This policy explains what personal data Joblumi processes, why, for how long, and who else receives it. It covers the website joblumi.com and the Joblumi app at joblumi.com/app. It follows the EU General Data Protection Regulation (GDPR) and the German Telecommunications Digital Services Data Protection Act (TDDDG).
1. At a glance
- Your CV is personal data. We use it only to provide the features you ask for. We never sell it and never give it to employers.
- Before you create an account, your answers and drafts stay in your browser. An uploaded CV is read once and not stored by us.
- Your account data is stored in the EU (Cloudflare database with EU jurisdiction).
- AI features run through Anthropic in the USA. Anthropic does not train its models on your data.
- Payments are handled by Link (Stripe), which acts as its own controller.
- Analytics and advertising only with your consent: Google Analytics and the Meta Pixel load only if you agree in the cookie banner (section 4).
- You can download all your data and delete your account at any time on the page “Account” in the app (joblumi.com/app/account).
2. Who is responsible
Controller under Art. 4(7) GDPR:
Nick Schäfer, Joblumi An der Mannsfaust 9, 60599 Frankfurt am Main, Germany Email: hello@joblumi.com
We have not appointed a data protection officer. For all privacy questions, write to hello@joblumi.com. Emails to this address are forwarded by Cloudflare Email Routing to Nick Schäfer’s business mailbox at Google Workspace (section 15).
3. Visiting our website
What happens: When you open a page, your browser sends technical data to our hosting provider Cloudflare: IP address, date and time, page address, referring page, browser type and operating system. Cloudflare needs this to deliver the page and to protect it against attacks.
Where: Cloudflare runs a worldwide network. Your request is answered by a data centre near you. Your account data is stored separately in the EU (section 7).
Error logs: Cloudflare keeps the logs of our service for up to 7 days, so we can find errors. We do not write CV content or email addresses into them.
Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is a secure, working website. Reading technical data from your device for this purpose is strictly necessary (§ 25(2) no. 2 TDDDG).
Cookies and browser storage: The table lists every cookie and every entry in your browser’s storage that joblumi.com uses for sign-in, consent, statistics and marketing. Statistics and marketing cookies are set only after your consent (section 4).
| Name | Provider | Purpose | Duration | Category |
|---|---|---|---|---|
__Secure-better-auth.session_token |
Joblumi | Keeps you signed in (section 7) | 30 days | Necessary |
jl_li_state, jl_li |
Joblumi | Only when you connect LinkedIn: protects against forged replies, then holds your name and email until collected (section 6) | 10 or at most 5 minutes | Necessary |
joblumi_consent (browser storage, not a cookie) |
Joblumi | Stores your choice in the cookie banner and the version of the banner text; after 12 months we ask again | 12 months | Necessary |
_ga |
Tells visitors apart (Google Analytics) | 13 months | Statistics | |
_ga_<ID> |
Keeps the state of a visit (Google Analytics) | 13 months | Statistics | |
_fbp |
Meta | Recognises your browser for ad measurement (Meta Pixel) | 3 months | Marketing |
_fbc |
Meta | Stores the ad click ID, only if you came from a Meta ad | 3 months | Marketing |
4. Analytics and advertising (only with your consent)
We use Google Analytics 4 and the Meta Pixel on our website and, for sign-up and purchase only, in the app, and only if you agree in our cookie banner. In the app, we send only two events, with your consent: account created and pass bought (with price and currency). We never send app content, CVs or job data. Before you agree, neither tool loads and neither sets a cookie. “Accept all” and “Reject all” are equally easy. You can also choose the categories “Statistics” and “Marketing” separately. You can change or withdraw your choice at any time under “Cookie settings” in the footer of every page. Withdrawing does not affect processing that happened before.
Statistics: Google Analytics 4
Provider: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, as our processor (Art. 28 GDPR).
What for: to see which pages people visit, how they find us and where they leave, so we can improve the website.
Data: a pseudonymous ID in a cookie, the pages you view, campaign parameters in the page address (utm), time, referring page, device and browser type, and an approximate location (country, region, city) that Google derives from your IP address. Google Analytics 4 does not store IP addresses. We have switched off Google Signals and do not link Google Analytics with advertising accounts. Google deletes the event data after 2 months.
Transfer: Google may process data in the USA. Google LLC is certified under the EU-U.S. Data Privacy Framework (Art. 45 GDPR).
Marketing: Meta Pixel
Provider: Meta Platforms Ireland Limited, Merrion Road, Dublin 4, D04 X2K5, Ireland.
What for: to measure how well our ads on Facebook and Instagram work and to show our ads to people who visited our website.
Data: cookie IDs, the page you view, actions such as signing up or buying a pass (without the content of your documents), your IP address and browser data. We do not send your email address or phone number to Meta. If you are signed in to Facebook or Instagram, Meta can link this data to your account.
