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Meta Flow Ltd. (dba “Lumen”)
This Privacy Policy, including jurisdiction specific policies (collectively herein after the “Policy”) describes how Meta Flow Ltd. and its subsidiaries (collectively, “Lumen”, “Company”, “we”, “us” or “our”) collect, use, share, and otherwise process personal information in connection with each user of the services (each, a “User” and “you”) and your use of: (i) Lumen’s website located at www.lumen.me (the “Website”); (ii) Lumen’s proprietary metabolic breath analyzer (the “Lumen Device”); (iii) Lumen’s mobile and web application platforms (the “Lumen App”); and (iv) Lumen’s services, which include food, lifestyle and wellness suggestions based on a User’s day-to-day life, preferences, activities, sleep habits, and real-time assessments of carbohydrate availability and metabolic fuel use as measured through the Lumen Device, landing pages, marketing digital assets, and all related services, features, content, and products (collectively, the “Lumen Services”).
By accessing or using the Lumen Services, you acknowledge that you have read, understood, and agree to be bound by this Policy. If you do not agree with this Policy, please do not access or use the Lumen Services.
This Policy applies globally to all users of Lumen Services. Certain jurisdictions may have additional requirements, which are addressed in jurisdiction-specific sections of this Policy. In particular, users in specific jurisdictions such as the United States (including the California Consumer Privacy Act), Japan and Israel, should refer to Section 13 (“Additional Disclosures”);
This Policy does NOT apply to: Job applicants - please refer to our Job Applicants Privacy Notice, which describes our personal data processing practices for job applicants, or employees (including former employees).
AMENDMENTS: We reserve the right to amend this Policy (or any policies referred to) from time to time, at our sole discretion. The most recent version of this Policy will always be posted on the website, and the update date will be reflected in the “Last Updated” heading. We will provide notice to you if these changes are material, and, where required by applicable law, we will obtain your consent. Any amendments to the Policy will become effective immediately, unless we notify otherwise. We recommend you review this Policy periodically to ensure that you understand our most updated privacy practices.
CONTROLLER CONTACT INFORMATION:
Meta Flow Ltd. is the data controller or owner, as defined under applicable data protection laws. Its physical address is: 30 Ha’arba’a Street, Tel Aviv, Israel, and can be contacted by the means detailed below. For jurisdiction-specific contact information, please refer to Section 13 of this Policy.
“Personal Information” means information that identifies an individual or may, with reasonable effort, identify an individual, either alone or in combination with other information, all unless anonymized. The Collection of Personal Information varies dependent on the Lumen Services that you use, according to the specification below. For the avoidance of doubt, we will treat any Non-personal Information connected or linked to any Personal Information as Personal Information as long as such connection or linkage exists.
“Non-personal Information” means non-identifying and without reference to the identity of any User, such as technical data that is necessary for the performance of the Lumen Services, for example, app analytics, taps and inputs, Wi-Fi network information, operating system, mobile device type, Lumen Device technical information, browser and keyboard language. For purposes of this Policy, we will treat any Personal Information that is anonymized and deidentified in a way that such individual can no longer be personally identified as Non-personal Information and may use or share this information in aggregated form for statistical, research or other lawful purposes.
