Privacy Policy

Last updated: March 2026 · Effective immediately

1. Who We Are

Lumina ("we", "us", "our") is an AI-powered emotional intelligence tool operated at luminasoul-vhjmhpie.manus.space. We are committed to protecting your personal data and respecting your privacy in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

For any privacy-related queries, contact us at: [email protected]

2. What Data We Collect

Account Data

If you sign in via Manus OAuth, we receive your name, email address, and a unique identifier (openId). This is used to manage your account and Pro subscription status.

Conversation Data

Messages you send to the Lumina AI are processed in real time to generate responses. We do not permanently store your conversation content on our servers. Conversation history is stored locally in your browser (localStorage) only.

Payment Data

Payments are processed by Stripe. We do not store your card details. We receive a Stripe Customer ID and payment confirmation to activate your Pro status.

Usage Data

We collect anonymised analytics (page views, session counts) to improve the service. This data cannot be used to identify you personally.

We use essential cookies for session management and optional analytics cookies. See our Cookie Policy for full details.

3. How We Use Your Data

We use your data to:

Provide and improve the Lumina AI service
Manage your account and Pro subscription
Process payments via Stripe
Send transactional communications (e.g. payment confirmation)
Comply with legal obligations
Prevent fraud and ensure security

We do not sell your data to third parties. We do not use your conversations to train AI models.

4. Legal Basis for Processing (UK GDPR)

Purpose	Legal Basis
Providing the AI service	Contractual necessity
Processing payments	Contractual necessity
Analytics & improvement	Legitimate interests
Marketing communications	Consent (opt-in only)
Legal compliance	Legal obligation

5. Data Retention

Account data is retained for as long as your account is active. If you delete your account, we will delete your personal data within 30 days, except where we are required to retain it for legal or financial compliance purposes (e.g. Stripe transaction records, which are retained for 7 years under UK tax law).

Conversation data stored in your browser's localStorage is entirely under your control and can be cleared at any time via your browser settings or within the Lumina app.

6. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

Right of access — request a copy of the data we hold about you
Right to rectification — request correction of inaccurate data
Right to erasure — request deletion of your data ("right to be forgotten")
Right to restrict processing — request we limit how we use your data
Right to data portability — receive your data in a machine-readable format
Right to object — object to processing based on legitimate interests
Rights related to automated decision-making — the Lumina AI does not make legally significant automated decisions about you

To exercise any of these rights, contact [email protected]. We will respond within 30 days. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO).

7. Third-Party Services

Stripe — payment processing. Stripe Privacy Policy

Manus AI Platform — AI model inference and hosting infrastructure. Data processed under Manus's data processing agreement.

AWS CloudFront — content delivery network for static assets.

8. International Data Transfers

Some of our service providers may process data outside the UK. Where this occurs, we ensure appropriate safeguards are in place (such as UK adequacy decisions or Standard Contractual Clauses) to protect your data to the same standard as required under UK GDPR.

9. Children's Privacy

Lumina is not intended for users under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us immediately at [email protected].

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by updating the "Last updated" date at the top of this page. Continued use of Lumina after changes constitutes acceptance of the updated policy.