Privacy Policy

1. Privacy at Lumen Weekly

Lumen Weekly is designed as a reflective writing space where people can think, write, read, and connect through ideas.

We aim to collect only the personal data reasonably needed to operate, protect, provide, and improve the platform.

This Privacy Policy explains what personal data we collect, how we use it, who may process it on our behalf or in connection with the service, how long we keep it, and what rights you may have.

2. Who We Are

Lumen Weekly is operated by:

Lumen Weekly Labs DOO
Bulevar despota Stefana 18
Belgrade, Serbia

For privacy-related questions, requests, or concerns, contact:

support@lumenweekly.com

For the purposes of applicable data protection laws, Lumen Weekly is the controller of personal data processed through the platform, unless stated otherwise.

3. What Data We Collect

Depending on how you use Lumen Weekly, we may process the following categories of personal data.

Account Data

This may include:

• your email address;
• authentication and login information;
• your chosen pseudonym or display name;
• preferred language;
• account settings;
• account status;
• Premium or entitlement status;
• feature, participation, or moderation restrictions.

Public Content

For the purposes of this Privacy Policy, Public Content includes material that you intentionally publish or make available in shared areas of Lumen Weekly, including:

• published reflections;
• discussion posts;
• highlights;
• previews or excerpts;
• translated or display versions;
• other writing or material intentionally made available through shared platform features.

Public Content may contain personal information if you choose to include it.

Please think carefully before including sensitive, private, or identifying information in material that you publish or share with others.

Drafts and Unpublished Writing

Drafts and unpublished reflections are stored so that you can continue writing, edit your work, and decide whether to publish it.

They are not intended to be visible to other users.

Private Messages

Private Messages include conversation content sent through Lumen Weekly's messaging features.

Private Messages are not Public Content and are not intended to be publicly visible.

They may be processed where reasonably necessary to:

• provide and operate messaging functionality;
• deliver and display messages between participants;
• provide translation where requested;
• support moderation and safety;
• investigate reports;
• prevent abuse;
• enforce the Terms of Use and Community Guidelines;
• meet legitimate technical, security, operational, or legal requirements.

Publication, Interaction, and Moderation Data

This may include:

• publication or submission status;
• associated weekly themes or discussions;
• publication dates and timestamps;
• selected highlights or previews;
• Inspire actions and follows;
• connection and messaging activity;
• reports;
• moderation status and review information;
• content history where needed for moderation, safety, or platform integrity;
• account or feature restrictions related to moderation or abuse prevention.

Payment and Subscription Data

If you purchase Premium access, we may process information relating to your purchase and subscription, including:

• selected plan and billing period;
• Premium entitlement status;
• subscription status;
• purchase, renewal, cancellation, and expiration information;
• transaction, subscription, or customer identifiers;
• amount and currency;
• payment status;
• refund, reversal, or dispute status where applicable;
• billing country or other transaction-related information made available to us by the payment provider;
• information needed to provide billing or subscription support.

Lumen Weekly does not directly collect or store your full payment card details.

Payment information is submitted to and processed by Creem as described in Section 11.

Technical and Security Data

We may process technical information needed to operate and protect the platform, such as:

• device and browser information;
• IP address;
• log data;
• authentication and security events;
• error and diagnostic information;
• basic usage information needed for operation, security, debugging, and improvement.

Where you consent to analytics, additional usage and traffic information may also be processed as described in Section 10.

Communication Data

If you contact us, we may process the information you provide in that communication.

4. What We Do Not Require

Lumen Weekly is designed around pseudonymous participation.

We do not require users to publicly provide their real name, profile photo, or real-world identity.

Your email address is used internally for account and service purposes and is not publicly displayed by Lumen Weekly.

Because reflections, discussions, and private conversations may involve personal or sensitive topics, we encourage users not to include information they do not want others to read or discover.

