Privacy Policy

Privacy Policy

Effective Date: July 1, 2026 Last Updated: September 30, 2026

Published by Guided Lifestyle & Optimal Wellness, LLC (California limited liability company)www.officialglow.ai

Your privacy is foundational to everything we build at G.L.O.W. This document explains in plain language exactly what information we collect, why we collect it, how we protect it, and every right you have over it. We have written this Policy to cover both our current practices and our planned future features so you always know exactly what to expect as G.L.O.W. grows.

1. Introduction and Who We Are

G.L.O.W. — Guided Lifestyle and Optimal Wellness — is an AI-powered cosmetic surgery recovery companion application (the "App") owned and operated by Guided Lifestyle & Optimal Wellness, LLC, a California limited liability company ("G.L.O.W.," "Company," "we," "us," or "our"). The App is distributed under the brand name G.L.O.W. and features Lumi, an AI-powered recovery companion designed to provide users with personalized educational wellness content, recovery tracking tools, and guided support throughout their post-surgical recovery journey.

This Privacy Policy ("Policy") describes how we collect, use, store, protect, and share personal information in connection with your use of the App, our website at www.officialglow.ai, and any related services. It also describes the choices and rights you have over your personal information — including rights that apply to features not yet launched, so you are never surprised as the product evolves.

This Policy applies to:

• All registered users of the G.L.O.W. web application
• Visitors to our website at www.officialglow.ai
• Any person who communicates with us via email, in-app messaging, or support channels
• All current and future features of the G.L.O.W. platform, including Phase 2 features described throughout this Policy

By creating an account, accessing the App, or using any of our services, you acknowledge that you have read, understood, and agree to the data practices described in this Policy. If you do not agree, please do not use the App.

1.1 Our Privacy Principles

• Data Minimization. We collect only the personal information we need to deliver the service. We do not collect data speculatively or because it might be useful someday.
• Purpose Limitation. Information you provide for one stated purpose is not repurposed without your knowledge and, where legally required, your explicit separate consent.
• Transparency and Control. We tell you what we collect, why, who we share it with, how long we keep it, and what you can do about it. This Policy is written to be readable, not to obscure.
• Security by Design. Privacy and security protections are built into the product from day one, not layered on as an afterthought.

1.2 A Note on Phase 2 Features

This Policy is intentionally comprehensive. It covers both current App features and planned Phase 2 features — including photo analysis, push notification expansions, in-app advertising, and expanded AI capabilities — that are not yet live. Sections addressing Phase 2 features are clearly marked. Their inclusion does not mean those features are currently active. You will receive notice before any Phase 2 feature affecting your data is activated.

1.3 Contact Information

We aim to respond to all privacy inquiries within ten (10) business days and formal rights requests within the timeframes specified in Sections 11 through 14.

2. Definitions

• "Personal Data" or "Personal Information" means any information that relates to an identified or reasonably identifiable individual. This includes both direct identifiers (name, email) and indirect identifiers (device ID paired with procedure type) that could be combined to identify you.
• "Sensitive Personal Information" means a subset of personal data warranting heightened protection. For G.L.O.W. users this includes health-adjacent information you voluntarily enter into the App: procedure type, surgery date, recovery logs, symptom notes, and photos.
• "Aggregated Data" means information combined and anonymized across multiple users in a way that cannot identify any individual. Not personal data.
• "De-identified Data" means personal information processed to remove identifiers such that re-identification risk is negligible and we commit to making no attempt to re-identify it.
• "Processing" means any operation performed on personal data including collection, storage, use, disclosure, restriction, or deletion.
• "Service Providers" means third parties that process personal data strictly on our behalf under contracts prohibiting them from using your data for their own purposes.
• "App" means the G.L.O.W. web application and all associated services.
• "Phase 2" means planned product features not yet active at this Policy's effective date, disclosed here for transparency.
• "Lumi" means the AI-powered recovery companion within G.L.O.W., powered by Anthropic's Claude large language model technology.

3. Information We Collect

The information we collect falls into three categories: (1) information you provide directly; (2) information collected automatically through your use of the App and website; and (3) information related to Phase 2 features not yet active. Each is described in full below.

3.1 Information You Provide Directly

Account Registration Data

• Full name
• Email address
• Password — stored using one-way cryptographic hashing. We do not store, transmit, or have access to your plain-text password at any point.
• Date of birth or age confirmation — used solely to verify the 18+ eligibility requirement. Not used for marketing or profiling.

Recovery Profile Information

Used exclusively to tailor your recovery content, timelines, and Lumi guidance. Never shared with your surgeon, any medical provider, any insurance company, or any third party for clinical or financial purposes.

• Type of cosmetic or plastic surgery procedure (e.g., rhinoplasty, breast augmentation, liposuction, abdominoplasty, facelift, blepharoplasty, Brazilian butt lift, mommy makeover, and other supported procedures)
• Approximate surgery date or recovery start date
• Self-reported recovery stage or week number
• Optional: geographic region or city — used to surface locally relevant content, not for precise location tracking

Recovery Tracking and Diary Entries

Optional self-tracking tools. If you use them, we collect:

• Drain output logs — volume, dates, and times you record manually
• Symptom notes and wellness check-ins you choose to enter
• Personal journal or diary entries you write within the App
• Medication reminder titles and times you set — we do not collect or store medication names, dosages, or clinical information
• Recovery milestone completions you mark within the App

All diary entries, notes, and logs are private by default, visible only to you, and never shared with any third party.

