Privacy Policy

Last revised: 2026-06-11 / Established: 2026-06-10

This English text is a translation provided for convenience. In case of any discrepancy, the Japanese version prevails.

Lumo ("we", "us") sets out below how user information is handled in the iOS application "Feelmo" (the "App") and the websites feelmo.jp and docs.feelmo.jp (together, the "Service").

We design the Service and this policy on one principle: data about your body exists to be observed — never to be bought and sold for guessing.

1. Information We Handle

1.1 Data the App keeps on your device

The following stays on your device only as a rule, and is never sent to our servers automatically:

• Emotion logs — feelings and notes you record in the App
• HRV-derived data — heart-rate-variability data from Apple Watch / HealthKit, and the Regulation Score computed from it
• Behavior logs — sleep, sunlight, activity, and similar records

1.2 HealthKit data

• HealthKit access is requested step by step, per feature, and can be revoked per data type at any time from iOS Settings
• HealthKit data is never used for advertising or marketing, and never provided or sold to any third party, including data brokers (we comply with Apple's guidelines)

1.3 AI coaching

Only when you use the AI coaching feature, anonymous context that cannot identify you (e.g. a summary of recent regulation trends) may be sent for processing. It contains no name, contact details, or device identifiers. Processing may take place outside your country; only the anonymous context above is ever sent.

1.4 Websites

• Language preference — stored in your browser's local storage (not sent to us)
• Analytics — we may collect page-view statistics with a cookie-free tool (Vercel Analytics); never used to identify individuals

1.5 Inquiries

When you contact us, we receive your email address and the information needed to respond (device model, OS version, etc.).

2. Purposes of Use

1. Providing, maintaining, and improving the Service
2. Computing and displaying the Regulation Score
3. Generating AI coaching suggestions (anonymous context only)
4. Responding to inquiries
5. Statistical analysis that does not identify individuals
6. Compliance with laws and our terms

We do not use your information for medical diagnosis, credit, employment, insurance underwriting, or any other automated decision with significant effect on you.

3. Third-Party Provision

We do not sell your heart data or any data about your body. We do not provide your information to third parties without consent, except: (1) where required by law; (2) to protect life, body, or property when consent is difficult to obtain; (3) for public health or sound child development when consent is difficult to obtain; (4) for cooperation with public authorities where obtaining consent would impede their duties.

4. Outsourcing

We may entrust handling of information to contractors (e.g. cloud providers) within the scope of the purposes above, under appropriate supervision.

5. Security

We take necessary and appropriate measures — encryption in transit, access control, least privilege — to prevent leakage, loss, or damage.

6. Retention

• Data on your device is under your control (you can delete it at any time)
• Inquiry records are deleted after a reasonable period following resolution

7. Your Rights

• Export — you can export your data as CSV in the App at any time (exported CSV cannot be imported back into the App)
• Deletion — you can delete your data in the App at any time; deleting the App also removes on-device data
• Requests — you may request disclosure, correction, deletion, or suspension of use under applicable law (including the APPI, GDPR, and CCPA) via the contact in Article 10

8. Minors

Users under 18 should use the Service with the consent of a parent or guardian. We do not knowingly collect personal information from children without such consent.

9. Not Medical Information

The App is not a medical device; nothing in the Service is a basis for diagnosis, treatment, or prevention. Consult a medical professional for any health concern.

10. Contact

• Email: contact@lumo.tokyo — we usually reply within 2 business days (日本語 / English)

11. Changes

We may revise this policy as laws or the Service change. Material changes are announced on this page. The revised policy takes effect when posted here.