Privacy Policy
Last updated 18 August 2026
What we collect
Account details, FOFS completion records, cycle activity and session responses, coach feedback, uploaded artefacts and, where consented, session audio recordings.
How we use it
To deliver your Lumina cycles, generate your final reports, provide organisation-level adoption reporting and meet IAL's programme quality obligations.
Consent
Audio capture is opt-in and can be withheld or withdrawn at any time from your profile. Withholding consent does not block cycle completion.
Retention and purge
Session audio is automatically purged 90 days after capture. Written reflections and final reports are retained for the life of your subscription plus 12 months.
Organisation visibility
Organisation admins can see completion status, cycle progress and final reports for their funded users. They cannot see raw reflection entries or coach notes.
Your rights
You may request access to, correction of, or deletion of your personal data by contacting the IAL data protection officer.