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Privacy Policy

Last updated: 26 July 2026

This Privacy Policy explains how List or Lift Ltd ("Lumi", "we", "us", or "our") collects, uses, and protects your information when you use the Lumi mobile application and related services (the "App").

We are the data controller for your information. If you have any questions, contact us at privacy@thelumi.co (see "Contact us" below).

  • Company: List or Lift Ltd
  • Company number: 15622259 (England and Wales)
  • Registered office: 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom

Please read this policy carefully. By using the App, you agree to the collection and use of information as described here.


1. A quick summary

  • Lumi is a beauty app. To personalise your skin, hair, and makeup guidance, we process the photos you choose to scan, along with the profile and preferences you give us.
  • Your scan photos may be considered biometric or sensitive data. We only process them with your consent, to give you your results, and you can delete them at any time.
  • Your scan photos are sent to trusted AI providers to generate your results. We do not use your photos to train third-party AI models, and we do not sell your personal data.
  • We do not run third-party advertising and we do not track you across other apps or websites.
  • You can view, edit, or permanently delete your account and data at any time from inside the App.

2. Information we collect

a. Information you give us

  • Account information: your email address, and the name and birth year you provide. If you sign in with Apple or Google, we receive your name and email (or Apple's private relay email if you choose to hide it) from that provider.
  • Profile and preferences: your onboarding answers (such as your goals, skin type, concerns, hair type, and where you like to shop), your routine, your saved looks and boards, and the products on your shelf.
  • Photos and scans: the photos you take or upload for a facial scan, color scan, hair scan, product scan, or "try it on" feature, and the results we generate from them (such as a glow score, undertone, skin metrics, and recommendations).
  • Messages: the messages you send to Lumi, our in-app AI assistant.

b. Sensitive information (your face and scan photos)

To provide the App's core features, we process photos of your face and skin. Depending on where you live, this may be treated as sensitive personal information or biometric data under laws such as the UK GDPR, the EU GDPR, and certain US state laws. We only process this information with your consent, and only to generate and store your results. You can withdraw your consent, and delete your scans or your whole account, at any time from inside the App. See "Your face and scan data" below for the specifics.

c. Information we collect automatically

  • Device and technical data: device type, operating system version, app version, language, and general diagnostic or crash information.
  • Usage data: how you use the App, such as which features you open and your routine completion streak.
  • Approximate network information: your IP address is processed by our backend provider to deliver the service and to protect against abuse.

d. Purchase information

  • If you subscribe, your subscription status and transaction identifiers are processed through Apple and our subscription provider RevenueCat. We never receive or store your full card details. Payment is handled entirely by Apple.

We only ask for the camera and photo library permissions needed to let you scan and try on looks. You can change these permissions at any time in your device settings.


3. How we use your information

We use your information to:

  • Provide the core features of the App, including analysing your scans and generating your personalised results, routines, and recommendations.
  • Create and secure your account, and let your data sync across your devices.
  • Power Lumi, our AI assistant, using the context you have shared (such as your scan and shelf) so its answers are personal to you.
  • Process your subscription and manage your access to premium features.
  • Send you optional reminders and notifications that you have turned on (for example, a routine reminder).
  • Maintain, protect, and improve the App, and to prevent fraud and abuse.
  • Comply with our legal obligations.

We do not use your information for third-party advertising, and we do not sell it.


4. Legal bases (UK and EU users)

Where the UK GDPR and EU GDPR apply, we rely on the following legal bases:

  • Consent: for optional features such as push notifications, and for processing your scan photos (including any biometric or special-category data). You can withdraw consent at any time.
  • Performance of a contract: to provide the App and the features you request.
  • Legitimate interests: to keep the App secure, prevent abuse, and improve our service, in a way that does not override your rights.
  • Legal obligation: where we must process information to comply with the law.

5. How your photos are processed by AI

To generate your results, the photos and text you submit are sent securely to trusted AI providers that perform the analysis and image generation on our behalf, including Google (Gemini models, accessed through OpenRouter). These providers process your content only to return a result to us. They do not use your content to train their general-purpose models for this use case, and any short-term retention they perform is limited to operating their service and monitoring for abuse, under their own terms. Your scan photos are stored in our secure backend so you can see your history, and you can delete them at any time.

We do not use your face or your photos to build advertising profiles, and we do not sell them.


6. Your face and scan data

Because face and skin data is sensitive, we want to be specific about how we handle it.

