Legal
Privacy Policy
How the Rubicon Creators website and our apps, Lumen and Agent Hub, handle your data.
Last updated
This policy is issued by Mariia Kirpichnikova, a sole trader (Autónomo) established in Spain, trading as Rubicon Creators. For data protection purposes that person is the controller for everything below, and you can reach them at mariiakirpichnikova@gmail.com.
It covers the website at rubiconcreators.com and the apps we publish. They are not alike. The website collects almost nothing. Lumen is a self-reflection app you share personal reflections with. Agent Hub is a remote control for AI agents that run on your own machines. Each product has its own part below, and the last part — your rights, complaints, age, changes — applies to all of them.
It is written in plain English on purpose. If anything in it is unclear, that is a defect — write and say so.
01 · Website
The website
rubiconcreators.com — the studio's site, including these legal pages.
01
In short
The website has no accounts, no forms, no shopping cart and no comments. It sets no cookies and stores nothing in your browser. It loads nothing from third-party servers — the fonts are served from this domain, not from a font network.
Two things involve your data: the hosting provider keeps ordinary server logs, and privacy-preserving analytics count visits without identifying you. If you email us, the email lands in a mailbox. That is the whole of it.
02
Cookies and browser storage
The website sets no cookies, and there is no cookie banner because there is nothing to consent to. Nothing is written to local storage or session storage either.
That is checked rather than claimed: an automated test loads every page in a clean browser and inspects what it leaves behind.
03
Server logs
The website is hosted on Vercel. Like any web server, it records requests: your IP address, the page requested, the time, the referring page and your browser's user-agent string. These logs exist to keep the service running and to investigate abuse and faults, are held under the host's own retention schedule, and are not used to build a profile of you.
04
Analytics
The website uses Vercel Web Analytics and Vercel Speed Insights. Both are cookieless. They report aggregate figures — how many people viewed a page, how quickly it loaded — rather than the behaviour of an identifiable person, and they do not follow you to other sites.
05
If you email us
The contact link opens your own email program with a message template; nothing is submitted through the website. Your message goes directly to mariiakirpichnikova@gmail.com, a Gmail mailbox, so Google processes it as part of delivering and storing it. If you would rather sign a mutual NDA before sending anything confidential, ask.
We keep business correspondence while we deal with your enquiry and for up to three years afterwards, so we can pick up an old thread. Ask and we will delete it sooner.
06
Why we are allowed to do this
- Server logs and analytics: our legitimate interest in running a working, non-abused site and knowing whether it performs (Article 6(1)(f)). Both are minimal and do not identify you.
- Email: taking steps at your request before a contract (Article 6(1)(b)), or our legitimate interest in replying to people who write to us (Article 6(1)(f)).
Processors for the website: Vercel Inc. (hosting, logs and analytics) and Google (the mailbox).
02 · Apps
Our apps
Each app has its own part. Both are published on the App Store by the same operator, and the policy each app shows in its settings matches its part here.
02.1 · Lumen
Lumen
A self-reflection app: you answer questions about yourself, and it uses AI to build a personal map and gentle insights you can return to.
01
What it is, and what it is not
Lumen is a tool for self-reflection. It is not therapy, not diagnosis, not medical advice, and not a replacement for professional care. The insights it generates are hypotheses, not conclusions about you.
That matters here because the questions invite honest answers — about your goals, relationships and self-esteem, how you are doing with sleep, energy, stress, anxiety and your emotions, and your finances. That content is sensitive, and this part treats it that way.
Lumen is not a crisis service. If you are in crisis, contact a professional, someone you trust, or your local emergency services. The app lists support resources, but it cannot respond to an emergency and does not monitor you for your safety.
02
What it collects
- Your reflections — the answers you write, check-in notes, and the maps, insights and images generated from them. This can include what you tell the app about your health, sleep, stress, emotions and finances.
- An account identifier. You can use the whole app signed in anonymously, with a random identifier and no name attached. Your name and email are collected only if you choose to connect Apple or Google.
