Privacy Policy — ADHD Coach (English version)
Provided for convenience; the Polish text is authoritative. DE/FR/ES translations do not exist yet; consult a qualified lawyer before launch in those markets.
Version: DRAFT 0.2 (first release, R1) · Date: 2026-10-09 · Applies to: the ADHD Coach mobile app (on Google Play: “Planer dnia ADHD”) for Android and iOS, published by LUMA Sp. z o.o. The sign-up list on our website has a separate policy: https://adhdcoach.lumasoft.pl/en/waitlist-privacy/.
1. In short
- Your tasks, steps, focus sessions, energy check-ins, settings and reminders stay on your phone. We have no access to them. The app works without an account and without internet.
- This version has no AI features. Nothing goes to AI providers, speech-recognition services or any models.
- We send error reports only if you turn them on yourself (off by default).
- There are no payments and no ads. We do not track you and do not sell data.
- Tasks and check-ins can reveal health information, so we treat them as highly sensitive. That is why they never leave the phone.
- A live version of this summary is in the app: Me → Data and privacy → What leaves the phone.
2. Controller
LUMA Sp. z o.o. (full name: LUMA Spółka z ograniczoną odpowiedzialnością), ul. Gawronia 15, 04-785 Warsaw, Poland, KRS: 0001244636, NIP: 9522285489, REGON: 544875680. Data protection contact (including exercising your rights): support@lumasoft.pl.
LUMA has not appointed a Data Protection Officer. [TO VERIFY: written Art. 37 GDPR assessment — see the list at the end.]
3. What ADHD Coach is — and is NOT
ADHD Coach is a wellness / day-organising app for people who find planning, starting tasks and focusing difficult.
ADHD Coach is NOT: a medical device, a diagnostic or therapeutic tool, a substitute for psychotherapy or treatment, or a crisis intervention service.
If you or someone near you is in danger, call 112. The in-app Support screen shows helplines for your selected country and works offline.
4. What stays on your phone only
We store the following in the app’s storage on your phone (and nowhere else):
| Data | Purpose |
|---|---|
| Tasks, steps, notes, “done” items, routines | Running your day plan |
| Focus sessions and their results | Focus counter, summary |
| Energy check-ins | Matching the number of tasks to your energy |
| Settings: look, language, country for helplines, reminders, how long “done” items are kept | Running the app as you set it |
| Age band and an “age gate passed” flag (see section 8) | Protecting people under 16, ordering of helplines |
LUMA has no access to this data and does not decide on any purpose of processing outside your phone, because we send it nowhere. We list it here for transparency. [TO VERIFY: assessment of LUMA’s role for purely local data — see the list at the end.]
Tasks and check-ins can reveal health information (e.g. a medication name, a doctor visit), which is special category data (Art. 9 GDPR). Because it stays on your phone, we do not ask for consent to process it. Protection depends on your phone’s safeguards (screen lock, system encryption). The app has no passcode of its own. If you write something very personal there, set a screen lock.
System backup. On iOS, if iCloud backup is turned on, the app’s data may be included according to the system settings. Apple then processes it as a separate controller, not LUMA. The app has Android backup turned off (android.allowBackup: false), so Android Auto Backup does not copy its data. A copy can be made only by exporting a file from the app.
5. What may leave the phone, and when
5.1 Error reports (Sentry) — only after you turn them on
The switch Me → Data and privacy → Error reports is off by default. Until you turn it on, the app does not connect to Sentry. Turning it off stops sending at once.
Once on, we send to Sentry (Functional Software, Inc., a processor): the error description and stack trace, phone model and OS version, app version, event time, general performance data from some launches and, if you are signed in, your account identifier. Before sending we strip content fields (task titles and steps, notes, messages, e-mail, tokens). This is a technical filter and not an absolute guarantee. Sentry servers receive the connection’s IP address. [TO VERIFY: whether Sentry stores it.]
- Legal basis: your consent — Art. 6(1)(a) GDPR (turning the switch on). You withdraw it by turning the switch off. [TO VERIFY: basis and ePrivacy compliance — see the list.]
- Region and retention: [TO VERIFY: Sentry project region (EU or US), retention period, DPA with Sentry.]
- Transfer outside the EEA: [TO VERIFY: if US — an Art. 46 GDPR mechanism or Data Privacy Framework certification.]
5.2 Account (not available in this version)
In this version an account cannot be created: the app has no sign-up, and sign-up in the authentication service (Supabase Auth) is disabled on the server side. Nothing is passed to Supabase. An account will appear only together with optional features, with a separate notice about data processing.
5.3 Contacting us
If you write to support@lumasoft.pl, we process the message and sender address to reply (Art. 6(1)(f) GDPR — our interest in handling enquiries). Please do not send health information there. Retention: [TO VERIFY]. Mail provider: [TO VERIFY].
5.4 Google Play (distributor)
You download the app from Google Play. Google is a separate controller of installation, Google account, device and store data, under its own policy: https://policies.google.com/privacy. LUMA receives aggregated statistics from Google (installs, crashes and freezes per Android vitals), with no data identifying you. On iOS the Apple App Store works analogously.