Roles: We and Meta are joint controllers for collecting the data on our website and transmitting it to Meta (Art. 26 GDPR). Our agreement with Meta is the Meta Controller Addendum (facebook.com/legal/controller_addendum). Meta is responsible for answering your rights for this part. You can also contact us to exercise your rights for this part (Art. 26(3) GDPR). For everything Meta does with the data afterwards, Meta is the sole controller under its privacy policy (facebook.com/privacy/policy).
Transfer: Meta may process data in the USA. Meta Platforms, Inc. is certified under the EU-U.S. Data Privacy Framework (Art. 45 GDPR).
Storage: Meta decides how long it keeps this data (see Meta’s privacy policy); the cookies expire as shown in section 3.
Legal basis
Your consent: Art. 6(1)(a) GDPR, and § 25(1) TDDDG for storing and reading cookies on your device. Transfers to the USA are based on the EU-U.S. Data Privacy Framework (Art. 45 GDPR); an appeal against this framework is pending before the Court of Justice of the European Union.
Google Search Console
We use Google Search Console to see how our pages appear in Google search. It sets no cookies on our website. We only receive summary figures from Google, such as search terms and clicks, and no data about you.
5. Cloudflare Turnstile (bot protection)
Before we send a sign-in code and before AI features that work without an account, we check with Cloudflare Turnstile that you are a human. Turnstile reads technical signals from your browser, such as IP address, browser header and TLS fingerprint. Cloudflare uses them to detect bots and, as its own controller, to improve its bot detection.
Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is protecting sign-in and our AI features against automated misuse and cost. Reading these signals is strictly necessary for this protection (§ 25(2) no. 2 TDDDG).
6. Before you have an account
Your answers and drafts stay in your browser
On /start we ask about your goal, target job, experience, languages, preferred cities, applications so far, obstacles, weekly goal and how you heard of us. Until you create an account, your answers are saved only in your browser’s local storage, so you can continue where you stopped. The same applies to a CV or cover letter draft you create without an account, to your settings in the Assessment Trainer and to your language choice. We do not receive this data. You can delete it at any time by clearing your browser data.
Legal basis: Saving in your browser is strictly necessary for the service you asked to use (§ 25(2) no. 2 TDDDG).
If you upload a CV
When you upload a CV (PDF or Word) on /start or on a tool page such as the CV check:
- Our server receives the file and keeps it in working memory only.
- It sends the file to our AI provider Anthropic (section 9), which reads the stations of your CV into fields.
- We send the fields back to your browser. Your browser shows your (G)ATS Score (German ATS Score), the findings and a preview.
- We delete the file. We do not store the original file. Until you create an account, the fields stay in your browser only.
In the app (with an account), reading the file runs in the background. For this, the uploaded file is kept encrypted in Cloudflare R2 in the EU while it is being read. Then we delete it, at the latest after 24 hours. We store the fields we read as your CV in your account (section 8).
Anthropic deletes the file automatically within 30 days (details in section 9).
Legal basis: Art. 6(1)(b) GDPR, because you ask us to check your CV.
Connecting LinkedIn
In the start flow at /start, under “From my LinkedIn profile”, you can click “Connect with LinkedIn”. Your browser then goes to LinkedIn, where you sign in and agree. LinkedIn then sends us, through its “Sign In with LinkedIn using OpenID Connect” interface, your name, email address, a link to your profile photo, your language setting and an ID that only applies to Joblumi. Of these we use only your name and email address, to fill those fields in your CV. We discard the photo link, language and ID straight away. LinkedIn does not share your jobs, education or skills through this interface.
Our server stores none of it: it puts your name and email into a cookie (jl_li) for at most 5 minutes so your browser can collect them after it returns, and deletes the cookie when collected. We use LinkedIn’s access token once and discard it. After that, your name and email stay only in your browser, like your other answers, until you create an account. You can undo this with “Don’t use my LinkedIn data”.
LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland, is itself responsible for the processing at LinkedIn (sign-in, your consent), under its privacy policy. LinkedIn learns that you connect Joblumi.
Legal basis: Art. 6(1)(b) GDPR, because you ask us to start your CV with your LinkedIn details. Connecting is optional; without it you type your name and email yourself.
Free tools on our website
Some tools on our website work without an account.
- Run only in your browser: the CV check (format and readability), the German level test, the CV photo check, the salary calculator, the cover letter layout and the online assessment practice test. What you enter stays in your browser and is not sent to us.
- CV in German: we send only the text of your CV to our AI provider Anthropic (section 9). Photos and other images in your file are never sent. A scanned PDF without text is not read at all. We store neither your file, nor its text, nor the result. The result stays only in this browser tab, for at most 2 hours.
- Job ad analyzer: we remove email addresses and phone numbers from the ad before the AI reads it. We store nothing.
- Limits against misuse: we count requests per connection and per network for one day. We store only a code made with a key that changes every day, never your IP address (see also section 7).
- Continue in the app: if you take a result into the app, it goes with you in your browser. We save it only when you have an account and confirm it in the app, for example with “Use this CV”, “Add this job to my board”, “Add German B2 to my CV”, “Use this photo in my CV”, “Use the grey background” or “Compare this offer”. Without this click, the result stays only in your browser tab and expires as described above.
