Privacy Policy

Last Updated: July 24, 2026

1. Introduction

Fluxora LTD (trading as LabLumen) ("we", "our", or "us") is committed to protecting your privacy. We are the Data Controller of your personal data for the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information, including the health information you choose to share with us.

2. Information We Collect

We collect several types of information:

• Identity Data: Email address, name (if provided).
• Health Data (Special Category Data): Symptoms you report, and lab results, medical images (such as MRI, CT, or X-ray files), or photos you upload, together with the health insights generated from them.
• Payment Data: When you make a purchase, our payment processor (Stripe) collects your payment details. We do not receive or store your full card number.
• Technical Data: IP address, browser type, device information, and usage data.
• Cookies: See the Cookies and Analytics section below.

3. Legal Basis for Processing

Under the UK GDPR, we must have a legal basis to process your data. We rely on the following:

• Explicit Consent: Because you provide Health Data (Special Category Data), we require your explicit consent to process it for the purpose of generating your health insights. You grant this consent via the consent checkbox before an analysis runs. You may withdraw it at any time by ceasing to use the analysis features or by deleting your account.
• Performance of Contract: To provide the LabLumen service to you — creating your account, processing your inputs, and taking payment.
• Legitimate Interests: To keep the Service secure, prevent fraud and abuse, and maintain and improve the general (non-health) functioning of the application. We do not rely on legitimate interests to process your Health Data.
• Legal Obligation: To comply with our legal and regulatory obligations.

4. How We Use Your Information

We use the collected information to:

• Provide and maintain the Service.
• Generate health insights based on the inputs you submit.
• Process payments and manage your credits or subscription.
• Notify you about changes to our Service and provide customer support.
• Monitor general usage to keep the Service secure and improve it.

5. Third-Party AI Providers

To generate your analysis, we send the content you submit (for example, your uploaded medical images, lab values, or symptom descriptions) to third-party artificial-intelligence providers who process it on our behalf as Data Processors under contract. These currently include:

• Google LLC (Google / Gemini models)
• OpenAI, L.L.C. (GPT models)
• Anthropic, PBC (Claude models)

These providers process your data only to return the analysis to us. Under their enterprise/API terms, data submitted through their APIs is not used to train their models. We may change providers as technology evolves and will keep this list current. Payment processing is handled by Stripe, Inc., and our application and data are hosted by our cloud hosting and database providers, all acting as processors.

6. Cookies and Analytics

We use two categories of cookies and similar technologies:

• Strictly necessary: Required to run the Service (for example, keeping you signed in). These are always active.
• Analytics (optional): Used to understand how the Service is used. These load only after you accept them via our cookie banner. We use Google Analytics for this; the Google tag that provides it may also set advertising cookies. We also use Vercel Web Analytics, which is cookieless and does not track you across sites.

You can change your choice at any time using the "Cookie Preferences" link in the site footer. If you decline, no analytics or advertising cookies are set. We never share the contents of your uploads, results, or health information with these providers.

7. International Data Transfers

Some of our providers (including the AI providers named above) are based in the United States or process data outside the UK and European Economic Area (EEA). Where we transfer your personal data outside the UK/EEA, we ensure a comparable level of protection through appropriate safeguards, such as the UK International Data Transfer Agreement (IDTA) or the European Commission's Standard Contractual Clauses (SCCs).

8. Data Storage and Security

Your data is stored securely, and we apply technical and organizational measures designed to protect it against unauthorized access, loss, or misuse.

9. Data Retention

We retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy, or to comply with legal obligations. When you delete your account, we delete or anonymize your personal data, subject to any retention required by law.

10. Disclosure of Data

We do not sell your data. Beyond the processors described above, we may disclose data to:

• Legal Requirements: If required by law or to protect against legal liability.
• Business Transfers: In connection with a merger or sale of Fluxora LTD assets.

11. Your Data Protection Rights

Under the UK GDPR, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate data.
• Erasure: Request deletion of your personal data ("Right to be forgotten").
• Restriction: Request that we restrict the processing of your data.
• Portability: Request the transfer of your data to another party.
• Withdraw Consent: Withdraw your consent to our processing of your health data.

To exercise these rights, please contact us at support@lablumen.net.

12. Complaints

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO.

13. Children's Privacy

Our Service is not intended for use by children under the age of 18. We do not knowingly collect data from children.

14. Contact Us

Fluxora LTD
Email: support@lablumen.net