AI Companion Conversation Data

• The full text of each message or question you submit to Lumi
• Contextual session data passed to the AI: your procedure type and recovery week, to improve response relevance
• Conversation history within an active App session

See Section 6 for a complete explanation of how Anthropic processes this data.

Payment and Billing Information

All payment processing is handled by Stripe, Inc. We do not collect, store, or have access to your full card number, CVV, expiration date, or bank account details. We retain:

• Subscription tier and active billing period
• Transaction confirmation tokens issued by Stripe (non-sensitive reference identifiers only)
• Billing country and, where required for tax purposes, billing address or postal code
• Subscription status: active, cancelled, past due, or paused
• Renewal dates, cancellation dates, and upgrade or downgrade history

Stripe is an independent data controller for payment card data. Review their privacy policy at stripe.com/privacy.

Push Notification Data

If you grant push notification permission, we collect and store:

• Your browser push subscription — a unique identifier issued by your browser's push service (for example, Apple, Google, or Mozilla) used to route notifications to your device
• Your notification preference settings — which notification types you have enabled or disabled
• Timestamps of notifications sent and, where supported by the platform, whether a notification was opened

Push notifications from G.L.O.W. may include recovery milestone reminders, daily wellness check-in prompts, drain log reminders, Lumi follow-ups, and important App updates. You can withdraw notification permission at any time in your browser or device settings.

Customer Support and Communications

• Your name and email address
• The content of your message, support request, or feedback
• Screenshots or attachments you voluntarily submit
• Records of prior communications with our support team
• Satisfaction ratings or feedback you provide after support interactions

3.2 Information Collected Automatically

Device and Technical Information

• Device type, manufacturer, model, and hardware specifications
• Operating system type and version
• Browser type and version
• IP address — used for security and fraud prevention, and to derive general region at city or state level only. We do not store precise GPS location derived from IP.
• Connection type
• Language, locale, and time zone settings

Usage and Interaction Data

• Screens and features you access within the App, and the order in which you access them
• Duration and frequency of App sessions
• Content cards, recovery guides, and FAQ entries you open, save, or dismiss
• Recovery timeline milestones you view or interact with
• Lumi interaction frequency and general topic categories of questions asked — aggregated, not individual profiling
• Buttons, navigation elements, and interactive components you tap
• Search queries entered within the App
• Timestamps of key actions within the App

Performance and Diagnostic Data

• App crash reports including device state at time of crash
• Error logs and exception reports
• App load times, screen render times, and API response time metrics
• Network request performance data

Diagnostic data is used exclusively to identify bugs, improve App stability, and maintain service quality. It is never used for advertising or profiling, and is never sold.

Cookies and Similar Technologies — Website

Our website and web application use:

• Strictly Necessary. Required for basic site function: authentication, security tokens, session management. Cannot be disabled.
• Functional. Remember your preferences — language, logged-in status, display settings.
• Analytics. Help us understand website navigation patterns and identify friction points. Used only for improving the web experience. Not used for behavioral advertising.
• Phase 2 — Advertising Cookies. Not currently active. Will be deployed only when Phase 2 advertising launches, with required notice and consent. See Section 3.4.

You can manage cookie preferences through your browser settings or our cookie preference center. You can also use the Global Privacy Control (GPC) signal — see Section 16.

3.3 Phase 2: Photo Upload and Analysis

G.L.O.W.'s Phase 2 roadmap includes an optional photo upload and visual recovery tracking feature.

What Will Be Collected

• Photos you voluntarily upload through a user-initiated upload flow
• Date and time of each upload
• Optional user-provided labels or notes associated with each photo
• Photo file metadata — G.L.O.W. will strip GPS location data embedded in photo files before storing them

How Photo Data Will Be Used

• To display your personal recovery photo timeline within the App, visible only to you
• To enable side-by-side visual comparison across recovery stages
• If you explicitly opt in: to provide AI-assisted visual recovery observations — general educational observations only, not medical evaluation or diagnosis

What We Will Never Do With Your Photos

• We will not use your recovery photos to train AI models without your separate, explicit opt-in consent
• We will not display your photos to other users under any circumstances
• We will not share your photos with any third party except as required by law
• We will not use facial recognition technology or derive biometric identifiers from your photos
• We will not use your photos for advertising, marketing, or promotional materials without completely separate written consent

Photo Storage and Deletion

• All photos will be encrypted at rest using AES-256 in isolated, access-controlled cloud storage
• You may delete individual photos or your entire photo library at any time from within the App
• Deleted photos will be permanently removed from our servers within 30 days
• Photo data is never converted to anonymized form — it is deleted in full upon your request

3.4 Phase 2: Advertising Data

When G.L.O.W. launches advertising-supported features in Phase 2, we will update this section with an effective date. At that time, we may collect:

• Advertising Identifiers. If G.L.O.W. is offered as a mobile app in the future: Apple IDFA and/or Android AAID, subject to your device's tracking permission settings. On iOS, we will request permission through Apple's App Tracking Transparency (ATT) framework before accessing your IDFA. Denial has no impact on core G.L.O.W. features.
• Ad Interaction Data. Whether you viewed, tapped, or dismissed an advertisement.
• Attribution Data. Used to determine whether a user action was influenced by a specific ad campaign.
• Advertising Cookies and Pixels. Third-party advertising cookies and pixels on our website. We will update our cookie disclosure and provide consent mechanisms before these are deployed.