Legal basis: Art. 6(1)(b) GDPR, because you use the tool at your request. Limits against misuse: Art. 6(1)(f) GDPR, our legitimate interest is protecting the tools against misuse and cost.
Contact form
If you use our contact form, your message goes by email to hello@joblumi.com. We do not store it in our database. It is handled like any email to us (section 17). Legal basis: Art. 6(1)(b) GDPR if your message is about a contract, otherwise Art. 6(1)(f) GDPR, our legitimate interest is answering you.
Campaign source
If you came via an ad or a partner link, the link may contain a campaign code (UTM parameters) and the page you came from. We keep this only in the memory of the open page. If you create an account, we save it with your profile. This tells us which channels bring people who find Joblumi useful.
Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is measuring our marketing without tracking cookies.
7. Your account
Sign-up: You sign up with your email address and a 6-digit code that we send you. We do not use passwords.
Data: email address, name (if you give it), your questionnaire answers and the time you created the account.
Sign-in cookie: After you sign in, we set the cookie __Secure-better-auth.session_token. It keeps you signed in for 30 days. It is strictly necessary for the account you asked for (§ 25(2) no. 2 TDDDG).
Session record: For each sign-in, our sign-in software stores the session with its validity and your browser identifier (user agent). We do not store your IP address with it. We use this to keep sessions secure.
Signed-in devices and account sharing. For each sign-in we store the time and the browser and device type that your browser sends (user agent). We do not store your IP address for this. We use these data to show you your signed-in devices, to sign you out on the oldest device if you are signed in on more than 3, and to send you an email when you sign in on a new device. We also count how many new sign-ins an account has in a short time. If the number is unusually high, a person at Joblumi looks at it; we never block an account automatically, and we write to you first (terms, section 3.5). Legal basis: our contract with you (Art. 6(1)(b) GDPR) and our legitimate interest in keeping accounts secure and personal (Art. 6(1)(f) GDPR). We delete sign-in data when the session ends, at the latest after 30 days, and the counts after 30 days. If we have sent you a warning, we keep a record of it for 12 months. You can object to this processing (Art. 21 GDPR).
Limits for sign-in codes: To stop misuse, we count how many codes are requested for an email address. We store only a hashed (SHA-256) form of the address, for a short time.
Protecting the free plan: To stop people from using the free plan with many accounts, we take four steps. The first two happen when you request a sign-in code, the others when you create an account:
- We check the domain of your email address against a list of disposable email services that we keep on our own server. If the domain is on the list, we do not send a code. We store nothing extra for this.
- Cloudflare Turnstile checks that you are a human (section 5).
- We compare your email address with the addresses of other accounts, in lower case and without a +suffix (for Gmail also without dots). If an account for the same mailbox already exists, for example kim@… and kim+2@…, the new account gets no free AI runs. We store nothing extra for this.
- From your IP address, shortened to its network (IPv4 /24, IPv6 /64), and a secret key, we create a code (HMAC). We create a new random key every day and delete it after that day. Only while the key exists could we tell which network a code belongs to. After that, nobody can, not even us. We store only this code with a count of how many new accounts from this network got the free AI features that day. We do not store your IP address. We delete the count after about one day.
From the sixth new account from the same IPv6 network (/64), or from the twenty-first new account from the same IPv4 network (/24), on the same day, the new account gets no free AI runs, including Ask Lumi. We note this in the account. The account itself works as usual, and a pass unlocks everything. For our own overview we keep only totals of how many networks had one, two, three or more new accounts on a day. We do not see the codes.
Shared networks: Offices, universities and mobile networks often share one network among many people. If your new account got no free AI runs although you created only this one account, write to hello@joblumi.com from the email address of your account. We check it by hand and unlock your free runs.
Where: Cloudflare D1 database, created with EU jurisdiction, so the data is stored in the EU.
Legal basis: Art. 6(1)(b) GDPR (contract for using Joblumi). Session record, code limits and protecting the free plan: Art. 6(1)(f) GDPR, our legitimate interest is a secure service and protecting the free plan against misuse and cost. You can object to this (section 18).
