Lumignon – Secrets & Prières

A candle that burns only on your device, an evening prayer at 8 pm, a personal prayer on request by e-mail, a directory of the «secret» tradition (Switzerland), emergency numbers and background knowledge — the app collects no data

Privacy policy

Last updated: 5 September 2026

The Lumignon app collects no data. It has no account, no login, no device identifier, no analytics, no advertising, no trackers, no third-party SDKs and no push server. The candle you light and the intention you write with it stay on your device only and are never sent. The app only loads public files (directory, content, country details) from babala.ch, without any identifier. If you want to contact us — to ask for a personal prayer, to add yourself to the directory as a «faiseur de secret», to report something or to ask for a change or deletion — you write us an e-mail yourself at info@babala.ch (to ask for a personal prayer, alternatively a WhatsApp message to our number +41 76 792 63 50): the app only opens your mail app or your WhatsApp with a prepared text, and you decide whether to send it. We treat these messages like normal correspondence (explained below). They may contain information about health and religious activities; this is sensitive personal data (Art. 5(c) Swiss FADP) — please do not write diagnoses and only what is needed. We publish directory entries only with the explicit consent of the listed person. The public files are hosted on our server at Hetzner in Germany.

1. Data controller

We have not appointed a data protection officer or an EU representative because we do not reach the relevant thresholds. Please address all requests to the contact above.

2. What data we process

What we explicitly do not collect

• No account, no login, no device identifier, no advertising ID
• Candles and intentions never leave your device; no candle data in iCloud or in the device backup
• No push server, no push token: your device schedules the evening notification itself
• No user content in the app: no chat, no messages through us, no uploads, no forms that send to us
• No advertising, no analytics, no trackers, no third-party SDKs, no app tracking
• No access to location, contacts, camera, microphone or photos
• No disclosure and no sale of e-mails, WhatsApp messages or health information; who prays in the team is not published

3. Permissions on your device

The app requests only the following permissions. Each of them can be revoked at any time in your device settings; the app remains usable afterwards, with reduced functionality.

• Notifications (optional, local only) — Only if you turn on the evening reminder: your device shows the notification “Tonight, someone prayed for you too” at 8 pm. The notification is scheduled on the device (no connection to us, no push token). Can be turned off at any time in the app or in the iOS settings.

4. Legal bases

We process personal data under the Swiss Federal Act on Data Protection (revFADP). Where the GDPR applies, we rely on:

• Performance of a contract (Art. 6(1)(b) GDPR) — everything needed for the app to deliver the function you requested.
• Legitimate interests (Art. 6(1)(f) GDPR) — secure and stable operation, abuse prevention, troubleshooting.
• Consent (Art. 6(1)(a) GDPR) — for anything you actively enable in this app: the local evening notification at 8 pm. Consent can be withdrawn at any time with effect for the future by revoking the permission in your system settings.
• Legal obligation (Art. 6(1)(c) GDPR) — in particular commercial and tax retention duties for payments.

The app itself does not process any personal data on our side. What you do in the app (candles, intentions, favourites, settings) stays on your device. We only receive personal data if you write us an e-mail yourself and — for listed people — for the directory entry. E-mails and sensitive data. A request for a personal prayer or a directory sign-up may contain information about health and religious activities (Art. 5(c) Swiss FADP). Before opening the mail app, the app tells you that your e-mail address becomes visible to us and that you should not write diagnoses. By sending the e-mail yourself, you explicitly consent to the processing of the information in it for the purpose of answering (Art. 6(7) FADP). The same applies to a prayer request by WhatsApp to +41 76 792 63 50 (the app tells you that your phone number becomes visible to us). We use e-mails and WhatsApp messages only to handle your matter, do not pass them on to third parties and delete them immediately on request, otherwise at the latest after 12 months. Please do not include full names or health information of other people. Directory entries are published only with the explicit consent of the listed person, given in their sign-up e-mail and confirmed in the verification call (name or short name, place, canton, languages, areas, phone or WhatsApp number, availability, note, date of check); consent can be withdrawn at any time by e-mail, and the entry is then deleted. Children and young people: requesting a personal prayer and signing up to the directory are intended for people aged 18 or over (confirmation in the app, stored locally only); the app is not directed at children and is not designed for the Kids category or COPPA. Who prays: a volunteer of the Babala Software team; we do not publish who that is. Call, SMS, WhatsApp: contacts with listed people run directly from your phone to theirs; we see none of it. With WhatsApp you act yourself as a WhatsApp user; the data goes to WhatsApp/Meta under their own privacy terms — to us only if you write to us yourself. Abroad: the public files are hosted in Germany, which offers adequate data protection under Annex 1 of the Swiss Data Protection Ordinance; depending on the mail provider, e-mails may also be processed outside Switzerland (providers with adequate protection or under the Data Privacy Framework). WhatsApp messages to us run via Meta (Ireland/USA; Swiss-U.S. and EU-U.S. Data Privacy Framework); you choose this channel yourself and can write an e-mail instead. Legal bases under the GDPR (for people in the EU/EEA, Art. 3(2) GDPR): e-mails and WhatsApp messages containing health-related information on the basis of your explicit consent given by sending (Art. 9(2)(a) GDPR); answering your request and maintaining your directory entry in order to carry out your request (Art. 6(1)(b) GDPR); publication of the entry on the basis of explicit consent (Art. 6(1)(a) and Art. 9(2)(a) GDPR); web server access logs, the handling of reports and keeping consent records on the basis of our legitimate interest in a secure, lawful service and in being able to demonstrate consent (Art. 6(1)(f) and Art. 7(1) GDPR). Your rights (Art. 25 ff. Swiss FADP; Art. 15–22 GDPR): access, rectification, erasure, restriction of processing, data portability, objection to processing based on legitimate interest, and withdrawal of consent at any time with effect for the future. As the app sends no data to us, we can only provide information about e-mails, WhatsApp messages and directory entries; you delete data on your device yourself (More › Delete my data). Write to info@babala.ch; we reply within 30 days. Complaints: you can complain to the Swiss Federal Data Protection and Information Commissioner (FDPIC, www.edoeb.admin.ch) and, in the EU/EEA, to the data protection supervisory authority of your habitual residence, place of work or place of the alleged infringement (Art. 77 GDPR). There is no automated individual decision-making and no profiling; entries are always decided by a human. Consumer Health Data Privacy Policy (Washington, Nevada and other US states) — applies to users in the USA (including the Washington My Health My Data Act, RCW 19.373, and Nevada SB 370). Collection by the app: the app collects no consumer health data; candles and intentions stay on your device. E-mails and WhatsApp: if you voluntarily write us an e-mail or WhatsApp message (e.g. a request for a personal prayer), it may contain health information. Source: only you. Purpose: only answering you or the prayer you asked for. Consent: by sending. Sharing: we never sell such data and do not share it with third parties; it is kept only in our mailbox or in the WhatsApp chat on our team’s phone (WhatsApp/Meta carries it under its own terms, as a service you use yourself). No geofencing, no advertising, no tracking. Your rights: access, deletion and withdrawal of consent by e-mail to info@babala.ch; reply within 45 days. Appeal: e-mail with the subject “Appeal” to info@babala.ch; reply within 45 days; if we uphold the refusal you may complain to your state Attorney General (Washington: www.atg.wa.gov/file-complaint). Deletion at the latest 12 months after the last exchange.

