Privacy Policy

Effective: March 31, 2026 · Last updated: March 31, 2026

Lumina28 Design (“we,” “us,” or “our”) operates the REIKYO mobile application. This Privacy Policy explains how we collect, use, and protect your information when you use REIKYO.

1. Data We Collect

REIKYO processes the following categories of data only while you are actively running an investigation session:

2. Data We Do NOT Collect

• No analytics or tracking SDKs are included in REIKYO.
• No server-side data storage — all data stays on your device.
• No advertising identifiers (IDFA) are accessed or transmitted.
• No location data is sent to any server.
• No audio recordings leave your device.
• No email addresses are collected unless you voluntarily share one via Apple Sign-In.

3. How Data Is Used

All data processing occurs entirely on your device. Sensor readings are fed to an on-device CoreML model for statistical anomaly detection. No data is transmitted to external servers, cloud services, or third parties for any purpose.

4. Third-Party Sharing

We do not sell, share, rent, or disclose your personal information to any third party. Period.

The only third-party service interaction is Apple’s StoreKit for processing in-app purchases and subscriptions. Apple handles all payment information directly; we never receive, process, or store your payment details.

5. Data Retention

Investigation sessions, sensor readings, audio recordings, and anomaly logs are stored locally on your device for as long as you choose to keep them. You may delete any session from the Sessions tab at any time. Uninstalling REIKYO removes all locally stored data permanently.

6. Your Rights Under California Law (CCPA/CPRA)

Under the California Consumer Privacy Act (Cal. Civ. Code § 1798.100 et seq.), as amended by the CPRA, California residents have the following rights:

• Right to Know (§ 1798.100): You may request the categories and specific pieces of personal information we have collected.
• Right to Delete (§ 1798.105): You may request deletion of your personal information.
• Right to Correct (§ 1798.106): You may request correction of inaccurate personal information.
• Right to Limit Use of Sensitive Personal Information (§ 1798.121): You may direct us to limit the use of sensitive PI.
• Right to Opt-Out of Sale/Sharing (§ 1798.120): You may opt out of the sale or sharing of your personal information for cross-context behavioral advertising.

We do not sell or share your personal information. Because all data is stored locally on your device and never transmitted to us, exercising these rights is as simple as deleting the app or individual sessions within it.

To submit a verifiable consumer request, contact us at legal@lumina28.design or roy.yamamoto@gmail.com.

7. Do Not Sell or Share My Personal Information

We do not sell or share your personal information. REIKYO contains no advertising, no tracking SDKs, and no cross-context behavioral advertising. No action is required on your part to opt out, as there is nothing to opt out of.

8. Children’s Privacy

REIKYO is not directed at children under the age of 13. We do not knowingly collect personal information from children under 13. If you believe a child under 13 has provided us with personal information, please contact us and we will take steps to delete such information.

9. Data Security

All data is stored within the iOS app sandbox, protected by the device’s hardware encryption (Data Protection class: Complete Protection). We do not operate servers that store your data, eliminating the risk of server-side data breaches.

10. International Users

REIKYO is developed in the United States. Because all data remains on your device and is never transmitted to us, no cross-border data transfer occurs.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated effective date. Continued use of REIKYO after changes constitutes acceptance of the revised policy.

12. Contact