Privacy Policy

This policy explains how Prompt LLC (“we,” “us,” “our”) handles personal information in Lumni (the “Service”). Prompt LLC is the controller of that information. Our legal contact is info@promptandmake.com, and privacy questions go to support@trylumni.com.

It applies to students, to parents and guardians, and to visitors to our website. It works alongside our Terms of Service.

Information you give us.

• Account: name, email address, password (stored only as a salted hash — we never see it), and whether you are a student or a parent.
• Academic and profile information a student chooses to enter: grade level, coursework and GPA, test scores, activities, intended fields of study, location and cost preferences, and family financial context used to estimate net price.
• Work product: school lists, application status, essay drafts and notes, planning entries, and interview practice.
• Messages to the AI assistant, and its responses.
• Correspondence when you contact support, ask for free access to Pro, or ask about Lumni for a school.
• Purchases. When you buy Lumni Pro in the App Store, Apple sends us a record of the transaction: the product, purchase and renewal dates, whether it is a trial, refund or cancellation status, Apple’s transaction identifiers, and a random identifier we give your account so Apple’s notices reach the right one. We never receive your name, card, or billing address from Apple.
• Plan and link records: whether your account has Pro, where it came from (a purchase, a linked account, a school license, or a grant from us), and when it starts and ends; link codes you make or enter; and a history of changes to these, so we can answer questions about an account accurately.

Information we collect automatically.

• Session and security data: IP address, browser and device type, and timestamps for sign-in, session, and consent records. We keep the IP address and user agent recorded when you accepted our Terms as evidence of that consent.
• Usage data: which features are used and when, and the token counts and computed cost of AI calls so we can meter expense and detect abuse.
• Diagnostic logs generated when something errors.

We use personal information only to:

• Provide the Service — build your list, plan coursework, estimate costs, and answer your questions.
• Personalize what you see to your own profile, which is the entire point of the product.
• Authenticate you and keep accounts secure.
• Meter and control our own operating costs, including AI usage.
• Detect, investigate, and prevent abuse, fraud, and security incidents.
• Respond to your support requests.
• Fix bugs and improve the product in aggregate.
• Comply with law and enforce our Terms.

Where the GDPR or similar law applies, our legal bases are performance of our contract with you, our legitimate interests in securing and improving the Service, your consent where we ask for it, and compliance with legal obligations.

To answer a question, critique an essay, or explain why a school might fit, we send the relevant parts of your input and profile to a third-party AI model provider, currently Anthropic, PBC, which processes it and returns a response.

Read-aloud is separate. If you press “Read aloud” to hear your profile summary spoken, the text of that summary is sent to Google (Gemini) to synthesize the audio, because our primary provider does not offer speech. Interview practice in the app is read aloud the same way: the counselor’s questions and replies are sent to Google to be spoken, unless you mute her voice. Nothing else is sent — not your essays, not your answers, not your counselor conversations. If you would rather nothing leave your device, your device can read the text aloud itself; the feature falls back to that automatically when the hosted voice is unavailable.

Spoken answers stay on your phone. When you answer an interview question out loud, your phone transcribes it on the device. The recording is never uploaded or stored; only the text of your answer is sent, exactly as if you had typed it.

• We use the provider’s commercial API under terms that prohibit training on data submitted through it. Your essays and conversations are not used to train anyone’s model — not the provider’s, and not ours.
• We send what the feature needs, not your whole record.
• The provider may retain the request briefly for abuse monitoring under its own terms, and acts as our processor.
• If we change providers, we will update this policy and hold the new one to the same no-training standard.

We disclose information only in these situations:

• Service providers that run the product on our behalf, bound by contract to use it only for that purpose: our hosting and database provider (Railway), our AI model provider (Anthropic), our email provider (Resend, for password resets and notifications), and Google (Gemini) for read-aloud speech only — the text being spoken, never your voice. Each receives the minimum needed for its job.
• Apple, which processes App Store purchases under its own privacy policy. We tell Apple nothing about you beyond the random account identifier attached to a purchase.
• Your school, if you join through its license: it learns that a seat is in use. It does not receive your conversations, essays, or other content from us.
• A linked parent or guardian, within the limits in Section 6.
• When you tell us to — for example, sharing an essay with a parent or exporting your data.
• Legal compliance: to comply with valid legal process, or where necessary to protect the rights, safety, or property of a user, the public, or us. Where we are legally permitted, we will attempt to notify the affected user first.
• Business transfer: if the company is acquired or merged, information may transfer to the successor, which will remain bound by this policy or give notice and a choice before materially changing it.

