Lumina Life:AI Guide APP PRIVACY POLICY
Welcome! Lumina Life:AI Guide Incorporated ("us", "we",or "our") operates this Lumina" mobile application (here in after referred to as the "App"or"Lumina").
Our Privacy Policy governs your use of the App, and explains how we collect, safeguard and disclose information that results from your use of our App.
We use your data to provide and improve the App. By using the App, you agree to the collection anduse of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, theterms used in this Privacy Policy have the same meanings as in our Terms and Conditions.
Our App Terms and Conditions (referred to throughout this Privacy policy as our "Terms") govern all use of our App and together with this Privacy Policy constitutes your agreement with us ("Agreement").
WHAT PERSONAL DATA WE COLLECT, AND WHY WE COLLECT IT
1.DEFINITIONS:
•Personal Basic Information: Covers your date of birth, time of birth, and place of birth, which are used to generate personalized fortune analysis content.
•App: Refers to the mobile application available for download on the iOS App Store or Google Play Store, and is subject to this Privacy Policy.
•Personal Data: Information that can identify a living individual either by itself or when combined with other data that we hold or may come to hold.
•Usage Data: Data collected automatically through your use of the App or from its infrastructure (e.g., page visit duration).
•Data Controller: A natural or legal person (either alone or jointly) who determines the purposes for which and the manner in which personal data is processed. In this case, we are the Data Controller of your data.
•Data Processors (Service Providers): Any natural or legal person who processes data on behalf of the Data Controller. We may utilize third - party service providers to help process your data efficiently.
•Data Subject: Any living individual whose personal data is being collected.
•User: The individual using our App, corresponding to the Data Subject in this context.
2.INFO WE COLLECT:
The personal data we collect through various parts of the App includes:
•Your Name
•Your Email
•Your Phone number
•Your Personal Basic Information
In addition, if you send us a comment or question through the APP or via email at [email protected], we will also collect and store the content of your feedback. Lumina App collects your personal data mainly for the following purposes:
1.AI Chat Interaction: Support you in entering personal information in the AI chat room. The AI system will use this information to gain a deeper understanding of your questions and needs, and provide you with accurate and personalized answers and suggestions. You can delete the chat information recorded by the AI by clearing the app cache to protect your personal information privacy.
2.Fortune Analysis and Display: Generate personalized fortune analysis, conduct personalized fortune interpretations, and analyze fortune change information based on your provided date of birth, time of birth, and place of birth.
3.Content Recommendation: Screen and display appropriate logs, information, and other content for you.
4.Subscription Management: Receive and process your App subscription payments through our third - party subscription management partner.
5.Feedback Handling: Identify the source of feedback or comments about the App.
6.Information Push: Push special offers and product services of Lumina Inc. to you via your phone number and email.
3.MOBILE DEVICE INFORMATION:
The Lumina App automatically consults and may transmit your unique device identifer or other information about your mobile device for the purposes of:
· Establishing and managing your subscription payments
· Supporting app analytics services In each case, we strive to use information about your device only where necessary or desirable to deliverthe Lumina App to you and optimize your experience using the Lumina App.
4.APP ANALYTICS TRACKING:
Our website uses Google Analytics tracking tomeasure trafic data. We also use a third party analytics tool to aggregate and organize usage analytics data, which receives app usage data via an Application Programming Interface and stores thisdata on servers controlled by the analytics provider, Segment.
5.NEWSLETTER:
You will be added to our email list automatically when you access our Lumina App. Our newsletters and other announcements are sent through a third party email service, which may use web beacons to track your interactions with ouremail - for example, whether an email is opened orclicked. We have access to this tracking information. You can opt-out of our email newsletters and othercorrespondence, or change your email notification preferences, anytime by clicking the unsubscribelink in the footer of our emails.
HOW WE TRANSMIT AND STORE YOUR DATA:
When you utilize the Lumina App, your Birth Chart Info is sent to a 3rd party API to receive a customized response, but not stored in any data base or server. The data received in response to this API call ("API Data") is stored locally on your device to generate the Lumina App content. If you choose to revise your information, including without limitation birth date and time, the Lumina App will send the updated information to the same API end point in order to obtain updated content for the App. Based on the birth chart information that we populate based on the API Data, we send a requestto a content management system to choose the content regarding your chart, transits, and other astrological markers to display within the App. The email address you use to log in will be stored: (1) in our encrypted user database to enable your continued access to the app [across devices] and (2) in/on our Mailchimp list (alongside any unsubscribe request to keep you opted-out if you choose to opt-out).
We maintain records of all Lumina App subscribers, past and present, indefinitely in order to optimize ourbusiness operations. Usage information about the App is stored on third party servers owned and controlled by Segment, but this data does notinclude personal data about you other than yourdevice itself.