Personal Information Collected Directly from You
We collect the following categories of personal information that you provide directly to us:
a. Account and Contact Information: Name, email address, password, and other account registration details, including address, including personalized data on your habits, gender, personal goals, age, region etc. We collect this information for the following purposes:
b. Health and Metabolic Data: Height, weight, sleep habits, food intake, caffeine intake, water intake, heart rate, breath data, prediabetes existence, GLP-1 medication intake, daily diet, exercise routine, real-time assessment of carbohydrate availability and metabolic fuel use (as measured via the Lumen Device), body activity data (including exercise types, steps, speed, and distance), as well as ongoing feedback that you provide us regarding your satisfaction from the diet plans, the difficulty to follow-up with the plans. We collect this information for the following purposes:
c. Community Content and Communications: Content, posts, comments, and other information you share in the Lumen Community pages, including feedback, testimonials, reviews. We may ask you to provide your feedback through third party integrations (such as Trustpilot, G2, etc.), or you may voluntarily do so on social media. These reviews may include your name and picture and will be displayed by Lumen on its website, landing pages or social media. Lumen further processes communications with the customer support team, sales team, or if you chat with us on social media, including through the App, via our AI customer support chat. We collect this information for the following purposes:
d. Commercial Information: Records of purchases, transaction history, subscription status and payment-related details. We collect this information for the following purposes:
Personal Information Collected Automatically
When you use the Lumen Services, we automatically collect certain information, including:
a. Usage Data: App, website, or other marketing assets’ analytics, click-stream data, activities on the Lumen Services, taps and inputs, information about your interaction with and use of the Lumen Services, information related to our communications with you, information concerning your traffic to and from the Website, your referral URLs to and from our Website, web login and access log information, the period of time the Lumen Services are used, and related timestamps. We collect this information for the following purposes:
b. Analytics and Marketing: The Lumen App may process advertising identifiers (such as IDFA on iOS; GAID on Android, affiliated IDs used for attribution and advertising-related measurement), IP, device ID and similar online identifiers. On iOS, we request your permission through Apple’s App Tracking Transparency (ATT) framework before accessing the IDFA. Such IDs are processed to provide analytic information, impressions and associate your actions with ads, campaign (views and engagement with our advertisements) and advertising and marketing assets, landing pages, social media pages, etc. We collect this information for the following purposes:
c. Device Information (including Lumen Device Technical Information): Device identifiers, unique device token, IP address, operating system, mobile device type, browser and keyboard language, Bluetooth, Wi-Fi network information, mobile device geo-location, location information as can be derived from your IP address, and mobile device motion information. Lumen further collects technical data from your Lumen Device, including firmware version, device performance metrics, connectivity and syncing information, diagnostic data, and error or troubleshooting logs. We collect this information for the following purposes:
d. Derived Personal Information: We may collect, generate, or otherwise process Personal Information inferred from other Personal Information we collect or obtain from you. This may include inferences, assessments, recommendations, suggested analysis, and other insights generated through your use of the Lumen Services, including to help provide personalized outputs and functionality through the Lumen Services. We collect this information for the following purposes:
e. Background Collection and Device Controls: Please note that certain portions of the information described above may also be collected from your device or software when the Lumen App is running in the background, meaning it has been launched but is not actively in use. Most mobile devices and related software allow you to control or disable the collection of certain information, including location services and certain permissions, through your device or application settings; however, doing so may affect the functionality of certain features of the Lumen Services. We collect this information for the following purposes:
f. Cookies and Tracking Technologies: Information collected through cookies, pixel tags, web beacons, and similar technologies (see Section 5 below).
Personal Information from Third Parties
We may receive Personal Information about you from third parties, including:
a. Third-Party Platform Information: Information from connected third-party platforms and social media accounts, when you choose to link such accounts to your Lumen account (such as: Apple Health, Motion and Fitness activity) and thereby providing us with access to information available on such accounts. To the extent that information is linked or connected to your identity, we will treat that information as your Personal Information. In addition, when you connect your social media to the Lumen App, Lumen will have access to information maintained therein, depending on your preferences. We may also receive Personal Information from payment service providers in connection with your payments, including information relating to the processing and confirmation of your transactions. We collect this information for the following purposes:
Generally, we process, use and store Personal Information to deliver the Lumen Services, including payment administration, billing, subscription management, metabolism tracking, personalized nutrition coaching, and to provide lifestyle guidance, operate, maintain, and improve the Lumen Services and develop new features. We further process the Personal Information to personalize the Lumen Services, content, and recommendations based on your metabolic data, usage patterns, and preferences. To comply with applicable laws, regulations, legal processes, and governmental requests. Finally, we may use certain information to improve our AI-enabled features using prompts, messages, inputs, and outputs generated through your use of such features; however, any use of Personal Information with AI tools or for AI-related purposes will be limited to what is necessary for the relevant purpose and subject to appropriate safeguards designed to protect Personal Information and support its secure and responsible use.
As a wellness product, we further conduct research and analysis using aggregated or de-identified data for statistical, scientific, and product development purposes.
