Who Operates Lumingo
Lumingo is currently operated by the Lumingo project. For now, the Lumingo project is the operator and controller of Lumingo. This wording may be updated after incorporation.
Lumingo is intended for users aged 16 and older. If you are under 18, you should use Lumingo only with permission from a parent or legal guardian.
Scope
This Privacy Policy applies to Lumingo's website, app, account features, AI learning features, chats, uploads, analytics, and support communications.
Lumingo is globally accessible, but it does not specifically target every jurisdiction, including the EU, UK, or California. Some privacy rights may depend on where you live.
Information We Collect
- Account information: email address, user ID, sign-in method, display name, avatar, preferred language, and account timestamps.
- Learning information: goals, target language, motivation, level, schedule, constraints, diagnostic answers, personalized learning plans, daily tasks, progress, scores, streaks, exercise results, and AI-generated learning content.
- Chat and AI content: prompts, messages, conversation history, learning context, AI responses, and related feedback.
- Upload information: uploaded text, document contents that can be extracted or provided, images, file names, and attachment context.
- Technical and analytics information: device/browser information, page views, referral and UTM information, product events, performance data, technical logs, AI operation logs, error logs, and reliability diagnostics.
- Payment information if paid plans launch: subscription status, plan, payment provider customer/subscription identifiers, and related billing metadata. Lumingo does not directly store full card details.
Uploads
Files uploaded during setup or chat are processed to provide AI responses and learning support. Lumingo does not store these uploads as standalone files, except for profile avatars.
Extracted content, file names, user messages, AI context, and related AI/technical logs may be stored as part of conversations, learning history, or reliability diagnostics. Profile avatars are stored as image files so they can be displayed in your account.
Please do not upload third-party personal data, confidential data, illegal content, medical, financial, or legal documents, or content you do not have rights to share.
How We Use Information
- Create and personalize your learning plan.
- Provide AI chat, diagnostics, explanations, and learning support.
- Save your account, settings, progress, and learning history.
- Operate, secure, debug, and improve Lumingo.
- Prevent abuse, enforce limits, and maintain reliability.
- Provide customer support.
- Understand product usage and improve the beta.
- Process billing if paid plans are introduced.
- Comply with legal obligations where applicable.
Legal Bases
Where privacy laws require a legal basis, Lumingo may rely on service performance, legitimate interests, consent where required, and legal obligations.
These bases help us provide your account, learning plan, AI features, progress tracking, support, security, debugging, analytics, abuse prevention, optional communications, and legally required processing. The exact legal basis may depend on the feature, the data involved, and your location.
AI Processing
Lumingo uses AI providers and subprocessors to generate responses, diagnostics, explanations, feedback, and personalized learning plans.
Your prompts, goals, chats, uploaded text, document contents, images, and learning context may be sent to AI providers or subprocessors to provide these features.
Lumingo does not use your user content to train Lumingo's own AI models unless Lumingo gives a new notice or updates this Policy.
Lumingo does not intentionally use user content to train third-party AI foundation models. However, AI providers may process data according to their own service terms, privacy terms, and subprocessor arrangements.
AI output may be inaccurate. Do not rely on Lumingo for medical, legal, financial, or other professional advice.
Cookies, Analytics, And Local Storage
Lumingo uses cookies and similar technologies for authentication, language preferences, password recovery, attribution, analytics, security, and app functionality.
Lumingo may also use browser local storage and session storage to keep temporary app state, drafts, recovery state, cooldowns, language switching state, and learning-flow continuity.
Lumingo uses analytics to understand how people use the product and where the experience can be improved. Current analytics are designed to be limited and product-focused, not to record everything you do.
Consent requirements for cookies and analytics may vary by jurisdiction. Lumingo may add or update consent controls as the product and legal setup mature.
Providers And Subprocessors
These providers process information to help operate Lumingo. Their processing may be subject to their own terms, privacy policies, and subprocessor arrangements.
- Supabase for database, authentication, and storage.
- Vercel for hosting, deployment, and performance insights.
- OpenRouter, OpenAI, and Anthropic for AI processing where used.
- PostHog for product analytics.
- Upstash for rate limiting and reliability.
- Stripe for payments if billing launches.
- Google OAuth for sign-in.
No Sale Of Personal Data
Lumingo does not sell personal data.
Lumingo also does not share personal data for cross-context behavioral advertising as part of the current product setup. If this changes, Lumingo will update this Policy and provide any required choices.
Children's Privacy
Lumingo is not intended for children under 16. Lumingo does not knowingly collect personal data from children under 16.
If we learn that a child under 16 has created an account or provided personal data, we may delete the account and related data. If you believe this has happened, contact privacy@lumingo.me.
Retention
Lumingo keeps information for as long as reasonably needed to provide the service, maintain security and reliability, support users, improve the product, comply with legal obligations, and resolve disputes.
While the beta is evolving, Lumingo uses retention criteria rather than fixed public retention periods. More specific retention and backup details may be added after Lumingo's legal setup matures.
Account Deletion
Account deletion is available in the working version of Lumingo from Settings when the deletion feature is enabled.
Deleting your account is intended to permanently remove your sign-in account and app-owned learning data, including your profile, goals, learning plans, progress, conversations, user-linked analytics, and user-linked AI operation logs.
If paid plans launch, account deletion may be temporarily blocked while subscription status or billing obligations are reviewed.
For practical instructions, see Account Deletion. You may also contact privacy@lumingo.me for deletion or privacy requests.
Your Privacy Rights
Depending on where you live, you may have rights to request access, correction, deletion, restriction, objection, portability, and withdrawal of consent where processing is based on consent.
These rights are not absolute and may depend on applicable law, identity verification, technical feasibility, and Lumingo's legal obligations. To make a request, contact privacy@lumingo.me.
Security
Lumingo uses technical and organizational measures to protect information, including authentication, access controls, database security rules, rate limiting, and operational monitoring. No online service can guarantee perfect security. For more detail, read the Security page. If you discover a security issue, contact security@lumingo.me.
International Processing
Lumingo is globally accessible. Your information may be processed in countries where Lumingo and its providers operate.
Because Lumingo does not yet have a finalized legal entity and international transfer setup, transfer wording and any required safeguards may be updated later.
Changes
Lumingo may update this Privacy Policy as the product, providers, legal setup, or data practices change. If changes are material, Lumingo will make reasonable efforts to show the updated Policy clearly.
Contact
Privacy and deletion requests: privacy@lumingo.me
General support: support@lumingo.me
Security reports: security@lumingo.me
Billing, when paid plans launch: billing@lumingo.me