A student and a parent may link their accounts, and both must take part — one makes a code, the other enters it. Each account links to at most one other, either side can unlink, and Pro is shared across the link while it lasts. Linking is intentionally narrow.

A linked parent can see: application progress and status, deadlines, the school list, and cost and aid information.

A linked parent cannot see: the student’s private conversations with the AI assistant, or their essay drafts — unless the student explicitly shares them.

This is enforced in our authorization layer, which resolves what a viewer may read before any data is loaded, and denies by default. Private student content is not sent to a parent’s browser and hidden there; it is never sent.

Separately from the product feature, a parent or guardian may have legal rights over a minor’s personal information. We honor those rights — see Section 9. Because exercising them can override the in-product boundary above, we verify the relationship first, and, except where law forbids it, we tell the student when a guardian requests access to their information. We think a teenager deserves to know that.

The Service is intended for high-school students and is not directed to children under 13. We do not knowingly collect personal information from them, and account creation requires confirming you meet the minimum age.

If we learn that we hold personal information from a child under 13 without verifiable parental consent, we delete it promptly. If you believe a child under 13 has given us information, email support@trylumni.com and we will act on it.

We are not a school official and do not operate as a contractor to any school district. Students sign up individually, so records here are generally not education records under FERPA. If we ever work directly with a school, we will handle that data under the agreement with the school and say so here.

• Account and profile information: while your account is open.
• Essays, lists, and planning data: while your account is open, or until you delete them.
• AI conversations: while your account is open, or until you delete a thread.
• Consent records: for the life of the account and for three years after closure, because they are the evidence that you agreed to our Terms.
• Security and usage logs: up to 24 months, then deleted or aggregated beyond identification.

When you delete your account we delete your personal information within 30 days, except where we must keep something to comply with law, resolve a dispute, or enforce our agreements. Residual copies may persist in encrypted backups for up to 90 days before rotating out.

Whoever and wherever you are, you can ask us to:

• Access — get a copy of the personal information we hold about you.
• Export — download your data in a portable JSON format, available immediately in Settings.
• Correct — fix anything inaccurate, mostly editable directly in the product.
• Delete — remove your account and personal information, available in Settings.
• Restrict or object to certain processing, and withdraw consent where processing relies on it.
• Complain to your data protection authority or state attorney general.

Email support@trylumni.com to exercise a right that isn’t self-service. We respond within 45 days (extendable once by 45 days where permitted), and 30 days where the GDPR applies. We will verify your identity first, and we will not discriminate against you for exercising any of this.

California. The categories in Section 2 correspond to CCPA categories including identifiers, education information, commercial information, internet activity, and — for financial context used in aid estimates — characteristics that may be treated as sensitive personal information. We use sensitive personal information only to provide the Service and for no purpose requiring a right to limit. We do not sell or share personal information. You may designate an authorized agent to make a request.

Do Not Track. We do not track users across third-party sites, so there is nothing for a DNT signal to change. We honor Global Privacy Control signals as opt-out requests where applicable.

We protect information with encryption in transit (TLS) and at rest, salted and hashed passwords, HTTP-only session cookies with strict attributes, an authorization layer that denies by default, and access controls that keep student content out of administrative views. Our own admin tools are built to show counts and costs, not to read essays or conversations.

No system is perfectly secure, and we do not claim otherwise. If a breach affects your personal information, we will notify you and the relevant regulators as required by law, without unreasonable delay. To report a vulnerability, email support@trylumni.com — we welcome it and will not pursue good-faith researchers.

We use a small number of strictly necessary cookies: a session cookie to keep you signed in, and security cookies to protect against cross-site request forgery. We do not use advertising, marketing, or third-party analytics cookies. Blocking the essential ones will stop sign-in from working.

We operate in the United States, and information is processed and stored there by us and our service providers. If you use the Service from outside the US, you understand that your information will be transferred to and processed in the US, where privacy law differs from your own. Where required, we rely on Standard Contractual Clauses or another lawful transfer mechanism.

We may update this policy. When we make a material change we will update the version and effective date above and notify you in the product or by email before it takes effect. We will not retroactively reduce your rights over information already collected without asking you first.

Prompt LLC
info@promptandmake.com
Privacy: support@trylumni.com
Support: support@trylumni.com

If you are a student and something here is unclear, write to us and ask. You are entitled to understand what happens to your information.