Privacy Policy

‍PRIVACY POLICY
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Effective Date: August 2, 2025

Lumi AI, Inc. (“Lumi”, “we”, “our” or “us”) is committed to protecting your privacy. This Privacy Policy applies to our services, including but not limited to the Lumi website at lumi-ai.com (the “Website”), and details how we access, collect and use personal data (personal information) shared by you (“you” or “your”).

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BY USING THE SERVICE YOU ARE AGREEING TO THE TERMS OF THIS PRIVACY POLICY. 

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IF YOU ARE USING THE SERVICE ON BEHALF OF AN ORGANIZATION, YOU REPRESENT THAT YOU HAVE THE AUTHORITY TO BIND THE ORGANIZATION TO THIS PRIVACY POLICY AND ARE AGREEING TO THIS PRIVACY POLICY FOR THAT ORGANIZATION. WHERE YOU ARE USING THE SERVICE ON BEHALF OF AN ORGANIZATION, “YOU” AND “YOUR” REFERS TO THE ORGANIZATION.
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1. DESCRIPTION OF THE SERVICE

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Lumi operates a service, via the Website, that uses generative AI technology to provide businesses with the ability to query their database/ data warehouse using natural language (collectively, the “Service”). In order to provide the Service to Lumi’s clients (each, a “Business”), Lumi often has to access personal data that may be sensitive or important to the clients of each Business (each, a “Client”) in order to answer Business’s questions via the Service. This Privacy Policy describes how we access, collect and use personal data regarding Clients and Businesses. 
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2. HOW WE OBTAIN PERSONAL DATA

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The Service involves accessing, collecting and processing personal data, which is information about individuals or that can be used to identify them. Subject to legal, contractual and technical requirements, you may choose not to provide Lumi with certain data or request the deletion of certain data, which may impact essential operations of the Service and/or the Website. In most cases, Lumi is not the personal data controller and only acts as a data processor. In cases where Lumi is the data processor and not the controller, please contact your data controller prior to contacting Lumi, in order to exercise any of your personal data rights. 
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3. PERSONAL DATA WE COLLECT 

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The following is a description of the personal data that we may access, collect, use and process in connection with the operation of the Service:

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• full names, email addresses and other contact information;

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• data regarding your use of the Service while using the Service;

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• your communications with Lumi, including query data, prompt data and other Business or Client data that you provide Lumi access to via the Service which may contain personal data or indirectly identify personal data through any associated raw data and/or metadata; 

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•  cookies and similar tracking technologies to track activities on the Service; and 

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• derivative data, including geolocation data, information about your computer, phone, mobile device, web-connected device or other devices used to connect to the Service (including the device’s model, manufacturer, and Internet Protocol address (i.e. IP address), if our Website is accessed from such device), web-browser type, operating system, access times, page history, and website analytics.

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Lumi may also collect anonymous data that does not identify you, including but not limited to responses to anonymous surveys and feedback requests, metrics and other types of statistical data, which could be derived from your use of the Service and analytical data concerning the Service. Lumi may also aggregate, anonymize and/or de-identify the personal data it collects about Businesses. We have implemented commercially reasonable security measures to properly encrypt, anonymize and/or de-identify such data. Lumi does not attempt to re-identify any previously anonymized or de-identified data.   
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4. PROCESSING OF PERSONAL DATA

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We process personal data for our legitimate business purposes. These uses include but are not limited to:

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• providing the Service to Businesses, including authentication of users and maintaining and tailoring the Services to Businesses’ needs based on the data provided;

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• understanding needs and improving the quality of the Service and Website, including providing customer support and feedback, providing additional support, analyzing functionality and technical issues, tracking use of the Service and Website and generating internal reports and data models that we use to improve the Service and Website; 

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• using cookies and third-party data website analytics software to gain a better understanding of Website use and activity;

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• protecting and supporting the security and integrity of the Service and users, including by detecting illegal, improper, suspicious or dangerous activity and taking steps to protect you, Lumi and third-parties against fraud, theft, piracy, error and other risks; 

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• contacting Businesses for various reasons, including when providing support for the Service and Website; and

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• for contractual, legal, regulatory or audit obligations, including responding to requests from law enforcement or a government agency asserting lawful authority to obtain the data or where Lumi has reasonable grounds to believe the data could be useful in the investigation of unlawful activity, complying with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the production of data, complying with court rules regarding the production of records and data, defending Lumi in a legal, regulatory or administrative proceeding or in a contractual dispute or providing information to our legal counsel.

