Privacy is the default across everything we build.
This Privacy Policy applies to the applications and online services of Lumwe ("we", "our", or "us"), the operating brand of 17866381 Canada Inc., a federally incorporated Canadian technology company based in Québec, Canada. It covers our Apple-platform apps — Mansio, Ritmel, Grasp Lexicon, and Grasp — and our online services, Nurbell and the Inference API.
Our applications are designed to work without Lumwe user accounts, advertising identifiers, tracking profiles, or analytics SDKs. User-created content and app records are stored on the user's device unless the user deliberately uses an Apple system feature or external service outside Lumwe's control.
Our online services process only the information you or your organization submit, on infrastructure we operate in Canada. Lumwe does not sell personal information, does not use customer data for advertising, and does not use your content or requests to train models.
Four apps, two services — one privacy baseline.
On-device applications
Mansio
iPadOS / iOS · immigration & travel trackerOrganizes trips, passports, visas, permits, and residence-day progress. These records can be sensitive, but they stay on the device — Lumwe does not collect or receive them.
Grasp Lexicon
iOS · French dictionary & vocabularyLookup, pronunciation, morphology, and vocabulary review. Lookup history, saved words, and study lists are stored locally. Optional camera lookup extracts text only for the active request and is never uploaded.
Ritmel
iOS · schedule captureTurns typed text, voice, shared content, or clipboard text into Apple Calendar events using iOS system frameworks. Calendar data and voice are not uploaded to Lumwe servers.
Grasp
Learning workspaceHelps organize documents, notes, vocabulary, practice, and learning progress. Study materials and review data are stored locally on the device. AI-assisted features operate only on content you choose to use and are never used for advertising, profiling, or model training.
Online services
Nurbell
B2B SaaS · nurbell.comAn AI-powered export-compliance platform for businesses. It processes the trade data your organization submits — products, destinations, parties, and documents — on Lumwe infrastructure in Canada. Covered in detail in §05.
Inference API
Developer service · api.aolva.com (alias: api.lumwe.com)An AI inference service. Requests you send are processed on Lumwe's own GPU servers in Canada. Request content stays in Canada and is never used to train models. Covered in detail in §05.
What we do not collect from app users.
Across the four covered applications, Lumwe does not collect, store on Lumwe servers, sell, or share the following categories of data:
- Personal identifiers such as name, email address, phone number, Apple ID, or government identifier
- Precise GPS location, background location, or location history
- Documents, notes, vocabulary lists, calendar events, travel records, passports, visas, permits, or residence records entered into the apps
- Device identifiers used for advertising or cross-app tracking, including IDFA
- Behavioral advertising data, browsing history, or profiling data
- Payment card or billing information from App Store transactions
We do not include third-party advertising SDKs, third-party analytics SDKs, social login SDKs, or tracking frameworks in the covered apps.
The apps, side by side.
| Feature | Grasp | Grasp Lexicon | Mansio | Ritmel |
|---|---|---|---|---|
| User account required | No | No | No | No |
| Data sent to Lumwe servers | Not collected | Not collected | Not collected | Not collected |
| Primary local data | Study content | Vocabulary | Travel records | Calendar drafts |
| Calendar access | Not required | Not required | Not required | Read & write |
| Microphone access | Not required | Not required | Not required | Voice input only |
| Camera / photo access | Not required | Optional lookup | Not required | Not required |
| Advertising or tracking | None | None | None | None |
| Third-party data sale | None | None | None | None |
Nurbell & the Inference API.
Unlike the on-device apps, these are operated services that process data on Lumwe infrastructure. We built them on our own compute in Canada precisely so that data residency and privacy stay under our control.
Nurbell · nurbell.com
What it processes. To produce export-compliance results, Nurbell processes the business data your organization submits: product descriptions, destinations, parties, shipment details, and uploaded documents. Business accounts include the contact details needed to operate the service.
Where it lives. This data is processed and stored on Lumwe infrastructure located in Canada and does not leave Canada in the normal course of operating the service.
How we use it. Submitted data is used only to deliver the compliance features you request and to operate, secure, and support the service. It is not sold, not used for advertising, and not used to train models.
Retention & deletion. Customer data is retained for the life of the account or as set out in your service agreement, and is deleted on verified request. Customer organizations control access for their own users.
Inference API · api.aolva.com · api.lumwe.com
What it processes. The API processes the request content you send — prompts and accompanying inputs — to return an inference result. Account and usage metadata are processed for authentication, reliability, and billing.
Where it lives. Requests are served on Lumwe's own GPU servers in Canada. Request content stays on Canadian soil and is not routed to third-party model vendors.
How we use it. Request content is used only to generate your result and operate the service. It is not sold, not used for advertising, and not used to train Lumwe or any third-party models. We keep operational logs to the minimum needed for reliability, abuse prevention, and billing.
Your responsibility. You are responsible for the data you submit and for having the right to send it. Do not submit content you are not permitted to process.