When Phase 2 advertising launches, we will:

• Provide at least 30 days advance notice by email and in-app notification
• Update this Policy with a new effective date
• Provide clear opt-out mechanisms for interest-based advertising
• Publish a complete list of advertising partners in this Policy
• Explicitly exclude your health and recovery data from all advertising targeting logic — procedure type, surgery date, drain logs, symptom notes, and photos will never be used for advertising targeting

3.5 Information We Do Not Collect

To be completely explicit about our data collection limits, we do not collect:

• Social Security numbers or government-issued identification numbers
• Precise real-time GPS coordinates
• Device contacts, call logs, or SMS messages
• Camera roll or photo library contents without an explicit, user-initiated permission request at the time of the action
• Data from other health apps or your device health data store (Apple HealthKit, Google Fit) without a separate explicit permission request — this integration is not currently active
• Audio or video without your knowledge
• Complete financial account information — only Stripe-issued billing tokens as described in Section 3.1
• The identity, name, or contact information of your surgeon or healthcare provider
• Biometric identifiers: fingerprints, facial geometry, voiceprints, or iris scans
• Psychological or behavioral profiles for sale to third parties

4. How We Use Your Information

We use personal information only for the purposes described below. We do not use your data in ways you would not reasonably expect based on how you use the App.

4.1 To Provide, Operate, and Personalize the App

• Generating personalized recovery timelines, care cards, and milestone checklists based on your procedure type and stage
• Tailoring Lumi's educational responses to your procedure, recovery week, and self-reported symptoms
• Surfacing relevant recovery guides, FAQ content, and wellness tips
• Enabling recovery tracking: drain logs, symptom check-ins, milestone completions
• Remembering your in-app preferences and settings across sessions
• Delivering push notifications relevant to your recovery schedule

Legal basis: Performance of contract.

4.2 To Process Payments and Manage Subscriptions

• Processing subscription payments through Stripe
• Managing billing cycles, renewals, upgrades, downgrades, and cancellations
• Issuing receipts and subscription confirmations
• Resolving billing disputes, payment failures, and refund requests
• Maintaining financial records required by law

Legal basis: Performance of contract; legal obligation.

4.3 To Send Push Notifications

• Recovery milestone reminders and daily check-in prompts
• Drain log reminders at intervals you configure
• Lumi follow-up messages and wellness tips
• Important account alerts: subscription renewal, password changes
• Critical App updates and changes to this Policy or our Terms of Service
• Phase 2: Promotional notifications about new features or offers, if you separately consent

Legal basis: Performance of contract for service-related notifications; consent for promotional notifications.

4.4 To Communicate With You

• Responding to support requests, questions, and feedback
• Sending account-related transactional emails: welcome messages, password resets, subscription confirmations
• Notifying you of material changes to this Policy or our Terms of Service
• Optional product updates and feature announcements to users who have opted in

Legal basis: Performance of contract for transactional communications; consent for promotional email.

4.5 To Operate, Maintain, and Improve the App

• Diagnosing and resolving bugs, crashes, and performance issues
• Analyzing aggregated, anonymized usage patterns to understand feature engagement
• Testing and evaluating new features
• Improving the accuracy and quality of recovery content
• Internal research and quality assurance using exclusively de-identified, aggregated data — never identifiable personal information

Legal basis: Legitimate interest in maintaining and improving the product.

4.6 For Safety, Fraud Prevention, and Security

• Detecting and preventing unauthorized account access
• Identifying and blocking fraudulent subscription activity
• Monitoring for Terms of Service violations
• Protecting the security and integrity of our infrastructure and user data

Legal basis: Legitimate interest in protecting users and the platform.

4.7 To Comply With Legal Obligations

• Complying with applicable federal, state, and local laws
• Responding to valid legal process: subpoenas, court orders, government requests
• Fulfilling tax reporting and financial record-keeping obligations
• Cooperating with regulatory inquiries as required by law

Legal basis: Legal obligation.

4.8 What We Will Never Do With Your Data

These prohibitions are absolute. They apply now, in Phase 2, and to any future version of G.L.O.W., regardless of product changes or corporate events.