8. Using the app
What we store in your account:
| Data | What for |
|---|---|
| Your CVs (as structured data, including a photo if you add one) and cover letters | Editor, PDF and Word export |
| Older versions of each CV (the last 10) and the history of your (G)ATS Score (score and time) | Restoring “Earlier versions”, the curve on the score page |
| Jobs you add: title, company, city, ad text, status, dates, notes, salary, and our analysis of the ad | Job versions, language check, board |
| Interview material: likely questions, your self-introduction, your stories, interview-day notes, your answers in the Mock Interview Trainer with its feedback | Interview preparation |
| Offers, salary wishes, negotiation texts, follow-up and rejection notes you save | Offer and follow-up features |
| Assessment Trainer: tasks you answered, your answers, time per task, results | Practice and your progress |
| (G)ATS Score results and findings | Showing and fixing issues |
| Pass details: type, start and end, amount, payment reference, a characteristic of your payment method (section 11), refunds | Unlocking the pass, money back, withdrawal |
| Consent records: what you agreed to, text version, time | Proof (Art. 7(1) GDPR) |
| Usage counters per day and feature | Free limits and fair use |
| Progress: points, level, streak, daily tasks, badges | Streak and rewards in the app |
| Events, for example “score shown”, “app opened” (at most once a day) or “pass bought”, without free text and without IP address. After a withdrawal we ask, optionally, what was missing; you pick from fixed reasons, and we store only the reason you picked, no free text | Seeing where people get stuck, who comes back, improving the product |
| Your vote on an AI answer (thumbs up or down): type of answer, a reference to the item (for example the job), time, no text | Checking the quality of our AI features |
| Your email settings (section 12) | Sending only the emails you want |
| Time of your last sign-in | Deletion after 12 months without sign-in (section 17) |
Photo and other optional fields: A photo, date of birth, nationality or marital status are not required in a German CV. These fields are optional. When we send your saved CV to the AI, we leave out the photo. Please do not add data about health, religion, political views, trade union membership or sexual orientation to your documents. Joblumi does not need them. Data about other people: If your documents name other people, for example a reference or the contact person in a job ad, you are responsible for being allowed to use their data. We process it only to create your documents.
PDF export: We create PDFs with Cloudflare Browser Rendering. Your document is processed for a few seconds and not stored there.
Legal basis: Art. 6(1)(b) GDPR for all features. Events, withdrawal reason and votes on AI answers: Art. 6(1)(f) GDPR, our legitimate interest is improving the product. Last sign-in: Art. 6(1)(f) GDPR, our legitimate interest is not to keep unused accounts forever. Consent records: Art. 6(1)(c) GDPR with Art. 7(1) GDPR.
Voice input
Text fields in the app have a microphone button. After a short notice and only when you click it, the app uses your browser’s built-in speech recognition. For this, your browser sends the audio to its own provider (Google for Chrome, Apple for Safari, Microsoft for Edge), under that provider’s privacy terms. Joblumi receives only the resulting text, never the audio.
Following employers
If you follow a company, we store which companies you follow in your account. We use this only to check these companies’ new jobs and to tell you about them in the app and by email. We never tell a company that you follow it, and we don’t use your list for anything else. Legal basis: our contract with you (Art. 6(1)(b) GDPR). You can unfollow a company or change or stop the emails at any time under “Alerts” and with the link in each email. We delete your list when you delete your account.
To check for new jobs, we fetch the companies’ public job lists once a day, without any data about you. We store only job title, location, link and date, and no names of contact persons (see also joblumi.com/bot).
Contact persons in job ads
When you add a job ad to your board, it can contain the name and contact details of a contact person at the company. We store this only in your board, so you can prepare your application and follow up. Nobody else sees it, and we don’t use it for anything else. Legal basis: Art. 6(1)(f) GDPR (your and the company’s interest in handling the application). Because this data comes from a published job ad and is used only in your board, we don’t inform each contact person separately (Art. 14(5)(b) GDPR). It is deleted with the job or your account.
Company briefing
With a pass, you can ask for a briefing on the company behind a job ad. Our fetcher JoblumiBot reads up to 5 public pages of that company’s website. We send the page text to our AI provider Anthropic (section 9) to write the briefing, and we don’t store the page texts. For you only, we store the page addresses and titles and the statements in the briefing, each with a short quote from the company’s page. We delete them after 30 days, or earlier with the job or your account.
The pages can name people. The briefing names only the managing directors or other company leaders, and the contact person named in the job ad, with name and job title only. It doesn’t name other employees, and it doesn’t use photos or private details. Legal basis: Art. 6(1)(f) GDPR. Our and your legitimate interest is preparing for an interview with information the company has published itself. People named on these pages are not informed individually, because that would take disproportionate effort (Art. 14(5)(b) GDPR). They can object or ask for deletion at any time: hello@joblumi.com. Details on JoblumiBot: joblumi.com/bot.
Browser extension (Chrome)
Our Chrome extension works only when you click its icon or press Alt+Shift+J, and only on the tab you have open. It reads nothing in the background and has no access to other tabs or to your browsing history.
- Save to Joblumi: After your click, the extension reads the text of the job ad on that page. If you marked text on the page, it reads only that text. On LinkedIn, Indeed and StepStone it reads only the ad you opened; if it cannot find the ad there, it reads nothing and asks you to mark the text. On other sites, such as careers pages, it reads the main part of the page if it cannot find the ad, and otherwise the visible text of the page, in both cases without forms, drop-down lists, cookie notices, menus and the page footer. It offers saving only if the text looks like a single job ad. When you press “Save to Joblumi”, it sends this text and the page address (without tracking parts) to your account. Nothing else from the page is sent. If the text is not a job ad, we do not store it. Otherwise we store the job on your board like a job you add in the app (table above, AI analysis as in section 9). If the ad names a contact person, the section “Contact persons in job ads” applies.
- Already saved: After your click, the extension automatically sends the page address to your account and gets back only the status of your own card, to show whether you already saved this job.
