Privacy Policy for Prompi

Last updated: 23 August 2026

Prompi is made by Lumio Studio. This policy explains what happens to your data. It is short

because the app does very little with it.

The short version

Prompi has no accounts and no servers of ours. Your scripts, your recordings and your voice

never reach Lumio Studio. There is nothing for us to look at, sell, or lose.

What stays on your device

DataWhere it livesWho can see it
Your scriptsOn your iPhoneYou
Your recordingsOn your iPhone, until you save them to Photos or delete themYou
Your measured speaking paceOn your iPhoneYou
Your settingsOn your iPhoneYou

We do not receive any of it.

Camera, microphone and speech

Prompi asks for three permissions and uses each for one thing:

Speech recognition runs on your iPhone. Prompi requests on-device recognition

(requiresOnDeviceRecognition = true) so your audio is not sent to Apple's servers for transcription.

If the on-device language model for your chosen language is unavailable on your device, Prompi

will tell you and fall back to speed scrolling. It will not silently send your voice anywhere.

Recognition output is used to move the script and, if you turn captions on, to write captions onto your

own video. It is discarded when you close the prompter. It is never stored on a server.

Subscriptions

Payment is handled entirely by Apple. We never see your card, your name, or your billing address.

To manage subscriptions and free trials we use Adapty (Adapty Tech Inc., United States) as a data

processor. Adapty receives a randomly generated identifier, your purchase and trial events, your app

version, device model, operating system version and country. It does not receive your scripts, your

recordings, your voice, or your name.

Because Adapty is in the United States, this is a transfer of data outside Turkey and outside the

European Economic Area. It is carried out under standard contractual clauses.

Analytics and tracking

Prompi does not use advertising SDKs, does not track you across other apps or websites, and

does not ask for the App Tracking Transparency permission, because it has nothing to track you for.

Apple may provide us with aggregate, anonymous App Store metrics (installs, crashes, subscription

counts). We cannot identify anyone from these.

Deleting your data

Because we hold nothing, deleting your data means removing it from your own devices. Prompi

gives you one control that does all of it:

Settings → Delete all my data. This erases every script, every unsaved recording, your measured

speaking pace and every setting on this iPhone. It cannot be undone.

Recordings you have already saved to Photos are yours and stay in Photos. Delete those in Photos.

Deleting the app also removes its local data.

iCloud sync is not enabled in this version. If a future version adds it, this policy will say so

before it ships.

Your rights

Because Prompi holds no personal data on any server we control, there is no file for us to

produce, correct or erase. You already hold and control all of it.

You still have rights under the law, and you can exercise them by writing to us:

informed about the purpose, to know about transfers abroad, to request correction or destruction, to

object to automated decisions, and to claim compensation for unlawful processing.

restriction, portability, and objection.

sell or share personal information, and never have.

Write to contact@lumiostudio.co. We answer within 30 days. If you are in Turkey and are not

satisfied, you may complain to the Kişisel Verileri Koruma Kurumu. In the EEA, you may complain to

your national supervisory authority.

Legal basis for processing

Where the GDPR applies: the on-device processing described above is necessary to perform the contract

you enter when you use the app (Article 6(1)(b)). Subscription management through Adapty rests on the

same basis. We do not rely on consent for anything, because we do not process anything optional.

Where the KVKK applies: processing is necessary for the performance of a contract under Article 5(2)(c).

Children

Prompi is not directed at children under 13 and we do not knowingly collect data from them. There

is no sign-up, no profile and no social feature, so there is nothing for a child to disclose to us.

Security

Your data is protected by iOS itself: device encryption and the app sandbox. We do not operate a

server that could be breached, because we do not operate a server.

Changes

If this policy changes materially we will update the date at the top and note the change in the app's

release notes. Continuing to use Prompi after a change means you accept it.

Who we are

Lumio Studio

contact@lumiostudio.co

Data controller for the purposes of the KVKK and the GDPR.