Privacy Policy

[LEGAL ENTITY NAME], [REGISTERED ADDRESS], is responsible for your personal data processed through the Lumina app, extension, website and services. Under India's Digital Personal Data Protection Act, 2023 (“DPDP Act”) we are the data fiduciary; under GDPR-style laws, the controller.

Contact us about privacy at [CONTACT EMAIL]. Our grievance officer is [GRIEVANCE OFFICER NAME & EMAIL].

Account data: your email address, an optional name, a password hash (argon2id — we never store your password), the plan and trial status of your account, and the version and date of the Terms and Privacy Policy you accepted.

Security and session data: active sign-in sessions with the type of client (web, desktop, extension), a device name you can see in your account, creation and last-seen times, and IP addresses — used to keep your account secure, detect abuse and rate-limit sign-in attempts.

Lumina AI: the text you explicitly submit to an AI action and the result, the action type, and daily usage counts (number of requests, character counts and an estimated cost). We keep an identical-request cache for up to 7 days so repeating the same request is instant and cheaper.

Voice typing: the audio recorded while you hold the voice key, the languages you chose, and how many seconds you used each day. Audio and transcripts are processed in memory to produce the text and are never stored or cached by us.

Memory Sync and Lumina Pass: encrypted blobs, revision numbers, timestamps and device identifiers needed to sync. The content is encrypted on your device with keys we never receive, so we cannot read your vault, passwords, passkeys or learned words. See Security.

Communications: messages you send us (for example support requests) and our replies.

Payments (when introduced): billing details handled by a payment provider; we will receive only what is needed to manage your subscription (such as plan, period and the last digits of a card), never full card numbers.

Website: an essential session cookie when you sign in, and standard server logs (IP address, time, requested page, browser type) kept for security and troubleshooting.

• What you type with the writing engine — it is processed on your PC only.
• Anything typed in password fields or excluded apps, sites and private windows.
• Your Lumina Pass master password, encryption keys or decrypted vault contents.
• Advertising identifiers. We don't sell or rent personal data and don't use it for advertising.

• Provide the Services you asked for — accounts, Pro features, AI actions, sync (performance of a contract / your consent under the DPDP Act).
• Keep accounts and the Services secure — detect and prevent fraud, abuse and attacks, enforce limits (legitimate interests / legitimate uses permitted by law).
• Communicate with you about your account, security and important changes (contract / legitimate interests).
• Improve reliability and costs using aggregated usage counts — not the content of your text (legitimate interests).
• Comply with law and respond to lawful requests (legal obligation).

Where we rely on consent, you can withdraw it at any time (see section 10); this doesn't affect processing before withdrawal.

When you use an AI action or voice typing, only the selected text or the audio you recorded is sent over an encrypted connection to our AI model provider to produce the result, which is returned to you. The provider processes them under its own terms, which for our current plan may include using inputs to improve its products and services, and may involve human review. Don't send sensitive or confidential information (passwords, financial, health or other people's personal details) to Lumina AI or voice typing.

We keep AI text requests and results in our cache for at most 7 days (then only counts). We never store or cache voice recordings or transcripts.

Never sent to AI: what you type with the offline writing engine, anything in password fields, and everything in Lumina Pass and Memory Sync. Those features never send anything to an AI provider.

• Account data: while your account is open, then deleted within 30 days of account deletion (except what we must keep by law).
• Sessions: until you sign out or revoke them; security logs up to 12 months.
• AI cache: up to 7 days. Daily usage counts: up to 24 months, for billing and abuse prevention.
• Encrypted sync and vault data: until you delete it or your account; backups roll off within 35 days.
• Audit records of administrative actions on your account: up to 24 months.

We share personal data only with service providers that process it on our behalf under contracts requiring confidentiality and security:

• Hosting and infrastructure — servers and databases ([HOSTING PROVIDER REGION — e.g. data centre in the EU/India]).
• Our AI model provider — only for the Lumina AI and voice typing requests you make.
• Email delivery — for account and security emails.
• Payment provider — when online payments are introduced.

We may disclose data if required by law or to protect rights, safety and security, and in connection with a merger or acquisition (with notice to you). We never sell personal data.

Our providers may process data outside your country. Where we transfer personal data internationally we use appropriate safeguards required by applicable law and only transfer to countries not restricted by the Government of India under the DPDP Act.

Depending on where you live, you have the right to:

• Access a summary of your personal data and how it is processed;
• Correct and complete inaccurate or incomplete data;
• Delete your data and account (“erasure”);
• Export your data in a portable format;
• Withdraw consent and object to or restrict certain processing;
• Nominate another person to exercise your rights in case of death or incapacity (DPDP Act);
• Grievance redressal — contact our grievance officer, [GRIEVANCE OFFICER NAME & EMAIL]; we aim to respond within 30 days. If you're not satisfied, you may complain to the Data Protection Board of India or your local data protection authority.

You can do much of this yourself: view devices and sign out sessions on your account page; inspect, export or erase everything the desktop app learned in Settings → Memory. For anything else, email [CONTACT EMAIL]. We may need to verify your identity first.

Encryption in transit (TLS) everywhere, argon2id password hashing, hashed session tokens, rate limiting, least-privilege access, audit logging of administrative actions, and end-to-end encryption for Lumina Pass and Memory Sync. Details are on our Security page.

If a personal data breach occurs, we will contain it, investigate, and notify the Data Protection Board of India and affected users as required by the DPDP Act and other applicable laws, with the information you need to protect yourself. Because Lumina Pass and Memory Sync data is end-to-end encrypted, it remains unreadable even if encrypted copies were exposed.

Lumina is not directed at children. Users under 18 may use an account only with verifiable consent from a parent or lawful guardian, and we do not track, profile or target advertising at children. If you believe a child has given us data without such consent, contact us and we will delete it.

We use one essential cookie, lumina_session, to keep you signed in on the website. It is httpOnly and secure, and is removed when you sign out. We don't use advertising, analytics or third-party tracking cookies.

We will post changes here with a new version number and effective date. For material changes we will notify you by email or in the app and ask you to review the update when you next sign in.

[LEGAL ENTITY NAME], [REGISTERED ADDRESS]. Privacy: [CONTACT EMAIL]. Grievance officer: [GRIEVANCE OFFICER NAME & EMAIL].