• Sell, rent, license, or transfer your personal information to third-party advertisers, data brokers, or marketers for their own use
• Share your information with health insurance companies, life insurers, employers, or any entity that could use it to affect your insurability, premiums, coverage, or employment
• Share your information with your surgeon, hospital, medical practice, or any healthcare provider
• Use your health-adjacent recovery data as inputs to advertising targeting — procedure type, surgery date, drain logs, symptom notes, and photos are permanently excluded from advertising logic
• Make automated decisions that have legal or similarly significant effects on you without the opportunity for human review
• Use your data in ways that would require us to be classified as a HIPAA Covered Entity or Business Associate

5. Legal Basis for Processing Personal Data

• Contractual Necessity. Processing required to deliver the services you subscribed to: account creation, service delivery, subscription management, transactional communication.
• Legitimate Interests. Processing necessary for our legitimate business interests — App improvement, security monitoring, fraud prevention, diagnostic data collection — where those interests are not overridden by your rights. We have assessed each legitimate interest purpose for proportionality.
• Legal Obligation. Processing required to comply with applicable law: financial record-keeping, tax reporting, responses to lawful legal process.
• Consent. For specific activities beyond core service delivery — promotional email, Phase 2 photo analysis, Phase 2 advertising, and future features involving sensitive information — we will request explicit, freely given, specific, and informed consent. You may withdraw consent at any time without affecting core App functionality.

Contact legal@lumiintelligence.ai with questions about the legal basis for any specific processing activity.

6. AI Technology — Lumi and Anthropic Claude

Lumi is powered by large language model technology developed and operated by Anthropic, PBC ("Anthropic"). This section provides a complete explanation of how that technology works and the privacy implications.

6.1 How Lumi Generates Responses

• Your message text and relevant recovery context (procedure type, recovery week) are formatted as an API request
• The request is transmitted over an encrypted HTTPS connection to Anthropic's API servers
• Anthropic's Claude AI model processes the request and generates an educational response
• The response is returned over the same encrypted connection and displayed in the App

Lumi does not retain persistent memory between separate App sessions. Within a session, prior messages are included for conversational coherence. Starting a new session resets Lumi's context.

6.2 What Anthropic Receives

• The full text of your message or question as submitted
• System-level context we configure: your procedure type, recovery week, and the instructional framing that defines Lumi's educational role and limitations
• Prior messages in the current session included for conversational coherence

We intentionally minimize the personal information in each request. Your name, email, account identifiers, payment information, and drain log data are not transmitted to Anthropic. However, if you voluntarily include personal information in your messages — full name, surgeon's name, specific medication details — that information will be in the API request. We recommend not including sensitive personally identifiable information in your Lumi conversations.

6.3 Anthropic's Data Practices

Anthropic maintains its own privacy practices at anthropic.com/privacy. As of this Policy's effective date:

• Guided Lifestyle & Optimal Wellness, LLC maintains a paid commercial API agreement with Anthropic. Commercial API customers typically have different data handling terms than free-tier users — specifically, commercial API data is generally not used to train Anthropic's foundational models by default.
• We have configured our integration to minimize data retention by Anthropic's systems to the extent contractually available.
• Anthropic may retain conversation data for safety monitoring, abuse prevention, and compliance consistent with their published policies.

We will update this section if we change AI providers, if our Anthropic agreement changes materially, or if Anthropic's privacy practices change in a way material to G.L.O.W. users.

6.4 AI Accuracy and Limitations

• AI responses may contain inaccuracies, outdated information, or generalizations that do not account for your specific clinical circumstances
• Lumi does not have access to your medical records, surgeon's notes, or clinical assessments
• Responses are not reviewed by licensed healthcare professionals before delivery
• The same question may produce different responses across sessions due to the probabilistic nature of large language models
• Lumi cannot diagnose conditions, prescribe treatments, or replace the judgment of your surgeon or any licensed medical provider

Every Lumi response is educational in nature. Nothing Lumi tells you should be acted upon without first consulting your surgical team.

6.5 Phase 2 AI Capabilities

• Photo analysis — AI models may analyze recovery photos to surface general educational observations. Requires separate consent. The same prohibition on using photos for model training without explicit opt-in applies.
• Voice interaction — Future voice-based interaction with Lumi will include a separate disclosure covering audio data handling before launch.
• Expanded personalization — Future AI capabilities that incorporate longer-term memory or deeper recovery profile integration will be disclosed and, where required, will require your consent before activation.

7. How We Share Your Information

We do not sell your personal information. We do not share it with advertisers, healthcare providers, or insurance companies. The sharing described below is limited to what is strictly necessary to operate the App, comply with law, or act on your explicit direction.

7.1 Service Providers Acting on Our Behalf

All service providers are contractually prohibited from using your data for their own purposes and are required to maintain security standards equivalent to ours.

• Stripe, Inc. — Payment Processing. Processes subscription payments and handles payment card data under PCI-DSS compliance. Independent data controller for payment information. Privacy policy: stripe.com/privacy.
• Anthropic, PBC — AI Infrastructure. Powers the Lumi AI companion. See Section 6 for full details.
• Supabase, Inc. — Backend Database and Authentication. Provides backend database and user authentication infrastructure. Your account credentials, recovery profile, recovery log data, and App usage records are stored in Supabase's cloud database (built on AWS infrastructure). Bound by Data Processing Agreement with us. Privacy policy: supabase.com/privacy.
• Browser Push Services (for example, Apple, Google, and Mozilla) — Push Notification Delivery. If you enable notifications, your browser's push service routes them to your device using your push subscription. These providers do not receive recovery data — only your delivery token and notification payload.

We will update this list when we add or change service providers in a way material to your privacy.

