Privacy Policy

Zafeiry OÜ, a private limited company registered in Estonia, trading as Lumigen ("Lumigen", "we", "us", or "our") provides an AI-powered platform for generating videos, images, avatars, voices, and related media (the "Service"). This Privacy Policy applies to personal information we collect when you visit our website, create an account, or use the Service.

By using the Service you acknowledge that you have read and understood this Privacy Policy. If you do not agree with it, please do not use the Service.

We collect information in two main ways: information you give us and information we collect automatically when you use the Service.

Please do not send us sensitive personal data unrelated to the features you are using — for example, government identifiers or health data. We have no need for it and prefer not to receive it.

We use personal information to:

• Provide the Service, including account creation, authentication, and generating the content you request;
• Process payments and manage your subscription and credit balance;
• Send transactional messages (receipts, security alerts, service notices);
• Respond to support requests and handle compliance or legal inquiries;
• Monitor, debug, and secure the Service, prevent fraud and abuse, and enforce our Terms;
• Measure aggregate usage and improve the Service;
• Send you marketing communications where permitted — you can opt out at any time;
• Comply with legal obligations.

We do not use your prompts, uploads, or generated content to train our own AI models.

Generation runs on third-party AI providers that process your inputs on our behalf to produce the output you requested. Those providers operate under their own privacy policies and their agreements with us. We do not sell your inputs.

We do not sell your personal information. We share it in the following circumstances:

• With service providers that operate the Service on our behalf, including cloud hosting and infrastructure providers, AI model providers, payment processors, email delivery services, and analytics tools. These providers are engaged under terms intended to protect your information.
• With Affonso (our affiliate-tracking platform): when you convert to a paid plan through an affiliate link, we share your email address with Affonso for the purpose of attributing and paying the referring affiliate's commission. Affonso acts as a data sub-processor under our instructions. For more information see Affonso's Privacy Policy.
• With legal and government authorities where required by law, subpoena, court order, or to protect our rights, safety, or property, or that of others;
• In connection with a business transaction, such as a merger, acquisition, financing, or sale of assets, in which case we will make reasonable efforts to notify you before your information becomes subject to a different privacy policy;
• With your consent for any other purpose disclosed at the time of collection.

We retain personal information for as long as necessary to provide the Service, maintain your account, enforce our Terms, resolve disputes, comply with our legal and tax obligations, and otherwise as required or permitted by applicable law. When retention is no longer needed, we delete or anonymize the information so it can no longer reasonably be linked to you.

We use reasonable technical and organizational measures designed to protect personal information against unauthorized access, use, alteration, or disclosure. Please note that no method of transmission or storage is completely secure.

If we become aware of a personal data breach that affects your information, we will notify affected users and authorities to the extent required by applicable law.

Lumigen is operated from Estonia, within the European Economic Area (EEA). To provide the Service, we use global infrastructure and third-party AI providers located outside the EEA, including in the United States. When your personal data is transferred outside the EEA, we ensure appropriate safeguards are in place, such as the European Commission's Standard Contractual Clauses (SCCs) or adequacy decisions where applicable.

For a list of the key third-party providers we use and the countries in which they operate, please contact us at privacy@lumigen.app.

Regardless of where you live, you can:

• Access and update your account information in your account settings;
• Request a copy of your personal information;
• Delete your account and associated user content from your account settings or by emailing privacy@lumigen.app;
• Opt out of marketing email via the unsubscribe link in any marketing message.

Depending on where you live, you may have additional rights under applicable data protection laws — for example, under the European Union's General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA). These may include the right to access, correct, delete, or port your personal information, to restrict or object to certain processing, or to withdraw consent. We do not sell your personal information.

To exercise any of these rights, please contact privacy@lumigen.app. We will respond to rights requests as required by applicable law. Some information may be retained after a deletion request for the limited purposes described in Section 5, such as billing records required by tax law.

If you believe we have not adequately addressed your concerns, you may have the right to lodge a complaint with your local data protection authority.

We use a small number of cookies and similar technologies. Some are strictly necessary to authenticate you, keep your session active, and secure the Service. Others remember your preferences, such as light or dark theme. We may also use analytics and marketing technologies to measure traffic, debug errors, and understand how the Service is used.

You can control cookies through your browser settings. Blocking strictly necessary cookies will break parts of the Service.

The Service is not intended for children under the age of 16. You must be at least 16 years old to use the Service. We do not knowingly collect personal information from users under 16. If you believe a child under 16 has provided us with personal information, please contact privacy@lumigen.app and we will delete it.

We may update this Privacy Policy from time to time. When we do, we will update the "Last Updated" date at the top of this page. For material changes, we will provide reasonable notice where required by law. Your continued use of the Service after the effective date constitutes acceptance of the updated policy.

If you have questions about this Privacy Policy or how we handle your personal information, please contact us: