Privacy Policy

Welcome to Lumi Buddy (“Lumi Buddy,” “we,” “our,” or “us”). Lumi Buddy is an AI companion service operated by Lumi AI, a business registered in Thailand.

Lumi Buddy is an AI-powered companion platform designed to provide personalized conversations, memory features, voice interactions, visual AI capabilities, relationship-building experiences, subscription services, and other artificial intelligence-powered features (collectively, the “Services”).

Your privacy is important to us. This Privacy Policy explains how we collect, use, process, store, share, protect, and retain your personal information when you access or use our Services through our mobile applications, websites, or any future platforms operated by Lumi Buddy.

This Privacy Policy applies to all current and future Services provided by Lumi Buddy, including any features, technologies, products, subscription plans, AI capabilities, communication methods, or functionalities that may be introduced in the future unless otherwise stated.

By creating an account, accessing, or using our Services, you acknowledge that you have read, understood, and agree to the collection and use of your information as described in this Privacy Policy.

If you do not agree with this Privacy Policy, you should discontinue using our Services.

Our Commitment to Privacy

At Lumi Buddy, we believe that trust is the foundation of every meaningful relationship.

Because our Services are designed to become a trusted AI companion, we recognize that users may choose to share personal conversations, memories, preferences, goals, emotions, images, voice interactions, and other sensitive information with us.

We are committed to handling this information responsibly by:

• Collecting only the information necessary to provide and improve our Services.
• Being transparent about how your information is collected and used.
• Protecting your information using reasonable administrative, technical, and organizational security measures.
• Giving you meaningful control over your personal information whenever possible.
• Continuously improving our privacy and security practices as our Services evolve.

Scope of This Privacy Policy

This Privacy Policy applies to all information collected through:

• The Lumi Buddy mobile application;
• The Lumi Buddy website;
• AI-powered conversations;
• Voice features, including current and future voice-based services;
• Image and visual AI features;
• Memory and personalization features;
• Subscription and payment services;
• Customer support communications;
• Promotional campaigns and events;
• Beta features and experimental services;
• Any other products or services provided by Lumi Buddy now or in the future.

This Privacy Policy does not apply to third-party services that operate independently from Lumi Buddy, even if they are accessible through our Services. Those services are governed by their own privacy policies and terms.

Changes as Our Services Grow

Lumi Buddy is continuously evolving.

As we introduce new AI technologies, communication methods, subscription offerings, personalization systems, or additional features, we may update this Privacy Policy to reflect those changes.

Unless otherwise stated, newly introduced features and Services will also be governed by this Privacy Policy.

If we make material changes that significantly affect how your personal information is handled, we will provide appropriate notice through the application, our website, email, or other reasonable communication channels before the changes take effect.

Your continued use of the Services after such updates becomes effective constitutes your acceptance of the revised Privacy.

For the purposes of this Privacy Policy, the following terms shall have the meanings set forth below:

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2.1 "Account"

An account registered by a user to access and use the Services, including any associated profile, authentication credentials, subscription status, preferences, memories, achievements, relationship progress, and other account-related information.

2.2 "AI Features"

Any artificial intelligence-powered functionality provided by Lumi Buddy, including but not limited to text conversations, personalized responses, memory features, recommendations, image understanding, voice interactions, relationship systems, AI-generated content, and any future AI capabilities introduced as part of the Services.

2.3 "Content"

Any information, text, prompts, conversations, memories, images, voice recordings, audio, files, feedback, preferences, profile information, or other materials that are created, submitted, uploaded, generated, stored, or exchanged through the Services.

2.4 "Device"

Any smartphone, tablet, computer, wearable device, smart display, or other hardware capable of accessing the Services.

2.5 "Image Features"

Features that enable users to upload, analyze, generate, edit, process, or otherwise interact with images or visual content, including AI Vision, profile images, avatars, image generation, image editing, and future visual AI technologies.

2.6 "Lumi Buddy"

The AI companion platform, including its mobile applications, websites, APIs, software, services, features, subscription plans, and any products operated under the Lumi Buddy brand.

2.7 "Memories"

Information intentionally stored to personalize future interactions, including user preferences, relationship milestones, interests, important events, conversation summaries, reminders, goals, personality preferences, and other personalization data.

2.8 "Paid Services"

Any subscription plan, add-on, premium feature, virtual item, consumable purchase, promotional offering, or future paid product made available through the Services, including but not limited to Premium, Infinity, message packs, voice packs, image packs, and future subscription offerings.

2.9 "Personal Information"

Any information that identifies, relates to, describes, or can reasonably be linked to an individual, including but not limited to names, email addresses, profile information, account identifiers, IP addresses, device identifiers, and other information protected under applicable privacy laws.

2.10 "Relationship Features"

Features that support engagement and progression between users and Lumi Buddy, including friendship levels, relationship badges, achievements, XP, milestones, gifts, streaks, seasonal events, and future engagement systems.

2.11 "Services"

All products, applications, websites, AI features, subscription services, communication tools, APIs, software, and future services provided or operated by Lumi Buddy.

2.12 "Subscription Plan"

Any free or paid access tier that provides specific features, usage limits, retention periods, benefits, or pricing, including future subscription plans that may be introduced.

2.13 "Third-Party Services"

Services, platforms, software, infrastructure providers, payment processors, AI providers, authentication providers, analytics providers, cloud service providers, or other external partners that assist in delivering the Services.

2.14 "User"

Any individual who accesses, browses, registers for, or otherwise uses the Services.

2.15 "User Content"

Any Content submitted, uploaded, created, generated, or shared by a User through the Services, including conversations, prompts, images, voice interactions, memories, profile information, and feedback.

2.16 "Voice Features"

Features that enable voice-based interactions, including voice chat, voice calls, voice messages, speech recognition, text-to-speech, voice synthesis, and future voice communication technologies.

2.17 "Website"

Any website, web application, landing page, or online platform owned or operated by Lumi Buddy.

2.18 "Applicable Law"

Any law, regulation, governmental requirement, court order, or legally binding obligation applicable to Lumi Buddy or its users in connection with the Services.

2.19 "Business Transfer"

A merger, acquisition, restructuring, financing, sale of assets, or other transaction involving Lumi Buddy that may require the transfer of user information as part of the business operation.

2.20 "Future Services"

Any new products, AI capabilities, communication methods, subscription plans, technologies, integrations, or features introduced after the effective date of this Privacy Policy. Unless otherwise stated, Future Services shall be governed by this Privacy Policy.

To access or use the Services, you must meet the eligibility requirements described in this Section.

By creating an Account or using the Services, you represent and warrant that you satisfy these requirements.

3.1 Minimum Age Requirement

The Services are intended for users who are at least 13 years of age, or the minimum age required by the laws of their country or region to use online services independently.

If the laws of your country require a higher minimum age, that higher age requirement shall apply.

Users who do not meet the applicable minimum age may not create an Account or use the Services without the involvement and consent of a parent or legal guardian where permitted by applicable law.

3.2 Parental or Legal Guardian Consent

If you are under the age required to independently use the Services under the laws of your country or region, you may only access or use the Services with the permission and supervision of your parent or legal guardian, where such use is permitted by applicable law.

Parents and legal guardians are responsible for monitoring the activities of minors using the Services and ensuring that such use complies with this Privacy Policy, our Terms of Service, and applicable laws.

3.3 Accurate Registration Information

You agree to provide accurate, complete, and up-to-date information when creating an Account.

You are responsible for maintaining the accuracy of your account information and promptly updating it whenever necessary.

Providing false, misleading, or fraudulent information may result in the suspension or termination of your Account.

3.4 One Account Per Individual

Unless expressly authorized by Lumi Buddy, each user should maintain only one personal Account.

Creating multiple Accounts for fraudulent purposes, abuse of promotional offers, circumvention of service limitations, or other prohibited activities is not permitted.

3.5 Account Security

You are responsible for maintaining the confidentiality of your login credentials and for all activities that occur under your Account.

You agree to notify Lumi Buddy immediately if you become aware of any unauthorized access, suspected compromise, or security incident involving your Account.

