Last updated: 23 August 2026
This privacy policy explains how personal data is processed when you use the LumiAR mobile application. Deutsche Version. The separate website privacy policy applies when you visit gintli.com or support.gintli.com.
1. Controller
The controller and developer is Gellert Gintli, a private individual, Holzhof 12, 38667 Bad Harzburg, Germany. “Gintli Studios” is the project name used for the websites and apps; it is not a company or separate legal entity. Email: support@gintli.com.
2. Data processed in LumiAR
Camera and augmented reality
LumiAR requests camera access only when you use augmented-reality features. Camera images are processed in real time on your device. They are not uploaded to Gintli Studios, retained by us, or used for identification or advertising. You can deny or revoke camera access in the iOS or iPadOS settings; non-AR viewing remains available.
Learning progress and settings
Quiz answers, learning progress, downloaded experiences, and app settings are stored locally on your device. Gintli Studios does not receive or have access to this information. You can reset progress in the app and remove local app data by deleting the app.
Catalog and content downloads
The app connects to Microsoft Azure to retrieve the online catalog and download learning and 3D content. The delivery server necessarily receives technical connection data such as the IP address, request time, requested resource, and basic device or app request information. This data is used only to deliver content, maintain security, and diagnose technical failures.
Optional Apple diagnostics
If you enable Apple’s option to share analytics with app developers, Apple may make crash and diagnostic reports available to Gintli Studios. These reports may include the device model, operating-system and app versions, and technical crash information. LumiAR does not use advertising SDKs or cross-app tracking, and diagnostic reports are not intended to contain camera images or learning content. You can change diagnostic sharing in your Apple device settings.
3. Purposes and legal bases
- Providing the app, AR functions, progress features, and requested downloads: Article 6(1)(b) GDPR.
- Secure and reliable content delivery, abuse prevention, and troubleshooting: Article 6(1)(f) GDPR. Our legitimate interest is operating a secure and stable service.
- Improving stability using diagnostics voluntarily shared through Apple: Article 6(1)(f) GDPR. You can stop future sharing in your Apple settings.
4. Recipients and international transfers
Microsoft Azure is used to deliver the online catalog and downloadable content. Apple operates the App Store and, where enabled by you, supplies diagnostic reports. These providers may process technical data outside the European Economic Area. Their applicable adequacy mechanisms and contractual safeguards are described in the Microsoft Privacy Statement and Apple Privacy Policy.
Gintli Studios does not sell app data and does not disclose camera images or learning progress to advertisers.
5. Retention and deletion
Local progress and settings remain on your device until you reset them or delete the app. Technical delivery logs are retained only as long as required under the Azure configuration for content delivery, security, and troubleshooting, and are then deleted or anonymized. Logs associated with a security incident may be retained until the incident has been fully investigated. Apple retains diagnostic information according to its own policies and your device settings. Support emails are normally deleted within three months after the request is resolved unless legal or contractual retention duties require longer storage.
6. Children
LumiAR is intended for adults and children aged 12 and older. The app does not require a Gintli Studios account and does not ask children to consent to advertising or behavioral tracking. Camera images and learning progress stay on the device. Where consent is legally required for processing concerning a child, it must be given or authorized by the holder of parental responsibility as required by applicable law.
7. Your rights
Depending on the circumstances, you may have rights of access, rectification, erasure, restriction, objection, data portability, and withdrawal of consent. Because Gintli Studios cannot access data stored only on your device, those records must be managed using the app or device controls. For server logs, diagnostics available to us, or support correspondence, contact support@gintli.com.
You may lodge a complaint with a supervisory authority, in particular the authority for your place of residence or the State Commissioner for Data Protection of Lower Saxony.
8. Changes
We will update this notice when LumiAR’s data processing changes. The current version and its revision date will remain available at this URL.