Privacy Policy

1. Who we are

Lumen ("Personal Finance Notion", "the Service", "the app") is a personal finance tracking application operated by MG ("we", "us", "our"), an independent developer based in Indonesia.

This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and the choices and rights you have. It applies to your use of the Service through any web or installable (PWA) interface.

If you do not agree with this policy, please do not use the Service.

2. Plain-language summary

• The Service is a tool for recording and visualising your own finances. You enter or import your transactions; we do not connect to your bank or move money.
• We collect the account details you sign up with and the financial data you choose to put into the app.
• When you use the AI bulk-import feature, the content you submit (such as bank-email text or statement images) is sent to a third-party AI provider (OpenRouter) so it can be read and converted into transactions.
• We use a small number of service providers (for sign-in, hosting, database, email, and AI parsing) to run the app.
• We do not sell your data and do not use it for advertising.
• You can access, correct, export, or delete your data — see Sections 9 and 10.
• The Service is a public beta. Please keep your own copies of important data.

3. Scope of this policy

This policy covers personal data processed by the Service itself. It does not cover:

• Third-party services you choose to connect or use alongside the Service (for example, your email provider, or any external automation or "agent" you set up to push transactions into the Service through our integrations API). Those are governed by their own privacy policies, and you are responsible for them.
• Websites or services that link to or from the Service.

4. Data we collect

4.1 Account and identity data

• Email address (required to create an account).
• Password, stored only in hashed form — we never store or see your plain-text password.
• If you sign in with Google: your Google account email, name, and profile basics provided by Google's sign-in service.
• Email verification status and security-related timestamps (for example, when your sessions were last invalidated after a password change).
• Account settings you configure, such as your timezone and display preferences.

4.2 Financial and usage data you provide

The Service exists to store the information you put into it. This includes:

• Transactions you create (amount, date, type, category, account, notes).
• Bank account labels you set up inside the app. These are names/labels for your own organisation — we do not ask for, receive, or store your bank login credentials, card numbers, or banking access.
• Categories and budgets you define.
• Wishlist items you add for future-purchase planning.
• Integration API keys you generate to use our integrations API. These are stored only in hashed form, together with metadata such as creation date, expiry, and last-used time.

4.3 Content submitted to the AI bulk-import feature

When you use the AI-assisted bulk import, you may submit content such as bank-notification email text, statement text, or images for the app to parse into structured transactions. See Section 6 for how this content is handled.

4.4 Technical data

• Log and device data: IP address, browser/device type, and basic request logs, used for security, debugging, and reliability.
• Local on-device storage: as a Progressive Web App, the Service stores a copy of your data in your browser/device storage (IndexedDB) so the app can work offline and queue changes. This data lives on your device until you clear it (see Section 10.3).

We do not use third-party advertising or cross-site tracking technologies.

5. How we use your data

We use personal data only to operate and improve the Service:

• To create and secure your account and authenticate sign-in.
• To store, display, and let you manage your transactions, budgets, and other records.
• To run the AI bulk-import and parse submitted content into transactions.
• To send transactional emails (email verification, password reset, and similar account/security messages). We do not send marketing email.
• To maintain reliability, prevent abuse, debug issues, and protect the security of users and the Service.
• To comply with applicable legal obligations.

Legal basis. We process your data on the basis of your consent (given when you create an account and accept this policy), to perform the agreement to provide the Service to you, to pursue our legitimate interests in operating and securing the Service, and to meet legal obligations. This reflects the principles of Indonesia's Law No. 27 of 2022 on Personal Data Protection (the "PDP Law") and comparable data-protection standards.

6. AI bulk-import — important disclosure

The AI bulk-import feature works by sending the content you submit (for example, pasted bank-email text or uploaded statement images) to OpenRouter, a third-party AI model-routing provider, which forwards it to an underlying large language model so the content can be read and converted into structured transaction data.

Please understand:

• This content leaves our systems and is processed by OpenRouter and the underlying model provider for the purpose of parsing it.
• We use this content only to extract transaction details for your import. We do not use it to train our own models.
• OpenRouter and the downstream model providers handle data under their own terms and privacy policies, which we do not control beyond the configuration options available to us.
• You decide what to submit. We recommend you do not include information you are not comfortable sharing with an AI provider, and that you remove or redact any highly sensitive details that are not needed to identify a transaction.

If you prefer not to use third-party AI processing, you can enter transactions manually instead.

7. Service providers (sub-processors)

We rely on a limited set of trusted providers to run the Service. They process data only as needed to provide their function to us:

We do not sell, rent, or trade your personal data. We may disclose data if required by law, to enforce our Terms, or to protect the rights, safety, or security of users or the Service.

8. Data storage, security, and location

• Passwords and integration API keys are stored only in hashed form.
• Data is transmitted over encrypted connections (HTTPS/TLS).
• Access to systems is restricted, and we apply security measures including email verification and session invalidation on password change.
• A copy of your data is also stored locally on your device (IndexedDB) to support offline use; protecting your device and browser is your responsibility.

The Service is operated from Indonesia, and our service providers (Section 7) may store or process data in other countries. By using the Service, you understand that your data may be transferred to and processed outside your country of residence and outside Indonesia, in jurisdictions whose data-protection laws may differ. We take reasonable steps to ensure such transfers are consistent with the PDP Law and applicable data-protection standards.

No method of storage or transmission is completely secure. While we work to protect your data, we cannot guarantee absolute security.

9. Data retention

• We keep your account and financial data for as long as your account is active.
• When you delete your account, your data is removed as described in our Data Deletion Policy.
• After deletion, residual copies may persist briefly in encrypted backups until those backups rotate out, and we may retain a minimal record where needed to meet legal, security, or fraud-prevention obligations.

10. Your rights and choices

10.1 Your rights

Consistent with Indonesia's PDP Law — and extended to all users regardless of location as a matter of good practice — you have the right to:

• Access the personal data we hold about you.
• Correct inaccurate or incomplete data (most data can be edited directly in the app).
• Delete your data and account (see the Data Deletion Policy).
• Withdraw consent to processing, and to object to or restrict certain processing.
• Obtain a copy / portability of the data you have provided.
• Lodge a complaint with a competent data-protection authority.

To exercise any right that you cannot complete inside the app, contact us using the details in Section 14. We will respond within a reasonable time and in line with applicable law.

10.2 Cookies and local storage

The Service uses storage technologies that are strictly necessary to run it, including a session cookie to keep you signed in and browser storage (IndexedDB) for offline functionality. We do not use advertising or analytics cookies that track you across other sites.

10.3 On-device data

Because the app stores a local copy of your data on your device, you can remove that local copy at any time by clearing the site's data in your browser, or by uninstalling the app if you added it to your device. This does not by itself delete data stored on our servers — for that, see the Data Deletion Policy.

11. Children's privacy

The Service is intended for users 18 years of age or older and is not directed at children. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us and we will delete it.

12. Public beta notice

The Service is currently offered as a public beta. This means features may change, and — although we take reasonable precautions and maintain backups — there is a higher-than-normal risk of bugs, downtime, or data loss. Please keep your own independent copies of any financial records that matter to you.

13. Changes to this policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last updated" date above. If we make a material change, we will provide a more prominent notice (for example, an in-app message or email). Your continued use of the Service after an update takes effect means you accept the revised policy.

14. Contact us

For any privacy question, request, or concern — including exercising your data rights — contact:

MG — mg.terok77@gmail.com

Please use the subject line "Privacy request" so we can respond promptly.