5. How We Use Personal Data

We may use personal data to:

• create and manage accounts;
• authenticate users and protect account security;
• provide writing, reading, discussion, discovery, messaging, and community features;
• save drafts and publish Public Content according to user actions;
• display pseudonyms, reflections, discussion posts, highlights, previews, and related platform information;
• enable Inspire, Follow, connections, messaging, reporting, and other community features;
• support translations or multilingual display versions;
• provide and manage Premium access;
• activate, renew, expire, or cancel Premium entitlements according to subscription status;
• verify purchase and payment status;
• provide subscription and billing support;
• assist with refunds, payment issues, or disputes where appropriate;
• moderate content and protect the community;
• review reports and enforce the Terms of Use and Community Guidelines;
• apply publishing, participation, feature, messaging, Premium, or account restrictions where needed;
• prevent abuse, spam, misuse, fraud, and security incidents;
• respond to support requests and communications;
• maintain, debug, improve, and protect the platform;
• understand how people find and use Lumen Weekly where analytics consent has been provided;
• comply with applicable legal obligations.

6. Legal Bases for Processing

In accordance with applicable data protection law, including the Serbian Law on Personal Data Protection, we process personal data on one or more of the following legal bases.

Contract

We process personal data where it is necessary to provide Lumen Weekly and its features to you, including:

• account creation and authentication;
• saving and publishing content;
• messaging;
• platform interactions;
• providing Premium access;
• managing subscriptions;
• verifying payment status;
• administering purchases and entitlements.

Legitimate Interests

We may process personal data where necessary for legitimate interests such as:

• platform security;
• moderation;
• abuse and fraud prevention;
• product improvement;
• enforcing platform rules;
• protecting users and the integrity of the community;
• resolving technical or operational issues.

Consent

Where processing is based on your consent, including the use of Google Analytics, we process the relevant data only after you have given that consent.

You may withdraw or change your consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.

Legal Obligation

We may process personal data where necessary to comply with applicable laws, tax or accounting obligations, lawful requests, or other legal requirements.

7. Visibility of Content and Messages

Drafts and Unpublished Writing

Drafts and unpublished reflections are not intended to be visible to other users.

They are stored so that you can continue writing, edit your work, and decide whether to publish it.

Published Reflections

Published reflections are intended to be visible to logged-in Lumen Weekly users and may appear in Discover or other platform-supported areas.

They may be displayed together with information such as your pseudonym, weekly theme, highlight, preview, publication date, and related interaction signals.

Discussion Posts

Content you publish in a discussion is intended to be visible to users who have access to that discussion.

Discussion content may remain visible after a discussion is closed, depending on the platform's current functionality.

Private Messages

Private Messages are not publicly visible and are intended to be accessible only to the participants in the relevant conversation through the normal user experience.

Lumen Weekly does not provide administrators with unrestricted access to private conversations.

Where reasonably necessary for moderation, safety, abuse prevention, or review of a user report, authorized administrators may receive limited relevant message context.

Where additional context is genuinely necessary, an authorized administrator may explicitly access a full conversation through the administrative interface. Such full-conversation access is logged.

Authorized technical personnel may also access message data where reasonably necessary for security, maintenance, legal, or operational purposes.

Private Messages and translations are not copied into general audit logs as message bodies.

Public Previews and Sharing

Where Lumen Weekly provides sharing features, limited parts of published Public Content may be visible outside the platform.

These may include information such as:

• weekly theme;
• pseudonym;
• selected highlight;
• preview;
• context;
• call to action.

Full reflections are not intended to be publicly accessible through these limited preview features unless the platform explicitly provides otherwise.

8. Moderation and Safety Data

Lumen Weekly may review content and related account activity to enforce the Terms of Use and Community Guidelines, protect users, and prevent abuse.

Moderation-related information may include:

• review status;
• reports;
• moderation decisions;
• rejected or removed content;
• messaging moderation outcomes;
• repeated violations;
• temporary or permanent restrictions.

For Private Messages, the standard administrative moderation view is limited to relevant message context rather than unrestricted access to all conversations.

Where full-conversation access is used through the administrative interface, that access is recorded.