3.6 Eligibility to Enter Into a Legal Agreement

By using the Services, you represent and warrant that you have the legal capacity to enter into a binding agreement under the laws applicable in your jurisdiction.

If you are using the Services on behalf of a company, organization, or other legal entity, you represent and warrant that you have the authority to bind that entity to this Privacy Policy and our Terms of Service.

3.7 Availability of the Services

The Services may not be available in every country or region.

Lumi Buddy reserves the right to limit, suspend, or restrict access to certain Services, features, subscription plans, or AI capabilities based on applicable laws, regulatory requirements, licensing obligations, technical limitations, or business considerations.

3.8 Compliance with Applicable Laws

You are responsible for ensuring that your access to and use of the Services complies with all applicable laws, regulations, and governmental requirements in your jurisdiction.

You may not use the Services where such use is prohibited by law.

3.9 Right to Refuse or Terminate Access

Lumi Buddy reserves the right, at its sole discretion and to the extent permitted by applicable law, to refuse registration, suspend, restrict, or terminate access to the Services if:

• You fail to meet the eligibility requirements described in this Privacy Policy or our Terms of Service;
• You provide false or misleading information;
• Your use of the Services violates applicable laws or our policies;
• Your activities pose a security, legal, or operational risk to Lumi Buddy, other users, or third parties.

Such actions may be taken with or without prior notice where permitted by applicable law.

If you subscribe to Paid Services or purchase digital products, we may receive information relating to those transactions.

This may include:

• Subscription plan
• Purchase status
• Renewal status
• Transaction identifier
• Purchase date
• Expiration date
• Promotional offers
• Trial eligibility
• Purchase history

Lumi Buddy does not collect or store your complete payment card information.

Payments are processed by the applicable platform or payment provider, such as Google Play, Apple App Store, or other authorized payment processors.

4.9 Device & Technical Information

When you access the Services, certain technical information may be collected automatically.

This may include:

• Device model
• Device manufacturer
• Operating system
• Operating system version
• Application version
• Device language
• Time zone
• IP address
• Network information
• Crash reports
• Diagnostic logs
• Performance metrics
• Unique device identifiers (where permitted by law)

This information helps us maintain security, diagnose issues, optimize performance, and improve the reliability of the Services.

4.10 Usage Information

We may collect information about how you interact with the Services.

Examples include:

• Features used
• Frequency of use
• Session duration
• Screens visited
• Buttons tapped
• AI feature usage
• Subscription feature usage
• Error reports
• Navigation patterns
• General engagement metrics

Usage information helps us improve user experience, identify technical issues, understand feature adoption, and develop future improvements.

4.11 Communications

If you contact us, participate in surveys, provide feedback, report bugs, or communicate with our support team, we may collect information such as:

• Email correspondence
• Support requests
• Feedback
• Feature suggestions
• Survey responses
• Bug reports
• Attachments voluntarily provided
• Communication history
• We use this information to provide support, improve our Services, and respond to your inquiries.

4.12 Information from Third Parties

We may receive limited information from trusted third-party service providers to support the operation of the Services.

Depending on the features you use, this information may include:

• Authentication information from sign-in providers
• Subscription status from app stores
• AI processing results from AI service providers
• Fraud prevention signals
• Analytics information
• Other information necessary to operate the Services.

We only use such information for purposes consistent with this Privacy Policy and applicable law.

4.13 Future Information Categories

As Lumi Buddy evolves, we may introduce new Services that require the collection of additional categories of information.

Any new categories of information will be collected only where appropriate, consistent with applicable law, and in accordance with this Privacy Policy or any additional notices provided to you.

Artificial intelligence is a core component of the Services.

Lumi Buddy uses AI technologies to provide personalized conversations, companionship, assistance, recommendations, personalization, and other intelligent features designed to enhance your experience.

As our Services continue to evolve, we may introduce additional AI capabilities that are also governed by this Privacy Policy unless otherwise stated.

5.1 AI-Powered Services

The Services may include, but are not limited to, the following AI-powered features:

• AI conversations
• Personalized responses
• Memory and personalization
• Relationship development
• Voice interactions
• Image understanding
• Image generation
• AI recommendations
• Smart suggestions
• AI-assisted writing
• AI-assisted planning
• AI-generated summaries
• AI-generated content
• AI agents
• Future artificial intelligence capabilities

The availability of specific AI features may vary depending on your subscription plan, device, region, applicable law, or future service updates.

5.2 How AI Uses Your Information

To provide AI-powered functionality, the Services may process information that you voluntarily provide or generate while using the Services.

This information may include:

• Messages
• Prompts
• Conversation history
• Memories
• Preferences
• Voice interactions
• Images
• User instructions
• Profile information
• Relationship progress
• Feedback
• Other information necessary to generate AI responses.

The information processed depends on the specific AI feature being used.

5.3 Personalization

One of Lumi Buddy's primary goals is to provide a personalized AI companion experience.

Where supported, AI may use your existing memories, preferences, relationship history, conversation context, saved information, subscription benefits, and other personalization settings to generate responses that are more relevant and consistent with your previous interactions.

Personalization may improve over time as your interactions with the Services increase.

5.4 AI Memory

Certain AI features may create, update, retrieve, summarize, or organize memories in order to improve future interactions.

Depending on the feature, memories may be:

• created automatically by AI;
• saved by you;
• edited by you;
• deleted by you; or
• managed according to your subscription benefits.

You remain in control of your memories through the controls provided within the Services, where available.

5.5 AI-Generated Content

Responses, recommendations, summaries, generated images, generated voice, and other outputs produced by AI are automatically generated and may contain inaccuracies, omissions, or content that does not reflect factual information.

AI-generated content is intended to assist and entertain users and should not be considered professional advice, factual guarantees, or official statements.

You are responsible for evaluating AI-generated content before relying upon it.

5.6 AI Decision-Making

Lumi Buddy does not use AI to make legally binding decisions on your behalf.

AI-generated outputs are intended to support your experience and should not replace your own judgment or professional advice.

Where AI provides suggestions or recommendations, the final decision remains entirely yours.

5.7 AI Service Providers

To deliver AI-powered functionality, Lumi Buddy may use one or more trusted third-party artificial intelligence service providers.

Depending on the Services, user requests and related information necessary to generate AI responses may be securely transmitted to such providers for processing.

The AI providers used by Lumi Buddy may change over time as our Services evolve.

5.8 AI Improvements

Lumi Buddy continuously improves its AI-powered Services.

Improvements may include:

• new AI models;
• updated prompts;
• improved personalization;
• better memory capabilities;
• enhanced reasoning;
• improved safety systems;
• new communication methods;
• future AI technologies.

These improvements are intended to enhance the quality, reliability, safety, and usefulness of the Services.

5.9 Future AI Features

Lumi Buddy is designed as an evolving AI platform.

Future Services may include additional AI capabilities, intelligent agents, automation features, integrations, communication technologies, or other artificial intelligence services that are not currently available.

Unless otherwise stated, such future AI features will also be governed by this Privacy Policy.

5.10 Responsible Use of AI

Users should use AI responsibly and in accordance with applicable laws, this Privacy Policy, our Terms of Service, and any applicable Community Guidelines or AI Usage Policy.

Users should not rely solely on AI-generated content for decisions involving:

• medical matters;
• legal matters;
• financial matters;
• emergency situations;
• safety-critical decisions; or
• any matter where professional advice is required.

5.11 Availability of AI Features

Certain AI features may be unavailable, limited, modified, suspended, or discontinued due to:

• subscription limitations;
• maintenance;
• service outages;
• legal or regulatory requirements;
• third-party provider availability;
• technical limitations;
• safety considerations; or
• future product changes.

Lumi Buddy reserves the right to modify AI features from time to time in order to improve the Services or comply with applicable legal and operational requirements.

5.12 AI Training & Model Improvement

Lumi Buddy is committed to protecting your privacy while continuously improving the quality, safety, and performance of the Services.

To provide and improve our AI-powered features, we may analyze certain interactions, feedback, diagnostic information, and service performance data. Such processing may be performed by Lumi Buddy and, where necessary, by trusted third-party service providers acting on our behalf.