- Voice input, if you use it. Audio is sent for transcription and then discarded; it is not saved in the app, in storage or in analytics, and the temporary file is deleted straight after.
- Device and diagnostic data — an installation identifier, a push token if you enable notifications, crash reports, and an app-integrity check that confirms requests come from the genuine app.
- Subscription and purchase state, so the app knows what you have access to.
- Usage analytics — which screens and features are used, and standard app events such as installs, sessions and updates.
03
How your answers are processed by AI
To build your map, Lumen sends your answers to Anthropic, which analyses them and returns the result. Under Anthropic's commercial API terms, inputs and outputs are kept for a limited period — no longer than 30 days — for operational and safety purposes, and are not used to train its models.
OpenAI handles two jobs. It transcribes voice input, transiently. And it draws your map's image from a prompt built out of your map's content — so text derived from your reflections reaches it. Under OpenAI's API terms, requests may be kept for up to 30 days to monitor for abuse, and are not used for training by default.
Both act as our processors. Neither receives your reflections for any purpose other than producing your result.
Because reflections can carry heavy content, the analysis may flag material that suggests distress, so the app can show you support resources. It is a safety feature, not surveillance.
04
Service providers
- Google Firebase — sign-in, database, cloud functions, file storage, push messaging, remote configuration, crash reporting (Crashlytics), app-integrity checks (App Check), and Google Analytics for Firebase.
- Apple and Google sign-in — only if you choose to connect an account.
- PostHog (EU Cloud) — product analytics, hosted in the EU, with session replay and location lookup switched off.
- Adapty and Apple StoreKit — subscription and purchase state.
- Anthropic — analysis of your answers.
- OpenAI — voice transcription and map images.
05
Analytics and tracking
Lumen does not track you across other companies' apps and websites, which is why it shows no App Tracking Transparency prompt. It runs no ad networks, shares nothing with data brokers, and its subscription SDK is configured not to collect your advertising identifier or IP address.
Two analytics tools tell us whether the app works. PostHog records the screens and features you use, hosted in the EU. Google Analytics for Firebase records standard app events such as installs, sessions and updates against an app-instance identifier. Neither is used for advertising.
06
Subscriptions
Some of Lumen is free and some needs a subscription. Apple takes the payment through the App Store and Adapty tracks entitlements for us. We can see what you are entitled to and your purchase history; we never see your card details.
07
Why we are allowed to do this
- Providing the app — your account, generating and storing your maps, running the service: performing our contract with you (Article 6(1)(b)).
- Sensitive answers — where what you share reveals your health or emotional state, we rely on your explicit consent, given when you accept the in-app disclaimer and choose to answer (Article 9(2)(a)). You withdraw it by deleting your data.
- Diagnostics, app integrity and analytics — our legitimate interest in keeping the app working, safe and improving, kept proportionate (Article 6(1)(f)).
You never have to answer a question. You can stop at any point, and delete everything you have written.
08
Where your data is kept, and deleting it
Your reflections, check-ins, maps and images are kept while your account exists, so you can return to them. Deletion is account-wide: Settings → Delete account removes your answers, check-ins, maps and generated images from our database and storage. There is no option to delete a single map on its own.
Copies sent to Anthropic and OpenAI expire under their retention, described above. If you cannot reach the setting, write to mariiakirpichnikova@gmail.com and we will do it for you.
02.2 · Agent Hub
Agent Hub
A remote control for AI agents that run on servers and computers you own or administer.
01
How it works, and what stays on your machine
You install the AgentHub Connector on your machine, and the app talks to it through our relay. Your agents, their memory, your files and the full conversation history stay on your machine. Our servers carry messages between the app and your connector, and keep only what the app needs to show you your systems.
02
What it collects
- An account identifier. The app signs you in anonymously, with a random identifier that has no name or email attached.
- Your systems — the names you give your servers and agents, the permissions you grant, online status, connector version, and the basic host details the connector reports: hostname, operating system and architecture.
- Session metadata — titles, timestamps and status of your agent sessions, so the app can list them.
- Scheduled jobs and skills — the names, schedules and prompts of your agent's scheduled jobs, and the names and descriptions of its skills, mirrored so you can see them while the agent is offline.
