Privacy Policy

Effective date: 22 August 2026

Who we are

Luumi is provided by Luumi AB, reg. no. 559533-4409, Åsboholmsgatan 28, 504 51 Borås, Sweden ("Luumi", "we", "us"), which is the data controller for the processing described here.

Contact for data protection matters: info@luumiapp.se.

Information we collect

Information you provide:

Account details: name or username, email, date of birth, gender identity

Profile information: photos, video, bio, interests, relationship preferences

Sensitive information you choose to share: sexual orientation, functional variation, neurodivergence, and health-related needs and accommodations (see Sensitive personal data below)

Messages and content you send to other users, hugs, and reports you submit

Subscription status. Payment details are handled by Apple and Google and are not stored by us

Anything you tell our support team

Information collected automatically:

Device and usage data: device type, operating system, crash logs, app performance, features you use

Approximate location, based on IP address or, if you allow it, GPS, for match suggestions

Log data: login times and session length

To create an account you must provide certain information, such as your age and email address. Without it we cannot provide the service.

Why we process your data and our legal basis

To provide the service (contract performance, Art. 6(1)(b)): create your account, show your profile, suggest matches, enable messaging, manage subscriptions

Safety and security (legitimate interest, Art. 6(1)(f), and legal obligation, Art. 6(1)(c)): detect and prevent fraud, harassment, and illegal content, investigate reports, enforce our Terms, and meet our obligations under the DSA

To improve the service (legitimate interest, Art. 6(1)(f)): understand usage patterns, test and develop features

Communication (contract Art. 6(1)(b) and consent Art. 6(1)(a)): service and billing notices always, marketing only with your consent

Accounting and legal claims (legal obligation Art. 6(1)(c) and legitimate interest Art. 6(1)(f)): retain records and handle disputes

You may object to processing based on legitimate interest. We will then stop the processing unless we have compelling legitimate grounds that override your interests.

Sensitive personal data

Information about sexual orientation, functional variation, neurodivergence, and health constitutes special categories of personal data under Article 9 GDPR.

We process such data only with your explicit consent (Art. 9(2)(a)), and only to provide relevant matching and accommodations. You decide what you share, and you can remove the information or withdraw your consent at any time in your profile settings. Withdrawing consent does not affect the lawfulness of processing carried out beforehand.

Please note that what you put in your profile is visible to other users. If you write sensitive information in free text or in messages, it may also be included in the automated moderation described below.

Content moderation and AI

To keep Luumi safe, text, photos, and video you upload are automatically scanned using AI-assisted moderation provided by OpenAI, in order to detect content that violates our Terms of Service.

Flagged content is reviewed in our admin system, where our team decides whether to keep or remove it. Content sent to OpenAI is used only for moderation and is not used to train AI models. The processing takes place under a data processing agreement and with the transfer safeguards described below.

The legal basis is our legitimate interest in a safe service and our obligation under the DSA to counter illegal content. For content containing sensitive data, the processing additionally relies on your explicit consent as described above.

Automated decision-making and profiling

Our matching function uses your profile and preferences to suggest other users. This is a form of profiling, but it has no legal consequences for you.

Moderation may mean that content is blocked or hidden automatically. Decisions with a significant effect on you, such as suspending your account, are made or checked by a human. You always have the right to have an automated decision reviewed by a person, to express your point of view, and to contest the decision. Contact us at info@luumiapp.se. See also the moderation section of our Terms of Service.

Who we share data with

Other users: your profile is visible to other users for matching purposes. You control what you share.

Processors: cloud hosting and storage, AI-assisted content moderation (OpenAI), analytics tools, and support tools. They may process the data only on our instructions, under processing agreements that meet Article 28 GDPR.

Apple and Google: handle purchases and payments as independent controllers under their own privacy policies.

Authorities: where required by law or to protect life and safety.

Business transfers: data may be transferred in a merger, acquisition, or sale of the business. We will inform you if this materially changes how the data is handled.

We do not sell your personal data and we do not use it for third-party advertising.

How long we keep your data

Active accounts: for as long as the account exists.

After account deletion: data is deleted within 30 days, with the exceptions below.

Accounting records: 7 years after the end of the calendar year in which the financial year ended, as required by the Swedish Accounting Act.

Reports, moderation decisions, and suspensions: up to 2 years, in order to handle appeals and repeat violations and to defend legal claims.

Messages you delete are removed from your view, but may remain with the recipient until they delete them too or the account is deleted.

Transfers outside the EU and EEA

Some providers, such as OpenAI, may process data in the United States or other countries outside the EU and EEA. When this happens we safeguard the data using the European Commission's Standard Contractual Clauses, where applicable combined with the EU-U.S. Data Privacy Framework, together with supplementary measures. You can request information about the safeguards applied by contacting us.

Your rights

You have the right to:

access your data and receive a copy of it

have inaccurate data corrected

have data erased

request restriction of processing

object to processing based on legitimate interest, and to direct marketing

receive your data in a machine-readable format and transfer it

withdraw consents you have given

not be subject to a decision based solely on automated processing that produces legal or similarly significant effects

Contact us at info@luumiapp.se. We respond within one month. If the matter is complex we may extend this by up to two further months and will inform you if we do.

If you are unhappy with how we handle your data, you can lodge a complaint with the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY), Box 8500, 104 20 Stockholm, imy.se.

Security

We protect your data with encryption in transit (HTTPS/TLS), access controls so that only those who need access have it, and ongoing security review.

In the event of a personal data breach involving risk, we notify IMY within 72 hours and inform you if the breach is likely to result in a high risk to you. No transmission over the internet is completely secure, and we cannot guarantee absolute security.

Children

Luumi is not intended for anyone under 18. We do not knowingly collect data from minors. If we learn that a minor has created an account, we will delete the account and the associated data.

Cookies and similar technologies

We use only the cookies technically necessary to make the app and website work. We do not currently use analytics or marketing cookies. If we introduce them, we will ask for your consent first. See our Cookie Policy for details.

Language

This policy is available in Swedish and English in app. If you are a consumer, the language version you were presented with applies.

Changes to this policy

We may update this policy. For material changes we will inform you in the app or by email before they take effect.

Contact us

Luumi AB, reg. no. 559533-4409

Åsboholmsgatan 28, 504 51 Borås, Sweden

Email: info@luumiapp.se