Unless otherwise stated, your personal conversations, memories, images, voice interactions, or other personal content will not be intentionally used by Lumi Buddy to train publicly available artificial intelligence models.

Where third-party AI service providers process information to generate responses, such processing is subject to the agreements and privacy practices applicable to those providers. Lumi Buddy carefully selects service providers that support appropriate privacy and security standards.

We may use aggregated, anonymized, or de-identified information that cannot reasonably identify you to:

• Improve the quality of the Services;
• Enhance AI safety and reliability;
• Identify bugs and technical issues;
• Measure service performance;
• Develop new features;
• Conduct internal research and analytics; and
• Improve the overall user experience.

If Lumi Buddy introduces optional programs that allow users to contribute their conversations or other content for AI improvement, research, or future model development, participation will be voluntary unless otherwise required by applicable law. Where appropriate, users will be provided with additional notice and any available choices before such information is used for those purposes.

As our AI technologies continue to evolve, we may introduce new methods for improving our Services. Any such activities will be conducted in accordance with this Privacy Policy and applicable law.

5.13 AI Safety & Human Oversight

Lumi Buddy is designed to provide helpful, engaging, and responsible AI-powered experiences. While we continuously improve our AI technologies, artificial intelligence is not infallible and may occasionally produce inaccurate, incomplete, outdated, misleading, or unexpected responses.

AI-generated content is created automatically based on available information, user input, and the capabilities of the underlying AI systems. Responses should not be interpreted as verified facts, official statements, or professional advice.

Users should exercise their own judgment before relying on AI-generated content, particularly when making decisions involving health, legal matters, financial matters, personal safety, or other important life decisions.

To help maintain the safety, reliability, and integrity of the Services, Lumi Buddy may implement various safety measures, including but not limited to:

• Content safety filters;
• Abuse and misuse detection;
• Spam prevention;
• Fraud detection;
• Security monitoring;
• System integrity protections;
• AI safety improvements; and
• Other responsible AI safeguards.

Where necessary and permitted by applicable law, Lumi Buddy may review limited information relating to reported content, technical issues, suspected abuse, fraud, security incidents, or violations of our Terms of Service or Community Guidelines.

Any such review will be limited to what is reasonably necessary to investigate, protect the Services, comply with applicable law, enforce our policies, or protect the rights, safety, and security of Lumi Buddy, our users, and third parties.

We continuously evaluate and improve our AI safety practices as new technologies, risks, and regulatory requirements evolve.

The availability, behavior, and capabilities of AI features may change over time as we introduce improvements, safety enhancements, or new technologies.

Lumi Buddy uses the information we collect to operate, maintain, improve, personalize, protect, and support the Services.

The purposes described below explain how your information may be processed depending on the features you use, your subscription plan, your preferences, applicable law, and future Services introduced by Lumi Buddy.

We only process personal information where there is a legitimate purpose for doing so and in accordance with applicable law.

6.1 To Provide the Services

We use your information to provide the core functionality of Lumi Buddy, including:

• Creating and managing your Account;
• Authenticating your identity;
• Delivering AI-powered conversations;
• Providing memory and personalization features;
• Supporting voice interactions;
• Supporting image-related features;
• Providing relationship progression systems;
• Synchronizing your information across supported devices;
• Processing subscriptions and purchases;
• Delivering customer support; and
• Operating all other Services requested by you.

6.2 To Personalize Your Experience

Lumi Buddy is designed to provide a personalized AI companion experience.

We may use your information to:

• Remember your preferences;
• Personalize AI responses;
• Maintain conversation continuity;
• Improve memory features;
• Adapt communication styles;
• Recommend relevant features;
• Recognize relationship milestones;
• Customize achievements and rewards;
• Improve future interactions.

Personalization helps create a more consistent and meaningful experience over time.

6.3 To Operate AI Features

Your information may be processed in order to enable AI-powered functionality.

Depending on the feature being used, this may include:

• Understanding prompts;
• Generating responses;
• Maintaining conversational context;
• Processing images;
• Processing voice interactions;
• Retrieving memories;
• Producing recommendations;
• Creating summaries;
• Supporting future AI capabilities.

Only the information reasonably necessary to provide the requested AI functionality will be processed.

6.4 To Improve the Services

We continually improve Lumi Buddy.

Information may be used to:

• Improve product quality;
• Improve AI performance;
• Enhance personalization;
• Develop new features;
• Improve accessibility;
• Improve reliability;
• Improve user experience;
• Optimize system performance;
• Measure feature adoption.

Where possible, we use aggregated, anonymized, or de-identified information for research and product improvement.

6.5 To Maintain Security

We use information to protect our users, our Services, and our infrastructure.

This may include:

• Detecting unauthorized access;
• Preventing fraud;
• Preventing abuse;
• Detecting suspicious activity;
• Protecting user Accounts;
• Monitoring system integrity;
• Investigating security incidents;
• Protecting against malicious activities.

6.6 To Communicate With You

We may use your information to communicate with you regarding:

• Account notifications;
• Service updates;
• Subscription information;
• Purchase confirmations;
• Security alerts;
• Support requests;
• Feature announcements;
• Promotional communications (where permitted);
• Changes to our Services;
• Changes to this Privacy Policy or other legal documents.

You may opt out of certain promotional communications where applicable.

6.7 To Process Payments and Subscriptions

Where applicable, information may be used to:

• Verify subscription status;
• Process purchases;
• Restore purchases;
• Prevent payment fraud;
• Apply subscription benefits;
• Verify promotional eligibility;
• Provide customer support relating to purchases.

Payment processing is performed by authorized payment providers.

Lumi Buddy does not store your complete payment card information.

6.8 To Comply With Legal Obligations

We may process information where necessary to:

• Comply with applicable laws;
• Respond to lawful governmental requests;
• Cooperate with law enforcement where legally required;
• Protect legal rights;
• Resolve disputes;
• Enforce our agreements;
• Meet regulatory obligations.

6.9 To Enforce Our Policies

Information may be used to investigate violations of:

• This Privacy Policy;
• Our Terms of Service;
• Community Guidelines;
• AI Usage Policy;
• Applicable laws.

Where appropriate, we may suspend, restrict, or terminate access to the Services in accordance with our policies and applicable law.

6.10 To Develop Future Services

Lumi Buddy is continuously evolving.

Information may be used to:

• Develop future AI capabilities;
• Improve personalization systems;
• Expand voice features;
• Expand image features;
• Improve memory systems;
• Introduce new subscription offerings;
• Develop future communication technologies;
• Improve the overall quality and safety of the Services.

Any future processing will remain subject to this Privacy Policy and applicable law.

6.11 Internal Business Operations

We may use information for legitimate internal business purposes, including:

• Business planning;
• Product management;
• Quality assurance;
• Performance monitoring;
• Capacity planning;
• Financial reporting;
• Internal audits;
• Risk management;
• Service administration.

Where possible, such activities rely on aggregated or de-identified information rather than information that directly identifies individual users.

6.12 Our Privacy Principles

Whenever we process personal information, we strive to follow these principles:

• We collect only information reasonably necessary for the Services.
• We use information only for legitimate and transparent purposes.
• We implement reasonable safeguards to protect personal information.
• We seek to provide users with meaningful control over their information whenever possible.
• We continuously improve our privacy, security, and AI governance practices.
• These principles guide how Lumi Buddy designs, develops, and operates its Services.

To deliver, maintain, improve, secure, and support the Services, Lumi Buddy may work with trusted third-party service providers that perform services on our behalf.

These providers may assist us in delivering AI-powered features, authentication, cloud infrastructure, payment processing, analytics, customer support, communications, security, and other operational functions necessary for the Services.

We carefully select service providers that support appropriate privacy, security, and operational standards.

Our use of third-party providers may change over time as our Services evolve.

7.1 AI Service Providers

Lumi Buddy may use one or more trusted third-party artificial intelligence service providers to generate AI-powered responses and support AI-related features.

Depending on the Services you use, information necessary to fulfill your request may be securely transmitted to an AI service provider for processing.