Your information, including Personal Data, may be transferred to computer slocated outside of your state, province, country orother governmental jurisdiction where the dataprotection laws may differ from those of your jurisdiction. If you are located outside the UnitedStates and choose to provide information to us,please note that we transfer the data, including Personal Data, to the United States and process itthere.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. We will take all the steps reasonably necessary toensure that your data is treated securely and in accordance with this Privacy Policy and no transferof your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your dataand other personal information.
Additional Information for California Residents
California Privacy Notice Provisions
This section of the Privacy Policy provides additional information for California residents (“consumer” or “you”) and applies to “Personal Information,” as defined by the California Consumer Privacy Act 2018, as amended by the California Privacy Rights Act 2020 (the “CCPA”), whether collected online or offline. This section describes our information practices and any rights you may have regarding your Personal Information pursuant to the CCPA.
Categories of Personal Information We Collect
For purposes of this section, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Please note that Personal Information does not include:
•Publicly available information, such as information lawfully made available from government records, information we have a reasonable basis to believe is lawfully made available to the general public by you or by widely distributed media, or by a person to whom you have disclosed the information and not restricted it to a specific audience;
•Deidentified or aggregated information; and
•Information excluded from the CCPA's scope, like:health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
The following identifies the categories of personal information we collect about you (and have collected in the prior 12 months), as enumerated by the CCPA. Depending on how you use the Services, we collect the following categories of personal information through our Services:
1.Identifiers: Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, or other identifiers;
2.Customer records information: Name, physical characteristics or description, address, or telephone number;
3.Characteristics of protected classifications under California or federal law: Race, religion, sexual orientation, gender identity, gender expression, age (if you choose to provide such information);
4.Commercial information: (not relevant to Lumina)
5.Biometric information: Height;
6.Internet or other electronic network activity information: (not relevant to Lumina);
7.Geolocation data: Mobile device location;
8.Audio, electronic, visual, thermal, olfactory, or similar information: Photos, videos;
9.Professional or employment-related information;
10.Education information (non-public); and
11.Inferences
Categories of Sources from Which Personal Information is Collected
Depending on how you interact with our Services, we generally collect the categories of Personal Information listed above from the following categories of sources:
•directly from the consumer;
•from operating systems and platforms, and
•from third parties.
Retention of Personal Information
Lumina retains the Personal Information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. Rather than delete your Personal Information, we may also deidentify it by removing identifying details. If we deidentify the data, we will not attempt to reidentify it.
Business or Commercial Purposes for Collecting and Disclosing Personal Information
We may use and disclose the Personal Information we collect for the following business purposes, as more fully described above:
•To operate our Sites and provide our Services in accordance with our Terms of Service and/or any other agreement you may have with us;
•To manage your Personal Information and accounts;
•To respond to your questions or inquiries;
•To conduct promotional activities, including contests or surveys;
•To undertake internal research for technological development and demonstration;
•To improve, upgrade or enhance our Sites and Services;
•To send you informational or promotional communications;
•To detect bugs, security incidents (including to protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity);
•To undertake activities to verify or maintain the quality or safety of a Service, Site or transaction;
•To carry out other purposes that are disclosed to you and/or to which you consent;
•To conduct financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions, and to maintain appropriate business records and enforce company policies and procedures;
•To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings; and
•To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
Disclosures of Personal Information for a Business Purpose
We may disclose your Personal Information to the third parties or others as described above in this Privacy Policy, for any of the business purposes described above in this Privacy Policy.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information in our role as a business for a business purpose:
•Identifiers;
•Commercial information;
•Internet or other electronic network activity information;
•Geolocation data;
•Audio, electronic, visual or similar information;
•Inferences; and
•Sensitive personal information
Sensitive Personal Information
Our collection, use, and disclosure of Sensitive Personal Information is generally limited to what is reasonable and proportionate for the following purposes:
•To perform the services or provide the goods as reasonably expected by you;
•To detect security incidents that compromise the availability, authenticity, integrity, and confidentiality of sensitive Personal Information that is stored or transmitted;
•To resist malicious, deceptive, fraudulent, or illegal actions directed at Lumina and to prosecute those responsible for those actions;
•To ensure the physical safety of you and others;
•For short-term, transient uses;
•To verify your information, provide customer support, or provide similar services; and
•With respect to a service or device that is owned, manufactured, manufactured for, or controlled by Lumina, to verify or maintain the quality or safety, improve, upgrade, or enhance the service or device.
We do not sell or share Personal Information about individuals we know are under age sixteen (16).