7.2 Phase 2: Advertising Partners

• Health-adjacent recovery data (procedure type, surgery date, drain logs, symptoms, photos) will never be shared with advertising partners or used in advertising targeting
• Advertising will be based only on non-health contextual signals
• Clear, accessible opt-out mechanisms for interest-based advertising will be provided
• If G.L.O.W. is offered as a mobile app, we will comply with Apple's App Tracking Transparency requirements and will not access IDFA without explicit permission
• A full list of advertising partners and the data shared with each will be published in this Policy when advertising is activated

7.3 Business Transfers

In the event of a merger, acquisition, reorganization, asset sale, or bankruptcy, your personal information may be transferred to a successor entity. If this occurs:

• We will provide at least 30 days advance notice by email and in-app notification before data is transferred to an entity whose privacy practices materially differ from this Policy
• The successor entity will be required to honor the commitments in this Policy, or you will be given the opportunity to delete your data before transfer

7.4 Legal Process and Government Requests

We may disclose personal information when we have a good-faith belief that disclosure is required by law, by valid legal process, or to protect the safety of our users or the public. We will challenge requests we believe are overbroad or lack proper legal authority.

Consistent with California AB 1242, we will not comply with out-of-state legal process seeking personal information in connection with enforcement of another state's laws where compliance would violate California law.

7.5 With Your Explicit Consent

Beyond the categories above, we will not share your personal information with any third party without your explicit, separately obtained, informed consent. You may withdraw consent at any time by contacting legal@lumiintelligence.ai.

7.6 Aggregated and De-Identified Data

We may share aggregated, de-identified data that cannot identify any individual for purposes such as general wellness research or publishing insights about post-surgical recovery patterns. Before any such sharing, we apply technical and administrative measures to prevent re-identification.

8. HIPAA Notice — Important Disclosure

HIPAA governs how covered healthcare entities — hospitals, physicians, health insurers, and their business associates — handle patient health data. G.L.O.W. is a consumer wellness app, not a healthcare provider, health plan, or clearinghouse. Our services do not create a doctor-patient relationship, generate clinical records, or integrate with covered healthcare systems.

• Information you enter into G.L.O.W. does not form part of your official medical record
• G.L.O.W. does not transmit your information to your surgeon, hospital, or any covered healthcare entity
• Your data in G.L.O.W. is not subject to HIPAA's patient access, correction, or accounting rights
• You should not use G.L.O.W. as a substitute for your official post-operative care instructions or communications with your surgical team

Despite not being subject to HIPAA, we apply strong technical safeguards, strict contractual controls on service providers, and internal access restrictions to health-adjacent data that exceed what is required of a general consumer app.

9. How Long We Keep Your Information

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.

9.1 Active Account Data

All account registration data, recovery profile information, recovery tracking entries, push notification preferences, and conversation history are retained while your account is active.

Cancelling a paid subscription does not delete your data. When you cancel, your access continues until the end of the current billing period and your account then moves to the Free tier — your account, recovery profile, tracking entries, and conversation history are all retained so you can pick up exactly where you left off if you resubscribe. If you want your data removed after cancellation, submit a deletion request through the "Request Data Deletion" option in the App's Account screen or as described in Section 9.9.

9.2 Payment and Transaction Records

Retained for a minimum of seven (7) years from each transaction date as required by U.S. federal tax law (26 U.S.C. § 6001) and California financial record-keeping regulations. Payment card data is held by Stripe under their own PCI-DSS retention policies.

9.3 Customer Support Records

Retained for three (3) years from the date of each interaction for consistent, informed assistance and dispute resolution purposes.

9.4 Push Notification Tokens

Retained while your account is active and notifications are enabled. Tokens for accounts with notifications disabled or inactive for more than twelve (12) consecutive months are purged. Deleted as part of account deletion.

9.5 Diagnostic and Technical Data

App crash reports, error logs, and performance data are retained for a maximum of ninety (90) days, then automatically deleted or anonymized. Data escalated into active bug investigations may be retained until the issue is resolved plus thirty (30) days.

9.6 AI Conversation Data

Lumi conversation history we store within our systems is retained for the duration of your account's active status and deleted within thirty (30) days of account deletion. Anthropic's retention of API data is subject to their own policies. We do not retain identifiable AI conversation logs beyond what is needed for session continuity.

9.7 Phase 2: Photo Data

Photos are retained while your account is active and you have not deleted them. Individual photos you delete are permanently removed within thirty (30) days. All photos are deleted within thirty (30) days of account deletion. Photo data is never converted to anonymized form — it is deleted in full.

9.8 Following Account Deletion

• Account profile, recovery log data, journal entries, notification preferences, and conversation history deleted or irreversibly anonymized within thirty (30) days of your verified request
• Transaction records retained for the legally mandated period described in Section 9.2, stored in isolation from active user data
• Aggregated, anonymized statistical data derived from your activity cannot be retroactively removed because it cannot be linked to you
• Written confirmation sent to your registered email when deletion is complete

9.9 Requesting Early Deletion

You may request deletion of specific data categories at any time by contacting legal@lumiintelligence.ai with subject line "Data Deletion Request." We will confirm receipt within five (5) business days and process within thirty (30) days.

10. How We Protect Your Information

Security is a design requirement at G.L.O.W. We implement and continuously maintain technical, administrative, and physical safeguards designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction.