We may retain moderation or abuse-prevention records where reasonably necessary to protect the platform, enforce rules, resolve disputes, or prevent repeated misuse.

9. Pseudonymous Use

Your public identity on Lumen Weekly is based on your chosen pseudonym.

Your account may still be linked internally to your email address and other account information for authentication, security, account recovery, moderation, abuse prevention, subscription administration, and service operation.

Pseudonymity does not mean that activity on the platform is anonymous to Lumen Weekly.

10. Analytics and Cookies

Lumen Weekly uses essential cookies and similar technologies that are necessary for the platform to operate, including authentication, security, language selection, and storing your preferences.

With your consent, we use Google Analytics 4 (GA4) to understand how people find and use Lumen Weekly and how they move through the platform.

Analytics may include information such as:

• the source, medium, and campaign through which you reached Lumen Weekly;
• landing pages;
• pages and areas of the platform you visit;
• the Lumen Weekly interface language you use;
• approximate geographic information such as country or region;
• browser language;
• device type, browser, and operating system;
• completion of account registration;
• encounters with Premium restrictions;
• steps in the Premium upgrade, checkout, and purchase journey.

For signed-in users, we may use an internal technical account identifier to associate analytics events from the same user across sessions.

This identifier is not your email address, pseudonym, or the content you write.

We do not send your email address, pseudonym, reflections, drafts, discussion posts, Private Messages, or other writing content to Google Analytics.

Google Analytics is not activated until you accept analytics.

If you choose “Essential only”, you can continue using Lumen Weekly without Google Analytics tracking.

You can later change your analytics choice in the “Privacy & Cookies” section of your account settings.

We do not collect analytics data retroactively for the period before you gave consent.

We use analytics to understand platform usage, traffic sources, campaign effectiveness, feature discoverability, Premium conversion journeys, and to improve the Lumen Weekly experience.

We do not use Google Analytics for advertising, remarketing, or advertising profiling.

11. Third-Party Service Providers

We may use trusted third-party providers to help operate Lumen Weekly, including providers for:

• hosting and infrastructure;
• authentication;
• databases;
• email delivery;
• error monitoring;
• security and abuse prevention;
• automated or AI-assisted moderation;
• translation or language processing;
• usage and traffic analytics;
• payment processing;
• billing and subscription administration.

These providers may process personal data only as needed for their role in providing the relevant service and subject to applicable contractual and legal safeguards.

Creem

Premium purchases are processed through Creem, operated by:

Armitage Labs OÜ
Registry code: 16977866
Rotermanni 14
Tallinn 10111
Estonia
Website: https://creem.io

Creem acts as Merchant of Record for Premium transactions processed through its service.

Creem may process information necessary to:

• process payments;
• administer billing and subscriptions;
• issue invoices or receipts;
• calculate and collect applicable taxes;
• process refunds, reversals, or payment disputes;
• prevent payment fraud and abuse;
• comply with legal and regulatory obligations.

Lumen Weekly does not directly store full payment card details.

Creem processes transaction information in accordance with its own applicable terms and privacy practices.

Google Analytics

Where you have consented to analytics, we use Google Analytics 4, a service provided by Google.

Google may process analytics information in accordance with its applicable terms, privacy practices, and data protection arrangements.

12. AI-Assisted and Automated Features

Lumen Weekly may use automated, AI-assisted, or third-party tools to support:

• moderation;
• safety;
• translation;
• abuse prevention;
• quality review.

These tools may process content and related platform data where needed for these purposes.

Automated tools may not always be accurate, and moderation decisions may also involve human review and judgment.

13. International Data Transfers

Some of the service providers we use, including analytics, payment, and other technology providers, may process personal data outside Serbia or outside your country of residence.

Where such transfers take place, they are subject to the data protection arrangements and safeguards applicable to the relevant provider and required by applicable law.

14. Data Retention

We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.