- Quick check: If you press “Check my fit for this ad”, we compare the saved job with your CV, as in the app (section 9).
- Fill this form: If you press “Fill this form”, the extension loads your Joblumi CV. It fills only your name, email, phone, city, LinkedIn profile and, where the form has a date field for it, your earliest start date into empty fields of the form on that page. In drop-down lists it picks only the country code, country, city, notice period and earliest start date (also as a date or month), and only from your CV and the values you set in your profile; it never answers other questions or gives consents for you. If the form has a CV upload field, Joblumi creates your CV as a PDF (section 8, PDF export) and the extension attaches it. The PDF contains your whole CV, including a photo if you added one. The extension never submits the form: you check it and send it yourself. Nothing from the form is sent to Joblumi. What you send goes to the employer or its application portal, under their privacy terms.
We offer the extension in the Chrome Web Store, run by Google Ireland Limited. When you install or update it, Google processes data as its own controller, under its privacy policy (policies.google.com/privacy). From Google we receive only aggregated statistics, such as the number of installs.
The extension talks only to joblumi.com. After you sign in to Joblumi, it gets its own sign-in key once, valid for 30 days and only for the extension’s functions; we store only a fingerprint (hash) of this key. Signing out in the app, “Sign out everywhere” and deleting your account revoke it. Until it has this key, it uses your Joblumi sign-in (the sign-in cookie, section 7). When you open the side panel, it checks with your account whether you are signed in, have a pass and which app language you chose. The text it reads stays only in the open side panel until you save it. The extension contains no tracking and no advertising and loads no code from outside its package. In your browser it stores only its setting (which Joblumi address it uses), its sign-in key, your app language and, until you close the browser, which tab you clicked.
Data from the extension is used only to provide the features described here. We do not sell it, do not use it for advertising or credit checks, and do not pass it on except to the processors named in section 15. No person at Joblumi reads it, unless you ask us to, or for security or legal reasons. Joblumi’s use of this data adheres to the Chrome Web Store User Data Policy, including the Limited Use requirements. All transfers use an encrypted connection (HTTPS).
Legal basis: Art. 6(1)(b) GDPR, for contact persons in ads Art. 6(1)(f) GDPR (see above). Reading the page and the entries the extension keeps in your browser are strictly necessary for the function you asked for (§ 25(2) no. 2 TDDDG). You can remove the extension at any time under chrome://extensions. This also deletes its entries in your browser. Jobs you saved stay in your account until you delete them.
9. AI features (Anthropic)
Which features use AI: reading an uploaded CV, the content and language part of the (G)ATS Score, the language check and the analysis of job ads, “Improve with AI”, translation between English and German, job versions of your CV, cover letters, likely interview questions, the company briefing, your self-introduction, the feedback of the Mock Interview Trainer, Ask Lumi, and the other writing aids in the app. Every AI text is marked “Written with AI support”. The format and readability part of the (G)ATS Score and the tasks of the Assessment Trainer run without AI on your data: the tasks are prepared in advance, and your answers are checked by our own code.
Same document, same score: So that the same document always gets the same (G)ATS Score, we store a checksum of its content together with the rating levels from the AI. We store no text and no link to your account, and we delete this after 90 days. For Job match the same applies to a job ad and a CV: we store a checksum of both, together with the requirement lines the AI found in the job ad and their levels (shown, partly, missing). We store no CV text and no link to your account, and we delete this after 90 days.
What is sent: the content needed for the task, for example your CV and the job ad. Your CV usually contains your name and contact details. We do not send your account email or account ID separately. If you translate a CV, its texts go to the AI. If you paste a sample cover letter as a model, its text goes to the AI too; we do not store the sample.
Ask Lumi: Your message to Lumi goes to Anthropic together with the details from your account that it needs (for example your jobs and your next step). So that you can continue a conversation, we store the last 40 messages at Cloudflare in the EU. “New chat” clears the history; it is deleted with your account. It is part of “Download all my data”.
LinkedIn profile check: The text you paste from your LinkedIn profile is first checked only in your browser. Only when you ask for suggestions is it sent to Anthropic. We do not store it, and we never access LinkedIn ourselves.
Provider: Anthropic Ireland, Limited, which acts as our processor under a data processing agreement (Art. 28 GDPR). Anthropic processes the data in the USA. An EU processing location is not available.
Transfer to the USA: based on the EU Standard Contractual Clauses (Art. 46(2)(c) GDPR), which are part of Anthropic’s data processing agreement.
No training: Anthropic’s commercial terms do not allow Anthropic to train its models on our customers’ content.
Storage at Anthropic: Anthropic deletes inputs and outputs automatically within 30 days. If its automated safety systems flag content as a breach of its usage policy, Anthropic may keep it for up to 2 years.
Our gateway: On our live service, AI requests pass through Cloudflare AI Gateway. Logging is switched off in the gateway: it stores neither the content nor any other record of the requests. We count our daily limits in our own database.
Check every result: AI can make mistakes. Check every line before you send it.
Legal basis: Art. 6(1)(b) GDPR.