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We may disclose personal data to our parent companies, affiliates, subsidiaries, employees and contractors for the same purposes described above. 

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5. THIRD-PARTY SERVICES

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This Privacy Policy only applies to personal data that Lumi accesses, collects, processes and discloses and does not apply to the access, collection, processing and disclosure of data by third parties through third-party services, including OpenAI, AWS, PostHog, Google, Vercel, Microsoft, Redis, Pinecone and Slack, which may be broader than set forth in this Privacy Policy, and that may be embedded into the Service. In many cases, third parties may collect personal data about online activities over time and across different websites and services. We strongly recommend that each Business reads each third-party privacy policy carefully before using the Service and has the legal right to process personal data from its Clients using Lumi and these third parties. Please contact us directly using the information found below to learn more about third-party data practices.

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6. COOKIES AND TRACKING TECHNOLOGIES 

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The Service uses tracking technologies, such as cookies, web beacons and Google Analytics, to collect personal data, such as IP addresses and device information. Based on this data, third-parties may be able to resolve identities across multiple devices. This data is collected, used and disclosed in accordance with the terms of this Privacy Policy and the applicable third-party privacy policies. Certain Service features may rely on tracking technologies and by declining to accept cookies or by changing certain settings on a device, these features may stop working. You have the right to opt-in and opt-out of certain cookies that are not necessary for the operations of the Service, including third-party cookies, and may do so by contacting Lumi using the information below. 

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7. OBTAINING, RECTIFYING AND CONTROLLING PERSONAL DATA

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You may contact Lumi to obtain a copy of any personal data we have collected about you, the production of which may be subject to a fee as permitted by applicable law. You may also contact Lumi to correct inaccurate personal data or to complete incomplete personal data.  

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You may be able to opt-out of some or all of the ways in which personal data is processed, or request the deletion of certain personal data, except where the personal data is necessary or vital for:

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• the performance of contractual obligations, such as the Terms and Conditions and/or Order Form;

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• to comply with our legal obligations;

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• protecting Client or Business interests or those of another person; and

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• our legitimate interests or the legitimate interests of a third-party,

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and may do so by requesting deletion by contacting us using the contact information found below. Please note that exercising an opt-out right or requesting deletion of your personal data may impact your use of the Service or certain Service features. In the event you are not satisfied with Lumi’s response to your exercise of a privacy right, you may submit an appeal to Lumi for further information concerning our decision or to seek re-consideration of your request. 

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8. DATA STORAGE AND RETENTION

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While Lumi is a US based company, the personal data provided through the Service may be stored and processed by third parties in countries around the world. You authorize Lumi and third parties acting on our behalf to process personal data in any country of their choosing, which may cause the data that we access, including personal data, to be subject to privacy protections and legal rights that may not be equivalent to those in your country. 

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Personal data that is retained by Lumi is only retained until you request its deletion, until Lumi no longer requires such data for the purpose for which it was collected, or as long as is legally necessary. Lumi may aggregate, anonymize and/or de-identify personal data, and retain such de-identified data for purposes and time periods permitted by applicable law. 

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9. CHILDREN 

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Lumi complies with the U.S. Children’s Online  Privacy Protection Act and other applicable laws and regulations concerning children and the Internet. The Service and Website are not directed to children under the age of 18 and we do not knowingly solicit or collect any personal data from children under the age of 18. If Lumi is made aware of the fact that we may have inadvertently collected data from children under the age of 18, we will promptly take measures to delete the data from our records. If you are the parent or guardian of a child who you believe may have provided Lumi with personal data without your consent, please contact us using the information below. 

