Draft, pending legal review. This text is an early draft for a product that has not launched. It will be reviewed by counsel and finalised before the app is released.
Privacy Policy
1. Who is responsible
Two different parties handle data related to LumVPN:
- LumVPN ("we", "us") provides this website and the LumVPN app, and is responsible for the purchase records described below.
- The operator of LumSub provides user accounts and the network service the app connects to, and is responsible for that data under the LumSub privacy policy, published on the LumSub website.
2. This website
This website has no cookies, advertising, analytics or third-party scripts, and no forms. Our hosting provider may keep standard server logs, which can include IP addresses, pages requested and times, for security and troubleshooting. If you email us, we use your address and message to reply.
3. Data in the app
The table shows the planned design. We will update it to match the released app, including how long each item is kept, before launch.
| Data | Who receives it | Purpose and handling |
|---|---|---|
| Email address and account details | Operator of LumSub | Sign-in and account recovery. Your device sends these directly to the operator; they don't pass through our purchase system. |
| Random user number, and store purchase records (transaction ID, product, amount, currency, time, status) | Us and the operator of LumSub | Activating what you bought, handling renewals and refunds, reconciliation and accounting. |
| Network configuration | Sent by the operator of LumSub to your device | Connecting to the service. It doesn't pass through our purchase system. |
| Internet traffic while the VPN is on | Passes through servers of the network service | Providing the VPN. Handled under the LumSub privacy policy (section 4). |
| Routing rules and decisions | Stay on your device | Choosing whether traffic uses the VPN or connects directly. What you visit isn't uploaded for this. Downloading rule updates doesn't include your identity. |
| Crash and diagnostic data | Your device's platform provider, if you agree in your device settings | Fixing problems. The app has no third-party analytics tools. |
4. The network service
The operator of LumSub states in its privacy policy that it doesn't log the websites or apps you access, DNS queries, or connection logs on its own servers, and that it keeps some data needed to run and bill the service, such as your email address, plan records and short-lived server logs. Please read that policy before using the service. These are the operator's statements. Before launch, we plan to have an agreement in place that limits use of app users' data to providing the service.
5. What we don't do
We don't sell your data, use it for advertising, or disclose it to third parties for their own purposes. The app contains no advertising. We share data only as this policy describes: with the operator of LumSub so that it can provide the service you asked for, with providers that work for us (section 6), and where the law requires it (section 7).
6. Providers that work for us
We use providers for website hosting, email and app distribution and payment. App stores process your purchase and payment details under their own privacy policies; we don't receive your card details.
7. Legal requests
We may disclose data if applicable law requires it. We can only provide what we actually hold, which is limited as described above. A VPN isn't a way to avoid legal obligations.
8. International transfers
Data may be processed outside your country. Details and safeguards will be confirmed in the final policy.
9. Your choices and rights
Depending on where you live, you may have rights to access, correct, delete or object to the use of your data. For data we hold, contact privacy@lumvpn.com. For account data, the LumSub privacy policy explains how to contact its operator. The app will let you delete your account from inside the app. Some purchase records may have to be kept for accounting and tax reasons.
10. Children
LumVPN isn't directed at children. Please don't use it if you are below the minimum age required where you live.
11. Changes
If this policy changes, we'll publish the new version here with its date, and tell app users about significant changes.
12. Contact
Email: privacy@lumvpn.com.