Privacy policy
Short version: your artwork stays on your device. We collect as little as we can, never sell it, and never use advertising trackers.
Draft. This policy is a draft pending review by a qualified lawyer and is not yet in force. Items in [brackets] are still to be completed.
Draft of 28 September 2026. Applies to lumierpro.com and the Lumier Pro app.
1. Who we are
Lumier Pro is made by Epic Legend (Pty) Ltd, a private company registered in South Africa (registration number [registration number]), with its address at [physical address], South Africa ("we", "us").
We are the responsible party under South Africa's Protection of Personal Information Act 4 of 2013 (POPIA) and the controller under the EU and UK General Data Protection Regulation (GDPR) for the personal information described here.
Our Information Officer is [name of Information Officer], reachable at support@lumierpro.com (subject line "Privacy"). [EU/UK representative under GDPR Art. 27, if required: name and address]. Our PAIA manual is available at [link to PAIA manual].
2. At a glance
- Your artwork never leaves your device unless you export or share it yourself. It is stored in your browser's private storage for Lumier Pro, not on our servers.
- No account is needed to use the app. An account is optional and only needed for purchases and premium downloads (and, later, sync).
- Payments are handled by Paddle, our merchant of record. We never see your card details.
- Crash reports and usage statistics are off by default. They are sent only if you switch them on, and never include your artwork.
- No advertising, no selling, no third-party trackers. This website sets no cookies and loads nothing from other companies.
3. What we collect and why
| Information | Why we use it | Legal basis |
|---|---|---|
| Server logs when you visit the site or load the app: IP address, browser and operating system, page or file requested, date and time, referring page. | To deliver the site and app, keep them secure and investigate abuse. | Legitimate interests (GDPR Art. 6(1)(f)); POPIA s11(1)(f). |
| Account details (optional): email address, the identifier from a sign-in provider you choose (such as Google or Apple), and your plan and entitlements. | To create and secure your account, confirm what you've bought and deliver premium content. | Performance of a contract (GDPR Art. 6(1)(b)); POPIA s11(1)(b). |
| Purchase records we receive from Paddle: email, country, plan, subscription status, transaction and customer identifiers, amounts and dates. | To activate and manage your subscription, provide support and keep financial records. | Contract; legal obligation for tax and accounting records (GDPR Art. 6(1)(b), (c)); POPIA s11(1)(b), (c). |
| Premium download records: account identifier, pack requested, IP address and time. | To deliver packs you're entitled to and prevent link sharing or abuse. | Contract and legitimate interests; POPIA s11(1)(b), (f). |
| Support messages: whatever you send us, such as your email address, device details and screenshots. | To answer you and improve the app. | Legitimate interests, or contract if it concerns a purchase; POPIA s11(1)(b), (f). |
| Crash reports and usage statistics (opt-in only): app version, browser and operating system, device class, graphics backend, error messages and stack traces, performance timings, and a random installation identifier. Never your artwork, file contents or file names. | To find and fix bugs and make the app faster on real devices. | Consent (GDPR Art. 6(1)(a)); POPIA s11(1)(a). You can switch it off at any time in the app's settings. |
What we don't collect. We do not receive your artwork, brushes, documents or the files you import. They are processed entirely on your device. We don't collect precise location, contacts, biometric data or any special personal information. We don't use your information for advertising, and we don't sell or rent it to anyone. We don't make decisions about you based solely on automated processing.
4. Cookies and on-device storage
This website (lumierpro.com) sets no cookies and uses no analytics or third-party scripts.
The Lumier Pro app stores things on your device so that it can work at all, and work offline: your documents (in the browser's Origin Private File System), an offline copy of the app (Cache Storage), and your preferences (local storage). If you sign in, the app keeps a sign-in token on your device. All of this is strictly necessary for the service you asked for, stays on your device, and is never used to track you. You can remove it by clearing site data for lumierpro.com in your browser, which also deletes artwork you haven't exported.