Your CCPA Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights. Subject to certain exceptions, consumers have the right to make the following requests:
Right to Know/Access. You have the right to request (up to twice per year subject to certain exemptions), free of charge, that we disclose information about our collection and use of your Personal Information, including:
•The categories of Personal Information we collected about you;
•The categories of sources from which the Personal Information is collected;
•The business or commercial purpose for collecting that Personal Information;
•The categories of third parties with whom we disclose Personal Information; and
•The specific pieces of Personal Information we have collected.
Right to Correct. Subject to certain conditions and exceptions, you have the right to request that we correct inaccuracies in your Personal Information.
Right to Delete. Subject to certain conditions and exceptions, you have the right to request that we delete your Personal Information. Once we receive and confirm your request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
Right to Limit Use and Disclosure. We do not engage in uses or disclosures of “sensitive personal information” that would trigger the Right to Limit Use of Sensitive Personal Information under the CCPA.
Right to Non-Discrimination. We will not discriminate against you in terms of price or service level for exercising any of the rights described in this section.
Exercising Your Rights Under CCPA:
California residents can exercise the above privacy rights by contacting us at [email protected]or by requesting your personal data through the app settings using the “Download Data” feature.
Authorized Agent. You may designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that you directly verify your identity and the authority of your authorized agent.
Businesses operating as an authorized agent on behalf of a California resident must provide both of the following:
•(1) Certificate of good standing with its state of organization; and
•(2) A written authorization document, signed by the California resident, containing the California resident’s name, address, telephone number, and valid email address, and expressly authorizing the business to act on behalf of the California resident.
Individuals operating as an authorized agent on behalf of a California resident must provide either of the following:
•(1) A notarized power of attorney signed and dated by the California resident naming the authorized agent as the California resident’s representative; or
•(2) A written authorization document, signed by the California resident, containing the California resident’s name, address, telephone number, and valid email address, and expressly authorizing the individual to act on behalf of the California resident.
We reserve the right to reject (1) authorized agents who have not fulfilled the above requirements, or (2) automated CCPA requests where we have reason to believe the security of the requestor’s personal information may be at risk.
California “Shine the Light” Disclosure
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Sites and Services who are California residents to request, once per calendar year, certain information regarding our disclosure of Personal Information (if any) to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information provided below. Please include in your request a current California address and your attestation that you are a California resident.
Additional U.S. State Privacy Disclosures
If you live in Colorado (effective July 1, 2023), Connecticut (effective July 1, 2023), Utah (effective December 31, 2023), or Virginia (effective January 1, 2023), you may have these rights:
•(1) The right to confirm whether Lumina is processing your Personal Information, and to access your Personal Information.
•(2) The right to request we correct inaccuracies in your Personal Information.
•(3) The right to request we delete your Personal Information.
•(4) The right to request a copy of the Personal Information you provided to us.
•(5) The right to opt out of (i) processing of your Personal Information for targeted advertising purposes and (ii) profiling in furtherance of decisions that produce legal or similarly significant effects.
To exercise rights (1) through (4), please contact us at [email protected]. For right 5(iii), please note Lumina does not use Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects. Therefore, the consumer rights that apply to such decisions are not applicable to Lumina.
Our Use of Your Personal Data and Other Information:
Lumina uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to respond to your questions or try to resolve your problem. Also, if you provide Personal Data in order to obtain access to the Application, we will use your Personal Data to provide you with access to the Application and to analyze your use of the Application.
Our Disclosure of Your Personal Data and Other Information:
There are certain circumstances in which we may share your Personal Data in the following circumstances without further notice to you:
Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets. As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.
Agents, Consultants and Related Third Parties: Lumina, like many businesses, sometimes hires other companies to perform certain business-related functions and to help us understand and improve the use of our Services. Examples of such functions include web hosting, maintaining databases and processing payments. We may share any information we receive with vendors and service providers retained in connection with providing the Services.
Legal Requirements: Lumina may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Lumina, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
Accessing the Application Through Apple or Google: If you use Apple Keychain to automatically log into the Application, your user login information is shared with Apple, Inc.
For more information on how Apple, Inc. uses this data, go to https://www.apple.com/privacy/.If you access the Application through the
Google Play store, Google LLC will collect data regarding your use of the Application as described in more detail at https://play.google.com/about/developer-distribution-agreement.html. Such information will be subject to the Google LLC privacy policy available at https://www.google.com/intl/en_us/policies/privacy/?fg=1.
Your Choices:
You may choose to set your profile to “private” which will prevent Users from viewing your Personal Readings, but please note that setting your profile to “private” may not prevent Users from creating Compatibility Readings with you. Also, please note that setting your profile to “private” may not prevent other Users from seeing your personal insight headers and indications if they share a similar pattern with you.
