Lumina Twin Privacy Policy

1. Introduction

This Privacy Policy explains how Lumina Twin ("Lumina Twin," "we," "us," or "our") collects, uses, stores, discloses, and protects personal information in connection with our website, waitlist, communications, applications, browser extensions, and related services (collectively, the "Service").

Lumina Twin is owned and operated by LUMINOVA AI TWIN INC, which is responsible for processing personal information through the Service.

Lumina Twin is being designed as a consent-first AI memory and digital legacy platform. Our core commitment is simple: we do not collect personal activity data for the AI memory twin unless the user has first been told what will be collected and has given permission.

2. Current Service Status

Lumina Twin is currently in an early-access phase with open account creation. Users may create accounts and consent settings first, but browser extension activity collection, connected-source imports, memory uploads, AI analysis, and twin chat begin only after the user activates the Stripe trial with a payment card.

3. Information We Collect

Depending on how you use the Service, we may collect the following categories of information:

• Contact and update information: email address, signup timestamp, consent record, source page, IP address, and browser or device information.
• Account information: name, email address, login credentials, account preferences, billing status, and plan information if accounts or subscriptions are enabled.
• Consent and privacy settings: the categories of data you approve, pause, revoke, delete, or export.
• User-provided memory content: notes, journal entries, uploaded files, voice recordings, transcripts, photos, links, answers to prompts, and other material you choose to provide.
• Permission-based activity data: browser activity, page titles, URLs, search context, shopping interests, reading signals, media interests, app activity, device permissions, or connected-account data, but only where the relevant feature is available and you have granted the required permission.
• AI-generated information: summaries, extracted memories, inferred preferences, personality insights, confidence scores, source links, and AI chat outputs generated from approved data.
• Technical information: IP address, device type, browser type, operating system, log files, security events, diagnostics, cookies, and similar technologies.

4. How We Use Information

We may use personal information to:

• operate, maintain, secure, and improve the Service;
• manage account creation, product updates, email verification, billing notices, and user communications;
• create, organize, search, summarize, and analyze approved memory data;
• generate AI twin responses based on approved memories and evidence;
• honor consent, deletion, export, access, and privacy choices;
• detect, prevent, and respond to fraud, abuse, security incidents, and unlawful activity;
• comply with legal obligations and enforce our Terms of Service;
• prepare future subscriptions, billing, plan limits, and customer support workflows.

5. Consent-First Collection

Lumina Twin is intended to collect sensitive personal activity data only after clear notice and affirmative permission. Where future features allow automatic data collection, we intend to provide category-level controls, pause controls, deletion controls, and visibility into what has been collected.

You may withdraw consent for future collection through available product controls. Withdrawal of consent does not necessarily affect processing that occurred before withdrawal, but we will honor deletion requests as described in this Policy and as required by applicable law.

You must not use Lumina Twin to secretly collect, monitor, record, upload, or analyze another person's information. If you submit information about another person, you are responsible for having all permissions and legal rights required to do so.

6. Voice, Likeness, and Synthetic Audio

Voice features are optional. If you choose to use them, we may process approved voice recordings, transcripts, consent records, generated audio, and voice profile metadata to create or operate synthetic voice replies. We require consent before creating or using a synthetic voice profile.

Do not upload voice recordings or request a synthetic voice profile for another person unless you have the legal right and all required permissions to do so. Voice features may be unavailable, inaccurate, delayed, or disabled during beta.

7. Marketing Communications

If you opt in to receive updates, we may send product announcements, beta updates, and related communications. You may unsubscribe at any time using the unsubscribe link in an email or by contacting us.

We may use an email marketing provider, including Hostinger Reach or a similar service, to send and manage these communications. Such providers process contact information on our behalf and are not authorized to sell your personal information.

8. No Sale of Personal Information

We do not sell personal information. We do not intend to use Lumina Twin memory data for third-party advertising or to allow unrelated third parties to build profiles about users for their own purposes.

9. Service Providers and Disclosures

We may disclose information to vendors and service providers who help us operate the Service, such as hosting providers, infrastructure providers, analytics providers, email delivery providers, payment processors, security providers, customer support tools, and AI model or API providers. These providers are permitted to process information only for authorized service purposes.

We may also disclose information if required by law, court order, subpoena, legal process, government request, or to protect rights, safety, security, and the integrity of the Service.

10. AI Processing and Sensitive Data

Lumina Twin may process highly personal information if a user chooses to provide or approve it. AI outputs may include summaries, inferences, classifications, confidence levels, and simulated responses based on approved data. AI outputs can be incomplete, inaccurate, or uncertain, and should not be treated as a definitive statement of what a person would have said, done, believed, or chosen.

We will design the Service to label AI-generated responses clearly and to preserve evidence-based source context where practical.

Lumina Twin is not designed for medical, legal, financial, emergency, safety, employment, insurance, housing, immigration, or other high-impact decisions. Do not rely on AI outputs as professional advice or emergency support.

11. Legacy Access

Future legacy-access features may allow a user to designate trusted contacts or family members who can access approved memories or AI twin interactions after a specified event or condition. We will process such access according to the user’s settings, applicable verification procedures, and applicable law.

12. Retention

We retain personal information for as long as reasonably necessary to provide the Service, maintain records, comply with legal obligations, resolve disputes, enforce agreements, and protect the Service. Waitlist records may be retained until you unsubscribe, request deletion, or we no longer need them for early-access communications.

If we discontinue or permanently wind down the Service, we will try to give users reasonable notice and a limited window to export or download available account data, unless legal, security, emergency, technical, or third-party platform limits prevent us from doing so. After that window ends, personal information, memory data, AI-generated records, and account data may be deleted, disabled, archived, or no longer available through the Service.

If your trial or subscription is canceled, we may delete collected twin data from active use immediately while retaining limited records needed for billing, fraud prevention, security, audit, dispute resolution, legal compliance, or enforcement of our agreements.

13. Deletion, Export, and User Rights

We intend to provide tools for users to access, export, correct, pause, and delete their data. Depending on where you live, you may have legal rights to request access, correction, deletion, portability, restriction, objection, withdrawal of consent, or information about how your data is processed.

To make a privacy request, contact us at support@luminatwin.com. We may need to verify your identity before completing a request.

14. Security

We use reasonable administrative, technical, and organizational safeguards designed to protect personal information. No system is perfectly secure, and we cannot guarantee absolute security. Users should choose strong passwords, protect account credentials, and notify us of suspected unauthorized access.

15. International Transfers

Personal information may be processed in Canada, the United States, the European Economic Area, or other jurisdictions where we or our service providers operate. These jurisdictions may have data protection laws that differ from those in your location.

16. Children

The Service is not intended for children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided personal information to us, contact us so we can take appropriate action.

17. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the effective date and may provide additional notice through the Service or by email.

18. Contact

For privacy questions or requests, contact us at support@luminatwin.com.