Introduction
Luma AI Ltd. and its related entities (“Luma AI”, “we”, “our” or “us”) provide the websites located at https://luma.ai/ (“Website”) and all of their subdomains, subpages and successor sites thereof through which the Luma AI Services are provided (together – the “Services”).
Luma AI is dedicated to protecting your privacy rights and making our practices regarding your personal data more transparent and fairer. Please read this policy, as it includes important information in respect of your personal data.
This Privacy Policy (“Policy”) is designed to help you understand how we collect, store, use and share your personal data. This Policy applies whenever you visit our Website or otherwise access or use any of our Services.
We strongly urge you to read this Policy and make sure that you fully understand and agree to it. If you do not agree to this Policy, please discontinue and avoid using our Services. You have the right to cease using our Services at any time.
This Policy is integrated into and forms part of our Terms and Conditions.
For any questions or concerns, please contact us via our email address: help@luma.ai.
This Policy describes the following –
1. What types of personal data we collect
2. Tracking technologies
3. Why we process your personal data
4. With whom we share your personal data
5. Your privacy rights
6. Transfer of personal data
7. How we protect your data
8. Minors
9. Retention
10. Updates to this Policy
11. Controlling version
12. Contact us
1. What types of personal data do we collect?
We collect personal data about you, which refers to any information that could potentially identify you through reasonable means (such as email address or name). This section outlines how and when we collect and process personal data about you.
1.1. Account information:
If you decide to register an account with our Services, we may collect your full name, email address, country, phone number, birthdate and user nickname.
1.2. Payment and Usage information:
When you use our Services, we collect information about your interaction with our Services. Such information includes purchase history and data pertaining to your activities on our Services, as well as information generated when you interact with our Website (for instance, how and when you use our Website).
1.3. Identifiers and technical information:
When you use our Services, we collect technical information such as IP address, device identifiers (e.g., IDFV for iOS devices and Android ID for Android devices), information about your device and connection, including user agent, connection type, timestamp, system language, device model, screen resolution and settings, battery level, available storage space, time zone, and operating system.
1.4. Communication information:
When you contact us via email or through the support channels on our Website, we collect the personal data you provide, which include your name, email address, and any other information you choose to provide.
We do not knowingly collect, process or disclose any sensitive personal data.
2. Tracking technologies
When you visit or access our Services, we use cookies, pixels, beacons, local storage and similar technologies ("Tracking Technologies"). These Tracking Technologies allow us to automatically collect information about you, your device, and your online behavior, in order to enhance your navigation in our Services, improve our Services' performance, perform analytics, customize your experience and offer you, for example, tailored content that better correspond with your interests. You can learn more about our use of Tracking Technologies by visiting our Cookie Policy.
2.1. What types of Tracking Technologies do we use?
When you use or access our Services, we use the following categories of Tracking Technologies:
(a) Strictly necessary Tracking Technologies: these Tracking Technologies are automatically placed on your computer or device when you access or take certain actions on our Services. These Tracking Technologies are essential to enable you to navigate around and use the features of our Services.
(b) Functionality Tracking Technologies: these Tracking Technologies allow our Services to remember choices you make (such as your language) and provide enhanced and personalized features. For example, these Tracking Technologies are used for authentication (to remember when you are logged-in) and support other features of our Services; and
(c) Performance Tracking Technologies: these Tracking Technologies collect information about your online activity (for example the duration of your visit on our Services), including behavioral data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics (based on aggregated information).
2.2. How and by who are Tracking Technologies stored on your device?
We store Tracking Technologies on your device when you visit or access our Services – these are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example, our analytics service providers, business partners and advertisers), who run content on our Services – these are called Third-party Tracking Technologies. Both types of Tracking Technologies may be stored either for the duration of your visit on our Services or for repeat visits.
You can manage your Tracking Technology preferences through your browser settings include changing your browser settings to send a “Do-Not-Track” signal. In such case, your browser will send us a special signal to stop tracking your activity. However, please note that certain features of the Services may not work properly or effectively if you delete or disable cookies.