Such information may include:

• User prompts;
• Conversation context;
• Memory information required to generate personalized responses;
• Voice interaction data;
• Image data;
• User instructions;
• Other information reasonably necessary to provide the requested AI functionality.

Lumi Buddy does not require all AI features to use the same provider. Different features may rely on different AI technologies depending on performance, safety, availability, quality, cost, regional availability, or future product development.

7.2 Authentication Providers

To simplify account registration and improve account security, Lumi Buddy may integrate with trusted authentication providers.

Depending on the sign-in method you choose, we may receive limited information necessary to authenticate your identity, such as your email address, display name, profile image, or a unique account identifier.

Authentication providers process your information according to their own privacy policies and terms.

7.3 Cloud Infrastructure & Data Storage Providers

Lumi Buddy relies on secure cloud infrastructure to operate the Services.

Cloud service providers may assist with:

• Database hosting;
• File storage;
• Backup services;
• Content delivery;
• Infrastructure monitoring;
• Disaster recovery;
• Scalability;
• System availability.

Only information reasonably necessary to provide these services is stored or processed through such infrastructure.

7.4 Payment & Subscription Providers

If you purchase Paid Services, your transactions may be processed by authorized payment providers.

Depending on your platform, purchases may be processed through:

• Google Play;
• Apple App Store;
• Authorized payment processors;
• Future payment providers supported by Lumi Buddy.

Lumi Buddy does not receive or store your complete payment card information.

Payment information is processed directly by the applicable payment provider in accordance with its own privacy policy and security standards.

7.5 Analytics & Diagnostics Providers

To improve reliability and user experience, Lumi Buddy may use analytics and diagnostic service providers.

These providers may assist us in understanding:

• Application performance;
• Feature usage;
• Stability;
• Crash reports;
• Diagnostic information;
• Service reliability;
• General usage statistics.

Whenever reasonably possible, analytics information is aggregated, anonymized, or de-identified before being used for internal analysis.

7.6 Communication Service Providers

Lumi Buddy may use trusted communication providers to deliver important notifications and messages.

These communications may include:

• Account verification;
• Password reset instructions;
• Subscription notifications;
• Service announcements;
• Security alerts;
• Customer support communications;
• Product updates;
• Promotional communications where permitted by applicable law.

7.7 Security & Fraud Prevention Providers

To help protect our users and Services, Lumi Buddy may use trusted third-party security providers that assist in detecting and preventing:

• Unauthorized access;
• Fraud;
• Spam;
• Abuse;
• Automated attacks;
• Security threats;
• Malicious activity;
• Other activities that may compromise the integrity of the Services.

These providers may process limited technical information necessary to perform security-related functions.

7.8 Customer Support Providers

Where appropriate, Lumi Buddy may use trusted third-party providers to help deliver customer support services.

Such providers may assist with:

• Support ticket management;
• Email communications;
• Bug reporting;
• Technical troubleshooting;
• Customer feedback management;
• Service quality improvements.

Only information necessary to respond to your request will be shared with such providers.

7.9 Future Service Providers

As Lumi Buddy continues to evolve, we may engage additional service providers to support new technologies, AI capabilities, infrastructure, communications, payment systems, analytics, customer support, security, or other operational needs.

Any future providers will be selected based on appropriate technical, operational, privacy, and security considerations.

Unless otherwise stated, any information processed by future service providers will remain subject to this Privacy Policy.

7.10 Our Responsibility

Although certain aspects of the Services rely on trusted third-party providers, Lumi Buddy remains responsible for managing those relationships in accordance with applicable law.

We seek to work with providers that implement appropriate technical and organizational measures to protect personal information and process information only for authorized purposes.

Where required by applicable law, we enter into appropriate contractual arrangements with our service providers to safeguard personal information and ensure that information is processed in accordance with our instructions and applicable legal requirements.

7.11 Third-Party Privacy Policies

Third-party service providers operate independently from Lumi Buddy and maintain their own privacy policies, terms of service, and security practices.

We encourage users to review the privacy policies of any third-party services they choose to use in connection with Lumi Buddy.

Lumi Buddy is not responsible for the privacy practices of third-party services that operate independently of our Services.

Lumi Buddy respects your privacy and does not sell your personal information to third parties.

We only share personal information when it is reasonably necessary to provide the Services, fulfill your requests, comply with applicable laws, protect the rights and safety of our users, or support the legitimate operation of the Services.

Whenever possible, we limit the information shared to the minimum amount necessary for the intended purpose.

8.1 Service Providers

We may share limited personal information with trusted third-party service providers that perform services on our behalf.

Depending on the Services you use, these providers may assist with:

• Artificial intelligence processing;
• Cloud hosting and infrastructure;
• Authentication;
• Data storage;
• Customer support;
• Analytics and diagnostics;
• Security monitoring;
• Payment processing;
• Push notifications;
• Email communications;

Other operational services necessary to provide the Services.

These providers are permitted to process your information only as necessary to perform services for Lumi Buddy and are expected to protect your information using appropriate privacy and security measures.

8.2 AI Processing

When you use AI-powered features, certain information necessary to generate AI responses may be securely transmitted to trusted AI service providers.

The information shared depends on the feature you use and may include:

• User prompts;
• Conversation context;
• Memories required for personalization;
• Voice interaction data;
• Images submitted for processing;
• User instructions;

Other information reasonably necessary to fulfill your request.

Information is shared only to the extent necessary to provide the requested AI functionality.

8.3 Payment Processing

If you purchase Paid Services, your payment information is processed by the applicable payment platform or payment processor.

Lumi Buddy does not receive or store your complete payment card information.

We may receive limited transaction-related information necessary to:

• Verify purchases;
• Activate subscriptions;
• Restore purchases;
• Prevent fraud;
• Provide customer support.

8.4 Legal Requirements

We may disclose personal information where we believe disclosure is necessary to:

• Comply with applicable laws or regulations;
• Respond to lawful requests from governmental authorities;
• Comply with court orders or legal processes;
• Protect the rights, property, or safety of Lumi Buddy, our users, or others;
• Detect, investigate, or prevent fraud, abuse, security incidents, or illegal activities.

Any disclosure will be limited to the information reasonably necessary for the applicable legal purpose.

8.5 Protection of Rights

We may disclose information where reasonably necessary to:

• Enforce our Terms of Service;
• Investigate policy violations;
• Protect the integrity of the Services;
• Prevent unauthorized access;
• Defend legal claims;
• Protect our legal rights.

8.6 Business Transfers

If Lumi Buddy is involved in a merger, acquisition, investment, financing, corporate restructuring, sale of assets, bankruptcy proceeding, or other business transaction, user information may be transferred as part of that transaction.

If such a transfer occurs, we will take reasonable steps to ensure that your personal information continues to be protected in accordance with this Privacy Policy or as otherwise required by applicable law.

8.7 With Your Consent

We may share personal information with third parties where you have expressly requested or authorized such sharing.

You may withdraw your consent where applicable, subject to legal or contractual limitations.

8.8 Aggregated and De-Identified Information

We may share aggregated, anonymized, or de-identified information that cannot reasonably identify an individual user.

Such information may be used for:

• Research;
• Service improvement;
• Product development;
• Business analysis;
• Performance measurement;
• Statistical reporting.

This information does not identify you personally.

8.9 No Sale of Personal Information

Lumi Buddy does not sell your personal information to third parties for monetary compensation.

If our privacy practices change in the future in a manner that would require additional notice or consent under applicable law, we will update this Privacy Policy and provide appropriate notice where required.

8.10 Future Sharing Activities

As Lumi Buddy introduces new Services, AI capabilities, integrations, or technologies, additional information sharing may become necessary to support those Services.

Any future sharing of personal information will be conducted only where appropriate, consistent with this Privacy Policy, and in accordance with applicable law.

Lumi Buddy offers both free and paid Services.

Certain features, usage limits, storage capacity, personalization options, AI capabilities, and other benefits may vary depending on your subscription plan, purchased products, promotional offers, or future service offerings.