5.5 Export and import of a file
Me → Data and privacy → Data backup saves your tasks to a file (JSON) through the system share sheet. You decide where the file goes (disk, e-mail, cloud). From then on you protect it — the file is not encrypted. Import reads the file you pick and adds its contents to the data on the phone. Nothing is sent to us.
5.6 Reminders
Reminders are local: your phone’s system shows them at the set time. We use no push-notification server and no push tokens — no data is passed to anyone. A reminder’s text may be visible on the lock screen, depending on system settings. Android 13+ asks for notification permission; you can withdraw it in system settings.
5.7 What R1 does not do
We do not send data to AI providers (Anthropic, OpenAI), speech services (Deepgram), payment services (RevenueCat, Stripe), or advertising and analytics networks. The app uses no microphone, camera or location. Dictation from your keyboard (if you use it) is performed by your system (Apple/Google), not by ADHD Coach.
6. Crisis support
The Support screen shows helplines from data stored in the app. We determine the country locally: from your choice or your phone’s region setting — never from an IP address. The app may recognise crisis-related words in your entry locally and show helplines; this check runs on the phone and nothing is sent. [TO VERIFY: scope of local recognition in the R1 build.] This does not replace professional help.
| Country | Helpline |
|---|---|
| Poland | Telefon Zaufania: 116 123 |
| Germany | Telefonseelsorge: 0800 111 0 111 |
| France | 3114 (Numéro National de Prévention du Suicide) |
| Spain | Teléfono de la Esperanza: 717 003 717 |
| UK | Samaritans: 116 123 |
| Life-threatening emergency | 112 |
[TO VERIFY: currency of the numbers and the countries covered against the data in lib/crisis/lines.ts.]
7. Retention
| Data | Period |
|---|---|
| Data on the phone | Until you delete it or uninstall the app. “Done” items disappear after the period chosen in Data and privacy → History of done items (90 days, a year, or at once) |
| Error reports (Sentry), if on | [TO VERIFY: period at Sentry] |
| Account (Supabase) | None — an account cannot be created in this version |
| Support correspondence | [TO VERIFY] |
8. Age: 16+ and the age gate
The app is for people who are at least 16. On first launch we ask for your date of birth. The app computes your age on the phone and discards the date at once — it is not stored, not sent and not in error reports. Only the result remains: an age band (“16–17” or “18+”), a verification timestamp and — if the age is too low — a block on that installation. The “16–17” band only affects the order of helplines (the youth line first). After uninstalling and reinstalling the gate appears again; we use no persistent device identifiers to detect that.
9. Your rights
- Data on your phone: it is at hand — you view, correct, export (Data backup) and delete it (Delete data → From this phone) directly in the app. The rights in Arts. 15–20 GDPR concern data LUMA holds, and there is none here.
- Data we do hold (account, error reports, correspondence): access (Art. 15), rectification (16), erasure (17), restriction (18), portability (20), objection to processing based on Art. 6(1)(f) (21) and withdrawal of consent at any time (7(3)) — without affecting the lawfulness of earlier processing. Write to support@lumasoft.pl.
- Error reports without an account identifier may not be linkable to you; then we will not be able to point them out (Art. 11 GDPR).
- Complaint: the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw, https://uodo.gov.pl. Residents of other countries: the authority in their country of residence (e.g. DE state/federal authorities, CNIL, AEPD, ICO).
- We make no solely automated decisions about you and do not profile you within the meaning of Art. 22 GDPR.
- Providing data is voluntary. The app works fully without an account and without error reports.
10. Security
Local data sits in the app’s storage on your phone and is protected by system safeguards (app sandbox, screen lock). Communication with Supabase and Sentry (when you turn it on) is encrypted (HTTPS/TLS). We do not send error reports without your consent. In case of a personal data breach we notify the President of UODO within 72 hours and you if the risk is high.
11. What will change when we turn on AI features or an account with synchronisation
In the future we plan, among other things, an AI assistant (conversation, splitting tasks into steps), synchronisation between devices and a paid plan. Today none of these features runs or processes your data.
Before we turn one on:
- We will publish an updated policy and tell you in the app at least 30 days ahead where the change is material.
- We will ask for a separate, explicit consent (Art. 9(2)(a) GDPR) on a separate screen, apart from the terms — because texts sent to AI may contain health data. The consent will be specific to the feature, and you will withdraw it with one switch.
- We will name the providers (e.g. an AI model provider in the USA), the mechanism for transfers outside the EEA and the retention period.
- We will carry out a data protection impact assessment (DPIA, Art. 35 GDPR) before such processing starts.
- An app update will not switch these features on for you — they stay off by default and nothing is sent without your consent.
Paid features will be billed by the store (Google Play or Apple); RevenueCat may manage subscriptions. We will describe that in the policy before launch.
12. Changes to this Policy
The current version applies from the date of publication. We will tell you in the app at least 30 days ahead about material changes (especially concerning health data). We keep earlier versions and provide them on request.
13. Contact
support@lumasoft.pl · Controller: LUMA Sp. z o.o., ul. Gawronia 15, 04-785 Warsaw, Poland (KRS: 0001244636, NIP: 9522285489, REGON: 544875680). This document concerns the ADHD Coach app (“Planer dnia ADHD”).