Below is a list of useful links that can provide you with more information on how to manage your cookies:
(a) Google Chrome;
(b) Mozilla Firefox;
(c) Safari (Desktop);
(d) Safari (Mobile);
(e) Android Browser; and
(f) Microsoft Edge
3. Why we process your personal data
Any personal data we collect is being used in a way that is consistent with this Policy, and is used as follows:
| Purpose | Legal basis |
|---|---|
| Provision of our Services; customer support. We use your personal data, such as your name and email address, to provide you with our services and provide customer support. This includes, for example, allowing you to log-in or responding to your inquiries. | The legal bases for processing this data are the performance of our contractual obligations towards you; your consent (where legally required); and our legitimate interests. Our legitimate interests in this case are the provision of our Services and supporting our customers. |
| Payments and transaction processing. We process personal data related to payments, such as your full name, billing information, payment method details, transaction history, deposit and withdrawal information, and records of financial activity on your account. This is done in order to process your payments, verify and record transactions, detect and prevent fraudulent or unauthorized activities, comply with anti-money laundering (AML) and counter-terrorism financing (CTF) requirements, and resolve any payment-related inquiries. | The legal bases for processing this data are the performance of our contractual obligations towards you (processing your payments and enabling your participation in the Services); compliance with our legal and regulatory obligations (including AML/CTF and reporting obligations applicable to gaming operators); and our legitimate interests. Our legitimate interests in this case are ensuring the secure and lawful operation of the payment process, preventing fraudulent or abusive activity, and maintaining accurate financial and transactional records. |
| Improve our Services. We collect and analyze information about you and your usage of our Services for the purposes of usability, quality, functionality and effectiveness of our Services, including debugging to identify and repair errors and undertaking internal research for technological development and demonstration. | The legal basis for processing this data is our legitimate interest. Our legitimate interests in this case are providing and improving our Services. |
| Integrity. We process certain information about you and your usage of our Services to keep the integrity and security of our Services, prevent fraud, verify your identity and enforce our policies. | The legal bases for processing this data are compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are keeping the integrity of our Services; detection of fraudulent activities; and the safety of our end-users. |
| Compliance with applicable laws; assistance to law enforcement agencies; exercising and defending legal claim. We may process your personal data in order to comply with our legal obligation under applicable laws and to exercise legal claims | The legal basis for processing this data is compliance with our legal obligations and our legitimate interests. Our legitimate interests in this case are compliance with our legal obligations, assisting law enforcement agencies and defending and exercising our legal claims. |
4. With whom do we share your personal data?
We may share your personal data with:
4.1. Affiliated companies:
We may share Personal Data internally within our affiliated companies and subsidiaries, for the purposes described in this Policy.
4.2. Payment processors:
We share your payment information with third party payment processors, for the purpose of facilitating your payments when using our Services. These third parties may have access to your Personal Data so that they may perform these tasks on our behalf.
4.3. Service providers:
Service providers working on our behalf and who need access to certain personal data in order to provide their services to us. These companies include, but are not limited to, cloud storage providers, analytics services, fraud prevention etc.
4.4. Law enforcement agencies:
We may disclose some data about you to government or law enforcement officials or private parties. The disclosure will be made in our sole discretion, as we believe it necessary or appropriate to respond to claims and legal procedures (including but not limited to subpoenas), to protect our or a third-party’s property and rights, to protect the safety of the public or any person, or to prevent or stop any activity we consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable. We also may be required to disclose an individual’s personal data in response to a lawful request by public authorities, including meeting national security or law enforcement requirements.
4.5. Auditors and advisers:
We share your data with our external auditors, advisors and professional service providers (e.g., lawyers, accountants, insurers etc.) to ensure our compliance with regulatory requirements and industry standards, auditing, managing disputes etc.