9.1 Free and Paid Services

Some features of the Services are available free of charge, while others require an active subscription or the purchase of digital products.

Paid Services may include:

• Subscription plans;
• Premium features;
• Add-on packs;
• Consumable purchases;
• Promotional plans;
• Trial offers; and
• Future paid products or services.

The availability of specific features and benefits may change over time.

9.2 Subscription Benefits

Subscription plans may provide additional benefits beyond those available through the free version of the Services.

Depending on the plan, benefits may include:

• Increased AI usage limits;
• Expanded memory capacity;
• Extended data retention;
• Additional voice features;
• Additional image features;
• Faster access to new features;
• Premium customization options;
• Higher usage quotas;
• Priority access to selected Services;
• Other subscription-specific benefits.

Subscription benefits may be modified from time to time as the Services evolve.

9.3 In-App Purchases

Users may purchase digital products or additional Services through supported application marketplaces or authorized payment providers.

Depending on the platform, purchases may include:

• Additional AI usage;
• Voice-related products;
• Image-related products;
• Digital consumables;
• Premium content;
• Feature unlocks;
• Future digital products.

Purchased digital products are generally intended solely for use within the Services unless otherwise specified.

9.4 Payment Processing

Payments are processed by the applicable platform or authorized payment provider.

Lumi Buddy does not collect, receive, or store your complete payment card information.

We may receive limited transaction-related information necessary to:

• Verify purchases;
• Activate subscriptions;
• Restore purchases;
• Detect fraud;
• Provide customer support;
• Manage subscription status.

9.5 Automatic Renewal

Where permitted by the applicable platform, subscriptions may automatically renew at the end of each billing period unless cancelled before the renewal date.

Renewal terms, billing cycles, and payment processing are managed by the applicable application marketplace or payment provider.

Users are responsible for managing their subscriptions through the platform from which the subscription was purchased.

9.6 Subscription Changes

Users may upgrade, downgrade, renew, or cancel their subscription through the applicable application marketplace or payment provider.

Changes to subscription benefits, usage limits, storage capacity, memory retention, or other features may take effect immediately or at the beginning of the next billing period, depending on the applicable platform's policies.

9.7 Promotions and Trial Offers

From time to time, Lumi Buddy may offer promotional pricing, introductory offers, free trials, discounts, bonus content, or other limited-time promotions.

Eligibility for promotional offers is determined by Lumi Buddy or the applicable application marketplace.

Promotional offers may be modified, limited, or discontinued at any time, subject to applicable law.

9.8 Refunds

Purchases made through application marketplaces are generally subject to the refund policies of the applicable marketplace.

Where purchases are processed through Google Play, Apple App Store, or another authorized payment provider, refund requests should be submitted through the applicable platform unless otherwise required by applicable law.

Lumi Buddy is generally unable to approve or process refunds for purchases managed directly by third-party application marketplaces.

9.9 Subscription Data

To operate subscription services, Lumi Buddy may process limited information relating to your subscription, including:

• Subscription status;
• Subscription plan;
• Purchase history;
• Transaction identifiers;
• Billing period;
• Renewal status;
• Promotional eligibility;
• Purchase restoration status;
• Usage entitlements.

This information is used solely to provide and manage your purchased Services.

9.10 Future Paid Services

As Lumi Buddy continues to evolve, additional subscription plans, digital products, premium features, consumable items, virtual goods, bundles, or other paid Services may be introduced. Unless otherwise stated, such future offerings will also be governed by this Privacy Policy.

9.11 Availability of Paid Services

Paid Services may not be available in all countries, regions, or application marketplaces.

Availability may vary depending on:

• Applicable laws;
• Regulatory requirements;
• Platform availability;
• Technical limitations;
• Licensing requirements;
• Business decisions.

Lumi Buddy reserves the right to modify, suspend, discontinue, or introduce Paid Services at any time, subject to applicable law.

9.12 No Ownership of Digital Services

Unless otherwise required by applicable law, purchasing a subscription or digital product grants you a limited, non-transferable, revocable license to access the purchased features within the Services.

Purchases do not transfer ownership of the underlying software, AI models, digital content, or intellectual property associated with Lumi Buddy.

Lumi Buddy retains personal information only for as long as necessary to provide the Services, fulfill the purposes described in this Privacy Policy, comply with applicable legal obligations, resolve disputes, enforce our agreements, and protect the security and integrity of the Services.

The retention period for different categories of information may vary depending on the type of information, the Services you use, your subscription plan, your account status, your preferences, applicable law, and operational requirements.

10.1 Subscription-Based Retention

Certain categories of information, including conversation history, memories, uploaded content, and other personalized data, may be retained according to the benefits and limitations of your current subscription plan.

Different subscription plans may provide different storage capacities, memory limits, retention periods, usage quotas, or personalization features.

As your subscription changes through an upgrade, downgrade, renewal, expiration, or cancellation, the retention of certain information may also change in accordance with the benefits of your current subscription plan.

10.2 Account Information

Basic account information may be retained for as long as your Account remains active.

Following account deletion, certain account-related information may be retained for a limited period where reasonably necessary to:

• Complete the account deletion process;
• Resolve disputes;
• Prevent fraud;
• Investigate abuse;
• Comply with legal obligations;
• Protect the security of the Services.

10.3 AI Conversations

Conversation history may be retained to support:

• Conversation continuity;
• AI personalization;
• Memory features;
• User-requested history;
• Service improvements;
• Customer support.

The availability and retention period of conversation history may vary depending on your subscription plan and the features available to your Account.

10.4 Memories & Personalization

Memories created by you or generated through your use of the Services may be retained in accordance with your subscription benefits.

Depending on the Services available to your Account, you may have the ability to:

• View memories;
• Edit memories;
• Delete individual memories;
• Manage personalization settings.

Deleted memories may remain in secure backup systems for a limited period before permanent deletion, where reasonably necessary for disaster recovery, system integrity, or legal compliance.

10.5 Voice & Image Data

Voice interactions, uploaded images, generated images, and other multimedia content may be retained only for as long as reasonably necessary to:

• Deliver the requested Services;
• Support personalization;
• Maintain conversation context;
• Improve service quality;
• Comply with legal obligations.

The availability and retention period of multimedia content may vary depending on your subscription plan and the specific Services used.

10.6 Diagnostic & Technical Information

Technical logs, crash reports, diagnostic information, and security-related records may be retained for a reasonable period to:

• Diagnose technical issues;
• Improve system reliability;
• Detect abuse;
• Maintain security;
• Monitor system performance;
• Comply with applicable legal obligations.

Such information is generally retained for operational purposes and is reviewed periodically.

10.7 Subscription & Transaction Information

Information relating to subscriptions and purchases may be retained for accounting, financial reporting, fraud prevention, tax compliance, dispute resolution, and other legal or operational purposes.

Retention periods for transaction records may be determined by applicable law or regulatory requirements.

10.8 Customer Support Communications

Communications with our customer support team, including support requests, bug reports, and feedback, may be retained for as long as reasonably necessary to:

• Respond to your requests;
• Improve customer support;
• Resolve disputes;
• Investigate technical issues;
• Improve the Services.

10.9 Legal Retention Requirements

In certain circumstances, Lumi Buddy may retain information for longer than normally required where necessary to:

• Comply with applicable laws;
• Respond to lawful governmental requests;
• Resolve legal disputes;
• Enforce our agreements;
• Protect our legal rights;
• Investigate fraud, abuse, or security incidents.

10.10 Account Deletion

When you request deletion of your Account, Lumi Buddy will take reasonable steps to permanently delete or anonymize your personal information within a reasonable period, unless retention is required by applicable law or is otherwise necessary for legitimate legal or operational purposes.

Certain information may remain temporarily in secure backups before being permanently deleted through our normal backup lifecycle.

10.11 Future Services

As Lumi Buddy introduces new AI capabilities, communication methods, subscription offerings, or other Services, additional categories of information may become subject to different retention practices.

Unless otherwise stated, such information will be retained only for as long as reasonably necessary to provide those Services and in accordance with this Privacy Policy.