10.1 Technical Safeguards

• All data transmitted between the App and our servers is encrypted using TLS 1.2 or higher — every API call, login, and data sync travels over an encrypted channel
• Sensitive data stored in our database is encrypted at rest using AES-256 encryption
• Passwords are stored using one-way cryptographic hashing with salting. We cannot retrieve your plain-text password.
• Authentication and session management are handled through Supabase's infrastructure, implementing industry-standard JWT session management, automatic session expiration, and refresh token rotation
• Production database access is restricted to a minimal set of authorized systems and personnel through role-based access controls — no employee has broad standing access to user data
• All API keys and secrets are stored in environment-isolated secret management systems and rotated on a regular schedule
• Phase 2: Photo data will be stored in dedicated, access-controlled cloud storage with AES-256 encryption at rest, isolated from the primary application database

10.2 Administrative Safeguards

• Internal access to user personal information is restricted strictly on a need-to-know basis
• Access logs for all production data systems are maintained and reviewed periodically
• All third-party service providers with access to user data are required to maintain equivalent or higher security standards under Data Processing Agreements
• We maintain a written incident response plan for data breaches and security events
• We conduct periodic reviews of data handling practices, access controls, and security configurations

10.3 Your Responsibilities

• Use a strong, unique password for your G.L.O.W. account — do not reuse passwords from other services
• Enable device-level biometric authentication to prevent unauthorized access if your device is lost or stolen
• Log out of the App when using a shared or public device
• Contact support@officialglow.ai immediately if you suspect unauthorized account access, a compromised password, or unusual account activity

10.4 Data Breach Notification

• We will notify affected users by email within seventy-two (72) hours of becoming aware of a breach affecting their personal data, to the extent required and permitted by applicable law
• Notifications will describe: which data categories were affected; the approximate timeframe; steps we are taking to contain and remediate; and recommended steps for you
• Applicable regulatory authorities will be notified as required by breach notification laws in relevant jurisdictions

No method of electronic storage or internet transmission is 100% secure. We apply commercially reasonable and industry-standard security measures but cannot guarantee absolute security.

11. Your Privacy Rights

We extend and honor the following rights to all users regardless of jurisdiction, because we believe privacy is a universal right.

11.1 Right to Know and Access

Know what personal information we hold about you, the sources, the purposes, and the third parties we share with. Request a copy in a structured, portable format (JSON or CSV) by contacting legal@lumiintelligence.ai.

11.2 Right to Correction

Request correction of inaccurate, incomplete, or outdated personal information. Update most account and profile information directly in the App's Settings menu. Contact support@officialglow.ai for corrections you cannot make yourself.

11.3 Right to Deletion

Request deletion of your personal information, subject to legal retention obligations (Section 9.2). Contact legal@lumiintelligence.ai with subject line "Data Deletion Request." Confirm within five (5) business days; complete within thirty (30) days. You may also delete your account directly from App Settings.

11.4 Right to Data Portability

Receive a copy of your personal information in a structured, machine-readable format and request we transmit it to another service provider where technically feasible.

11.5 Right to Restrict Processing

In certain circumstances — for example while a dispute about data accuracy is being resolved — request that we limit how we use your personal information.

11.6 Right to Object

Where we rely on legitimate interests as the legal basis, object to that processing. We will honor your objection unless we have compelling legitimate grounds that override your interests.

11.7 Right to Withdraw Consent

Withdraw consent for any activity based on consent at any time. Withdrawal does not affect lawfulness of prior processing and will not prevent access to G.L.O.W.'s core features based on contractual necessity.

11.8 Right to Opt Out of Push Notifications

Withdraw notification permission at any time through your browser or device settings. Does not affect your account or subscription.

11.9 Right Not to Be Discriminated Against

We will not discriminate against you for exercising any privacy rights — no denial of App access, no lower quality of service, no different pricing.

11.10 How to Submit a Privacy Rights Request

• Email legal@lumiintelligence.ai with subject line "Privacy Rights Request"
• Describe the right you wish to exercise and the data categories affected
• Or use the in-app support feature and select "Privacy and Data" as the topic

We will verify your identity before processing your request. We will respond within thirty (30) days. If an extension is needed (up to sixty days), we will notify you before the initial period expires. If we cannot fulfill a request due to legal obligations, we will explain the specific reason in writing.

12. California Consumer Privacy Rights (CCPA/CPRA)

If you are a California resident, you have specific rights under the CCPA as amended by the CPRA (collectively, "California Privacy Laws"). This section supplements Section 11. In the event of a conflict, this section governs for California residents.

12.1 Categories of Personal Information Collected in the Past 12 Months

• Identifiers. Name, email address, IP address, device identifiers, push notification tokens.
• California Customer Records (Cal. Civ. Code § 1798.80). Name, email address, subscription and payment records.
• Internet/Electronic Network Activity. App usage data, feature interaction history, navigation patterns, website browsing behavior on officialglow.ai.
• Health and Medical Information. Procedure type, surgery date, drain output logs, symptom notes, recovery milestone data — all voluntarily provided.
• Commercial Information. Subscription records, transaction history, billing status.
• Inferences. Personalized recovery content recommendations derived from procedure type and recovery stage.
• Sensitive Personal Information. Account login credentials (email and hashed password); health-adjacent recovery information described above.