- Approval requests — the action an agent asks you to approve, such as a shell command, and its risk level, until you respond.
- Device data — a push token and your notification preferences.
03
Messages and attachments
The messages you send to an agent, and its replies, pass through our relay and Firebase. Those copies are transient: they expire after 60 minutes and an hourly clean-up deletes them. Requests waiting for your connector expire after 10 minutes. Agent memory, workspace files and screen images are fetched on demand and not stored on our servers.
Photos and files you attach are uploaded to storage under your account, downloaded by your connector onto your machine, and deleted from our storage after 7 days. Images and files shown in a conversation — what you sent and what your agent produced — stay in your account's storage so the chat can display them, until you delete your account.
04
AI models
Agent Hub does not send your content to AI providers itself. Your agent runs on your machine and uses the model providers you configured for it, under your own agreements with them. Auto-review, if you turn it on, also runs on your machine, using your agent's own reviewer model.
05
Service providers
- Google Firebase — sign-in, database, cloud functions, file storage, and hosting of the connector downloads. The database is in Google's European multi-region.
- Our relay server, hosted in the Netherlands — carries messages between the app and your connector.
- Expo's push service, Apple Push Notification service and Firebase Cloud Messaging — delivery of notifications. A notification carries your agent's name and a short preview of its reply or of the command it asks to run; you choose which ones you get in Settings → Notifications.
06
Analytics and tracking
Agent Hub runs no analytics at all — no third-party analytics SDK, no ad networks, no data brokers, nothing combining your data with other companies' data. If that changes, this part will say so first.
07
Why we are allowed to do this
- Providing the app — pairing your machines, relaying messages, showing your systems: performing our contract with you (Article 6(1)(b)).
- Security, abuse prevention and keeping the service running: our legitimate interest, kept proportionate (Article 6(1)(f)).
08
Deleting your data
Your systems, session metadata and stored media are kept while your account exists. Settings → Account → Delete account disconnects every server and computer and erases your Agent Hub data from our database and storage. Data on your own machines is not touched.
If you cannot reach the setting, write to mariiakirpichnikova@gmail.com and we will do it for you.
03 · Everything
For all of the above
Your rights, and the rules that apply to the website and both apps alike.
01
International transfers
Some processors are outside the European Economic Area — Vercel, Google, Expo, Anthropic and OpenAI are US-based. PostHog for Lumen is hosted in the EU, and the Agent Hub relay in the Netherlands. Transfers outside the EEA rely on each provider's data processing agreement, which includes the European Commission's standard contractual clauses and, where the provider is certified, the EU–US Data Privacy Framework.
02
Your rights
Under the GDPR you can ask for a copy of your personal data, and ask us to correct it, delete it, restrict what we do with it, or hand it over in a portable format. You can object to processing based on legitimate interest, and where we rely on consent you can withdraw it at any time without affecting what came before.
To use any of these, write to mariiakirpichnikova@gmail.com, or use the controls in the app. We will reply within one month. We will not charge you, and we will not ask you to explain yourself.
If you have only visited the website and never emailed us or used an app, there is nothing tied to you for us to retrieve.
03
Complaints
If you think we have handled your data badly, tell us first — it is usually faster. You also have the right to complain to the Agencia Española de Protección de Datos (AEPD), or to the supervisory authority in the EU country where you live or work.
04
What we do not do
- No advertising networks, no retargeting, no cross-app or cross-site tracking.
- No selling or renting of personal data. Ever, to anyone.
- No sharing of your content beyond the processors named above, and then only to run the service.
- No automated decision-making that produces legal or similarly significant effects about you.
- No marketing email — we do not run a mailing list.
05
Age
The website sells business services and is not directed at children; we do not knowingly collect data about anyone under 14, the age of digital consent in Spain.
Both apps are for adults aged 18 and over and are not directed at children. If you believe a child has used one and given us their data, write to us and we will delete it.
06
Changes
If this policy changes materially, the date at the top changes with it. The apps link to this address, so the version published here is always the current one.