10. No automated decisions about you
Joblumi makes no decisions about you that have legal effects or similarly significant effects (Art. 22 GDPR). The (G)ATS Score rates a document against published rules. The Assessment Trainer and the Mock Interview Trainer rate your practice answers for you. These are suggestions for you, not decisions about you. We do not pass scores or results to employers or anyone else. You decide what you send. If a new account gets no free AI runs because of the network limit (section 7), this concerns only a free extra, and you can ask us to check it by hand.
11. Buying a pass (Stripe and Link)
How it works: Passes are sold through Stripe Managed Payments. Sold Through Link, LLC, a Stripe company (“Link”), acts as reseller. You pay on a checkout page run by Stripe.
What we send to Stripe: your account ID, your email address and the pass you chose.
What Stripe and Link collect themselves: your payment details, billing country and further data they need for payment, tax, fraud prevention and receipts. For payments from Europe, the transaction is processed by Stripe Technology Europe, Limited (Ireland). Stripe and Link act as their own controllers for this data. Their privacy policy applies: stripe.com/privacy.
What we receive back: whether the payment succeeded, the amount, a payment reference, refund or dispute notices, and a characteristic of your payment method that Stripe provides (for cards a fingerprint). It does not reveal your card number. We never receive your full card number.
Why we store the payment characteristic: Our money-back promise gives the full price back once per account and once per payment method (see our Terms, section 7). We use the characteristic only to check this limit. Legal basis: Art. 6(1)(f) GDPR, our legitimate interest is preventing misuse of a voluntary promise.
We do not store any payment method. If you choose to save your details in a Link account, that is between you and Link.
Legal basis: Art. 6(1)(b) GDPR.
If you withdraw: we store your name, the email address you bought with, the order number if you give it, the time of your withdrawal and the confirmation we sent you. We keep this record as proof, also after you delete your account, and delete it 3 years after the end of the year of your withdrawal. Legal basis: Art. 6(1)(c) and (f) GDPR (proof of the withdrawal against claims, limitation period under §§ 195, 199 BGB); it is exempt from erasure under Art. 17(3)(e) GDPR.
If you cancel: when you cancel on our cancellation page (/cancel), we store your name, the email address you bought with, the order number and the reason if you give them, the end date you ask for, the language and the time we received your cancellation. We keep this record as proof under § 312k BGB, also after you delete your account, and delete it 3 years after the end of the year we received it. Legal basis: Art. 6(1)(c) and (f) GDPR. We send the confirmation to the email address you entered, at most 2 per address and day; for this count we store the address only in hashed form.
12. Service emails
We send emails that belong to the service through Cloudflare Email Service (our processor):
- sign-in codes,
- purchase confirmation with contract details and withdrawal information,
- confirmation of a refund, withdrawal or cancellation,
- confirmation that your account was deleted,
- an email after you create your account saying your plan is saved,
- confirmation codes for deleting your account and for changing your email address (one code to the old and one to the new address; valid for 10 minutes; we store only a hash),
- an email when you sign in on a new device (section 7),
- a message if a payment did not go through,
- notices before your pass ends (at most two, in its last 5 days, with how to add more days) and that it has ended, unless you switch off “Your pass is ending” in your settings,
- with the 90-day pass, your progress in numbers on day 30 and day 60,
- a warning before we delete an account after 12 months without sign-in (section 17),
- only if you switch them on: a reminder of your next step (at most one a day, none if you have already been in Joblumi that day) and a weekly review on Sundays,
- alerts about new jobs at companies you follow, if you turned them on (no advertising),
- a weekly reminder for followed companies we can’t check automatically, if you turned it on (no advertising).
Your email settings. In your settings you switch the reminder, the weekly review, “Your pass is ending” and the emails about followed companies on or off. The reminder and the weekly review stay off until you switch them on. We store your choice with the time of the last change until you delete your account. None of these emails contain advertising.
Weekly reminder. Some companies don’t offer a public job feed, so Joblumi can’t check them. If you switch on “Weekly reminder for employers without alerts” (off by default), we send you one email a week, always on the same weekday, with links to the official careers pages of these companies. The email contains only the company names, the links, why you get it and links to stop or manage it. No ads, no offers. We send nothing if you don’t follow such a company. If you don’t click a link for 8 weeks, we ask once whether you want to keep the reminder, otherwise we switch it off. You can turn it off with one click in every email, without signing in, or in your settings. To prove your choice, we store when you switched the reminder on and off and which version of the setting text you saw. Legal basis: our contract with you (Art. 6(1)(b) GDPR); for the record, our legitimate interest in being able to prove your choice (Art. 6(1)(f) GDPR).
Legal basis: Art. 6(1)(b) GDPR. Purchase, withdrawal and cancellation confirmations are also legal duties (Art. 6(1)(c) GDPR; §§ 312f, 312k, 356a BGB).
13. Newsletter
Only with your consent: You can sign up on our newsletter page or tick “Send me job-search tips by email” when you create your account. We then store your email address, the date and time and where you signed up (for example the newsletter page or a link from one of our social media messages). Before you receive the first newsletter, we send you a confirmation email (double opt-in). Only after you confirm do you receive a welcome series (7 emails in the first 14 days) and then one newsletter a week.
