Privacy Policy

Last Updated: 2026/10/05

1. Introduction

This Privacy Policy explains how Luminacode, MB (“we”, “us”) handles information when you use the Synra mobile application and the website at synra.luminacode.lt (together, the “Service”). Synra is designed to collect as little as possible: you do not need an account, and the answers you give during setup stay on your device.

2. Who we are

3. Information we collect

3.1 Information that stays on your device

Your onboarding answers (for example, your goals and how you found Synra), your favourites, recently played sessions, player settings, timer preferences and similar preferences are stored locally on your iPhone. We do not receive them, and they are only used to shape your experience in the app. They are removed when you delete the app.

3.2 Purchase and subscription information

Subscriptions are sold and billed by Apple through the App Store. We never see or store your payment card details. To unlock premium content we receive limited information about your purchase — such as the product purchased, the transaction identifier, trial and renewal status, and the country of the store — together with an anonymous app user identifier.

3.3 Usage and device information

To understand which parts of Synra are useful and to fix problems, we may collect anonymous or pseudonymous usage events (for example: onboarding completed, a session played, the timer used), together with basic technical information such as device model, iOS version, app version, language and approximate region derived from your store or settings. This information is not used to identify you and is not linked to your name or email.

3.4 Information you send us

If you contact support, we receive your email address and whatever you choose to include in your message.

3.5 What we do not collect

Synra does not use your microphone, camera, contacts, photos or precise location. We do not collect health or fitness data, and Synra does not read from or write to Apple Health. We do not use your data for third-party advertising, and we do not track you across other companies’ apps or websites.

4. How we use information

  • To provide the Service and unlock the content you have subscribed to;
  • To restore purchases and manage free trials and subscriptions;
  • To keep the app working, diagnose crashes and improve features and content;
  • To answer your support requests;
  • To comply with legal obligations and prevent fraud.

Legal bases (GDPR): performance of a contract (providing the Service you subscribed to), our legitimate interest in keeping the app reliable and improving it, and compliance with legal obligations.

5. Service providers

We share the limited information described above only with providers that help us run the Service:

  • Apple (App Store) — Payment processing, subscriptions, refunds, and anonymous crash reports shared by users who opt in
  • Subscription management provider — Checking whether your subscription or trial is active and restoring purchases
  • Product analytics provider — Anonymous usage events, such as which screens are opened and which sessions are played

These providers process data on our behalf, under contract, and only for the purposes above. We do not sell or rent your personal information. We may disclose information if required by law, or as part of a merger, acquisition or sale of assets, in which case this policy continues to apply.

6. Retention

On-device data is kept until you delete it or delete the app. Purchase records are kept for as long as required for accounting and tax purposes. Usage data is kept in a form that does not identify you and is deleted or aggregated within 24 months. Support emails are kept for as long as needed to resolve your request.

7. Your choices and rights

Depending on where you live, you may have the right to access, correct or delete your personal data, to restrict or object to its processing, to data portability, and to withdraw consent. To make a request, email apps@luminacode.lt — we reply within 30 days. Because Synra has no accounts, deleting the app removes everything stored on your device; we can also delete any purchase or usage records linked to your anonymous identifier on request.

You can also lodge a complaint with a supervisory authority — in Lithuania, the State Data Protection Inspectorate (vdai.lrv.lt). California residents: we do not sell or share personal information as defined by the CCPA/CPRA.

8. International transfers

Some providers process data outside the European Economic Area, including in the United States. Where this happens we rely on appropriate safeguards such as the EU Standard Contractual Clauses or the EU–US Data Privacy Framework.

9. Security

Data is encrypted in transit, and access is limited to what each provider needs. No method of transmission or storage is completely secure, but we work to protect the little data we hold.

10. Children

Synra is not directed at children under 13, and we do not knowingly collect personal information from them. Some sessions are meant for parents to play for babies; the app is still operated by the adult. If you believe a child has sent us personal information, contact apps@luminacode.lt and we will delete it.

11. Website

This website does not use advertising or tracking cookies and does not require you to enter any personal information. The live audio demo runs entirely in your browser.

12. Changes

We may update this policy from time to time. We will post the new version here and update the date above; for material changes we will also give notice in the app.

13. Contact