10.12 Our Retention Principles

Lumi Buddy is committed to responsible data retention.

Whenever reasonably possible, we strive to:

• Retain personal information only for as long as necessary;
• Provide users with meaningful control over their information;
• Support deletion requests where applicable;
• Securely delete or anonymize information that is no longer required;
• Regularly review our data retention practices as our Services evolve.

Lumi Buddy is committed to protecting your personal information through appropriate administrative, technical, and organizational security measures designed to safeguard the confidentiality, integrity, and availability of the Services.

While no method of electronic transmission, storage, or processing can be guaranteed to be completely secure, we continually evaluate and improve our security practices to reduce risks and protect user information.

11.1 Security Measures

We implement reasonable safeguards designed to protect personal information against unauthorized access, disclosure, alteration, destruction, or misuse.

Depending on the nature of the Services, these safeguards may include:

• Encryption of data during transmission where appropriate;
• Secure cloud infrastructure;
• Authentication and access controls;
• Role-based administrative access;
• Secure software development practices;
• Security monitoring;
• Vulnerability management;
• Backup and disaster recovery procedures;
• Infrastructure security controls; and
• Other industry-recognized security practices.

Security measures are reviewed periodically and may evolve as technology and security standards improve.

11.2 Access Controls

Access to personal information is restricted to authorized personnel, service providers, or systems that require such access to perform legitimate operational, technical, customer support, security, or legal functions.

We seek to limit access based on the principle of least privilege whenever reasonably appropriate.

11.3 Account Security

Users are responsible for maintaining the confidentiality of their login credentials and for protecting access to their Accounts.

You should:

• Choose strong passwords where applicable;
• Keep your login credentials confidential;
• Avoid sharing your Account with others;
• Secure your personal devices;
• Notify Lumi Buddy promptly if you suspect unauthorized access to your Account.

Activities performed using your Account may be attributed to you unless otherwise required by applicable law.

11.4 Security Monitoring

To help maintain the security and reliability of the Services, Lumi Buddy may monitor systems, infrastructure, and technical activity for purposes including:

• Detecting unauthorized access;
• Identifying security vulnerabilities;
• Preventing fraud;
• Detecting abuse;
• Investigating suspicious activity;
• Maintaining service availability;
• Protecting the integrity of the Services.

Such monitoring is performed only to the extent reasonably necessary for security and operational purposes.

11.5 Third-Party Security

Certain components of the Services rely on trusted third-party providers.

While Lumi Buddy carefully selects providers that support appropriate privacy and security practices, each provider maintains its own security controls and operational procedures.

We encourage users to review the privacy and security information made available by the third-party services they choose to use in connection with Lumi Buddy.

11.6 Incident Response

If Lumi Buddy becomes aware of a security incident affecting personal information, we will take reasonable steps to:

• Investigate the incident;
• Contain and mitigate potential impacts;
• Restore affected Services where appropriate;
• Improve security measures;
• Provide notifications where required by applicable law.

The specific response to any security incident may vary depending on the nature and scope of the incident.

11.7 User Responsibilities

Security is a shared responsibility.

Users can help protect their information by:

• Keeping devices updated;
• Using secure networks whenever possible;
• Protecting login credentials;
• Logging out of shared devices;
• Reviewing Account activity where available;
• Reporting suspected security issues to Lumi Buddy.

11.8 No Absolute Security Guarantee

Although Lumi Buddy implements reasonable safeguards designed to protect personal information, no security system, technology, network, or method of electronic transmission or storage can guarantee absolute security.

Accordingly, Lumi Buddy cannot guarantee that unauthorized access, cyberattacks, technical failures, or other security incidents will never occur.

Users acknowledge these inherent risks when using internet-based services.

11.9 Continuous Security Improvement

Lumi Buddy continuously reviews and improves its security practices as technology, threats, regulatory requirements, and industry standards evolve.

Security improvements may include:

• Enhanced encryption technologies;
• Improved authentication methods;
• Infrastructure upgrades;
• AI safety enhancements;
• New monitoring capabilities;
• Enhanced fraud detection;
• Additional organizational safeguards.

Such improvements may be implemented without prior notice where reasonably necessary to protect the Services or comply with applicable law.

11.10 Future Security Technologies

As Lumi Buddy introduces new Services, AI capabilities, communication methods, or infrastructure, we may adopt additional security technologies and operational practices designed to protect users and the Services.

Unless otherwise stated, such security measures will form part of our ongoing commitment to protecting personal information in accordance with this Privacy Policy.

Lumi Buddy is a global service that may be accessed by users from different countries and regions.

To provide, maintain, improve, and secure the Services, your personal information may be processed, stored, transmitted, or accessed in countries other than the country in which you reside.

These countries may have different data protection laws than those applicable in your jurisdiction.

12.1 Cross-Border Processing

Depending on the Services you use, your information may be processed by Lumi Buddy or trusted third-party service providers located in different countries or regions.

Cross-border processing may occur for purposes including:

• Delivering AI-powered features;
• Cloud hosting and infrastructure;
• Authentication;
• Payment processing;
• Customer support;
• Security monitoring;
• Data backup;
• Analytics and diagnostics;
• Service reliability;
• Other operational purposes necessary to provide the Services.

12.2 International Infrastructure

To ensure the availability, scalability, reliability, and performance of the Services, Lumi Buddy may use cloud infrastructure, content delivery networks, databases, storage systems, and other technical resources that operate across multiple geographic regions.

As a result, personal information may be transferred between different countries where such infrastructure or service providers operate.

12.3 Appropriate Safeguards

Where personal information is transferred across national borders, Lumi Buddy seeks to implement reasonable contractual, technical, and organizational safeguards designed to protect personal information during such transfers.

We also seek to work with service providers that maintain appropriate privacy and security standards.

12.4 User Acknowledgement

By accessing or using the Services, you acknowledge and understand that your personal information may be transferred to, processed, or stored in countries outside your country of residence where necessary to provide the Services.

Such transfers will be carried out in accordance with this Privacy Policy and applicable law.

12.5 Service Provider Locations

Lumi Buddy may use service providers that operate internationally.

The geographic locations of our service providers may change over time as we improve our Services, expand our infrastructure, or adopt new technologies.

Unless otherwise stated, all information processed by such providers remains subject to the privacy and security obligations described in this Privacy Policy.

12.6 Business Continuity

To maintain service continuity, disaster recovery, and operational resilience, personal information may be replicated or backed up across multiple secure locations operated by Lumi Buddy or trusted service providers.

Such replication is performed solely for legitimate operational, security, backup, or disaster recovery purposes.

12.7 Future International Operations

As Lumi Buddy expands internationally, we may establish new infrastructure, engage additional service providers, or introduce Services in new countries or regions.

Any future international processing of personal information will be conducted in accordance with this Privacy Policy and applicable law.

12.8 Our Commitment

Regardless of where your personal information is processed, Lumi Buddy is committed to applying reasonable privacy and security measures designed to protect your information throughout its lifecycle.

We continuously review our international data handling practices and seek to improve our safeguards as our Services, technologies, and legal obligations evolve.

Lumi Buddy respects your privacy and is committed to providing you with meaningful control over your personal information.

Depending on your location, applicable law, and the Services you use, you may have certain rights regarding your personal information. Lumi Buddy strives to honor these rights wherever reasonably possible and in accordance with applicable law.

Some rights may vary depending on legal requirements, technical limitations, or the nature of the information involved.

13.1 Right to Access

You may request access to certain personal information associated with your Account.

Where reasonably practicable, you may also be able to view much of your personal information directly through the Services.

13.2 Right to Correct Information

You may update or correct inaccurate or incomplete personal information through your Account settings where available.

If certain information cannot be updated directly within the Services, you may contact Lumi Buddy for assistance.

13.3 Right to Delete Information

You may request the deletion of your Account and associated personal information.

Upon receiving a valid deletion request, Lumi Buddy will take reasonable steps to delete or anonymize your personal information in accordance with this Privacy Policy and applicable law.

Certain information may be retained where required for legal, security, fraud prevention, accounting, dispute resolution, or other legitimate operational purposes.