Provider: We send the newsletter with Brevo (Sendinblue group, France) as our processor (Art. 28 GDPR), with data stored in the EU. Brevo also sends the confirmation email and stores the proof of your confirmation.
Measuring opens and clicks: With your newsletter consent you also agree that we measure whether you open our emails and which links you click. For this, each email contains a tiny invisible image that is loaded when you open it, and the links first go through Brevo (em.joblumi.com). We see this per recipient and use it to find out which topics help and to stop sending to addresses that never open our emails. Legal basis: your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG). If you only want the emails without this measurement, you can block images in your email program; links then still go through Brevo. Unsubscribing ends the measurement.
Unsubscribe: every newsletter has an unsubscribe link. You can also write to hello@joblumi.com. After you unsubscribe, we keep your email address on a block list and the proof of your consent for up to 3 years, so we can respect your choice and prove that you had agreed.
Legal basis: Art. 6(1)(a) GDPR. You can withdraw your consent at any time with effect for the future (Art. 7(3) GDPR). Block list and proof: Art. 6(1)(f) GDPR.
14. Offers to customers
If you buy a pass, we may email you about our own similar products, for example a new pass, even without newsletter consent (§ 7(3) of the German Unfair Competition Act, UWG). You can object at any time with the link in every such email or by writing to hello@joblumi.com. This costs nothing beyond the usual transmission costs.
Once we start such emails, we add your email address to Brevo (section 13) for this, together with whether your pass is running and how many days it has. When your pass ends, we note that there.
Legal basis: Art. 6(1)(f) GDPR. Our legitimate interest is direct marketing to our customers.
15. Who receives your data
| Recipient | Role | What for |
|---|---|---|
| Cloudflare, Inc., 101 Townsend St., San Francisco, CA 94107, USA | Processor (Art. 28 GDPR); for improving Turnstile own controller | Hosting, database in the EU, file storage (R2), AI Gateway, PDF creation, service emails, forwarding of emails to hello@joblumi.com (Email Routing), Turnstile |
| Anthropic Ireland, Limited | Processor (Art. 28 GDPR) | AI features |
| Sold Through Link, LLC and Stripe group companies | Own controllers | Payment, tax, receipts, payment support |
| Google Ireland Limited (Google Workspace) | Processor (Art. 28 GDPR) | Mailbox for emails to hello@joblumi.com and replies |
| Google Ireland Limited (Google Analytics 4) | Processor (Art. 28 GDPR) | Website statistics, only with your consent |
| Meta Platforms Ireland Limited | Joint controller for collection and transmission (Art. 26 GDPR), then own controller | Ad measurement, only with your consent |
| LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland | Own controller | Only if you use “Connect with LinkedIn” in the start flow: sign-in at LinkedIn, sending your name and email to us (section 6) |
| Brevo (Sendinblue group), France | Processor (Art. 28 GDPR) | Newsletter and offers to customers, once we start them |
| Hetzner Online GmbH, Gunzenhausen, Germany (stored in Falkenstein) | Processor (Art. 28 GDPR) | Encrypted backup of our database and uploaded files, at most 30 days; Hetzner never holds the key |
We never sell your data and never pass it to employers, recruiters or data brokers. We disclose data to authorities only if the law requires it.
16. Transfers outside the EU
| Provider | Country | Basis for the transfer |
|---|---|---|
| Cloudflare | USA (stored data stays in the EU; requests are handled worldwide) | EU-U.S. Data Privacy Framework (Art. 45 GDPR); Standard Contractual Clauses as fallback |
| Anthropic | USA | Standard Contractual Clauses (Art. 46(2)(c) GDPR) |
| Stripe and Link | USA, among others | EU-U.S. Data Privacy Framework, according to Stripe’s privacy policy |
| Google (Workspace) | EU, transfers to the USA possible | EU-U.S. Data Privacy Framework; Standard Contractual Clauses as fallback |
| Brevo | EU | no transfer |
| processes under its own responsibility, also in the USA | under LinkedIn’s privacy policy; from Joblumi only the sign-in request goes there | |
| Google (Analytics) and Meta (Pixel) | USA possible | EU-U.S. Data Privacy Framework (Art. 45 GDPR) |
The European Commission has decided that the USA ensures an adequate level of protection for companies certified under the EU-U.S. Data Privacy Framework (adequacy decision of 10 July 2023). You can request a copy of the Standard Contractual Clauses from us.
