Privacy Policy

The Lumio Teams ("we," "us," or "our") operate the Lumio mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our App.

By using Lumio, you agree to the collection and use of information in accordance with this policy. If you do not agree, please do not use the App.

1. Information We Collect

1.1 Information You Provide

• Account Information: When you sign in with Apple, we receive your Apple ID user identifier and, if you choose to share it, your name and email address. Apple may provide a private relay email address on your behalf.
• Photos: You upload photos to generate AI-styled images. These photos are processed by our AI systems and third-party AI service providers to create your content.
• Feedback: Ratings, tags, and optional text you submit about generated content.

1.2 Information Collected Automatically

• Device Information: Device model, operating system version, unique device identifiers, and language settings.
• Usage Data: Features used, styles selected, generation history, session duration, and interaction patterns.
• Purchase Data: Records of subscriptions and in-app purchases made through Apple's payment system.
• Analytics: We use analytics tools to understand App usage and improve our service.

1.3 Information We Do NOT Collect

• We do not collect precise geolocation data.
• We do not access your contacts, calendar, or microphone.
• We do not read your photo library beyond the photos you explicitly select and upload.

• Provide Services: Process your photos through AI models to generate styled images and videos.
• Account Management: Create and maintain your account, manage credits and subscriptions.
• Improve the App: Analyze usage patterns and feedback to improve AI quality, add new styles, and enhance user experience.
• Customer Support: Respond to your requests and resolve issues.
• Safety & Security: Detect and prevent fraud, abuse, or violations of our Terms of Service.
• Communications: Send service-related notifications (e.g., subscription renewal reminders). We do not send marketing emails without your consent.

We do not sell your personal information. We may share information with:

• AI Service Providers: Your uploaded photos are sent to third-party AI model providers for image and video generation. These providers process photos solely for this purpose and are contractually bound to protect your data.
• Cloud Infrastructure: We use cloud hosting providers to store and process data securely.
• Analytics Providers: Anonymized usage data may be shared with analytics services to help us understand and improve the App.
• Legal Requirements: We may disclose information if required by law, regulation, legal process, or governmental request.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, your information may be transferred as part of the transaction.

Your photos are central to our service. Here is how we handle them:

• Photos you upload are transmitted securely (encrypted in transit) to our servers and third-party AI providers.
• Uploaded photos are used solely to generate your requested AI content.
• We do not use your photos to train AI models without your explicit consent.
• Generated images and videos are stored on our servers for 30 days, during which you can view, save, or share them. After 30 days, generated content is automatically and permanently deleted from our servers.
• We strongly recommend saving any content you wish to keep to your device before the 30-day period expires.
• When you manually delete a creation, it is removed from our servers immediately. Original uploaded photos are not retained after processing is complete.

Lumio processes photos that contain human faces. We want to be transparent about how facial data is handled:

5.1 What We Process

• When you select a photo, the App performs a face detection check entirely on your device using Apple's built-in Vision framework. This check determines only whether a face is present and sufficiently clear; it does not identify who you are. No facial data from this step is sent to our servers or any third party.
• Only after passing the on-device face check, your photo (including your facial features) is sent to third-party AI service providers to generate styled images. The AI uses your facial appearance to produce the output image.

5.2 What We Do NOT Do

• We do not extract, store, or create biometric identifiers, facial geometry maps, or faceprints from your photos.
• We do not use facial recognition technology to identify individuals.
• We do not compare your face against any database of faces.
• We do not build profiles based on facial features.
• We do not sell, lease, or trade any facial data to third parties.

5.3 Retention of Facial Data

• Your original uploaded photos (including facial data) are not retained on our servers after AI processing is complete.
• Our third-party AI service providers are contractually required to delete your photo data immediately after processing and are prohibited from retaining, copying, or using your photos for any other purpose, including model training.

5.4 Your Consent

By uploading a photo and tapping "Create," you provide your informed consent for us and our AI service providers to process your facial image solely for the purpose of generating your requested AI content. You may withdraw consent at any time by ceasing to use the service and requesting account deletion.

If you upload a photo of another person, you represent and warrant that you have obtained that person's explicit consent for their facial image to be processed by our AI service.

5.5 Illinois / BIPA Notice

If you are a resident of Illinois or any jurisdiction with biometric information privacy laws: Lumio does not collect, capture, or otherwise obtain biometric identifiers or biometric information as defined under the Illinois Biometric Information Privacy Act (BIPA) or similar laws. The face detection check used by the App determines only the presence and clarity of a face in a photo and does not extract facial geometry, measurements, or templates that could be used to identify a specific individual.

• Account Data: Retained as long as your account is active. You may request deletion at any time.
• Generated Content: Stored on our servers for 30 days from creation, then automatically deleted. You may also delete it manually at any time.
• Uploaded Photos: Not retained after AI processing is complete.
• Analytics Data: Retained in anonymized form for up to 24 months.

We implement industry-standard security measures including encryption in transit (TLS) and at rest, access controls, and regular security assessments. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

Depending on your jurisdiction, you may have the following rights:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate data.
• Deletion: Request deletion of your account and associated data.
• Portability: Request your data in a portable format.
• Opt-Out: Opt out of analytics data collection through your device settings.

To exercise any of these rights, contact us at the email address below.

Lumio is not intended for children under 13 (or the minimum age required in your jurisdiction). We do not knowingly collect personal information from children. If we become aware that we have collected data from a child, we will delete it promptly. If you believe a child has provided us with personal data, please contact us.

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. By using the App, you consent to such transfers. We ensure appropriate safeguards are in place for cross-border data transfers.

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy in the App and updating the "Last Updated" date. Your continued use of the App after changes constitutes acceptance of the revised policy.

If you have questions about this Privacy Policy or wish to exercise your data rights, please contact us:

Email: support_lumio@thematrixapp.com