12.2 Purposes for Collection

Each category is collected for the business purposes described in Section 4. Sensitive personal information is used only to provide the services you requested — not for secondary or unrelated purposes.

12.3 Third Party Disclosure

We disclose personal information to service providers (Stripe, Anthropic, Supabase, and browser push services) as described in Section 7. We do not sell personal information. We do not share for cross-context behavioral advertising at this time. Phase 2 advertising sharing will trigger an updated version of this section.

12.4 Notice of Right to Opt Out of Sale or Sharing

We do not sell personal information as defined under CCPA/CPRA. We do not share for cross-context behavioral advertising at this time. When Phase 2 advertising launches, we will provide an explicit opt-out mechanism and update this section.

12.5 Your California-Specific Rights

• Right to Know. Disclosure of specific pieces and categories of personal information collected, used, disclosed, and sold in the preceding 12 months.
• Right to Delete. Deletion of personal information collected from you, subject to legal exceptions.
• Right to Correct. Correction of inaccurate personal information.
• Right to Opt Out of Sale/Sharing. Not currently applicable. Will be activated for Phase 2 advertising.
• Right to Limit Use of Sensitive Personal Information. We use sensitive personal information only to perform the services you requested. No secondary or unrelated use occurs.
• Right of Non-Discrimination. You will not be discriminated against for exercising your California privacy rights.

12.6 Submitting a California Privacy Request

Email legal@lumiintelligence.ai with "California Privacy Request" in the subject line. We will respond within forty-five (45) days. Extension up to an additional forty-five (45) days is available with prior written notice. Authorized agent requests require written proof of authorization and direct identity verification with you.

12.7 Shine the Light (Cal. Civ. Code § 1798.83)

We do not disclose personal information to third parties for their own direct marketing purposes, so no Shine the Light disclosure is required. Confirm this practice by contacting legal@lumiintelligence.ai.

12.8 Notice at Collection

This Privacy Policy serves as our Notice at Collection and is accessible from the App registration flow and our website. We do not collect personal information from California residents before making this Policy available to them.

13. Additional U.S. State Privacy Rights

The following states have enacted comprehensive consumer privacy laws that may grant their residents additional rights: Colorado (CPA), Connecticut (CTDPA), Delaware (DPDPA), Florida (FDBR), Indiana (INCDPA), Iowa (ICDPA), Montana (MTCDPA), New Hampshire (NHPA), New Jersey (NJDPA), Oregon (OCPA), Tennessee (TIPA), Texas (TDPSA), Utah (UCPA), and Virginia (VCDPA).

To the extent these laws apply, you may have rights including: right to know, right to access, right to correct, right to delete, right to data portability, right to opt out of sale, right to opt out of targeted advertising, right to opt out of profiling for significant decisions, and right not to be discriminated against.

To exercise state privacy rights, email legal@lumiintelligence.ai with "State Privacy Rights Request" in the subject line and identify the specific right and your state of residence. We will respond within the timeframe required by your state's law. If we deny a request, we will explain the reason and provide information about how to appeal.

We honor the spirit of these state privacy laws for all users even where technical applicability thresholds may not require us to do so.

14. International Users and Cross-Border Data Transfers

G.L.O.W. is headquartered in the United States. G.L.O.W. is accessible to users worldwide. If you access the App from outside the United States, this section describes your rights and our data transfer practices.

14.1 Data Storage Location

Personal information is stored on servers in the United States through Supabase/AWS infrastructure. By creating an account from outside the United States, you understand that your data will be transferred to, processed in, and stored in the United States.

14.2 European Economic Area, United Kingdom, and Switzerland

• Personal information is transferred to the United States under transfer mechanisms consistent with applicable law. Where required, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission, or UK International Data Transfer Agreements (IDTAs), to govern EEA/UK-to-US transfers.
• You may have rights under the GDPR or UK GDPR in addition to the rights in Section 11, including the right to lodge a complaint with your national data protection supervisory authority.
• The legal bases for processing EEA/UK user data are the same as described in Section 5.
• Our data protection contact for EEA/UK inquiries: legal@lumiintelligence.ai

EEA residents may lodge complaints with their national supervisory authority (edpb.europa.eu). UK residents may contact the Information Commissioner's Office at ico.org.uk.

14.3 Canada

Personal information may be transferred to the United States in compliance with PIPEDA and applicable provincial privacy legislation. You may have rights to access, correct, and request deletion of your personal information and to lodge a complaint with the Office of the Privacy Commissioner of Canada at priv.gc.ca.

14.4 Australia

Personal information may be processed outside Australia consistent with the Australian Privacy Act 1988 and Australian Privacy Principles. You may lodge a complaint with the Office of the Australian Information Commissioner at oaic.gov.au.

14.5 Other Jurisdictions

If you are located in a jurisdiction not specifically described above and your local law provides privacy rights or data transfer protections, contact us at legal@lumiintelligence.ai. We will work to honor applicable local law requirements and respond within a reasonable timeframe.

