Legal

Lumo: Pro Camera RAW

Pro camera for iPhone — RAW, manual control, video; everything on the device, no account and no server

Privacy policy

Last updated: 5 September 2026

Lumo is a camera app. We run no server for this app, there is no account or login, and the app contains no analytics, no advertising and no third-party SDKs. Your photos and videos stay on your iPhone; we receive no data.

1. Data controller

Company: Babala Özdemir (Einzelunternehmen)
Address: Unterer Rainweg 22
4414 Füllinsdorf
Schweiz
E-mail: info@babala.ch
Phone: 076 792 63 50
Company ID: CHE-322.105.560
App identifier: iOS: ch.babala.lumo

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

Data	Purpose	Stored where	Retention
Photos and videos	Capture, editing and saving to your photo library	On the device and in your own photo library only (syncing through your iCloud settings is handled by Apple)	Until you delete them or remove the app
Location (optional)	Write the place of capture into the photo metadata	Only inside the image file on the device — never sent to us	As long as the image file exists
Sound (only for video recording and voice command)	Video sound track, level meters, optional voice command to take a photo	Only inside the video file on the device; the voice command is recognised on the device where the device supports it	As long as the video file exists
Presets, film looks, imported LUTs, settings	Keeping your settings	On the device only	Until you remove the app

What we explicitly do not collect

No account, no name, no e-mail address
No advertising, no advertising ID, no analytics, no trackers, no third-party SDKs
No server of our own: photos, videos and settings never leave the device
We receive no biometric data — Face ID is handled entirely by iOS

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.

Camera — To take photos and record video. Images are processed on the device.
Microphone — Only for the sound of your videos, the level meters and the optional voice command.
Speech recognition — Optional: voice command for hands-free capture. Uses iOS speech recognition, on the device where supported.
Photos — To save captures to your photo library and to show, edit and export them in the Lumo gallery.
Location (while using the app) — Optional: write the place of capture into the photo metadata. Stays on the device. Without permission photos are saved without a location.
Face ID — Only to unlock the hidden folder. Lumo never receives or stores biometric data.

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 camera (photos and video), the microphone (video sound, voice command), the photo library (saving and showing) and location (optional, metadata only). 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.

5. Recipients and third parties

No disclosure. This app does not transmit any data to us or to third parties. No analytics, advertising or tracking components are embedded.

6. Retention and deletion

We store nothing because we run no server for this app. Your photos, videos, presets and LUTs live on the device or in your photo library. Removing the app deletes the app data; photos in your library remain until you delete them.

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.

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.

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