4.6. Mergers and acquisitions:
We may transfer or otherwise share your data in case of entering into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets.
5. Your privacy rights
5.1. 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 data. To the extent these rights apply and concern you, you can contact us via the contact details available below and ask to exercise the following rights.
5.1.1. Rights of access to your personal data:
You have the right to receive confirmation as to whether or not personal data concerning you is being processed, and access your stored personal data, together with supplementary information.
5.1.2. Right of data portability:
You have the right to request us to move, copy and transfer your personal data easily from one IT environment to another, in a safe and secure way, without affecting its usability.
5.1.3. Right of rectification:
You have the right to request rectification of your personal data in our control in the event that you believe the personal data held by us is inaccurate, incomplete or outdated.
5.1.4. Right of deletion/erasure:
You have the right to request that we erase or delete personal data held about you at any time.
5.1.5. Right to restriction or objection to processing:
You have the right to request that we restrict or cease to conduct certain personal data processes at any time.
5.1.6. Right to withdraw your consent:
To the extent we process personal data on the basis of your consent, you may have the right to withdraw your given consent at any time.
5.1.7. Right not to be subject to automated decision making:
You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects on you
5.1.8. Right to opt-out of the sale or share of personal data:
In the event that we sell or share your personal data for behavioral advertising purposes, you may have the right to submit a request to opt-out of the sale or share of your personal data. After you opt-out, we may continue disclosing some personal data to our partners to help us perform business-related functions such as, but not limited to, providing the Services, ensuring that the Services are working correctly and securely, providing aggregate statistics and analytics and preventing fraud.
5.1.9. Right to non-discrimination:
You may have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.
5.1.10. Right to lodge a complaint:
All requests, complaints or queries may be addressed to us to the following email address: help@luma.ai. We will consider any requests, complaints or queries and provide you with a reply in a timely manner. We take our obligations seriously and we ask that any concerns be brought to our attention first, so that we can try to resolve them. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.
Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. You are welcome to contact us for any questions or requests through our contact details below.
6. Transfer of personal data
7. How we protect your data
8. Minors
We do not knowingly collect or solicit personal data from anyone under the age of 18 or under the local age of consent, unless consent is given by a parent or legal guardian. By accessing, using or interacting with our Services, you certify to us that you are not under the age of 18, or under the local age of consent, without parental consent to use our Services. In the event we learn that we have inadvertently gathered personal information from minors under the age of 18 (or under the local age of consent without parental consent), we will take reasonable measures to promptly delete such information from its records in a secure manner. If you believe that we may have any information from or about minors under the age of 18, please let us know at help@luma.ai.
9. Retention
We will retain your personal data for as long as necessary to provide our Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined while taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.
10. Updates to this Policy
From time to time, Luma AI reserves the right to modify the Policy through:
(i) posting a modified version on the Services. Such modified version will take effect immediately upon being posted and you agree to be bound by such modifications;
(ii) asking that you accept the modified Policy. Such modified version will take effect immediately upon your acceptance;
(iii) posting a notice about the modifications on the Services. Such modifications will take effect immediately upon the notice being posted and you agree to be bound by such modifications; or
(iv) sending you a notification via the e-mail address associated with your User Account at the time of such modification Such modification will take effect upon your continued use of the Luma AI Services.
If you do not agree to the modified Policy your sole remedy will be to terminate your User Account and immediately cease accessing and using the Services.
We reserve the right to change this Policy at any time. The most current version will always be posted through our Services (as reflected in the “Last Updated” heading). You are advised to check for updates regularly. By continuing to access or use our Services after any revisions become effective, you agree to be bound by the updated Policy.
11. Controlling version
This Policy has been drafted in English, serving as the original and controlling version of this Policy. Any translations of this Policy into other languages are provided for convenience only and shall not dictate the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the interpretation of the English language version shall prevail.
12. Contact us
If you have any questions about this Policy, please contact us at: help@luma.ai.