Privacy Policy

1. Scope

This Privacy Policy describes how Lumino Labs LLC ("Lumino", "we", "us"), a limited liability company registered in Delaware, United States, collects, uses, retains, and shares personal data when you use lumino.work and its connected portals (safewingcourier.com, celebritynetwork.club, theglobalcharity.com, glarusbank.com). By using the Service, you agree to the practices described here. If you do not agree, please do not use the Service.

2. Data We Collect

We collect the following categories of personal data:

• Account data: email address, hashed password (bcrypt), display name, referral code, email verification status.
• Content you upload: photos (avatar, product), voice samples for cloning, scripts and prompts, profile imagery for connected portals.
• Generated content: AI videos, photos, TTS audio, documents, profile pages, tracking pages, and related metadata (prompts, durations, selected voices, costs).
• Simulated banking (Glarus Bank) KYC: images of government ID (front/back), selfie, holder name, chosen username, submission history. Stored only for the lifetime of the simulated account and used solely to operate the simulation feature; not verified against real identity records.
• Payment data: transaction IDs, amounts, currencies, and statuses returned by NOWPayments. We do not collect or store wallet private keys, seed phrases, or full crypto addresses beyond what is returned by the processor.
• Usage data: credit balance, purchase history, tool usage logs, referral attribution.
• Virtual number data: rented number, rental dates, received SMS messages delivered through our number provider.
• Technical data: HTTP request logs from our hosting providers may include IP address, user-agent, and timestamps for security and diagnostics.

3. How We Use Your Data

• To create and maintain your account and authenticate you.
• To deliver the Service (generate content, run connected portals, rent numbers, operate the shop, process payments, and credit your wallet).
• To send transactional emails (email verification, password reset, payment confirmation, referral bonus notifications, bank portal notifications).
• To enforce our Terms of Service, detect abuse, prevent fraud, and comply with legal obligations.
• To produce anonymized and aggregated analytics that help us improve the Service.

We do not sell your personal data. We do not use your uploads, scripts, voice samples, or generated content to train third-party AI models outside what is required to perform the requested generation.

4. Third-Party Processors

We rely on a small number of third-party service providers (sub-processors) to operate the Service. Each is contractually bound to process your data only to perform its function and has its own privacy practices.

Categories of sub-processors we use:

• Cloud infrastructure and database hosting
• Object and file storage (images, audio, video, documents)
• Transactional email delivery
• AI video generation (pre-rendered avatar videos and real-time streaming transforms)
• AI voice cloning and text-to-speech synthesis
• AI text generation
• Cryptocurrency payment gateways
• SMS delivery for virtual phone number rentals
• Background job queue and caching

We share only the data each provider needs to perform its function. We do not use advertising, marketing-attribution, or third-party analytics tracking on the Service. A current list of specific sub-processors is available on request by emailing support@lumino.work.

5. Data Retention

• Generated videos: up to 7 days, then permanently deleted from Cloudflare R2.
• Generated photos and TTS audio: up to 7 days, then permanently deleted.
• Input uploads (source photos, voice samples): retained while referenced by active content; deleted with the parent generation.
• Cloned voices: retained until you delete them from the Voice Clone Studio.
• Simulated banking KYC images: retained while the underlying simulated account exists; deleted when the account is deleted.
• Account data and payment records: retained while your account is active, and for a reasonable period afterwards for fraud prevention, accounting, and legal obligations.
• Server logs: retained by our hosting providers according to their standard retention windows.

6. Your Rights

Depending on where you live, you may have the right to access, correct, export, restrict, or delete the personal data we hold about you, and to withdraw consent where processing is based on consent.

• You can review and update most profile data from the Settings page.
• You can delete voice clones, simulated bank accounts, and generated content directly from the relevant tool.
• To delete your entire account or request a copy of your data, email us at support@lumino.work.

We will respond within a reasonable period. Some data may be retained after deletion where required by law or for legitimate fraud-prevention purposes.

7. Cookies & Tracking

We use strictly necessary cookies to keep you signed in (authentication tokens stored in HTTP-only cookies) and to remember session-level preferences. We do not use marketing cookies, advertising identifiers, or third-party analytics trackers.

8. Children

The Service is for users aged 18 and older. We do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with personal data, please contact us and we will delete it.

9. International Transfers

Our processors operate in the United States, European Union, and other regions. By using the Service, you acknowledge that your personal data may be transferred to and processed in countries outside your own. Where required, we rely on standard contractual clauses or equivalent safeguards provided by our processors.

10. Security

We use industry-standard measures to protect your data, including TLS in transit, bcrypt password hashing, short-lived access tokens, rotating refresh tokens stored in HTTP-only strict cookies, rate limiting, security headers, and upload content-type validation. No system is perfectly secure; you are responsible for keeping your account credentials confidential.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date above. Material changes will also be announced in-app or by email. Continued use of the Service after changes take effect constitutes acceptance of the revised policy.

12. Contact

For privacy questions or data-subject requests, contact us at support@lumino.work.

Data controller: Lumino Labs LLC, registered in Delaware, United States.