Privacy Policy

Who we are

Lucerna is a screenwriting and film production management application developed by Luminos Film S.r.l. (hereafter: “we”, “the Controller”). It is a native macOS/iOS application, sold under a perpetual licence at a one-time price.

Data controller pursuant to Art. 4(7) GDPR:

Luminos Film S.r.l. Via Pietro Piffetti 48 10143 Turin (TO), Italy VAT: IT12361020014 privacy@luminosfilm.com

Zero-knowledge architecture: why we cannot see your data

This section is not marketing copy. It is the technical explanation of an architecture that makes it structurally impossible for us to access your content.

How sync works

Synchronisation uses Apple iCloud (CloudKit) exclusively.

• Your files are saved locally on your device and, if you have enabled it, synced to your personal iCloud account.
• We do not have access to your iCloud account. We cannot.
• Apple manages this infrastructure under their own privacy policy (apple.com/legal/privacy), which we recommend you read.
• Apple acts as data processor for the iCloud sync function, on your behalf, not ours.

If you do not use iCloud

Nothing different happens. The data stays on the local device. That is it.

libp2p relay server

We operate a relay server using the libp2p protocol to enable peer-to-peer connectivity between devices behind restrictive firewalls or NAT (corporate networks, public hotspots, etc.).

What the relay does

The relay routes encrypted traffic only. It acts as a temporary rendezvous point between two clients that cannot establish a direct connection.

• The relay does not see the content of the traffic. Communication is end-to-end encrypted.
• The relay does not store data. No content logs, no temporary files.
• The relay sees only the IP addresses of the clients involved in the session, for the duration of the session.

Legal basis: performance of contract (Art. 6(1)(b) GDPR). The relay is necessary to provide the sync feature when a direct connection is not possible.

Telemetry (Matomo)

We collect anonymous, aggregated telemetry via Matomo, an open-source analytics platform we self-host on our own infrastructure. Why? Because we want to know if the app crashes, which features get used and which do not, and when something stops working. Not to profile you. We are not interested in who you are.

What Matomo collects

Telemetry is pseudonymised at source: IP addresses are truncated before processing.

• Lucerna version in use
• Operating system version (macOS/iOS)
• Event type (document opened, export, crash, etc.)
• Approximate country/region (derived from the truncated IP)
• Session duration

What Matomo does not collect

• The content of your documents (scripts, notes, anything)
• Your name, email, or any identifying data
• Your precise location
• Biometric or advanced behavioural data

Legal basis and opt-out

Legal basis: legitimate interests of the Controller (Art. 6(1)(f) GDPR) to improve the product using aggregated usage data, balanced against your right to privacy via pseudonymisation.

You can disable telemetry at any time in Lucerna’s Preferences (Preferences > Privacy > Telemetry). That setting is respected immediately. No account required.

What we never collect

To be unambiguous:

• No user account. You do not have a Lucerna account. You have never given us an email address via the app.
• No advertising tracking. Zero third-party marketing SDKs.
• No data sales. We do not sell data to third parties. We have none to sell.
• No behavioural profiling. We do not know who you are. We do not want to.
• No cookies. This is a native app, not a website.

Recipients of data

Your personal data is not shared with third parties for commercial purposes. The parties that may come into limited contact with personal data in the course of service delivery:

Apple processes iCloud data under its own policies and in compliance with Standard Contractual Clauses (SCCs) approved by the European Commission for transfers to third countries.

International transfers

Data processed via iCloud may be stored on Apple servers located in the United States and other countries. Apple ensures an adequate level of protection via the SCCs under Commission Implementing Decision (EU) 2021/914.

Matomo telemetry is processed on infrastructure managed directly by Luminos Film, located within the EU. No additional transfer provisions apply.

Retention

Your rights

Under Articles 15-22 GDPR, you have the right to:

• Access (Art. 15): know whether we process data about you and obtain a copy.
• Rectification (Art. 16): correct inaccurate data.
• Erasure (Art. 17): request deletion of data, in the cases provided for.
• Restriction (Art. 18): restrict processing in certain circumstances.
• Portability (Art. 20): receive data in a structured, machine-readable format.
• Object (Art. 21): object to processing based on legitimate interests.
• Withdraw consent: where processing is based on consent, withdraw it at any time (e.g. by disabling telemetry in Preferences).

To exercise your rights, contact: privacy@luminosfilm.com

We will respond within 30 days. You also have the right to lodge a complaint with the competent supervisory authority. In Italy: Garante per la protezione dei dati personali (garanteprivacy.it). In the EU: the supervisory authority of your country of residence.

Security

Technical and organisational measures we apply:

• libp2p relay communications are encrypted using modern cryptographic protocols (Noise Protocol Framework, TLS 1.3).
• iCloud uses end-to-end encryption for eligible data categories as defined by Apple.
• Matomo telemetry is hosted on infrastructure with restricted access and multi-factor authentication.

Changes to this policy

We may update this policy at any time. For material changes, we will notify you via an in-app notification. Continued use of Lucerna after changes are published constitutes acceptance of the revised policy.

The current version is always available at lucerna.app/legal/privacy and in the app (Lucerna > About > Privacy Policy).

Contact

Luminos Film S.r.l. · Via Pietro Piffetti 48, 10143 Turin (TO), Italy privacy@luminosfilm.com

Lucerna is zero-knowledge software. Nothing more, nothing less.

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