To the extent applicable under data protection jurisdictions, such as the General Data Protection Regulations (“GDPR”) we will detail the lawful basis for processing Personal Information, as follows:
As detailed above, we collect Personal Information through the following methods:
We may share, disclose, or otherwise allow access to Personal Information we collect with third parties, as described below:
Advertising Partners: We may share certain data with advertising partners (such as AppLovin and similar partners) to enhance your experience, provide personalized advertising, measure advertising effectiveness, and improve the Lumen Services. The information shared may include usage data, device identifiers, and other information necessary to serve targeted advertisements and help us run and optimize the Lumen Services. AppLovin and similar partners use this information in accordance with their respective privacy policies, to serve targeted advertisements, measure the effectiveness of advertising campaigns, and improve user experience. For more information about AppLovin’s collection and use of your information, visit: http://www.applovin.com/privacy/
Authorities, law enforcement: We may disclose Personal Information to satisfy any applicable law, regulation, legal process, subpoena, or governmental request. We may also share Personal Information to enforce this Policy or the Terms of Use, including investigation of potential violations thereof; to detect, prevent, or otherwise address fraud, security, or technical issues; to respond to claims that any content available on the Lumen Services or the Website violates the rights of third-parties; or otherwise if we believe in good faith that this will help protect the rights, property or personal safety of Meta Flow, any of our Users, or any member of the general public.
Our Affiliated Companies: We may share Personal Information internally with our affiliated companies for the purposes described in this Policy. In addition, when we or any of our affiliated companies is undergoing any change in control, including by means of merger, acquisition, or purchase of all or substantially all of its assets, we may share Personal Information with the parties involved in such event. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Website or the Lumen Services.
Third Party Service Providers: We are partnering with several selected service providers whose services and solutions complement, facilitate, and enhance our own. Such third party service providers may have access to, or process on our behalf, Personal Information that we collect, hold, use, analyze, process, and/or manage. These service providers assist us with hosting, database and server co-location services, data analytics, payment processing, data analytics services, customer support, session replay records for app analytic purposes such as crashes, functionality and usability, and other operational, business, legal and financial functions. We remain responsible for any Personal Information processing done by Third Party Service Providers on our behalf not in accordance with the terms hereof, except for events outside of its reasonable control and except for such Third Party Service Providers with whom you have a direct contractual relationship.
Healthcare Providers: Your known health care providers, care management services or health care payers. In some instances, we will be working with you in conjunction with your own health care providers, care management services, or healthcare payers (insurance companies) (any such party is one of “Your Health Service Providers”). To the extent your relationship with us originates from one of Your Service Providers, we may provide your Personal Information to that party for its use in connection to the services it provides to you. Any Personal Information we provide back to Your Health Service Providers will be subject to Your Service Providers own privacy policies and practices, and you should confer with Your Health Service Providers if you have any questions regarding their own usage and treatment of your Personal Information.
Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, Personal Information may be transferred or shared with the parties involved in such transaction as part of the due diligence process or transfer of assets. If we believe that such change in control might materially affect your Personal Information then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our website or the Lumen Services.
Lumen Community members. If you participate in the Lumen Community, other people who are also logged-in to the Lumen Community will be able to see you some details which you agreed to be public such as your username and profile picture. In addition, other Lumen community members are able to see any content shared by you in the Lumen Community. We may use third-party review and customer feedback platforms, such as Trustpilot, to collect and display reviews about the Lumen Services and to invite customers to provide feedback. Where permitted by applicable law, we may share limited personal information with such providers for these purposes, such as your name, email address, order or subscription details, and other information necessary to verify your experience with the Lumen Services and send a review invitation. Reviews you submit through such third-party platforms may be publicly displayed together with the information you choose to include in your review or profile. These third-party platforms may process your personal information in accordance with their own privacy policies.
In the 12 preceding months, we have collected and/or disclosed the following categories of Personal Information:
| Category of Personal Information Collected | Personal Information Collected | Categories of recipients to whom Personal Information was disclosed |
| Identifiers | Full name, username, email address, postal address, telephone number, birthdate social media identifier, IP address, device identifiers, tax ID. | Service providers |
| Commercial information | Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Payment information such as Credit card or bank account numbers and billing information. | Service providers |
| Health-related information | Information that corresponds to a measurement of your physical/mental objective and/or subjective state and nutrition data, such as height, weight, sleep habits, food, caffeine and water intake, heart rate, breath data, real-time assessment of carbohydrate availability and metabolic fuel use as measured via use of the Lumen Device and through the Lumen App, daily diet, exercise routine, emotional and mental state, perceived sense of viability, as well as ongoing feedback that you provide us regarding your satisfaction from the diet plans, the difficulty to follow-up with the plans, as well as body activity data, such as types of exercise, number of steps, speed and distance and any Personal Information we derive from such information. | Service providers |
| Internet or other electronic network activity information | Search history, information on your interactions with our Website, Lumen App or advertisements, including taps and inputs, device motion, Wi-Fi network information, Lumen Device technical information, browser and keyboard language, the 'click-stream' and activities on the Lumen Services, and the period of time the Lumen Services were used and related timestamps. | Service providers |
| Geolocation data | Physical location or movements, including the location or movements of your device. | Service providers |
| Audio and visual information | Pictures you may have uploaded to Lumen Services and recorded customer services calls. | Service providers |
| Inferences drawn from other Personal Information | Information to create consumer profiles reflecting certain preferences and behaviors and customized content/offerings. | Service providers |
Lumen does not act as a data broker and does not sell Personal Information to third parties.
