Effective Date: March 30, 2026
Last Updated: March 30, 2026

This Privacy Policy describes how Lumiinous LLC (“Lumii,” “we,” “our,” or “us”) collects, uses, discloses, and safeguards personal information when you access or use our website, applications, products, and related services (collectively, the “Services”).

By using the Services, you acknowledge that you have read and understood this Privacy Policy.

1. Scope of This Policy

This Privacy Policy applies to personal information collected through:

• Our website 
• Pre-launch sign-ups and early access forms 
• Beta testing participation 
• Lumii devices and associated mobile or software applications (if applicable) 
• Customer support and communications 

2. Information We Collect

We collect information in the following categories:

3. How We Use Personal Information

We use personal information for the following purposes:

• To provide, operate, and maintain the Services 
• To communicate with you, including updates, announcements, and support responses 
• To manage early access programs and beta testing 
• To improve, develop, and refine our products and user experience 
• To monitor and analyze usage and trends 
• To ensure security, prevent fraud, and enforce our terms 
• To comply with legal obligations 

We do not use personal information for purposes that are materially different without providing notice.

4. Legal Basis for Processing (EEA/UK Users)

If you are located in the European Economic Area or the United Kingdom, we process your personal data based on:

• Consent (e.g., signing up for communications) 
• Legitimate interests (e.g., improving our Services, ensuring security) 
• Performance of a contract (where applicable) 
• Compliance with legal obligations 

5. How We Share Information

We do not sell personal information.

We may disclose personal information to:

5.1. Service Providers
Third-party vendors that perform services on our behalf, such as:

• Hosting providers 
• Email delivery platforms 
• Analytics providers 

These parties are contractually obligated to use personal information only as necessary to provide services to us.

5.2. Legal and Compliance
We may disclose information:

• To comply with applicable laws, regulations, or legal processes 
• To respond to lawful requests from public authorities 
• To protect our rights, property, or safety, or that of users or others 

5.3. Business Transfers
In connection with a merger, sale, financing, or acquisition, personal information may be transferred as part of that transaction.

6. California and U.S. State Privacy Rights

Under applicable U.S. state privacy laws, including the California Consumer Privacy Act as amended, you may have the right to:

• Request access to the personal information we collect about you 
• Request deletion of your personal information 
• Request correction of inaccurate personal information 
• Opt out of the “sale” or “sharing” of personal information (as defined by law) 
• Limit the use of certain sensitive personal information (if applicable) 

We do not sell or share personal information as defined under applicable laws.

To exercise your rights, please contact us using the information below.

7. Data Retention

We retain personal information only for as long as necessary to:

• Fulfill the purposes described in this Privacy Policy 
• Provide the Services 
• Comply with legal obligations 
• Resolve disputes and enforce agreements 

When no longer required, we will delete or anonymize personal information.

8. International Data Transfers

Your information may be transferred to, stored, and processed in the United States or other jurisdictions where our service providers operate.

Where required, we implement appropriate safeguards to ensure your personal information remains protected in accordance with applicable laws.

9. Data Security

We implement reasonable and appropriate administrative, technical, and physical safeguards designed to protect personal information.

However, no system is completely secure, and we cannot guarantee absolute security.

10. User-Generated Content and Product Interactions

If you interact with Lumii devices or submit content (such as feedback, responses, or communications):

• Such information may be processed to improve product functionality and user experience 
• We do not intentionally collect sensitive personal information unless voluntarily provided 
• Users should avoid sharing highly sensitive or confidential information during interactions 

11. Children’s Privacy

The Services are not directed to children under the age of 13 (or the applicable age in your jurisdiction).

We do not knowingly collect personal information from children. If we become aware of such collection, we will take steps to delete the information promptly.

12. Third-Party Links and Services

Our Services may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties.

We encourage you to review their privacy policies before providing any information.

13. Accessibility

We are committed to making our website accessible to all users, including those with disabilities.

Our efforts include:
• Clear and readable text structure
• Adequate color contrast
• Accessible forms and navigation

If you experience any accessibility issues, please contact us so we can improve your experience.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If we make material changes, we will provide notice through the Services or by other appropriate means. The “Last Updated” date reflects the most recent changes.

15. Contact Us

If you have questions or requests regarding this Privacy Policy or our data practices, please contact us:

Lumiinous LLC
Email: Customersupport@lumiinous.com

16. Personalization and Memory (AI Systems)

Lumii may provide functionality that enables the retention of certain information derived from user interactions (“Memory”) as part of the Services. Memory features are designed to support personalization, continuity, and an improved user experience.

Where enabled, Lumii may collect, generate, infer, or store information from user interactions, including user preferences, conversational context, interaction history, and usage-related signals.

16.1 Purpose of Processing

Information retained through Memory functionality may be used solely for:

Personalizing and tailoring the user experience over time;
Maintaining continuity and contextual awareness across sessions;
Improving relevance, accuracy, and usefulness of responses and features; and
Enhancing and developing the Services.

This processing is conducted to provide a more consistent and individualized experience consistent with commonly used personalization practices in modern AI systems.

16.2 User Control and Deletion

Users retain full control over Memory and interaction history within the Services.

Users may, at any time, delete stored memories and/or their interaction history through in-product settings or interface controls. Once deleted, such information will no longer be used for personalization purposes.

Where technically feasible, deletion actions are processed promptly in accordance with standard system practices. Residual copies may persist temporarily in secure backup systems for a limited period before being automatically deleted in the ordinary course of system operations.

16.3 Data Use Limitations

Lumii does not intentionally design Memory functionality to store Sensitive Personal Information, and users are strongly discouraged from providing confidential, sensitive, or high-risk personal data.

Information retained through Memory is used solely to support personalization and improvement of the Services and is not used for unrelated purposes.

16.4 Privacy Framework

Lumii implements Memory functionality in accordance with privacy-by-design and data minimization principles and seeks to align with applicable data protection frameworks, including principles reflected in the General Data Protection Regulation (“GDPR”) and guidance issued by relevant consumer protection authorities.