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Privacy Policy

Version of September 3, 2026 · applies to the Lumenglows app and to the website lumenglows.com · English translation; the German version is the authoritative one

1. The essentials

The Lumenglows app does not collect any personal data. It has no server of its own, no user account and no sign-in. It contains no analytics, no tracking, no advertising and no third-party components. All images are part of the app and are not loaded from the network.

Four points of contact remain, and this text explains each of them: access to the photo library in order to save an image, passing an image to Apple’s Shortcuts app (section 3), the handling of purchases by Apple, and visits to this website. On the device itself the app stores eight values: the list of images marked as favorites, three markers recording what has already been shown, a list of the images that are no longer new for you, the interface language you chose, and two values for the automatic wallpaper rotation (section 3).

2. Controller

The controller within the meaning of the Swiss Federal Act on Data Protection (revised FADP) and of the EU General Data Protection Regulation (GDPR) is:

Philippe Froehly
Schupfarterstrasse 6
5074 Eiken
Switzerland
Email: hallo@lumenglows.com

No data protection officer has been appointed; neither Art. 37 GDPR nor the FADP requires one for processing of this scale. Data protection enquiries go to the email address given above.

3. The Lumenglows app

The app works entirely on the device. In detail this means:

  • No server, no account. There is no sign-in, no registration and no transmission of usage data to the provider. Apart from the connection to Apple’s services through which purchases are handled (section 5), the app establishes no network connection.
  • No analytics, no tracking, no advertising. The app contains no analytics tools, no advertising networks and no third-party components. It does not request an advertising identifier and does not build profiles.
  • What stays on the device. The app keeps no usage log and stores no personal details. Five values are stored, and none of them says anything about you as a person. First, the list of images marked as favorites — a set of image names such as nebelwald. Second, a yes-or-no marker recording that the setup for the shortcut “Set as wallpaper” has been completed once. Third, a marker of the same kind for the instructions on the Apple Watch face; both decide nothing but whether the app shows a set of instructions again. Fourth, a list of the images that are no longer new on your device: at the first start this is the entire catalog as it stood then, and later the images added by an update join it as soon as you have opened them. This is what the app shows you as “New”. Fifth, the interface language chosen in the app — two letters, de or en. Sixth, a marker recording that the introduction shown at launch has already been completed. Seventh and eighth, two values for the automatic wallpaper rotation: how far the sequence has progressed and which wallpaper was set last. All eight sit in the app’s protected area, do not leave the device, go to no one, and are deleted together with the app. Selected categories and search terms are not stored, and no history of viewed images arises — the fourth list records neither time nor order.
  • The name in the heart is not stored. For the images in the “Heart & Name” series a name can be written into the picture. This name is stored nowhere: it exists only while the full-screen view is open and disappears with it. It is drawn solely into the image that is saved or shared, and therefore goes only where the user sends it.
  • The route through Apple’s Shortcuts. iOS lets no app set the wallpaper itself. Anyone choosing “Set as wallpaper” therefore hands the chosen image from Lumenglows to Apple’s Shortcuts app, which passes it on to Apple’s own action “Set Wallpaper Photo”. Only the image file from the app bundle and the name of the image are handed over; no personal details go with them, and the process stays on the device. Shortcuts is an app made by Apple and not part of Lumenglows; Apple’s privacy policy applies to what happens there. The route is optional: “Save to Photos” remains fully available (section 4).
  • Content is part of the app. All images are contained in the app bundle. No images are loaded afterwards, so no retrievals are logged either.

Opening a link to this website — from the purchase screen, for example — takes the user out of the app and into the browser. Section 7 applies to that.

4. Access to the photo library

In order to save a wallpaper, Lumenglows needs permission to add an image to the photo library. iOS asks for this permission the first time an image is saved.

For ordinary saving, only the Add Photos Only (add-only) permission is requested. It allows the app to place new images in the library, but not to read, view, alter or delete existing photos.

One single feature needs more: the Save for Apple Watch button places the wallpaper in an album named Lumenglows, which the watch uses to feed its watch face. Technically, finding an album before filling it is a read operation, and iOS offers no narrower level for it than full access to the photo library. iOS asks for that permission separately, and only the first time this particular button is tapped. Anyone who never taps it is never asked.

Even with that permission, Lumenglows does not go through the photo library: it searches only for its own Lumenglows album, and no existing photo is read, viewed, altered or deleted. No information about saved or existing images is collected or transmitted.

The permission can be withdrawn at any time under Settings › Apps › Lumenglows › Photos. Without it the app continues to work; only saving is then unavailable.

5. Purchases and Lumenglows Plus

Purchases are handled entirely by Apple. The seller is Apple Distribution International Ltd., Hollyhill Industrial Estate, Hollyhill, Cork, Ireland. The provider receives no payment data — no card details, and no billing addresses, names or email addresses of purchasers.

Whether Lumenglows Plus is unlocked is determined by the app through Apple’s StoreKit interface. The purchase receipt signed by Apple is verified locally on the device. The provider operates no server for this and does not store the result; it is determined afresh at each start.

For the processing involved in the purchase, in billing and in restoring earlier purchases, Apple is the controller in its own right. Apple’s privacy policy applies.

6. What Apple collects

Independently of the app, Apple provides the provider with reports in App Store Connect, for instance on the number of downloads and purchases as well as crash reports. This data is collected by Apple, not by the app.