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10. DO NOT TRACK DISCLOSURE

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Do Not Track (“DNT”) is a web or device setting that allows you to request that receivers of personal data stop their tracking activities. When you choose to turn on the DNT setting in your browser or device or use alternative consumer choice mechanisms, your browser or device sends a special signal to websites, analytics companies, advertising networks, plug-in providers and other web services you encounter to stop tracking your activity. Currently, there are no DNT technology standards and, as a result, we do not respond to DNT requests. 

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11. CALIFORNIA “SHINE THE LIGHT” RIGHT

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If you are a California resident, California Civil Code 1798.83 grants you the right to request disclosure of the categories of personal data we control and provide to third parties, and the names and addresses of these third parties, for direct marketing purposes during the preceding calendar year. If you are a California resident and would like to make this request, please contact us using the contact information set forth below.

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Please note that you may only make this request once per year.

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12. YOUR CALIFORNIA PRIVACY RIGHTS

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If you are a California resident, California Civil Code Section 1798.120 permits you to opt-out of the sale and sharing of your personal information to third parties. Currently, Lumi does not sell or share your personal information to third parties except as directly requested by Businesses via consent and as such no opt-out of the sale or sharing of such personal information is necessary. Although Lumi does not sell or share your personal information to third parties without consent, Lumi does provide a general opt-out right to all of our users. If you have any other questions about our privacy practices, please email us at privacy@lumi-ai.com.

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13. CHANGE OF OWNERSHIP OR BUSINESS TRANSITION

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In the event of, or in preparation for, a change of ownership or control of Lumi or a business transition such as the sale of some or all Lumi’s assets, we may disclose and/or transfer your personal and anonymous data to third-parties who will have the right to continue to collect and use such data in the manner set forth in this Privacy Policy.

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14. SECURITY

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We are committed to ensuring that your data is secure. To prevent unauthorized access, disclosure, or breach, we have put in place suitable and commercially reasonable physical, electronic, and administrative procedures to safeguard and secure the data we collect and process, including appropriate protections for any sensitive personal data we access, process or collect. Despite Lumi’s efforts to adequately protect your personal data, no electronic transmission can be guaranteed to be fully secure. As a result, our security measures may be compromised by hackers, cybercriminals and other unauthorized third parties attempting to improperly collect, access, steal and/or modify your information. You acknowledge and agree that the transmission of personal data to and from the Service is at your own risk and that you should only access the Service from a secure environment. 

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15. CONTACT PREFERENCES

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We will communicate with you through the Website, your email address and/or phone, to respond to support requests or comments. If you have provided us with your email address and would like to change the email preferences we associate with you (for example, unsubscribing from receiving certain types of email) you may do so by clicking a link within certain types of emails that we send to you or, if no link is available, by replying with “unsubscribe” in the email title or body. On rare occasions, some types of email are necessary for the Service and cannot be unsubscribed from if you continue to use the Service.

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16. UPDATES

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Lumi reserves the right, in its sole discretion, to modify this Privacy Policy at any time (each, an “Update”) and shall make each Update available on the Website. You are deemed to accept an Update by continuing to use the Service. Unless Lumi states otherwise, an Update is automatically effective 30 days after posting on the Website, except in such case where an Update is immaterial to any of your legal rights or legal obligations of Lumi and such Update is made only to correct a typographical, formatting or grammar inaccuracy, and in such case, an Update is effective immediately after posting on the Website.

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17. CONTACT US

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If you have requests, questions or comments about the Privacy Policy or our data collection in general, please contact our Data Privacy Officer or our Privacy Team at privacy@lumi-ai.com

 or:

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Privacy Support Team

https://www.linkedin.com/company/lumi-ai/