Privacy Policy
1. Introduction
This Privacy Policy ("Policy") describes how Lumora ("Developer", "we", "us") collects, uses, stores, and shares the personal data of users of the Lumora mobile application.
By using the App, you agree to the terms of this Policy. If you do not agree, please do not use the App.
2. Categories of Data Collected
2.1. Data you provide:
- Name, email address, gender (upon registration);
- Photos of clothing and wardrobe items;
- Photos used for the Virtual Try-On feature;
- Clothing sizes and style preferences;
- Payment transaction data (processed by third parties).
2.2. Data collected automatically:
- Device identifier (including the Google advertising ID), operating system, app version;
- IP address, session data; approximate location derived from the IP address;
- Device location — only with your permission, for the weather feature (a city can also be selected manually without granting location access);
- App feature usage data;
- Log files and error reports.
2.3. Data from third parties:
- Authentication data when signing in via Google, Apple, or other social networks.
3. Purposes of Data Processing
We process your data to:
- Provide and improve the Service;
- Generate personalized AI outfit recommendations;
- Process Virtual Try-On feature requests;
- Authenticate users and secure accounts;
- Provide technical support;
- Analyze App usage to improve functionality;
- Comply with applicable legal requirements;
- Detect and prevent fraud.
4. Legal Bases for Processing
- Performance of a contract — to provide the Service;
- Legitimate interest — to improve the Service and ensure security;
- Consent — for marketing communications (separately obtained);
- Legal obligation — when required by applicable law.
5. Sharing Data with Third Parties
We may share your data with the following recipients:
| Recipient | Purpose | Safeguards |
|---|---|---|
| Anthropic, Inc. | AI-powered style recommendations and textual wardrobe item analysis | Anthropic Privacy Policy |
| fal.ai (Fal, Inc.) | Virtual Try-On feature as well as advanced AI garment digitization and visualization (background removal, 3D mannequin rendering, and studio garment image generation from user photos) | fal.ai Privacy Policy |
| Contabo GmbH (Germany / EU) | Server hosting, database management, compute infrastructure, and secure media storage | GDPR compliance, Data Processing Agreement (DPA), Germany data centers |
| Payment processors | Payment and subscription processing (where applicable) | PCI DSS |
| Analytics services | App usage analysis and service stability monitoring | Respective service policies |
| TikTok (TikTok for Business) | Advertising campaign measurement: the advertising device ID (GAID), in-app events (registration, outfit creation, etc.), approximate location derived from the IP address, and — where available — email address and phone number in de-identified (hashed) form. This collection is optional and not required for the App to function | TikTok for Business Privacy Policy |
| Image generation & processing providers | Generating and visually adapting clothing representations based on descriptions and uploaded garment photos | Respective service privacy policies |
We do not sell your personal data to third parties.
We may disclose data as required by law, court order, or competent regulatory authorities.
6. International Data Transfers
Our core server infrastructure and primary databases are hosted in Contabo GmbH data centers located within the European Union (Germany), ensuring adherence to strict European data protection standards (GDPR). When interacting with specialized AI services (Anthropic, Inc., fal.ai / Fal, Inc.), data may be processed on secure nodes in the United States and EU under EU Standard Contractual Clauses (SCCs).
7. Data Retention
We retain your data for the duration of your account plus 1 year after account deletion. Certain categories of data (transactional, tax-related) are retained in accordance with applicable legal requirements. Data may be retained longer when there is a legal basis to do so (litigation, regulatory requirements).
8. Data Security
We apply technical and organizational measures to protect your data, including encryption in transit (TLS) and at rest.
However, we cannot guarantee absolute data security. Data transmission over the internet carries inherent risks. You acknowledge and accept this risk.
In the event of a data breach, we will notify you in accordance with applicable legal requirements.
9. Photos, Garment Digitization, and Virtual Try-On
Photos uploaded to the App (garment photos and user personal photos) are processed by computer vision algorithms and generative AI models for wardrobe cataloging, garment feature extraction, and outfit curation.
When using the Virtual Try-On feature or the advanced garment digitization model (generating studio-grade garment photos, 3D mannequins, and fixing photo defects), your photos are transmitted in encrypted form to the third-party service fal.ai (Fal, Inc.) for processing. Transmission is performed solely to generate the requested visual result. The Developer is not responsible for fal.ai's handling of such data after receipt.
We recommend not uploading photos that show the faces of other people, confidential information, or personal data of third parties. By uploading such photos, you assume full responsibility for obtaining consent from the individuals depicted.
10. Your Rights
Depending on applicable law, you have the following rights:
- Access — obtain a copy of your data;
- Rectification — correct inaccurate data;
- Erasure — request deletion of your data ("right to be forgotten");
- Restriction — restrict the processing of your data;
- Portability — receive your data in a machine-readable format;
- Objection — object to processing based on legitimate interest.
To exercise your rights, contact us at: support@lumenstyle.net
11. Account Deletion
To request the deletion of your account and associated data, send an email to support@lumenstyle.net with the subject "Account Deletion" from the email address associated with your account.
Data that will be deleted:
- User profile (name, email, gender, style preferences);
- Photos of clothing and wardrobe items;
- Saved outfits and recommendations;
- Virtual Try-On usage history;
- Session data and app settings.
Data that may be retained:
- Transaction and payment data — as required by tax and financial regulations (up to 5 years);
- Anonymized analytics data;
- Data required to fulfill legal obligations (court orders, regulatory requirements).
Timeframes: deletion requests are processed within 30 days. After account deletion, backup copies of data are removed within 90 days.
12. Children
The App is not intended for persons under 18 years of age. We do not knowingly collect data from minors. If you become aware that a child has provided us with data, please notify us immediately — we will delete such data.
13. Modifications to the Policy
We may update this Policy at any time. The current version will be published in the App with the update date indicated. Continued use of the App following any updates constitutes your acceptance of the revised Policy.
14. Contact Information
For privacy-related inquiries:
Email: support@lumenstyle.net