PART 1: PRIVACY POLICY
At LumeProxy, we believe that true privacy is achieved through the absence of data. This policy outlines our "Zero-Touch" approach to your personal information.
The Stateless Security Model
LumeProxy facilitates secure networking through encrypted tunnels. Unlike traditional services, our infrastructure is designed to be blind to your activity:
Local Cryptography: All encryption keys and tunneling protocols are generated and managed strictly on your device.
No Traffic Monitoring: We do not intercept, inspect, or record the websites you visit, the apps you use, or the data you transmit.
No Connection Logging: We maintain a strict policy against logging your source IP address, assigned VPN IP address, connection timestamps, or session durations. Your data exists only in transit and is never written to our persistent storage.
Integration of Third-Party Services
To ensure the technical viability and growth of LumeProxy, we utilize a limited selection of external service providers. These platforms interact only with technical metadata:
Firebase (Google): Used for real-time diagnostic reporting. In the event of an app crash, technical parameters (not personal data) are sent to help us optimize the code.
Attribution and Analytics (e.g., Adjust, AppsFlyer): These tools help us track the performance of our marketing campaigns. They may process pseudonymized technical IDs like your Advertising Identifier (IDFA or GAID) to determine if a specific advertisement led to an app installation.
Service Boundary: These third parties are legally restricted from accessing your VPN traffic or mapping technical signals to your real-world identity.
Legal Basis for Information Handling
Our processing of technical information is grounded in the following legal principles:
Performance of a Contract: The local management of your VPN connection is essential to provide the secure networking service you have initiated.
Legitimate Interests: We rely on pseudonymized technical telemetry to ensure the global stability of our nodes, prevent network abuse, and measure our commercial growth.
Your Bill of Data Rights
We empower every LumeProxy user with comprehensive rights over their digital information:
Right to Access: You may request an account of any data we have processed regarding your device or interaction with the app.
Right to Rectification: You have the right to demand the correction of any inaccurate or incomplete data we or our partners may possess.
Right to Erasure (Deletion): You may request the immediate deletion of your data. For the application itself, simply uninstalling LumeProxy will purge all local configurations.
Right to Know (Sharing & Selling): You are entitled to know if your data is shared or sold. LumeProxy does not sell your personal data. Sharing is strictly limited to the technical partners listed in Section 2 for the sole purpose of app maintenance.
Right to Object/Lodge a Complaint: If you believe your privacy has been compromised, you have the right to lodge a formal complaint with a data protection authority or a relevant regulatory body in your jurisdiction.
Retention Policy and Circumstances
Active Networking Data: This information is volatile and exists only in your device's RAM during an active session. It is permanently cleared the moment you disconnect.
Technical Telemetry: Data processed by our analytics partners is retained for the minimum period required for aggregate reporting—typically between 12 and 24 months—before it is fully anonymized or deleted.
Support Records: Correspondence via support channels is retained only until your inquiry is successfully resolved.
Opt-Out Mechanisms
You have the autonomy to restrict the sharing of technical identifiers:
Privacy Settings: You may choose "Opt out of Interest-Based Ads" (Android) or "Limit Ad Tracking" (iOS) within your system settings to block attribution platforms.
Zero-Permission Usage: You can use the core features of LumeProxy without granting optional permissions, such as notifications or usage stats sharing.
Governance and Data Protection Officer (DPO)
LumeProxy has appointed a Data Protection Officer to oversee our privacy compliance and address user concerns.
DPO Name: Alistair Thorne
Direct Email: layoutarbenjamin@gmail.com
PART 2: END-USER LICENSE AGREEMENT (EULA)
Grant of License
LumeProxy grants you a non-exclusive, non-transferable, revocable license to use the LumeProxy software on your personal device for secure networking purposes, subject to the terms of this agreement.
Prohibited Conduct
By using LumeProxy, you agree not to:
Use the service for any criminal activity, including but not limited to hacking, copyright infringement, or the distribution of illegal content.
Reverse engineer, decompile, or attempt to extract the source code of the LumeProxy tunneling engine.
Resell or commercially exploit the VPN service without express written consent.
Attempt to disrupt or overload the LumeProxy server infrastructure.
Intellectual Property Rights
The LumeProxy name, brand, logo, and underlying codebase remain the exclusive intellectual property of the developer. This license confers no ownership rights to the user.
Warranty Disclaimer
LumeProxy is provided "AS IS." While we maintain high-speed nodes and robust encryption, we do not warrant that the service will be error-free, uninterrupted, or capable of bypassing every regional network restriction.
Limitation of Liability
To the maximum extent permitted by law, LumeProxy and its affiliates shall not be liable for any damages resulting from your use of the service, including data loss, loss of privacy due to user-side negligence, or legal actions resulting from your online conduct.
Termination
This agreement is effective until terminated. We reserve the right to revoke your license immediately if we detect a violation of the Prohibited Conduct clauses. You may terminate this agreement at any time by uninstalling the application.