It reaches the provider in aggregated form only and does not allow any conclusions about individual persons. Whether analytics and crash data are passed on to developers at all is for users themselves to decide under Settings › Privacy & Security › Analytics & Improvements.

7. This website

Server logs

This website consists of static pages. It sets no cookies, uses no analytics or audience measurement, embeds no fonts, scripts or images from third-party servers and stores nothing in the browser. There is no contact form and no sign-in.

When a page is retrieved, the browser transmits technically necessary information to the hosting provider, which processes it briefly in server logs:

  • IP address of the requesting device,
  • date and time of the request,
  • the address requested and the volume of data transferred,
  • status code of the response,
  • browser identification (user agent) and, where applicable, the previously visited page.

This processing is necessary in order to deliver the page, to keep it operating and to fend off attacks. The legal basis is the legitimate interest in a secure and functioning web presence (Art. 6(1)(f) GDPR; for Switzerland Art. 31 FADP). The data is not used to identify individual persons and is not combined with other sources.

Hosting

The website is operated by a processor:

Hostinger International Limited, 61 Lordou Vironos str., 6023 Larnaca, Cyprus

The hosting provider maintains data centers in several countries and lets the location be chosen when ordering. The location chosen for this website is

Netherlands

A data processing agreement under Art. 28 GDPR is in place with the hosting provider. It forms part of its terms of service and is deemed concluded upon their acceptance; its wording is available at hostinger.com/legal/dpa. For transfers out of the European Economic Area it incorporates the European Commission’s standard contractual clauses.

How long the hosting provider retains these logs is not stated publicly. The operator of this website keeps no logs of its own alongside these and does not evaluate those of the hosting provider.

8. Contact by email

Anyone who writes to the provider transmits their email address, their name insofar as it is given, and the content of the message. This information is used solely to deal with the matter raised.

The legal basis is the performance of a contract or the answering of a pre-contractual enquiry (Art. 6(1)(b) GDPR) or, as the case may be, the legitimate interest in answering the enquiry (Art. 6(1)(f) GDPR).

The email address used is operated by an external provider, which is technically involved in processing the message. Email is not a secure means of transmission — it is not suitable for confidential information.

9. Disclosure and transfers abroad

Personal data is not sold and is not passed on for advertising purposes. Data is disclosed only

  • to Apple, insofar as this is necessary for the purchase and its handling — there under Apple’s own responsibility;
  • to the hosting provider of this website and to the email provider, each as a processor;
  • to authorities, insofar as a statutory obligation to do so exists.

The hosting provider has its contractual seat in Cyprus and therefore in the EU; the data center for this website is at the location named in section 7 above. According to the hosting provider’s own privacy policy, data may in addition be processed in the United Kingdom, in Lithuania, in the Netherlands and by service providers in further countries; some of its servers are located outside the European Economic Area.

Processing takes place in the USA at the email provider and at Apple. Such transfers are made on the basis of the European Commission’s standard contractual clauses — in the case of the hosting provider by way of the data processing agreement named in section 7 —, supplemented by the adaptations for Switzerland recognized by the FDPIC, or on the basis of an adequacy decision. A level of protection equivalent in every respect to the Swiss and European one cannot be guaranteed in all cases.

10. Retention periods

  • App: The list of favorites stays on the device until the favorites are removed or the app is deleted; the same applies to the two markers for the instructions, to the list of images already known and to the chosen language. No further data arises.
  • Server logs of the website: The retention period is determined by the hosting provider. It does not state it publicly (section 7); the operator of this website stores no logs itself.
  • Email correspondence: Retained for as long as the matter requires, then deleted; statutory retention obligations remain reserved.

11. Your rights

Under the GDPR, data subjects have the following rights:

  • Access to the data processed (Art. 15 GDPR);
  • Rectification of inaccurate data (Art. 16 GDPR);
  • Erasure (Art. 17 GDPR);
  • Restriction of processing (Art. 18 GDPR);
  • Data portability in a commonly used format (Art. 20 GDPR);
  • Objection to processing based on a legitimate interest (Art. 21 GDPR);
  • Withdrawal of consent given, with effect for the future (Art. 7(3) GDPR).

Under the revised Swiss FADP there are correspondingly the right to information (Art. 25), the right to have incorrect data corrected (Art. 32) and the right to have data handed over or transferred (Art. 28).

A practical limitation: because the app collects no data and no user accounts are kept, the provider is usually unable to locate any data relating to a particular person. A request for access can therefore usually be answered only in respect of existing email correspondence. Information about purchases is held by Apple; it must be requested there.

Please send enquiries to hallo@lumenglows.com. A follow-up question may be necessary in order to deal with the request if the data cannot otherwise be attributed; no further proof is required.

12. Right to lodge a complaint

Anyone who considers that their rights have been infringed may lodge a complaint:

13. Children, profiling, security

The app is not directed at children and knowingly collects no data from children. Since no data is collected at all, distinguishing by age is technically neither necessary nor possible.

There is no automated decision-making and no profiling within the meaning of Art. 22 GDPR.

The website is delivered exclusively over encrypted HTTPS. Within the app, the only connection used is the encrypted one to Apple’s services provided by Apple.

14. Changes to this policy

This policy is adapted when the app, the website or the legal situation change. The version published at https://lumenglows.com/datenschutz/ is the authoritative one; the date is given at the top of the page.

The Terms of Use apply in addition. Details about the provider are in the Legal Notice.