Privacy

The controller is Maksim Sabunov, trading as Lumilay, Kaupmehe 6, Tallinn, Estonia. You can reach him at contact@lumilay.com.

Lumilay is a named individual, not a company. The General Data Protection Regulation (GDPR) allows a natural person to be a controller, and this policy is written on that basis. There is no registry code or VAT number to give because no such registration exists.

lumilay.com is a static site. It sets no cookies of its own, runs no analytics, and loads no third-party scripts, fonts or trackers; its typefaces are served from this domain.

The site is delivered by Cloudflare, Inc. from its network. To serve a page Cloudflare processes the technical data every web request carries: IP address, browser identification, the URL requested and the time. Cloudflare keeps these logs under its own retention rules and may set a short-lived security cookie when it challenges a request it considers suspicious. Lumilay sees aggregate request counts and nothing about individual visitors.

Mail to contact@lumilay.com is forwarded through Cloudflare Email Routing to the controller’s mailbox. Your message and address are kept for as long as the correspondence needs and then deleted. The lawful basis is Lumilay’s legitimate interest in answering you (Article 6(1)(f)).

Keepin is a macOS application with an optional account for sync and enrichment. New accounts are closed by default: only allow-listed email addresses can sign in, and today that list is the author. The following describes what the service does for an account that exists.

Signing in

Keepin signs in with a Google account, a GitHub account, or a six-digit code sent to an email address. Sign-in runs through WorkOS, Inc., which also sends the code emails; Keepin runs no mail of its own. Codes expire after fifteen minutes. From Google or GitHub the service receives only what the openid, email and profile scopes carry: an identifier, the email address, the display name and the profile picture. Nothing else in those accounts is requested or read. Lumilay stores the email address, an internal user ID, and one record per signed-in device with its name and last-seen time.

Sync

Records (rooms, items, tags and settings) are stored in Cloudflare D1. Files you save are stored in Cloudflare R2, in a bucket created with a European Union location hint. Cloudflare documents a location hint as best-effort rather than a guarantee, and the D1 database carries no jurisdiction restriction, so data may be processed outside the EU. See 8.0.

AI enrichment

When a saved page is enriched, the content of that page is sent through Lumilay’s service to OpenRouter, Inc. and onward to the model provider it routes to, on Lumilay’s own key and limited to an allow-list of models. Only page content is sent, never account details.

Reading pages on your behalf

To read a saved link the service may visit that URL from Cloudflare’s network using Cloudflare Browser Rendering. The site you saved sees a request from Cloudflare, not from your Mac.

Payments

Keepin’s payment path uses Polar Software Inc. as merchant of record. It is dormant: the storefront is shut in every build and no payment data is collected.

On the Mac

The library itself lives on your Mac as one readable JSON file under Application Support. It does not leave the machine unless sync is on.

Plikka is a single-user assistant that its author installs and operates on his own server, connected to his own accounts. It is not available to anyone else. The personal data it handles is the ordinary content of its operator’s own mailbox, calendar and messages. Should that ever change, this policy will be updated first.

• Performance of a contract (Article 6(1)(b)) for creating an account, signing in, and syncing a library.
• Legitimate interest (Article 6(1)(f)) for security logging, abuse prevention and answering correspondence.
• Consent is not relied on anywhere on this site or in the software.

These organisations process personal data on Lumilay’s behalf:

• Cloudflare, Inc. (San Francisco, USA): hosting of this site, D1, R2, Browser Rendering, Email Routing.
• WorkOS, Inc. (San Francisco, USA): sign-in, including sending sign-in codes.
• OpenRouter, Inc. (USA) and the model providers it routes to: AI enrichment of saved pages.
• Polar Software Inc. (USA): payments, currently dormant.

Google LLC and GitHub, Inc. act as independent identity providers when you choose to sign in with them, under their own privacy policies.

Every processor above is established in the United States. Transfers rely on the processors’ data processing agreements incorporating the EU Standard Contractual Clauses, and where a processor is certified under the EU–US Data Privacy Framework, on that adequacy decision. Because the R2 location hint is best-effort and the D1 database has no jurisdiction restriction, Lumilay does not claim that data is stored only in Europe.

• Account and library data: until the account is deleted.
• Sign-in codes: fifteen minutes.
• Correspondence: for as long as the matter needs.
• Request logs at Cloudflare: under Cloudflare’s own retention rules.

You may ask for access to, correction of, erasure of, or restriction of processing of your personal data; for a copy of it in a portable form; and you may object to processing based on legitimate interest. Write to contact@lumilay.com.

Deleting a Keepin account is built in. The account-deletion request, confirmed by typing your own email address, removes the user record and everything that hung off it: records, files, sign-in codes, MCP tokens and audit rows.

You may complain to a supervisory authority. Lumilay’s is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), aki.ee.

This policy changes when the software does. The date at the top is the date of the last change, and the version on this page is the version that applies.