction, in line with Hong Kong tax and company record-keeping   requirements

Support,   security and audit logs

Support   records are kept while the account is active. System logs may keep an   internal reference ID after deletion, but no profile details

Support records deleted with the   account; logs kept only as long as needed for security and troubleshooting;   Crashlytics reports deleted after 90 days

Backups

Until overwritten through normal backup rotation;   restored data remains subject to the applicable deletion process

Overwritten within 35 days

When data is deleted, it may remain temporarily in backups until normal backup rotation completes, which happens within 35 days. We may retain limited information for longer where required by law, to resolve disputes, prevent fraud or preserve a legal claim. Records we keep after deletion are linked only to an internal reference ID so they can no longer reasonably be linked to the deleted person’s profile.

We use proportionate technical and organisational measures intended to protect personal data against unauthorised access, loss, misuse, alteration or disclosure. These measures include encrypted connections between the app and our servers (HTTPS), passwords for email-and-password accounts stored only in encrypted (hashed) form, token-based authentication for every request to our servers, sign-in through Apple or Google for people who choose it, and hosting on Amazon Web Services. Access to personal data is limited to authorised personnel who need it for their role.

No system can be guaranteed completely secure. Users and Coaches should protect their credentials, use appropriate device security and notify us promptly of suspected unauthorised access. If a data breach is likely to cause harm to affected people, we will notify them and the relevant regulators where required by law.

How to delete your account: in the LUMO app, go to Settings > Account > Delete account. If you cannot access the app, email lumoltd8@gmail.com from the email address linked to your account with the subject “Delete my account”, and we will delete it and confirm by email. When an account is deleted, we immediately and permanently delete the person’s profile and personal information, including food, weight and exercise logs, chats, uploads, location and data imported from connected health apps. We keep booking and transaction records that the other participant needs and that we must keep for tax and legal purposes, linked only to an internal reference ID, as described in section 12.

Users can view or edit supported profile, food and activity records in the app, and Coaches can edit supported profile information. A separate data export or download feature is not currently available. For additional access, correction, portability, objection, restriction, consent-withdrawal or deletion requests that apply under local law, contact lumoltd8@gmail.com. We may ask for information reasonably necessary to verify identity and authority before acting. We will acknowledge your request within 2 business days and aim to complete it within 30 calendar days. Where applicable law requires a shorter period, we will comply with that requirement. If additional time is permitted and reasonably required due to the complexity or nature of the request, we will notify you of the extension and the expected completion timeframe.

LUMO is not intended for persons under 18, and persons under 18 should not create an account or submit personal data.

If we learn that we collected personal data from a child contrary to the applicable age rule, we will take reasonable steps to restrict or delete it, subject to legal requirements. A parent or guardian who believes a child has provided information should contact lumoltd8@gmail.com.

We may send service communications needed to operate an account or booking, such as verification messages, security alerts, payment or subscription notices, booking updates and changes to important terms. These are not marketing messages, although some may still be controlled through device-notification settings where the feature allows.

LUMO does not currently send marketing messages or use personal data for direct marketing. If we introduce marketing in the future, we will update this Policy first and, where the law requires (including under Hong Kong’s Personal Data (Privacy) Ordinance), tell you what data we will use and obtain your consent before sending any marketing. Opting out of marketing will not stop necessary service communications.

LUMO provides general fitness, wellness and coaching support. It is not a medical device and is not intended to diagnose, treat, cure or prevent any disease, injury or medical condition. Information, progress insights and communications through the Services are not medical advice and should not replace advice from a qualified healthcare professional.

Users should seek appropriate professional advice before making decisions that may affect their health, particularly if they have a medical condition, are pregnant, take medication or experience symptoms or injury. This disclaimer is separate from the privacy practices described in this Policy.

Privacy rights vary by location. The provisions below apply only when the relevant law covers the person or processing. LUMO is offered in Hong Kong, Singapore, Australia and other Southeast Asian countries.

For personal data governed by Hong Kong’s Personal Data (Privacy) Ordinance, individuals may request access to and correction of their personal data, subject to permitted exceptions and any lawful fee. LUMO aims to collect data lawfully and fairly, provide notice of purposes and recipient classes, keep data accurate, retain it no longer than necessary, protect it with appropriate safeguards and use it consistently with the notified purpose or an applicable exception. Requests should be sent to the privacy contact in section 20.

For personal data governed by Singapore’s Personal Data Protection Act 2012 (PDPA), individuals may request access to and correction of their personal data, and may withdraw consent to its collection, use or disclosure, subject to legal exceptions. Withdrawing consent may mean we can no longer provide some Services. If a data breach is notifiable under the PDPA, we will notify the Personal Data Protection Commission and affected individuals as required. Requests should be sent to the privacy contact in section 20, and unresolved concerns may be raised with the Personal Data Protection Commission.

Where the Privacy Act 1988 (Cth) and the Australian Privacy Principles apply, individuals may request access to and correction of their personal information and may complain about a possible breach of the Australian Privacy Principles. Personal information may be disclosed to overseas recipients as described in sections 9 and 10, including providers located in Hong Kong, Singapore and the United States. Complaints should first be sent to the privacy contact in section 20. If a complaint is not resolved within 30 days, a person may contact the Office of the Australian Information Commissioner.

If EEA or UK data-protection law applies, a person may have rights to access, correct or erase personal data; restrict or object to certain processing; receive certain data in a portable format; withdraw consent for future processing; and complain to a competent supervisory authority. These rights are subject to legal conditions and exceptions. Where processing relies on legitimate interests, further information about the balancing assessment may be requested.

If California privacy law applies to Lumo and the relevant processing, a California resident may have rights to know, access, correct or delete personal information and to receive information about categories, sources, purposes and disclosures. Additional rights concerning sale, sharing or targeted advertising apply only if those activities and legal thresholds are present. LUMO does not sell personal data or share it for cross-context behavioural advertising (see section 9). We will not unlawfully discriminate against a person for exercising an applicable right.

People in other locations may have additional rights under applicable law. Contact us to make a request. We may explain if a requested right does not apply or if a lawful exception limits what we can provide.

We may update this Policy as LUMO, our providers, distribution locations or legal requirements change. We will post the updated version and revise the effective date. If a change is material, we will provide additional notice through the app, website, email or another appropriate channel before the change takes effect where required.

Controller: Lumo Ltd. Website: https://www.lumoltd.com. Registered or principal business address: 2310 Dominion Centre, 43-59 Queen’s Road East, Wanchai, Hong Kong. Privacy contact: lumoltd8@gmail.com. Support contact: lumoltd8@gmail.com. Account deletion: see section 14.1.

Please describe the issue or request and provide enough information for us to identify the relevant account and verify authority. We will investigate and respond in accordance with applicable law. If a concern is not resolved, a person may contact the Office of the Privacy Commissioner for Personal Data in Hong Kong where appropriate, or a competent data-protection authority in another region where that right applies.