Privacy Policy

1. Introduction

Lumo ("we," "our," or "us") provides a mobile application and web platform that transforms photos into coloring pages using artificial intelligence. This Privacy Policy applies to all users of the Lumo app (available on iOS and Android) and website.

By using Lumo, you agree to the collection and use of information in accordance with this policy.

2. Age Requirements

Lumo is designed for users 13 years and older. We do not knowingly collect personal information from users under 13.

Age Verification

• Users must be at least 13 years old to use this App
• By using Lumo, you represent that you are at least 13 years of age
• If you are under 13, you may not use this App

3. Information We Collect

3.1 Information You Provide

• Account Information: When you create an account, we collect your email address, name, and authentication information (via Apple Sign In or Google Sign In)
• Profile Information: Optional profile details such as username and avatar selection
• Photos: Images you capture or upload to create coloring pages (stored securely and processed only to generate coloring pages)
• Payment Information: Subscription and purchase information processed through Apple App Store or Google Play Store (we do not store credit card details)

3.2 Information Automatically Collected

• Device Information: Device type, operating system version, unique device identifiers
• Usage Data: Features used, pages generated, time spent in app, app crashes and errors

Note: We do not currently collect analytics data but may implement anonymized analytics in the future to improve our services. If we do, we will update this Privacy Policy and the app description on the App Store/Google Play.

3.3 Information We Do NOT Collect

• We do not track your location
• We do not access your contacts or calendar
• We do not collect biometric data
• We do not share your photos with third parties

4. How We Use Your Information

We use the information we collect for the following purposes:

4.1 Provide Services

• Generate coloring pages from your photos using AI
• Store and manage your created coloring pages
• Provide access to your account across devices
• Process subscription and in-app purchases

4.2 Improve Our Services

• Analyze app usage to improve features and performance
• Fix bugs and technical issues
• Develop new features based on user behavior
• Ensure app security and prevent fraud

4.3 Communication

• Send important service updates and notifications
• Respond to your support requests
• Notify you about subscription renewals or expiration
• Send optional promotional communications (you can opt-out anytime)

5. How We Store and Protect Your Information

5.1 Data Storage

• Cloud Storage: We use Google Firebase to securely store user data
• Encryption: All data is encrypted in transit (HTTPS/TLS) and at rest
• Server Location: Our servers are located in secure data centers in the United States
• Retention: We retain your data as long as your account is active or as needed to provide services

5.2 Security Measures

• Industry-standard encryption protocols
• Secure authentication via Apple and Google
• Regular security audits and updates
• Limited employee access to user data
• Secure API endpoints with authentication

5.3 Photos and Images

Important Information About Your Photos:

• Original Photos: Your original uploaded photos are stored securely and privately. Only you can access them. They are never shared with other users or third parties.
• Generated Coloring Pages: AI-generated coloring pages are initially private to your account only
• Public Sharing: If you choose to share a coloring page publicly:
  • Only the AI-generated coloring page becomes publicly visible on our website and community gallery
  • Your original photo remains private and is never shared
  • The shared coloring page becomes community content and will remain publicly available even if you delete your account
  • You retain copyright to your original photo; we have a license to display the generated coloring page
• Deletion:
  • You can delete any private coloring pages and your original photos at any time
  • When you delete your account, all private content is permanently removed
  • Publicly shared coloring pages remain available as community content
• Photos are never used for advertising or marketing purposes
• We do not use your photos to train AI models for other companies

6. Information Sharing and Disclosure

We do not sell, rent, or share your personal information with third parties except in the following limited circumstances:

6.1 Service Providers

• Firebase/Google Cloud: Cloud infrastructure and database services
• RevenueCat: Subscription management (only receives anonymized purchase data)
• Apple/Google: Authentication and payment processing
• AI Services: Image processing for coloring page generation (images are processed securely and not stored)

6.2 Legal Requirements

We may disclose your information if required by law or in response to:

• Valid legal processes (court orders, subpoenas)
• Protecting our rights, property, or safety
• Preventing fraud or illegal activities
• Protecting the safety of users or the public

6.3 Business Transfers

If Lumo is involved in a merger, acquisition, or sale of assets, your information may be transferred. We will notify you before your information becomes subject to a different privacy policy.

7. Your Rights and Choices

7.1 Access and Control

You have the right to:

• Access: View all personal information we have about you
• Update: Modify your account information and preferences
• Delete: Request deletion of your account and all associated data
• Export: Download a copy of your data
• Opt-out: Unsubscribe from promotional communications

7.2 Camera and Photo Access

• You can revoke camera and photo library access at any time through device settings
• Revoking access will prevent you from creating new coloring pages
• Previously created pages will remain accessible

7.3 Marketing Communications

• You can opt-out of promotional emails by clicking "unsubscribe"
• You can disable push notifications in device settings
• Essential service communications cannot be disabled

7.4 Account Deletion

To delete your account:

1. Go to Settings in the app
2. Select "Account Settings"
3. Choose "Delete Account"
4. Confirm your decision

Account deletion is permanent and will remove all your data, including coloring pages, within 30 days.

8. Third-Party Services

8.1 Authentication

• Apple Sign In: Apple Privacy Policy
• Google Sign In: Google Privacy Policy

8.2 Payment Processing

• Apple App Store: Apple Privacy Policy
• Google Play Store: Google Privacy Policy
• RevenueCat: RevenueCat Privacy Policy

8.3 Analytics and Performance

• Firebase Analytics: Firebase Privacy

9. International Users

Lumo is operated from the United States. If you are located outside the US, please be aware that information we collect will be transferred to and processed in the United States.

9.1 GDPR Compliance (European Users)

For users in the European Economic Area (EEA):

• Legal Basis: We process data based on consent and legitimate interests
• Data Protection Officer: Contact contact@doola.ai
• Rights: You have additional rights under GDPR, including data portability and the right to object
• Supervisory Authority: You can lodge a complaint with your local data protection authority

9.2 CCPA Compliance (California Residents)

California residents have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected
• Right to delete personal information
• Right to opt-out of sale of personal information (we do not sell personal information)
• Right to non-discrimination for exercising CCPA rights

10. Cookies and Tracking

The Lumo mobile app does not use cookies. However, our website may use:

• Essential Cookies: Required for website functionality
• Analytics Cookies: To understand website usage (can be disabled)

The mobile app may use similar technologies (local storage, device identifiers) for app functionality and analytics.

11. Data Retention

We retain your information as long as your account is active or as needed to provide our services. You can request deletion of your data at any time through the app settings.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated "Last Updated" date. For material changes, we will:

• Notify you via email
• Display an in-app notification
• Request consent if required by law

Your continued use of Lumo after changes indicates acceptance of the updated policy.

13. Contact Us

14. Additional Resources

• Terms of Service
• GDPR Information
• CCPA Information