5. Who we share it with
We share personal information only with the service providers we need to run Lumier Pro, under contracts that require them to protect it:
- DreamHost (New Dream Network, LLC, USA): hosts our website, app and servers, and therefore processes server logs and account data on our behalf as an operator.
- Paddle (Paddle.com Market Ltd and its affiliates): our merchant of record and reseller. When you buy Pro, you buy from Paddle, which processes your payment and billing details as an independent controller under Paddle's privacy notice.
- Sign-in providers such as Google or Apple, only if you choose to sign in with them. They act under their own privacy policies.
- Email delivery: [email provider, if used, for sign-in links and receipts].
- Professional advisers (lawyers, accountants, auditors) where necessary, under a duty of confidentiality.
- Authorities, where the law requires it or to protect the rights and safety of our users or others.
If our business is ever sold or restructured, personal information may transfer to the new owner, who will be bound by this policy.
6. International transfers
Our servers are hosted by DreamHost in the United States, and Paddle may process data outside South Africa and the EU. When personal information leaves South Africa, we transfer it only as POPIA section 72 allows, for example where the recipient is bound by a contract or laws that give comparable protection, or where the transfer is necessary to perform our contract with you. For transfers from the EU or UK, we rely on adequacy decisions or the European Commission's standard contractual clauses (and the UK addendum). [Confirm the DreamHost and Paddle transfer mechanisms.]
7. How long we keep it
- Server logs: [30] days, unless needed longer to investigate a specific security incident.
- Account details: while your account is open, and [90] days after you close it.
- Purchase records: for as long as tax and company law requires (in South Africa, generally five years).
- Premium download records: [90] days.
- Support messages: [two years] after the conversation ends.
- Crash reports and usage statistics: [90] days, then deleted or aggregated so they no longer identify an installation.
8. Security
We use HTTPS everywhere, keep the information we hold to a minimum, sign access tokens cryptographically, restrict server access to the people who need it, and keep payment details with Paddle rather than on our systems. Because your artwork is stored on your device, the security of your device also matters: use a screen lock and keep your browser up to date. If a breach ever affects your personal information, we will notify you and the relevant regulator as POPIA section 22 and the GDPR require.
9. Your rights
Depending on where you live, you have the right to:
- ask whether we hold personal information about you and get a copy of it (POPIA s23; GDPR Art. 15);
- have it corrected, or deleted if we no longer have a lawful reason to keep it (POPIA s24; GDPR Art. 16–17);
- object to processing based on legitimate interests (POPIA s11(3); GDPR Art. 21), and restrict processing (GDPR Art. 18);
- receive the information you gave us in a portable format (GDPR Art. 20);
- withdraw consent at any time, for example by switching off crash reports, without affecting earlier processing;
- complain to a regulator (see below).
To use any of these rights, email support@lumierpro.com with the subject "Privacy". We may need to confirm your identity first. We'll respond within [30 days], and we won't charge you for reasonable requests. Your artwork is on your device, so you can export or delete it yourself at any time.
10. Children
Lumier Pro can be used without an account, in which case we collect nothing about the person using it beyond server logs. Accounts and purchases are for people aged 18 or over, or younger people with the consent of a parent or guardian, as POPIA requires for children's personal information. If you believe a child has given us personal information without that consent, contact us and we'll delete it. [Confirm minimum age for accounts, e.g. 13 or 16 in some EU countries.]
11. Changes to this policy
We'll update this policy when our practices change, for example when sync launches. We'll change the date at the top, and for significant changes we'll tell you in the app or by email before they take effect.
12. Contact and complaints
Questions or requests: support@lumierpro.com, or by post to Epic Legend (Pty) Ltd, [physical address], attention: Information Officer.
If you're not happy with how we've handled your information, please tell us first so we can put it right. You can also complain to the Information Regulator (South Africa), or, if you live in the EU or UK, to your local data protection authority.