We use cookies, pixel tags (web beacons), and similar tracking technologies to collect information about your interactions with the Lumen Services. These technologies help us: remember your information and preferences; Recognize you when you return to the Lumen Services; Understand how you use the Lumen Services (analytics); Deliver and measure the effectiveness of advertising; and provide functionality and personalization.
If we integrate Trustpilot content, widgets, tags, cookies, pixels, SDKs, or similar technologies into the Lumen Services, Trustpilot and related providers may automatically collect certain information from your device or browser, such as your IP address, device and browser information, pages viewed, usage data, and cookie or similar tracking information, in order to provide the review content, measure interactions, and improve their services. For more information about how Trustpilot processes personal information, please review Trustpilot’s privacy policy available at: https://corporate.trustpilot.com/legal/for-businesses/privacy-policy/jun-2026.
There are different types of cookies or SDK, as applicable:
You may manage or remove cookies through your browser or device settings. Please note that disabling cookies may affect the functionality of certain features of the Lumen Services. For further details, please refer to our Cookie Policy at: https://www.lumen.me/cookie-policy, you may also opt out of certain tracking by emailing security@lumen.me.
The Lumen Services may include social media features (such as the Facebook “Like” button). These features may collect your IP address and information about which page you are visiting and may set a cookie to enable the feature to function properly. Social media features are governed by the privacy policy of the company providing them.
Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your Personal Information. To the extent these rights apply and concern you, you can contact us via the contact details available above and ask to exercise the following rights.
Right of Access. You may request confirmation of whether we process your Personal Information and, if so, request access to and a copy of such information.
Right to Correction. You may request that we correct inaccurate or incomplete Personal Information we hold about you.
Right to Deletion. You may request that we delete your Personal Information, subject to certain legal exceptions.
Right to Data Portability. You may request to receive your Personal Information in a structured, commonly used, and machine-readable format, and to transmit such information to another controller.
Right to Withdraw Consent. Where processing is based on your consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.
Right to Object. You may object to the processing of your Personal Information where we rely on legitimate interests as the legal basis.
Right to Restriction. You may request that we restrict the processing of your Personal Information under certain circumstances.
Right to Lodge a Complaint with a Supervisory Authority. You have the right to file a complaint with a local data protection supervisory authority.
Right Not to be subject to a decision based solely on automated processing. This includes profiling, which produces legal effects or similarly significantly effects to you.
Ask to withdraw any consent. At any time, you can withdraw any consent you have previously provided us in connection with our use and processing of your Personal Information.
Right to Limit the collection of your sensitive Personal Data. You have the right to limit the collection of your sensitive personal data that we use which is necessary to perform our Services.
Right not to be discriminated against for exercising your rights: You have the right to receive equal service and price and not be discriminated against for exercising any of your rights.
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements. Also, the exercise of some of these rights may make it impossible for us to continue to provide you with some or all of our Services.
When handling these requests, we may ask for additional information to confirm your identity and your request. Please note, upon request to delete your Personal Information, we may retain such data in whole or in part to comply with any applicable rule or regulation or response or defend against legal proceedings versus us or our affiliates, or as we are otherwise permitted under such law applicable to you. If you have additional concerns, you can also lodge a complaint with your local data protection authority.
Note, various rights can be exercised through the App or website without the need to contact us:
We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. Making a verifiable consumer request does not require you to create an account with us.
Meta Flow Ltd. is incorporated in Israel. Your personal information may be stored and processed in Israel and in other jurisdictions outside your country of residence, including the United States and the European Union, European Economic Area, where our service providers and affiliated companies operate. Your Personal Information will be maintained, processed, and stored by us and our authorized affiliates and service providers in the United States, EU and in Israel, and as necessary, in secured cloud storage provided by our third party service providers.