5. Recipients and third parties

We do not sell data and do not disclose it for advertising purposes. Data is disclosed only to the following parties, and only where required for operation:

Authorities and courts receive data only where we are legally obliged to provide it.

Transfers abroad

Some of the recipients listed above process data outside Switzerland and the EEA, in particular in the United States. We base such transfers on the European Commission’s Standard Contractual Clauses with the Swiss adaptations recognised by the FDPIC and, where applicable, on the EU-US Data Privacy Framework. We will provide information on the safeguards in place on request.

6. Retention and deletion

In the app: candles, intentions, history, favourites and settings stay on your device only until you delete them (More › Delete my data) or remove the app. E-mails to info@babala.ch (prayer requests, sign-ups, reports, change and deletion requests, support) and WhatsApp messages to +41 76 792 63 50 are deleted immediately on request, otherwise at the latest 12 months after the last exchange. Directory: entries remain published until the listed person withdraws them by e-mail (deletion usually within 2 working days) or we remove them. We keep the sign-up e-mail with consent and declarations as proof as long as the entry exists and at most 12 months afterwards; review notes and sign-ups that are not published at most 12 months after rejection. Web server access logs (IP address, time, file) at most 14 days. Our server is backed up daily (7 generations); deleted entries therefore also disappear from the backups at the latest 7 days after deletion. Users who loaded the directory earlier keep an offline copy until their app next refreshes.

Step-by-step instructions are available at Delete data.

7. Children and young people

This app is not directed at children. We do not knowingly collect personal data from children under 16. If we learn that such data has been submitted without parental consent, we delete it without delay.

8. Data security

Wherever the app transmits data at all, connections are encrypted via HTTPS/TLS. On the server side we use access restrictions, tenant separation and regular backups. Nobody can, however, guarantee absolute security for data transmission over the internet.

The app stores candles and intentions in a file with iOS data protection (encrypted while the device is locked) that is excluded from iCloud and device backups; they are never transmitted. The app only loads public files over HTTPS and sends no identifier and no content when doing so. On our server there is no database with user data for Lumignon, only public files. The mailbox info@babala.ch is password-protected and accessible only to the owner; WhatsApp messages are kept only in the WhatsApp app on our team’s locked phone. E-mails and WhatsApp messages relating to health are not passed on to third parties and are deleted once handled. Should a data security breach nevertheless occur that is likely to result in a high risk for you, we report it as quickly as possible to the Swiss Federal Data Protection and Information Commissioner (FDPIC, Art. 24 FADP) and inform you where necessary and possible.

9. Your rights

• Access to the personal data we process
• Rectification of inaccurate data
• Erasure or destruction of your data
• Restriction of and objection to processing
• Receiving or porting your data in a common format
• Withdrawal of consent with effect for the future

An informal message to info@babala.ch or a call to 076 792 63 50. We normally respond within 30 days. To verify your identity we may request suitable proof. You may also lodge a complaint with a supervisory authority (Switzerland: FDPIC; EU: your competent authority).

10. Changes to this policy

We may adapt this policy when the app or the legal framework changes. The version published on this page, with the date shown above, is the applicable one. We announce material changes inside the app.