Exclusions:
This Privacy Policy does not apply to any Personal Data collected by Lumina other than Personal Data collected through the Services. This Privacy Policy shall not apply to any unsolicited information you provide to Lumina through the Services or through any other means. This includes, but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential and Lumina shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.
Children:
Lumina does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services, as you will not be able to use the Services. We encourage parents and legal guardians to monitor their children’s Internet and mobile application usage, and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Lumina through the Services, please contact us, and we will endeavor to delete that information from our databases. In addition, certain romantic features have been intentionally disabled for users under the age of 18 in an abundance of caution.
Links to Other Third-Party Websites or Mobile Applications:
This Privacy Policy applies only to the Services. The Services may contain links to other Third-Party websites or mobile applications not operated or controlled by Lumina (the “Third-Party Applications”). This Privacy Policy does not apply to such websites or the Third-Party Applications and by providing such links we do not imply that Lumina endorses or has reviewed the websites or Third-Party Applications. We are not responsible for the privacy practices of any Third-Party Websites or Mobile Applications. We suggest contacting those sites or Applications directly for information on their privacy practices.
Integrating Social Media Services:
Through Lumina Services, you may choose to access certain social media services, such as Facebook and Twitter (“Social Media Services”). When you elect to access and use the Social Media Services through those Third-Party Applications you will be sharing your information (which will include Personal Data if you or other users elect to share such information) with those Social Media Services. As with other Third-Party Applications, the information that you or others share with the Social Media Services will be governed by the privacy policies and terms of service of the providers of such Social Media Services and not by Lumina’s Privacy Policy or Terms of Services and procedures. You may also be able to modify your privacy settings with these Social Media Services to, for example, control what information the Social Media Services disclose to other entities, including Lumina. We are not responsible for the privacy practices of any Social Media Services. Lumina shall have no liability or responsibility for the privacy practices or other actions of any Social Media Services.
You may also have the option of posting your Services activities to Social Media Services when you access content through the Services (for example, you may post to Facebook that you performed an activity on the Service); you acknowledge that if you choose to use this feature, your friends, followers and subscribers on any Social Media Services you have enabled will be able to view, comment, and react to such activity.
Security:
Lumina implements technical and organizational measures and takes reasonable steps to protect your Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, neither the Internet nor any email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Lumina cannot and does not guarantee that any Personal Data provided to Lumina will not become public under any circumstances. Please keep this in mind when disclosing any Personal Data to Lumina via the Internet.
Other Terms and Conditions:
Your access to and use of the Services is subject to the Terms of Service at Lumina App in the App Store and Google Play.
Changes to Lumina's Privacy Policy: The Services and our business may change from time to time; as a result, it may be necessary for Lumina to make changes to this Privacy Policy. Lumina reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.
International Users: If you are using Lumina Services from outside of the United States, you expressly acknowledge and agree that your Personal Data and other information will be processed in the United States and in other countries. Privacy and data security laws may be less stringent than or otherwise different from the laws in effect in your country of residence. You expressly consent to the processing of your Personal Data and other information in accordance with this Policy.
UK and EU GDPR Rights
Under UK and EU law, users have certain data protection rights as it relates to their personal information collected by businesses and organizations. Lumina embraces transparency and is committed to providing its users all their data protection rights. Every user utilizing our Services is entitled the following:
The right to access – You have the right to request Lumina for copies of your personal data. We may charge you a small fee for this service.
The right to rectification – You have the right to request that Lumina correct any information you believe is inaccurate. You also have the right to request Lumina to complete information you believe is incomplete.
The right to erasure – You have the right to request that Lumina erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request Lumina restrict the processing of your personal data, under certain conditions.
The right to notification – You have the right to be notified regarding any rectification or erasure of personal data or restriction of processing, unless this proves impossible or involves disproportionate effort.
The right to data portability – You have the right to request that Lumina transfer the data that we have collected to another organization, or directly to you, under certain conditions.
The right to object to processing – You have the right to object to Lumina’s processing of your personal data, under certain conditions.
The right to certain protections related to automated individual decision-making, including profiling – You have the right not to be the subject to a decision based solely on automated processing, including profiling, under certain conditions.
If you choose to exercise any of the above rights, we will respond within one month. Please send any requests to [email protected].
Access to Information; Contacting Lumina:
To keep your Personal Data accurate, current, and complete, please update your profile or contact us as specified below. We will take reasonable steps to update or correct Personal Data in our possession that you have previously submitted via the Services.
Please also feel free to contact us at our designated request address [email protected].comif you have any questions about Lumina’s Privacy Policy, our information practices, or if you need to access this Privacy Policy in a different format.