Overview

Effective date: July 4, 2026 Last updated: July 4, 2026 Applies to: Luma Anesthesia iOS app CE HALO LLC ("we," "us," "our") built Luma Anesthesia ("the app") for licensed healthcare professionals and students. This Privacy Policy explains what data the iOS app handles, how it is used, and your rights. We do not require an account to use the iOS app. We do not collect your name, email address, or any personal identifier at signup. The iOS app is designed to be usable anonymously.

1. What We Collect

a) Data you enter locally (stored only on your device, never sent to our servers): • Optional display name, clinical role, institution, and short bio (used only to personalize your local experience and to attribute community posts if you choose to share) • Your onboarding progress and preferences • Cached drug references, protocols, and clinical case content for offline use (7-day expiry) b) Data collected automatically: • Subscription data (via Apple and RevenueCat): purchase events, subscription status, product identifier, expiration date, and an anonymous user identifier assigned by RevenueCat. This data is required to deliver your subscription and enforce access. • Device and diagnostic data (via Apple, only if you opt in via iOS Settings → Privacy → Analytics & Improvements → Share App Analytics): crash reports and anonymized performance metrics. c) Data transmitted only when you use the AI chat feature: • The text you type into the AI chat prompt is transmitted to our AI providers (see Section 5) to generate a response. Do not include patient identifiers or Protected Health Information (PHI) in AI chat messages. We do not collect, store, or transmit any patient health data or Protected Health Information (PHI).

2. Local Storage on Your Device

The iOS app stores the following locally on your device only: • luma_profile — your optional display name, role, institution, and bio • luma_hero_seen — whether you have seen the onboarding screen • luma_terms_accepted — whether you have accepted the Terms & Agreements • luma_cache_* — cached clinical reference data for offline use (7-day expiry) You can clear all local data at any time by uninstalling the app from your device.

3. Subscriptions and Payments

Subscriptions are sold and managed exclusively through Apple's App Store. We do not see, store, or process your payment details. Apple handles all billing, renewal, refunds, and cancellation. We use RevenueCat (a subscription management service) to receive subscription status from Apple and grant access to premium features. RevenueCat receives an anonymous user identifier and your purchase events from Apple — nothing tying you personally to those events. To cancel or manage your subscription, tap Manage Subscription in the app's Account tab, or go to iOS Settings → your Apple ID → Subscriptions. For refund requests, use Apple's process: reportaproblem.apple.com. We cannot issue refunds directly.

4. Permissions

Luma Anesthesia requests no device permissions on iOS. The app does not access your camera, microphone, location, contacts, photo library, health data, or any other iOS permission-protected resource. The app requires only standard internet access to sync content and process subscriptions.

5. Third-Party Services (iOS)

The iOS app uses only the following third parties, each with a specific purpose: • Apple App Store — Subscription billing, receipt validation — Anonymous purchase events • RevenueCat — Subscription status management — Anonymous user identifier, Apple purchase events • OpenAI — AI chat responses (some features) — The text you type into the AI chat prompt (no personal identifiers) • Perplexity AI — AI chat responses (some features) — The text you type into the AI chat prompt (no personal identifiers) We have selected these providers because they maintain data protection standards consistent with this Privacy Policy. Your AI chat inputs are not used to train these providers' models when accessed through their business/API tiers. We do not use any advertising SDKs, third-party analytics beyond what is listed above, or trackers on the iOS app. Third-Party AI Services: Luma Anesthesia includes AI-powered features (AI Chat and Case Planner) that process user-typed questions through third-party AI providers. Specifically: • Perplexity AI — used for AI Chat responses. Learn more at https://www.perplexity.ai/hub/legal/privacy-policy • OpenAI — used for Case Planner and supporting AI features. Learn more at https://openai.com/policies/privacy-policy When you use these AI features, the text of your question is transmitted to Perplexity AI and/or OpenAI for processing. We do NOT transmit any personally identifiable information or patient health information to these services. Users are shown a consent screen before AI features become available and must explicitly accept before their questions are sent. Users are instructed never to enter patient-identifiable information into AI Chat or Case Planner. Data handling by these AI providers is governed by their respective privacy policies linked above. Data We Collect: Through our subscription provider (RevenueCat) and Apple App Store, we collect: email address (for account/support), anonymous user ID (for subscription tracking), device identifiers, purchase history, product interaction data, crash reports, and performance diagnostics. This data is used solely to provide app functionality, customer support, and app improvements. We do not sell your data or use it for advertising.

6. How We Use Data

We use the limited data described above to: • Deliver and maintain your subscription • Provide AI chat responses (when you use that feature) • Cache reference content on your device for offline use • Comply with legal obligations We never sell your data. We never share your data for advertising purposes.

7. Data Security

All server communication uses HTTPS/TLS 1.2+. Payment information is handled exclusively by Apple (which never shares your card details with us or with RevenueCat). We do not maintain a user database for the iOS app because iOS use is anonymous.

8. Your Rights (GDPR, CCPA, and Similar Laws)

Because the iOS app does not create a server-side account or store personal identifiers on our servers, most traditional "data access" and "data deletion" requests do not apply — there is no personal record of you to access or delete on our side. However, you always retain the following rights: • Delete all local app data: uninstall the app from your device • Delete your Apple subscription record: manage or cancel through iOS Settings → Apple ID → Subscriptions • Contact us with any question: email support@lumaeducationalapps.com EU / UK residents (GDPR): You have the rights of access, rectification, erasure, restriction, portability, and objection. Contact us to exercise any right. California residents (CCPA/CPRA): You have the right to know, delete, and opt out of the sale of personal information. We do not sell personal information.

9. Data Retention

• Local device data: retained until you uninstall the app or a cache entry expires (7 days). • Apple subscription data: retained by Apple according to Apple's Privacy Policy. • RevenueCat subscription events: retained by RevenueCat according to RevenueCat's Privacy Policy; contains no personal identifiers. • AI chat messages: retained temporarily by AI providers for response delivery only; not retained on our servers.

10. Children's Privacy

Luma Anesthesia is intended for licensed healthcare professionals, students, and adults aged 18 and older. We do not knowingly collect data from users under 18. If you believe a person under 18 has used the app, contact us and we will assist.

11. Apple App Store Compliance

• We comply with all Apple App Store privacy requirements • The app's App Privacy Nutrition Label in the App Store lists all data types collected • No data is linked to your identity on our servers • No data is used to track you across apps or websites • No third-party advertising SDKs are used

12. Changes to This Policy

We may update this policy from time to time. Material changes will be surfaced in the app on next launch. Continued use of the app after a material change means you accept the updated policy.

13. Contact

For privacy concerns, data requests, or any question: Email: support@lumaeducationalapps.com Company: CE HALO LLC, Buffalo, New York, United States This Privacy Policy governs the Luma Anesthesia iOS app. A separate policy may apply to any web version of Luma Anesthesia offered at lumaanesthesia.app.