Permissions are requested only when needed.
Files and documents: Mansio, Grasp, and Grasp Lexicon may let users import or export files. Files selected by the user are used only for the requested workflow and are not sent to Lumwe.
Camera or Photos (Grasp Lexicon only, if enabled): iOS asks before camera or photo access, used for lookup workflows such as recognizing text from an image. Images are not uploaded to Lumwe servers.
Calendar (Ritmel only): iOS prompts for calendar access before Ritmel creates or manages events. Revoking it in Settings → Privacy & Security → Calendars prevents Ritmel from writing events.
Microphone (Ritmel only): iOS prompts for microphone access when voice input is used. You may use text input or the Share Extension without granting microphone access.
No background tracking: the covered apps do not request background location, advertising-tracking permission, marketing push tokens, or background analytics collection.
Data stays under the user's control.
For the on-device apps, user data is stored locally and is not collected by Lumwe:
- Deleting an app removes that app's local data from the device, subject to normal iOS, iPadOS, macOS, iCloud, backup, and system behavior.
- Users can delete app records directly inside the app where deletion controls are provided.
- Calendar events created by Ritmel remain in Apple Calendar until deleted from Calendar or through Ritmel.
- Files exported by the user remain wherever the user saved or shared them.
For the online services (Nurbell, Inference API), data you submit is retained as described in §05 and deleted on verified request. Lumwe cannot retrieve or delete local app data on your behalf, because we do not receive or store it.
Not directed at children.
The covered applications and services are not directed at children under the age of 13, or the applicable age of digital consent in the user's jurisdiction. Lumwe does not knowingly collect personal information from children.
No advertising, analytics, or tracking SDKs.
The covered applications do not integrate third-party advertising networks, analytics SDKs, tracking SDKs, social login SDKs, or data-broker services. They may interact with Apple system frameworks chosen for core functionality — EventKit for calendar access, speech or dictation frameworks for voice input, file and photo pickers, camera access, and App Store purchase infrastructure — which are governed by Apple's privacy practices. Lumwe does not receive personally identifiable App Store billing information.
The online services run on Lumwe's own infrastructure in Canada. We do not route your Nurbell data or Inference API request content to third-party model vendors, advertising networks, or trackers. Limited operational sub-processors (such as infrastructure and payment processing) may be used strictly to run the service; these are bound to protect the data and are not permitted to use it for their own purposes.
App Store distribution: Apple may provide developers with aggregate App Store metrics, crash diagnostics, purchase status, or subscription status. Lumwe does not use that information for advertising or cross-app tracking.
PIPEDA & Québec Law 25.
Lumwe is the operating brand of 17866381 Canada Inc., incorporated in Québec, Canada. We design the covered applications to avoid collecting personal information, and we operate the online services in Canada with data residency in Canada. Where the online services process personal information on behalf of business customers, we do so under our agreement with that customer and in accordance with applicable Canadian privacy law, including PIPEDA and Québec's Law 25.
- Privacy questions may be sent to [email protected].
- Users should not send sensitive documents or app records by email unless they intentionally choose to do so.
- We aim to respond to privacy-related inquiries within 30 days.
We keep this page current.
We may update this Privacy Policy from time to time. The most current version will be available at lumwe.com/privacy. We update the "Last updated" date when material changes are made — including when a new product or service introduces Lumwe-operated data processing.
Questions? Reach out.
If you have questions about this Privacy Policy or Lumwe's data practices, please contact us:
Lumwe
Legal entity: 17866381 Canada Inc.
Québec, Canada
Website: lumwe.com
Email: [email protected]
Résumé de la politique de confidentialité.
Lumwe, marque opérationnelle de 17866381 Canada Inc., société de technologie constituée en société fédérale au Canada et établie au Québec, publie les applications Mansio, Ritmel, Grasp Lexicon et Grasp, ainsi que les services en ligne Nurbell et l'Inference API.
Aucune collecte de données personnelles par les apps
Lumwe ne collecte pas, ne vend pas et ne partage pas les renseignements personnels des utilisateurs de ses applications. Aucun compte Lumwe, traceur publicitaire ni SDK d'analyse tiers n'est utilisé. Documents, notes, vocabulaire, données de voyage, pièces d'identité et événements de calendrier sont conservés localement sur l'appareil, sauf exportation ou partage volontaire.
Services en ligne — données au Canada
Nurbell (nurbell.com) traite les données commerciales soumises par votre organisation pour produire des résultats de conformité à l'export. L'Inference API (api.aolva.com, alias api.lumwe.com) traite le contenu des requêtes que vous envoyez. Ces données sont traitées sur l'infrastructure de Lumwe au Canada, y demeurent, et ne sont jamais vendues, utilisées pour la publicité, ni utilisées pour entraîner des modèles.
Nous joindre
Pour toute question relative à la vie privée, écrivez à [email protected]. Conformément à PIPEDA et à la Loi 25 du Québec, nous visons une réponse sous 30 jours.