15. Children's Privacy — COPPA Compliance

G.L.O.W. is designed exclusively for adults age eighteen (18) and older. We do not knowingly collect, use, or disclose personal information from children.

• We require users to confirm they are at least 18 years of age during account registration
• We do not knowingly collect personal information from anyone under age 13
• If we become aware of personal information collected from a child under 13 without parental consent, we will delete it as promptly as possible
• If we discover a user is under 18, we reserve the right to close the account and delete associated data

If you are a parent or guardian and believe your child under 13 has provided us with personal information, contact legal@lumiintelligence.ai immediately. We will investigate and promptly delete the information and close the account if confirmed.

16. Do Not Track Signals and Global Privacy Control

16.1 Do Not Track (DNT)

Some browsers transmit a Do Not Track (DNT) signal to indicate the user does not wish to be tracked. No universally accepted technical standard exists for mandatory DNT responses. The G.L.O.W. App does not use cross-site behavioral tracking. Our website may use analytics cookies as described in Section 3.2 but does not engage in the cross-site third-party tracking DNT signals primarily address. If applicable law establishes specific DNT response requirements, we will comply.

16.2 Global Privacy Control (GPC)

The Global Privacy Control (GPC) is a browser-based signal communicating a user's preference to opt out of the sale or sharing of personal information for targeted advertising under applicable law including the CPRA.

When a user visits www.officialglow.ai with a GPC-enabled browser:

• We will treat the GPC signal as a valid opt-out from the sale and sharing of personal information under applicable California law
• We will immediately stop any data sharing governed by that opt-out for the duration of that session and for future visits from that browser until the signal is withdrawn
• GPC signals are processed on a per-browser basis; enable GPC on each browser or device you use

Because we do not currently sell personal information or share it for cross-context behavioral advertising, the practical effect of a GPC signal on current practices is limited. It will become more significant when Phase 2 advertising launches. Download a GPC-compatible browser or extension at globalprivacycontrol.org.

17. Third-Party Links and Services

The App and website may contain links to third-party websites, services, or resources — for example, Stripe's website, Anthropic's privacy policy, or external wellness resources referenced in recovery content. This Privacy Policy applies only to G.L.O.W.

When you click a third-party link, you enter a site or service we do not operate, control, or monitor. We encourage you to review the privacy policy of every third-party service before interacting with it. The inclusion of a link does not imply our endorsement of that resource or its privacy practices. We assume no responsibility for third-party content, privacy practices, security, or availability.

18. Changes to This Privacy Policy

18.1 Minor Changes

Updates that do not materially affect how we handle your personal information — clarifying language, typographical corrections, adding information about a new service provider that handles data identically to existing ones — will be made with an updated Last Updated date and a notice on our website.

18.2 Material Changes

Material changes significantly affect: (a) categories of personal information collected; (b) how we use it; (c) third parties with whom we share it; (d) your privacy rights; or (e) practices inconsistent with this Policy. For material changes we will:

• Provide at least fourteen (14) days advance notice by email to your registered address before the change takes effect
• Display a prominent in-app notification describing the nature of the change
• Post the updated Policy at www.officialglow.ai/privacy with both the new and prior effective dates clearly marked
• For Phase 2 features becoming active (advertising, photo analysis): the 30-day notice period described in Sections 3.3 and 3.4 applies

Continued use of the App after the effective date of a revised Policy constitutes acceptance. If you do not agree with a material change, stop using the App before it takes effect and request data deletion as described in Section 11.3.

18.3 Prior Versions

Prior versions of this Privacy Policy are archived and available upon request by contacting legal@lumiintelligence.ai.

19. Privacy Dispute Resolution

19.1 Contact Us First

For any privacy complaint, contact legal@lumiintelligence.ai with "Privacy Complaint" in the subject line. We will assign your complaint to a team member and provide a substantive written response within ten (10) business days.

19.2 Regulatory Complaints — United States

California residents may contact the California Privacy Protection Agency (cppa.ca.gov) or California Attorney General (oag.ca.gov). Other state residents may contact their state Attorney General. Federal complaints may be filed with the FTC at ftc.gov/complaint.

19.3 Regulatory Complaints — International

EEA residents: national data protection supervisory authority (edpb.europa.eu). UK residents: Information Commissioner's Office (ico.org.uk). Canadian residents: Office of the Privacy Commissioner of Canada (priv.gc.ca). Australian residents: Office of the Australian Information Commissioner (oaic.gov.au).

20. General Provisions

20.1 Entire Policy

This Privacy Policy, together with our Terms of Service and any feature-specific supplemental privacy notices we publish, constitutes the complete description of G.L.O.W.'s data practices for the G.L.O.W. App.

20.2 Severability

If any provision of this Policy is found unenforceable or in conflict with applicable law, it will be modified to the minimum extent necessary, or if modification is not possible, removed. Remaining provisions continue in full effect.

20.3 Language

This Policy is written in English. Where translations are provided for convenience, the English version controls in the event of any inconsistency.

20.4 Governing Law

This Privacy Policy is governed by the laws of the State of California, without regard to conflict-of-law principles.

21. How to Contact Us

We acknowledge all privacy inquiries within two (2) business days and provide substantive responses within ten (10) business days. Rights requests are processed within the timeframes specified in Sections 11 through 14.