17. How long we keep data
| Data | How long |
|---|---|
| Answers, drafts and settings in your browser | until you create an account or clear your browser data |
| Name and email from LinkedIn | with us at most 5 minutes in the cookie jl_li, then only in your browser or account |
| Uploaded CV file | without an account not stored by us; in the app until reading is finished, at the latest 24 hours; at Anthropic up to 30 days (up to 2 years if flagged, section 9) |
| Account and everything in it (documents, jobs, interview and assessment data, pass details, consent records) | until you delete your account. If you don’t sign in for 12 months, we email you; 30 days later we delete the account |
| Company briefing (page addresses, titles, statements with quotes) | 30 days, or earlier with the job or your account |
| Withdrawal record (name, purchase email, order number if given, time, confirmation) | 3 years after the end of the year of the withdrawal, also after account deletion |
| Cancellation record (name, purchase email, order number and reason if given, end date, language, time) | 3 years after the end of the year it was received, also after account deletion |
| Database history (Cloudflare D1 Time Travel) | 30 days, then overwritten |
| Events | as long as your account exists; when you delete it, we remove the link to you. Events without a link to an account are deleted after 14 months |
| Older versions of a CV | the last 10, until you delete the CV or your account |
| Ask Lumi history | the last 40 messages, until you start a new conversation or delete your account |
| Votes on AI answers, email settings, last sign-in | until you delete your account |
| Confirmation codes (hash only, valid for 10 minutes) | for deleting the account: until the next daily clean-up after expiry; for changing the email address: until you use the code or request a new one |
| Backups of the database and files | at most 30 days |
| Hashed email in the sign-in code limit | a short time |
| Sign-in data (time, user agent) | until the session ends, at most 30 days |
| Count of new sign-ins | 30 days |
| Warning record (account sharing) | 12 months |
| Network code with a count of new accounts (protecting the free plan) | about one day; the daily key is deleted after the day |
| Score memory (checksum of a document and its rating levels, no text, no link to your account) | 90 days |
| Server logs | up to 7 days |
| Companies you follow | until you unfollow or delete your account |
| Job list of followed companies (title, location, link, date) | until 30 days after the job is no longer listed |
| Weekly reminder: record of switching it on and off (time, text version) | as long as the feature or your account exists, then 3 years after the end of that year, blocked for any other use |
| Google Analytics event data | 2 months; cookies as in the table in section 3 |
| Meta Pixel data | Meta decides how long it keeps it; cookies as in the table in section 3 |
| Newsletter wish and consent | until you unsubscribe; block list and proof up to 3 years after that |
| Opens and clicks in our emails | until you unsubscribe, at most 2 years |
| Emails to us and contact form messages | until the matter is settled, unless records must be kept longer |
When you delete your account, we delete all data in your account at once. We keep only the records of your passes, your consents (for example to start the pass at once), refunds, withdrawals and the on/off record of the weekly reminder, blocked for any other use, to prove our contracts and to apply the once-per-account limit of the money-back promise (Art. 6(1)(c) and (f) GDPR). We delete these records 3 years after the end of the year in which you delete your account. Stripe and Link keep their own payment records under their own legal duties. After 30 days the other deleted data is also gone from the database history.
18. Your rights
You have the right to:
- access your data and receive a copy (Art. 15 GDPR),
- have incorrect data corrected (Art. 16 GDPR),
- have your data deleted (Art. 17 GDPR),
- restrict processing (Art. 18 GDPR),
- take your data with you in a common machine-readable format (Art. 20 GDPR),
- withdraw consent at any time with effect for the future (Art. 7(3) GDPR).
Most of this you can do yourself on the page “Account” in the app: “Download all my data” gives you a file with all your data (JSON). “Delete my account” deletes your account at once. For anything else, write to hello@joblumi.com. We may ask you to confirm your identity first, for example from the email address of your account.
Your right to object (Art. 21 GDPR)
Where we process your data based on our legitimate interests (Art. 6(1)(f) GDPR), you can object at any time for reasons arising from your particular situation. We will then stop, unless we can show compelling legitimate grounds that override your interests, or the processing serves legal claims.
You can object to direct marketing at any time, without giving reasons. We will then stop using your data for this purpose.
To object, write to hello@joblumi.com or use the link in the email.
19. Right to complain
You can complain to a data protection supervisory authority, in particular in the EU country where you live or work or where you think the breach took place (Art. 77 GDPR). The authority responsible for us is:
The Hessian Commissioner for Data Protection and Freedom of Information Postfach 3163, 65021 Wiesbaden, Germany poststelle@datenschutz.hessen.de
20. Do you have to give us data?
You can read our website and use the start questionnaire without giving us any personal data. To create an account, you need an email address. A CV, photo and the other details are voluntary, but some features don’t work without them. Without an account you can’t download documents or buy a pass.
21. Minimum age
Joblumi is for people aged 16 and over. We do not knowingly process data of children under 16.
22. Security
We use encrypted connections (TLS). Keys of our services are stored as protected secrets and never in our code. We use two-factor sign-in for all provider accounts. AI providers treat your CV and job ads as data, not as instructions. We do not write CV content or email addresses into our logs.
23. Changes to this policy
We update this policy when our services or the law change. The date at the top shows the current version. If a change affects how we use data you have already given us, we inform you by email before it takes effect.
24. Language versions
This policy exists in English and German (Datenschutzerklärung). Both have the same content. If they differ, the version in the language in which you use Joblumi applies: German if the app is set to German, otherwise English.