Privacy Policy

1. Scope and Effective Date

This Privacy Policy applies to the Lumeki app, websites, support channels, and related services. The operator of Lumeki is the controller or responsible organization for your personal information; the exact legal entity is identified in our app store listing, website, or in-app notices.

Effective date: July 16, 2026. By using Lumeki, you acknowledge that you have read this policy. Where local law requires separate consent, we will request it separately.

2. Information We Collect

To provide AI companionship, memory, sync, subscription, and safety features, we may collect:

• Account and sign-in information, such as email address, OAuth identifiers, login status, language, time zone, account status, and consent records.
• Profile information, such as display name, avatar, birth month or year, gender, preferences, interests, and profile text you provide.
• Service content, such as conversations with AI companions, Notes and AI responses, companion updates, mood records, memories, relationship progress, letters, voice, and audio-related information.
• Device and log information, such as device type, operating system, app version, device identifiers, IP address, network status, error logs, and safety events.
• Subscription and transaction information, such as plan, entitlement status, order or receipt identifiers, payment channel, refund, and cancellation status. We do not store full card numbers or CVV.
• Support and feedback information, such as questions, screenshots, contact details, and support records you submit by email, forms, or other channels.

We do not ask you to provide medical diagnoses, religion, political opinions, or other sensitive information. If you voluntarily share sensitive information in chat, we process it only as needed to provide the service, protect safety, comply with law, or with your consent.

3. How We Use Information

We use personal information where reasonably necessary for the following purposes:

• Create, authenticate, and maintain your account, language settings, and regional settings.
• Generate AI companion replies, Note responses, and companion updates; process Notes you save; maintain context; and manage long-term memory, relationship progress, letters, and voice features.
• Sync chats, memories, subscription entitlements, and preferences, while reducing unnecessary data transfer or storage where feasible.
• Process subscriptions, receipt validation, refunds, tax, entitlements, and anti-fraud checks.
• Protect the service through content safety checks, suspicious-login detection, abuse prevention, troubleshooting, and support.
• Measure feature performance, reliability, and product quality using aggregated or de-identified information where possible.

Unless we obtain your separate explicit consent, we do not sell your personal information and do not use your private conversations to train third-party general models.

4. AI, Emotional, and Safety Processing

Lumeki is an AI companion service. Companion updates and AI responses to Notes are AI-generated. With your separate consent, the messages, Notes, companion updates, conversation, memory, and relationship context, as well as reply text and voice settings, needed to generate AI replies, retain long-term memory, evaluate reply quality, and generate speech are processed by AI, long-term-memory, and speech service providers that we vet and bind by contract. Samples used for reply-quality evaluation are redacted first. Your Notes are visible only to you and the AI companions you had when you saved them, not to other users.

If the system detects self-harm, harm to others, child-safety, abuse, or unlawful-risk signals, we may automatically detect, block, downgrade, log necessary de-identified safety events, or take further steps required by law.

5. Storage and Security

To provide sign-in, chat, memory, voice, subscriptions, and cross-device experiences, relevant data is transmitted to our servers or service providers as needed. The app may also store language, notification, cache, session, and similar local data on your device to support core functionality.

We use encryption in transit, access controls, least-privilege permissions, log minimization, backups, and audits. Cloud data is not end-to-end encrypted, and authorized personnel or systems may access it when necessary for service, safety, support, or compliance.

6. Sharing, Processors, and Third-Party Services

We do not sell your personal information. To provide Lumeki, we may disclose necessary information to the following types of service providers or partners and require them to process it only under our instructions or legal obligations:

• Cloud infrastructure, database, object storage, and content delivery providers for hosting accounts, chats, images, audio, and backups.
• AI, speech, and long-term-memory service providers that we vet and bind by contract, for generating replies and speech, retaining and recalling long-term memory, and evaluating reply quality; samples are redacted first. We will update this disclosure and request renewed consent where required if the provider categories or purposes materially change.
• Sign-in and identity providers for email verification, third-party sign-in, and account security.
• Payment and subscription providers for purchases, renewals, cancellations, refunds, and entitlement syncing.
• Push notification, support, error monitoring, analytics, and anti-fraud providers for notifications, support, reliability, and security.
• Regulators, law enforcement, courts, dispute bodies, or professional advisers where required by law or necessary to protect legitimate rights.

Where a region requires separate consent, additional notice, or opt-out controls, we will provide the required notice or controls.

7. Cross-Border Transfers

Core service data, including account profiles, chats, and media, is stored in Singapore. Information needed to provide AI replies, long-term memory, speech, sign-in, subscriptions, and support is also transferred to the United States. Some AI service providers dynamically select processing locations within their supported regions based on model availability, security, and routing, so not every later processing country or region can be identified when you consent. Section 6 lists recipient categories and purposes.

8. Retention and Deletion

We keep personal information only as long as needed for the purposes described in this policy, contract performance, legal compliance, dispute resolution, and safety. In general:

• Account, preference, chat, memory, and relationship data is kept while your account is active unless you delete it or disable the relevant feature.
• After you delete chats or memories or close your account, we delete or anonymize related data from primary systems within a reasonable period; backups and logs are deleted on their rotation schedules.
• Subscription, payment, safety, anti-fraud, support, and compliance records may be retained longer where needed for law, audit, tax, or dispute purposes.
• Aggregated or anonymized data that does not identify a person may be used for statistics, reliability, and product improvement.

9. Your Rights

Depending on your location, you may have the following rights regarding your personal information:

• Request access to or a copy of personal information we hold about you.
• Request correction, supplementation, or updating of inaccurate information.
• Request deletion, cessation of collection, cessation of processing or use, or restriction of processing.
• Withdraw consent, without affecting processing that occurred before withdrawal.
• Export chats, memories, or account data, or request portable data in a machine-readable format.
• Close your account, clear companion data, delete memories, or manage privacy settings.
• Complain to us or to the data protection authority in your location.

10. Minors

Lumeki is not directed to children below the minimum digital-consent age in their location. Minors should use the service only with parent or legal guardian consent. In Korea, users under 14 require consent from a legal representative.

11. Updates and Contact

We may update this policy. For material changes, we will notify you through the app, sign-in flow, email, or another appropriate method, and request renewed consent where required.