Where Personal Information is transferred outside your jurisdiction, we ensure that appropriate safeguards are in place, including: Standard Contractual Clauses approved by the European Commission (for transfers from the EU/EEA/UK); Adequacy decisions by relevant data protection authorities; Contractual protections requiring recipients to protect Personal Information to standards consistent with this Policy; and your explicit consent, where applicable.
We are committed to ensuring that your Personal Information remains protected regardless of the jurisdiction in which it is stored or processed.
We retain your Personal Information for as long as reasonably necessary to fulfill the purposes described in this Policy, including:
(a) Providing the Lumen Services and maintaining your account;
(b) Complying with our legal and regulatory obligations;
(c) Resolving disputes and enforcing our agreements (including our Terms of Use available at: https://www.lumen.me/terms-of-use);
(d) Maintaining business records as required by applicable law; and
(e) Achieving legitimate business purposes, such as product improvement and analytics.
When Personal Information is no longer required for these purposes, we will delete or anonymize it in accordance with this Policy and applicable law. The specific retention period depends on the nature of the data, the purposes for which it was collected, and applicable legal requirements.
We implement and maintain industry-standard technical and organizational security measures designed to protect your Personal Information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, access controls, regular security assessments, and employee training.
While we strive to protect your Personal Information, no method of transmission over the Internet or electronic storage is completely secure. We encourage you to use the strongest password combination available and to take appropriate measures to protect your account credentials.
In the event of a data breach affecting your Personal Information, we will notify you and relevant authorities as required by applicable laws.
We may use your Personal Information to send you direct marketing communications about our products, services, promotions, and events. We will obtain your consent before sending marketing communications where required by applicable law.
You may opt out of receiving marketing communications at any time by:
(a) Clicking the “unsubscribe” link in any marketing email;
(b) Adjusting your communication preferences in the Lumen App settings; or
(c) Contacting us at support@lumen.me.
Please note that even if you opt out of marketing communications, we may still send you transactional or service-related messages (e.g., account notifications, security alerts).
The Lumen Services are intended for individuals over the age of 16. We do not knowingly collect Personal Information from children under 16 years of age. If you are under 16, you may not use the Lumen Services. If we become aware that we have collected Personal Information from a child under 16, we will take steps to delete such information as soon as practicable.
If you are a parent or guardian and believe your child has provided us with Personal Information without your consent, please contact us at support@lumen.me
U.S. Specific Notice
These specific U.S. provisions, supplement this Policy, and describe additional personal information practices concerning data subjects to whom U.S. laws apply to. These specific U.S. provisions should be read in conjunction with this Policy, and in the event of conflict between these specific U.S. provisions and the Policy, these specific U.S. provisions should apply.
For our privacy practices where US laws apply, please visit our U.S. Notice of Privacy Practices: https://www.lumen.me/notice-of-privacy-practices.
For our privacy practices where California Consumer Privacy Act (“CCPA”) laws apply, please visit our CCPA Notice: https://www.lumen.me/ccpa-notice.
Israel Specific Notice
Notwithstanding the legal bases for processing personal information detailed above, where Israeli Data Protection Laws Apply the processing is based on your consent.
You do not have any legal obligation to provide any information to us. However, we require the information mentioned above in order to provide you with the services. If you do not wish to provide us with personal information, please do not use the Lumen Services and we may not be able to provide you with the Lumen Services.
Japan Specific Notice
This section provides additional information required under the Act on the Protection of Personal Information (APPI, as amended) and the Telecommunications Business Act of Japan. This section supplements the general provisions of this Policy. In the event of any conflict between this section and the general provisions above, this section shall prevail with respect to users located in Japan.
For inquiries relating to personal information handling under Japanese law, including rights requests, complaints, and general questions, please contact us at japan@lumen.me.
The purposes of use for all categories of retained personal data are as specified in Section 1 above.
Individuals may have the following additional rights, subject to applicable legal limitations:
We do not currently charge fees for rights requests. If this changes, we will notify you in advance and the fee will not exceed a reasonable amount.
Personal Information Security
In addition to section 10, we further implement the following measures to ensure that personal information is secure:
In the event that Personal Information undergoes a security incident, and where required to do so under applicable law, we will respond and provide notifications regarding such incident.
Application Permissions
When you download and use the Lumen App, we will request the following permissions: