1. Who is responsible
Lunio is provided by Carlo Maryska (“we”, “us”). For questions about this policy or your personal data, contact hello@carlomaryska.com.
If you are in the European Economic Area (EEA), the United Kingdom, or Switzerland, Carlo Maryska is the data controller for personal data processed through Lunio, to the extent the GDPR, UK GDPR, or equivalent law applies. No data protection officer is appointed.
2. Data that stays on your device
The following is stored locally on your iPhone or iPad (including in Lunio’s App Group shared with its Screen Time extensions) and is not uploaded to a Lunio-operated server:
- Your display name and onboarding answers (age band, evening habits, triggers, goals, bedtime, and similar questionnaire answers).
- Which apps you choose to protect, Gentle Pause / Shortcuts setup, Hardcore-mode preferences, and your Power-Down window.
- Screen-time and scroll-minute activity measured during the protected evening window, including evening recap summaries.
- Streaks, achievements, and related progress state.
- Journal entries (day reviews and parked worries) and overnight to-dos.
- Manual sleep quality ratings you add in the app.
- Notification, haptic, and sleep-tracking preferences.
Lunio does not operate its own backend for this on-device data. We cannot read your Screen Time selection tokens, evening scroll history, Health samples, or journal text from our side.
3. Onboarding profile
During setup, Lunio asks for a first name (for greetings) and questionnaire answers such as age band, what keeps you up at night, how often it happens, triggers, what you have already tried, how long it has been going on, how you feel in the morning, what you want to change, an evening strategy, intended versus actual sleep time, whether you use a sleep-tracking device, how you found Lunio, and an optional referral code.
Some of those answers can relate to health or well-being (for example tiredness or sleep). That can be special-category data under Article 9 GDPR. You provide it voluntarily so Lunio can personalise the plan. It is stored on device and, after onboarding, may sync via iCloud as described below. It is not sent to PostHog or RevenueCat.
4. iCloud Sync
If you are signed in to iCloud on your device, Lunio starts syncing after onboarding (when your plan is created). There is no separate Lunio account. Sync uses the private CloudKit database for the container associated with your Apple ID:
- Onboarding profile and app settings (for example Power-Down times, ritual preferences, and notification preferences).
- Tomorrow to-dos.
- Journal entries (day reviews and parked worries).
Data is stored in your private iCloud database, not on a Lunio-operated server. Apple may also deliver silent CloudKit notifications so other devices signed in to the same iCloud account can stay in sync. Screen Time history, streaks, achievements, manual sleep ratings, and HealthKit samples are not included in iCloud Sync.
“Delete account” in Settings clears Lunio data on this device and deletes the synced CloudKit records. Your Apple subscription stays with your Apple ID until you cancel it in iOS Settings.
5. Apple Health
If you choose to connect Apple Health, Lunio requests access to Sleep Analysis so it can read your sleep (including stages such as in bed, awake, core, deep, and REM when available) and show it in Insights. Access is granted through Apple’s Health permissions and can be revoked in the Health app or iOS Settings. Health data is processed on your device and is not uploaded to Lunio, PostHog, or RevenueCat, and is not used for advertising.
Sleep data from Apple Health is health data (special-category data under Article 9 GDPR). The legal basis is your explicit consent via Apple’s Health permission sheet.
6. Screen Time & app protection
Lunio uses Apple’s Screen Time APIs (Family Controls), Managed Settings, and Device Activity to pause the apps you select during your Power-Down window, and to summarize evening phone use for your recap. Apple provides this in a privacy-preserving way: the app can restrict selected apps and derive evening activity metrics without sending your full usage history to us.
Gentle Pause may use a Shortcuts automation you set up yourself so that opening a protected app can open Lunio for a short ritual instead. Optional Hardcore mode applies additional on-device restrictions (for example blocking app uninstall and date/time changes). Those preferences stay on the device.
7. Notifications, Shortcuts & Reminders
- Notifications: Lunio can schedule local notifications for Power-Down start, morning review, and a one-shot reminder that a free trial is ending. Delivery happens on your device. You can turn categories off in Lunio Settings or disable notifications in iOS Settings.
- Shortcuts: Gentle Pause setup may require creating an automation in Apple’s Shortcuts app. That automation runs on your device.
- Reminders: If you choose to export to-dos, Lunio can create reminders in Apple Reminders via EventKit. This is optional, one-shot, and not a continuous sync.
- Background audio: Soundscapes can keep playing when the app is in the background. Audio stays on your device.
8. Product analytics (PostHog)
In release builds, Lunio uses
PostHog
(EU Cloud, eu.i.posthog.com) to understand whether onboarding and
core features work. Analytics are disabled in debug builds. We do not use
advertising SDKs, IDFA, or App Tracking Transparency, and we do not run
session replay / screen recording.
Events are anonymous. Lunio does not call PostHog identify, so we do not attach your name, email, or Apple ID to an analytics profile. Typical events include which onboarding screen was shown, whether Shortcuts setup was completed or skipped, that Pro was unlocked, which ritual type was started, and which soundscape was started (id and title). The SDK may also send standard app-lifecycle events (installed, opened, backgrounded) and device metadata such as app version, OS version, and an anonymous distinct ID stored on the device.
Journal text, parked worries, Health samples, Screen Time tokens, evening minute counts, to-dos, and your questionnaire answers are not sent to PostHog.
Legal basis: legitimate interests (Article 6(1)(f) GDPR) in making Lunio reliable and improving the product, balanced against your rights. You can object at any time by emailing hello@carlomaryska.com. Deleting your Lunio account resets the analytics ID on that device.
9. Subscriptions (RevenueCat & Apple)
Paid features are offered through Apple In-App Purchase. Lunio uses RevenueCat to manage subscription status and entitlements. RevenueCat may process purchase-related identifiers and subscription status. Payment details are handled by Apple; we do not receive your full payment card information.
10. Accounts
Lunio does not require a separate Lunio account, email signup, or social login. iCloud Sync uses your existing Apple ID through Apple’s iCloud services. Subscription status is tied to your Apple ID via the App Store and RevenueCat.
11. What we do not collect
- We do not sell or rent your personal data.
- We do not use your data for third-party advertising or cross-app tracking.
- We do not use advertising networks, SKAdNetwork campaign tracking, or IDFA.
- We do not build a marketing profile of you across other apps or websites.
- We do not operate a Lunio login, and we do not read your journal or Health data from our computers.
12. Who we share data with
We do not sell personal data. Depending on the features you use, the following parties process data:
- Apple: iOS, App Store / In-App Purchase, iCloud / CloudKit, Health, Screen Time, Shortcuts, Reminders, and (if you enable it) Apple’s aggregated crash and performance reporting. Apple typically acts as an independent controller for those platform services. See Apple’s privacy policy.
- PostHog, Inc.: product analytics on EU Cloud, as a processor for the events described above. See PostHog’s privacy policy.
- RevenueCat, Inc.: subscription status and entitlements, as a processor. See RevenueCat’s privacy policy.
Animations in the app (for example Lottie) are bundled with the app and are not a separate analytics or advertising service.
13. Apple diagnostics
Lunio may benefit from Apple’s standard, aggregated crash and performance reporting if you have shared analytics with app developers enabled on your device. You can control this in iOS Settings under Privacy & Security → Analytics & Improvements.
14. Legal bases (GDPR)
Where the GDPR applies, we process personal data on these bases:
- Contract / service delivery (Art. 6(1)(b)): to provide Lunio’s core features you request (protection windows, rituals, journal, to-dos, Insights, subscriptions).
- Consent (Art. 6(1)(a), and Art. 9(2)(a) where health data is involved): Screen Time authorization, Apple Health sleep access, notifications, Reminders export, and voluntary onboarding answers that relate to health or well-being.
- Legitimate interests (Art. 6(1)(f)): product analytics as described above, keeping the app secure and stable, and responding to privacy or support requests, balanced against your rights.
You may withdraw consent at any time in iOS Settings, Health, Screen Time permissions, or by using Delete account in Lunio, without affecting the lawfulness of processing before withdrawal.
We do not use automated decision-making that produces legal or similarly significant effects (Art. 22 GDPR).
15. Your rights (GDPR & similar laws)
Depending on where you live, you may have the right to access, rectify, erase, restrict, or object to certain processing, and to data portability. You may also withdraw consent and lodge a complaint with a supervisory authority — in Germany, typically the data protection authority of the federal state where you live, or the Federal Commissioner for Data Protection and Freedom of Information (BfDI).
Because most Lunio data lives on your device or in your private iCloud database, the fastest way to exercise many of these rights is directly on your device: edit or delete journal, to-dos, and your name in the app; use Delete account in Settings; revoke Health / Screen Time / notification / Reminders permissions; or delete the app. For access, objection (including to analytics), or other requests we must handle ourselves, email hello@carlomaryska.com.
16. International transfers
PostHog product analytics are sent to PostHog’s EU Cloud. Apple and RevenueCat may process data in the United States or other countries. Those transfers are governed by Apple’s and RevenueCat’s terms and applicable safeguards (including standard contractual clauses where required). Lunio does not operate a separate global data center for your Screen Time or Health data.
17. Retention
- On-device data remains until you delete it in the app, use Delete account, or remove the app (subject to iOS backup behavior).
- iCloud Sync data remains in your private CloudKit database until you delete the account in Lunio or otherwise remove it via Apple ID / iCloud controls.
- PostHog analytics are kept only as long as needed to understand product usage. Account deletion resets the anonymous ID on that device; you can also ask us to delete analytics records we can reasonably identify.
- Subscription records are retained by Apple and RevenueCat as needed to provide and audit purchases.
18. Children
Lunio is not directed at children. In the EEA the age for valid consent is generally 16 (member states may set 13–16). We do not knowingly collect personal information from children below the applicable age. If you believe we have, contact us and we will delete it.
19. Changes to this policy
We may update this policy as the app evolves. Material changes will be reflected here with an updated date at the top of the page.
20. Contact
Questions about privacy? Reach out at hello@carlomaryska.com.