Privacy Policy

Last updated 18 June 2026

This is a starter draft for the private beta and waitlist. It will be reviewed with a lawyer before public launch.

Who runs LucinOS

LucinOS is built and operated by Dmytro Bodlev, a private entrepreneur (ФОП) registered in Ukraine. For anything in this policy, the data controller is Dmytro Bodlev. You can reach me at privacy@lucinos.app.

What I collect

Account data — your email and authentication details, so you can sign in.

Your content — the life data you create: domain scores, the Inner Map, tasks, habits, goals, journal entries, and your conversations with Lucian. This is yours.

Waitlist data — if you request early access, your email, chosen language, an optional note about how you plan today, and the page you came from.

Usage analytics — privacy-light, cookie-light product analytics (page views, which features you use). No selling, no ad networks.

Why I use it

To run the product, keep you signed in, generate Lucian’s reflections, send you the email you asked for, and understand which parts of LucinOS help — so I can make it better. I do not sell your data, ever.

Legal basis (for EU/EEA users)

Under the GDPR, I rely on: contract (to provide the app you signed up for), consent (the waitlist and product emails — withdraw any time), and legitimate interests (keeping the service secure and improving it, balanced against your rights).

Where your data lives

Your primary data is stored with Supabase in Seoul, South Korea (`ap-northeast-2`). South Korea holds an EU adequacy decision (2021), so EU→KR transfers are covered.

Some processors are based in the US — Anthropic and OpenAI (the AI behind Lucian), Vercel (hosting), Resend (email), PostHog (analytics), and Lemon Squeezy (payments). These transfers are covered by Standard Contractual Clauses.

Your rights

You can access, correct, export, or delete your data, and object to or restrict certain processing. Email privacy@lucinos.app and I’ll handle it. EU users also have the right to complain to a supervisory authority.

Retention

I keep your account data while your account is open. Delete your account and I remove your personal data, except where I’m required to keep limited records (for example, payment records for tax).

Age

LucinOS is for people 16 and older. It’s not intended for children under 16.

Changes

If this policy changes in a way that matters, I’ll say so on this page and, where appropriate, by email.