  • What it is: the selfies and skin photos you choose to scan, and the analysis we generate from them (such as your glow score, undertone, skin metrics, and detected concerns).
  • Why we store it: so you can see your history, track your progress over time, and compare past scans. This is the core of the App's value.
  • Who can access it: our storage provider Supabase (secure database and file storage), and the AI providers that generate your results (Google Gemini, accessed through OpenRouter). No one else. We never sell it or use it for advertising.
  • How long we keep it: we keep your scans while your account is active so your history stays available. You can delete any individual scan, or your entire account and all associated scans, at any time from inside the App. After deletion, we remove them from our active systems, except where we must keep limited records to comply with the law.
  • AI provider retention: the AI providers process your scan only to return your result and may retain it briefly to run their service and prevent abuse, after which it is removed from their systems, except where the law requires otherwise.
  • Your control: you can withdraw your consent to scan processing at any time by deleting your scans or your account, and by turning off the camera and photo permissions in your device settings.

7. Who we share information with

We do not sell your personal data. We share information only with service providers who process it on our behalf, under contract, and only as needed to run the App:

  • Supabase: database, authentication, and secure file storage for your account and scans.
  • Google (Gemini via OpenRouter): AI analysis of your scans and messages, and image generation for try-on features.
  • RevenueCat and Apple: subscription management and payment processing.
  • Apple and Google: sign-in services, if you choose to use them.

We may also disclose information if required by law, to enforce our terms, or to protect the rights, safety, and property of our users or others. If our business is involved in a merger or acquisition, information may be transferred as part of that transaction, subject to this policy.


8. International transfers

We are based in the United Kingdom. Some of our providers process data in the United States or other countries. Where we transfer personal data outside the UK or the European Economic Area, we rely on appropriate safeguards such as the UK International Data Transfer Agreement, the EU Standard Contractual Clauses, or an adequacy decision.


9. How long we keep your information

We keep your information for as long as your account is active, so the App can show your history and track your progress over time. Your scan photos are kept while your account is active and are removed when you delete them or your account. You can delete individual scans, or permanently delete your account and all associated data, from inside the App at any time. After you delete your account, we remove your personal data from our active systems, except where we must keep limited records to comply with legal obligations or resolve disputes.


10. Your privacy rights

Depending on where you live, you have rights over your personal data. For UK and EU users, these include the right to:

  • Access the personal data we hold about you.
  • Correct inaccurate data (you can edit much of this in the App).
  • Delete your data ("right to erasure").
  • Restrict or object to certain processing.
  • Receive your data in a portable format.
  • Withdraw consent at any time, where we rely on consent.

To exercise any right, use the tools in the App or contact us at the email below. You also have the right to complain to your local data protection authority. In the UK, this is the Information Commissioner's Office (ICO) at ico.org.uk.


11. US state privacy rights

If you are a resident of California, Colorado, Connecticut, Utah, Virginia, or another US state with a comprehensive privacy law, you have rights over your personal information. These may include the right to:

  • Know and access the personal information we have collected about you, and the categories of sources and third parties.
  • Correct inaccurate personal information.
  • Delete your personal information.
  • Obtain a portable copy of the personal information you provided.
  • Limit the use and disclosure of sensitive personal information (which, for us, means your face and scan data).
  • Opt out of the sale of your personal information, "sharing" for cross-context behavioural advertising, and profiling that produces legal or similarly significant effects.

We do not sell or share your personal information, and we do not use it for targeted advertising or that kind of profiling. We will not discriminate against you for exercising any of these rights.

To exercise these rights, use the in-app tools or contact us at privacy@thelumi.co. We may need to verify your identity, using information already associated with your account, before we act on your request. You may use an authorised agent to submit a request with proof of authorisation. If we decline a request, you may appeal by contacting the same email, and California residents may also raise a complaint with the California Privacy Protection Agency or Attorney General.


12. Do-Not-Track

Some browsers and devices offer a "Do-Not-Track" (DNT) signal. There is no common industry standard for how to respond to DNT, and because we do not track you across other apps or websites for advertising, we do not currently respond to DNT signals. If a standard is adopted that we must follow, we will update this policy.


13. Other regions

If you are in Australia, New Zealand, Switzerland, or another country with its own privacy law, you may have additional rights, including to access or correct your personal information. Contact us at privacy@thelumi.co and we will handle your request in line with the applicable law. You also have the right to complain to your local privacy regulator.


14. Security

We use industry-standard measures to protect your information, including encryption in transit and access controls on our backend. No method of transmission or storage is completely secure, but we work hard to protect your data and to keep our providers held to the same standard.


15. Children

Lumi is not intended for children under 13, and we do not knowingly collect personal data from children under 13. During onboarding we ask for your birth year. If you are under the age of majority where you live, you should use the App only with the involvement of a parent or guardian. If you believe a child under 13 has provided us with personal data, please contact us and we will delete it.


16. Changes to this policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the "Last updated" date above and, where appropriate, notify you in the App. Your continued use of the App after changes take effect means you accept the updated policy.


17. Contact us

If you have any questions about this Privacy Policy or your data, contact us at:

List or Lift Ltd Email: privacy@thelumi.co 71-75 Shelton Street, Covent Garden, London WC2H 9JQ, United Kingdom

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