In general:

• account data is kept while your account exists;
• drafts and unpublished writing are kept while needed to provide the service or until deleted where deletion is available;
• published Public Content may remain available until removed, deleted, withdrawn, archived, or otherwise handled according to platform functionality;
• Private Messages may be retained while needed to provide messaging functionality and according to applicable account, moderation, safety, or deletion rules;
• technical and security logs are kept for a limited period needed for operation, debugging, and security;
• support communications may be kept as long as reasonably necessary;
• moderation and abuse-prevention records may be retained where needed to protect the platform or enforce rules;
• records of full-conversation administrative access may be retained as part of the moderation and audit trail;
• subscription, transaction, refund, and billing-related records may be retained as reasonably necessary for accounting, legal, tax, fraud-prevention, payment-support, or dispute-resolution purposes;
• records of analytics consent decisions may be retained where reasonably necessary to record your choice and demonstrate compliance with data protection requirements;
• analytics data processed through Google Analytics is retained according to the retention settings we apply within that service.

When data is no longer needed, we will delete or anonymize it where reasonably possible and in accordance with applicable law.

15. Your Rights

Depending on applicable law, you may have the right to:

• access personal data we hold about you;
• correct inaccurate data;
• request deletion of your data;
• restrict or object to certain processing;
• request a copy of your data;
• withdraw consent where processing is based on consent;
• lodge a complaint with the competent data protection authority.

You can change your analytics consent directly in the “Privacy & Cookies” section of your account settings.

To make another privacy request, contact:

support@lumenweekly.com

We may need to verify your identity before responding to certain requests.

16. Account Deletion

You may request deletion of your account by contacting:

support@lumenweekly.com

Account deletion and subscription cancellation are separate actions.

If you have an active recurring Premium subscription, requesting deletion of your Lumen Weekly account does not by itself cancel future subscription renewals.

You should cancel your recurring subscription through the available billing or customer portal, or another provided cancellation method, before requesting account deletion if you do not want the subscription to renew.

When an account is deleted, we will delete or anonymize personal data where reasonably possible, except where certain information must or may be retained for:

• legal obligations;
• accounting or tax requirements;
• security;
• fraud prevention;
• dispute resolution;
• moderation;
• abuse prevention;
• backup;
• payment records;
• legitimate operational reasons.

Content shared outside Lumen Weekly through links, screenshots, copies, or actions of other users may remain outside our control.

17. Security

We take reasonable technical and organizational measures to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure.

These measures may include:

• access controls;
• row-level access restrictions;
• secure authentication;
• encrypted communication;
• provider security measures;
• monitoring;
• scoped administrative access;
• audit logging;
• operational safeguards.

Access to Private Messages through the administrative interface is deliberately limited and, where full-conversation access is used, logged.

No online service can guarantee absolute security.

18. Email Communications

We may send you emails related to your use of Lumen Weekly, including:

• account and authentication messages;
• security or moderation notices;
• important platform updates;
• weekly introduction emails;
• reminders related to the current weekly cycle;
• Premium, subscription, or billing-related service messages where relevant.

We may also introduce optional newsletters, product updates, or promotional communications.

Where required, you will be able to unsubscribe from non-essential communications.

19. Children's Privacy

Lumen Weekly is not intended for children under the age of 16.

We do not knowingly collect personal data from children under 16.

If we become aware that such data has been provided, we will take appropriate steps to delete it.

20. Changes to This Privacy Policy

We may update this Privacy Policy as Lumen Weekly evolves.

If we make material changes, we will take reasonable steps to notify users, such as by posting the updated policy on the platform or sending a service-related notice.

Updating this Privacy Policy does not by itself change your analytics choice.

If the purpose or scope of analytics changes materially in a way that requires renewed consent, we will ask you to make a new choice where required.

The updated Privacy Policy will apply from the effective date shown at the top of the document.

21. Contact

For privacy-related questions, requests, or concerns, contact:

support@lumenweekly.com

Legal information

Platform: Lumen Weekly
Website: https://lumenweekly.com
App: https://app.lumenweekly.com
Contact: support@lumenweekly.com
Operator: Lumen Weekly Labs DOO
Registered address: Bulevar despota Stefana 18, Belgrade, Serbia