Introduction

This Privacy Policy explains how lummie.app ("Company," "we," or "us") collects and processes your personal data in compliance with the General Data Protection Regulation (GDPR/RODO).

1. Information We Collect

Personally Identifiable Information (PII): Name, email address, and authentication tokens from third-party services (e.g., Google).
Service Data: Natural language prompts you submit for code and image generation.
Technical Data: IP address, browser type, device identifiers, and usage patterns collected via cookies.

2. Legal Basis for Processing

We process your data based on:

Art. 6(1)(b) GDPR: Performance of a contract (to provide the Services).
Art. 6(1)(f) GDPR: Legitimate interests (to secure the platform and monitor for abuse).
Art. 6(1)(a) GDPR: Consent (for marketing communications, where applicable).

3. AI Training & Security Logs

Zero-Retention Policy: We do NOT use your prompts or generated results to train, improve, or retrain our AI models or those of our third-party providers.

Safety Moderation: To ensure compliance with our Platform Rules, we maintain ephemeral security logs for a maximum of 30 days. These logs are used solely for identifying abuse and are never utilized for machine learning.

4. Third-Party Processors & Reve API

We share specific data with the following categories of processors:

AI Providers: Your text prompts are transmitted to Reve API to generate visual content. Please review the Reve Privacy Policy for their specific data handling.
Cloud Infrastructure: To host the platform and databases.
Payment Services: PCI-compliant providers to process your subscriptions.

5. International Data Transfers

Some data may be processed in the United States. We ensure protection via Standard Contractual Clauses (SCCs) approved by the European Commission to maintain an equivalent level of data protection as in the EEA.

6. Data Retention

We retain your PII for as long as your account is active. Upon account deletion, PII is removed or anonymized within 90 days, except where longer retention is required for legal or financial compliance.

7. Your Rights (RODO/GDPR)

Under Polish and EU law, you have the right to access, rectify, or erase your data, as well as the right to data portability and the right to object to processing.

If you are in Poland, you have the right to lodge a complaint with the President of the Personal Data Protection Office (Urząd Ochrony Danych Osobowych - UODO).

8. Contact Information

For data-related inquiries, contact us at: legal@lummie.app