Additional information regarding account deletion is provided in Section 14 (Account Deletion).

13.4 Right to Manage Memories

Where memory features are available, you may have the ability to:

• View saved memories;
• Edit memories;
• Delete individual memories;
• Clear memory history;
• Manage personalization preferences.

The availability of these controls may vary depending on your subscription plan and the specific features available to your Account.

13.5 Right to Manage Communications

You may choose whether to receive certain non-essential communications from Lumi Buddy, such as product updates, newsletters, promotional messages, or marketing communications.

You may opt out of such communications at any time through the options provided within the communication or by contacting us.

Certain service-related communications, including security notifications, billing information, and important account updates, may continue to be sent where necessary for the operation of the Services.

13.6 Right to Manage Permissions

You may control certain device permissions used by the Services, including permissions relating to:

• Microphone;
• Camera;
• Photos or media;
• Notifications;
• Contacts (if applicable);
• Other device permissions.

Most permissions can be modified through your device settings at any time.

Disabling certain permissions may limit the functionality of specific features.

13.7 Right to Withdraw Consent

Where the processing of personal information is based on your consent, you may withdraw that consent at any time.

Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal became effective.

Certain Services may no longer function properly if consent required for those Services is withdrawn.

13.8 Right to Request Assistance

If you have questions regarding your personal information or wish to exercise any of your privacy rights, you may contact Lumi Buddy using the contact information provided in this Privacy Policy.

We will make reasonable efforts to respond to privacy-related requests within a reasonable period, subject to applicable law and operational requirements.

13.9 Verification of Requests

To protect the privacy and security of our users, Lumi Buddy may request additional information to verify your identity before processing certain privacy-related requests.

We may decline or limit requests that cannot reasonably be verified or that would adversely affect the rights, privacy, or security of other individuals.

13.10 Limitations

Certain privacy rights may be limited where necessary to:

• Comply with applicable laws;
• Protect the rights and freedoms of others;
• Prevent fraud or abuse;
• Maintain the security and integrity of the Services;
• Resolve disputes;
• Enforce our Terms of Service or other legal agreements.

Where a request cannot be fully fulfilled, Lumi Buddy will make reasonable efforts to explain the basis for the limitation where appropriate and permitted by applicable law.

13.11 Future Privacy Controls

As Lumi Buddy continues to evolve, we may introduce additional privacy tools and controls that allow users to better manage their personal information, AI interactions, memories, communication preferences, and future Services.

Unless otherwise stated, such privacy controls will be governed by this Privacy Policy.

Lumi Buddy respects your right to discontinue using the Services and request the deletion of your Account.

If you choose to delete your Account, we will take reasonable steps to permanently delete or anonymize your personal information in accordance with this Privacy Policy, our internal operational procedures, and applicable law.

Account deletion is intended to permanently remove your access to the Services and the personal information associated with your Account, except where retention is required or permitted by applicable law.

14.1 Requesting Account Deletion

You may request the deletion of your Account through the account settings within the Services, where available, or by contacting Lumi Buddy using the contact information provided in this Privacy Policy.

You may also submit an account deletion request through our Delete Your Lumi Buddy Account page.

To protect your privacy and security, we may request additional information to verify your identity before processing an account deletion request.

14.2 Information That Will Be Deleted

Subject to applicable law and legitimate operational requirements, deleting your Account may result in the permanent deletion or anonymization of information associated with your Account, including:

• Account profile information;
• Conversation history;
• Memories and personalization data;
• Relationship progress;
• Experience Points (XP);
• Badges and achievements;
• Uploaded images;
• Voice interactions;
• AI-generated content associated with your Account;
• Preferences and settings;
• Saved reminders;
• Other personal information associated with your use of the Services.

Once permanently deleted, this information generally cannot be recovered.

14.3 Information That May Be Retained

Certain information may be retained after account deletion where reasonably necessary to:

• Comply with applicable laws;
• Meet tax or accounting obligations;
• Resolve disputes;
• Detect or prevent fraud;
• Investigate security incidents;
• Enforce our Terms of Service;
• Protect the rights, safety, or security of Lumi Buddy, our users, or third parties;
• Maintain backup integrity during normal backup cycles.

Any retained information will be protected in accordance with this Privacy Policy and will be retained only for as long as reasonably necessary for the applicable purpose.

14.4 Active Subscriptions

Deleting your Account does not automatically cancel active subscriptions managed through an application marketplace or payment provider.

Users are responsible for managing, modifying, or cancelling their subscriptions through the platform from which the subscription was purchased.

Where applicable, subscription charges may continue until the subscription is cancelled in accordance with the policies of the applicable payment provider.

14.5 Effect of Account Deletion

After your Account has been deleted:

• You will no longer be able to access your Account;
• Your personalized AI experience will end;
• Memories and personalization features associated with your Account may no longer be available;
• Relationship progress, achievements, and other account-based progress may no longer be recoverable;
• Certain Services may no longer be accessible.

If you choose to create a new Account in the future, it will generally be treated as a new account unless otherwise provided by the Services.

14.6 Processing Period

Lumi Buddy will process valid account deletion requests within a reasonable period.

The time required to complete the deletion process may vary depending on factors including:

• System requirements;
• Backup procedures;
• Security verification;
• Technical limitations;
• Applicable legal obligations.

During the deletion process, certain information may remain temporarily inaccessible until permanent deletion or anonymization has been completed.

14.7 Withdrawal of Deletion Requests

Where technically feasible and before the deletion process has been completed, you may contact Lumi Buddy to inquire whether a pending deletion request can still be cancelled.

Once the deletion process has been finalized, permanently deleted information generally cannot be restored.

14.8 Future Services

As Lumi Buddy introduces new features, AI capabilities, communication methods, or subscription offerings, additional categories of personal information may become associated with your Account.

Unless otherwise stated, such information will also be subject to this Account Deletion policy.

14.9 Our Commitment

Lumi Buddy is committed to providing users with meaningful control over their personal information.

We continually review and improve our account deletion processes to help ensure that personal information is deleted, anonymized, or retained only where reasonably necessary and in accordance with applicable law.

Lumi Buddy is not intended for use by young children without appropriate parental or legal guardian involvement.

We are committed to protecting the privacy of children and handling children's personal information responsibly in accordance with applicable law.

15.1 Intended Audience

The Services are intended for users who meet the minimum age requirements described in Section 3 (Eligibility).

Individuals who do not meet the applicable minimum age may only use the Services where permitted by applicable law and with the involvement or consent of a parent or legal guardian, if required.

15.2 No Knowing Collection from Children

Lumi Buddy does not knowingly collect personal information from children in violation of applicable law.

If we become aware that personal information has been collected from a child without the required consent or legal basis, we will take reasonable steps to investigate the matter and, where appropriate, delete the relevant information or restrict the associated Account.

15.3 Parent or Legal Guardian Requests

Parents or legal guardians who believe that a child has provided personal information to Lumi Buddy without appropriate authorization may contact us using the contact information provided in this Privacy Policy.

Upon receiving a verified request, and where required by applicable law, we will take reasonable steps to:

• Review the request;
• Verify the identity of the requesting parent or legal guardian where appropriate;
• Remove or anonymize the child's personal information where applicable; and
• Provide assistance regarding the child's Account where reasonably possible.

15.4 User Responsibility

Users are responsible for ensuring that they satisfy the eligibility requirements described in this Privacy Policy and our Terms of Service.

Parents and legal guardians are encouraged to supervise children's online activities and help ensure the responsible use of AI-powered services.

15.5 AI Features and Children

Artificial intelligence may generate content that is intended for a general audience and may not always be appropriate for younger users.

Parents and legal guardians should supervise children's use of AI-powered features and exercise their own judgment regarding the suitability of the Services for minors.

15.6 Future Children's Features

If Lumi Buddy introduces features specifically designed for children in the future, additional privacy practices, parental controls, notices, or consent mechanisms may apply.

Such features will be governed by additional policies or notices where required by applicable law.

15.7 Our Commitment

Protecting children's privacy is an important part of Lumi Buddy's commitment to responsible AI and user safety.

We continually review our privacy practices to help ensure that children's personal information is handled responsibly, fairly, and in accordance with applicable legal requirements.

15.8 Age Misrepresentation

Users are responsible for providing accurate information when creating an Account, including information relating to their age where requested.

If Lumi Buddy reasonably believes that a user has provided false, misleading, or inaccurate information regarding their age in order to access the Services, we reserve the right to investigate the matter and, where appropriate and permitted by applicable law:

• Request additional verification;
• Restrict access to certain features;
• Suspend or terminate the Account;
• Remove or anonymize associated personal information where appropriate; or
• Take other reasonable measures necessary to protect the safety, privacy, and integrity of the Services.

Any action taken under this Section will be carried out in accordance with applicable law, our Terms of Service, and our commitment to protecting users, particularly children and minors.

Lumi Buddy uses cookies, local storage, device storage, and similar technologies to provide, maintain, improve, personalize, and secure the Services.

The specific technologies used may vary depending on the platform you use, including mobile applications, websites, or future platforms supported by Lumi Buddy.

These technologies help us remember your preferences, maintain secure sessions, improve performance, and deliver a more personalized user experience.

16.1 What Are Cookies and Similar Technologies

Cookies are small data files that may be stored on your device when you access certain Services, particularly through a web browser.

Because Lumi Buddy may also be available through mobile applications and future platforms, we may use technologies that provide similar functionality, including:

• Local storage;
• Secure device storage;
• Session storage;
• Application cache;
• Authentication tokens;
• Device identifiers where permitted by applicable law; and
• Other technologies that help operate and secure the Services.

16.2 How We Use These Technologies

These technologies may be used to:

• Maintain secure login sessions;
• Remember your preferences;
• Store language settings;
• Remember personalization settings;
• Support memory features;
• Improve application performance;
• Restore previous sessions;
• Protect account security;
• Prevent fraud;
• Improve service reliability;
• Support accessibility features; and
• Enhance the overall user experience.

16.3 Authentication

Certain information may be stored locally on your device to help maintain your authenticated session and reduce the need to repeatedly sign in.

Authentication information stored on your device is intended solely to support secure aceess to your Account and is handled using appropriate security measures.

16.4 Personalization

Lumi Buddy may use local storage or similar technologies to remember your preferences and personalize your experience.

Examples may include:

• Preferred language;
• Appearance settings;
• Notification preferences;
• AI preferences;
• Memory settings;
• Accessibility settings;
• Other user-selected preferences.

These settings help provide a more consistent experience across sessions.

16.5 Performance and Reliability

Technical information stored through cookies or similar technologies may help Lumi Buddy:

• Improve application performance;
• Reduce loading times;
• Restore interrupted sessions;
• Diagnose technical issues;
• Improve reliability;
• Improve compatibility across devices.

16.6 Analytics

Where analytics technologies are used, they may collect limited technical or usage information to help us understand how the Services are used and how they can be improved.

Where reasonably possible, such information is aggregated, anonymized, or de-identified before being used for product improvement and operational analysis.

16.7 Managing Cookies and Local Storage

Depending on your device, browser, operating system, or application settings, you may be able to manage, restrict, or delete certain cookies, local storage, or similar technologies.

Please note that disabling certain technologies may affect the availability, functionality, or performance of some features of the Services.

16.8 Third-Party Technologies

Certain third-party service providers integrated with Lumi Buddy may use cookies or similar technologies as part of the services they provide.

The use of such technologies is governed by the privacy policies of the respective third-party providers.

Lumi Buddy does not control the independent data collection practices of third-party services.

16.9 Future Technologies

As technology evolves, Lumi Buddy may introduce additional technologies that perform functions similar to cookies or local storage.

Unless otherwise stated, any such technologies will be used in accordance with this Privacy Policy and applicable law.

16.10 Our Commitment

Lumi Buddy seeks to use cookies, local storage, and similar technologies responsibly and only where reasonably necessary to provide secure, reliable, personalized, and high-quality Services.

We continually review these technologies to ensure they remain appropriate for the operation of the Services and aligned with our privacy principles.

One of Lumi Buddy’s core features is the ability to personalize interactions through memory and contextual understanding.

Memory features are designed to help Lumi Buddy provide more natural, consistent, and meaningful conversations by remembering information that you choose to share or information that is reasonably necessary to improve your experience.

You remain in control of your personal information, and Lumi Buddy strives to provide transparent and responsible memory management.

17.1 Memory Features

Depending on the Services and your subscription plan, Lumi Buddy may store information to support personalized experiences, including:

• Personal preferences;
• Interests;
• Goals;
• Important dates;
• Conversation summaries;
• Relationship milestones;
• Communication preferences;
• User-defined memories;
• AI-generated memories;
• Other personalization data reasonably necessary to improve future interactions.

The specific memory features available may vary over time as the Services evolve.

17.2 User Control

Where available, you have the ability to manage information stored as part of your personalized experience.

Depending on the Services, available controls may include:

• Viewing saved memories;
• Editing existing memories;
• Deleting individual memories;
• Managing personalization preferences;
• Clearing selected memory information;
• Reviewing information used for personalization.

The availability of specific controls may vary depending on your subscription plan, device, application version, or future Services.

17.3 Automatic Memory

Certain memories may be created automatically based on your interactions with the Services in order to improve continuity and personalization.

Automatic memories are generated using AI technologies and are intended to help Lumi Buddy better understand your preferences, interests, and previous conversations.

Not every conversation will be stored as a memory.

Lumi Buddy seeks to retain only information reasonably necessary to improve your personalized experience.

17.4 User-Created Memories

Where supported, you may voluntarily create or save memories that you want Lumi Buddy to remember.

Examples may include:

• Personal preferences;
• Important reminders;
• Relationship information;
• Favorite activities;
• Personal goals;
• Communication preferences;
• Other information that you intentionally choose to save.

You are responsible for the information you choose to store.

17.5 Memory Retention

Memories are retained in accordance with Section 10 (Data Retention).

The amount of memory that can be stored, the retention period, and available personalization features may vary depending on your subscription plan.

Changes to your subscription may affect available storage, retention limits, and personalization capabilities.

17.6 Memory Deletion

Where available, you may delete individual memories or request deletion of all memories associated with your Account.

Deleting memories may reduce Lumi Buddy's ability to provide personalized conversations and maintain continuity across future interactions.

Deleted memories may remain temporarily within secure backup systems for a limited period before being permanently deleted as part of our normal operational procedures.

17.7 Personalization

Information stored through memory features may be used to:

• Improve conversation continuity;
• Personalize AI responses;
• Remember user preferences;
• Reduce repetitive questions;
• Support relationship development;
• Improve future interactions;
• Enhance overall user experience.

Personalization is intended solely to improve your experience while using the Services.

17.8 Future Personalization Features

As Lumi Buddy continues to evolve, we may introduce additional personalization capabilities, including new memory technologies, intelligent assistants, contextual understanding, relationship features, communication methods, and other AI-powered personalization tools.

Unless otherwise stated, such features will be governed by this Privacy Policy.

17.9 Our Commitment

Lumi Buddy is designed to provide personalized AI experiences while respecting user privacy.

We are committed to providing meaningful transparency, responsible memory management, and user control wherever reasonably possible.

Our goal is to ensure that memory features enhance your experience without compromising your privacy or trust.

Lumi Buddy includes relationship and engagement features designed to create a more interactive, enjoyable, and personalized experience.

These features encourage long-term engagement by allowing users to develop a unique relationship with Lumi Buddy through conversations, activities, achievements, and other interactions.

Relationship and gamification features are intended solely to enhance the user experience and do not represent real-world relationships, legal status, financial value, or contractual rights.

18.1 Relationship Features

Depending on the Services and your subscription plan, Lumi Buddy may provide relationship-related features, including:

• Friendship Levels;
• Relationship Progress;
• Experience Points (XP);
• Achievements;
• Badges;
• Milestones;
• Daily Activities;
• Seasonal Events;
• Gifts;
• Rewards;
• Streaks;
• Personalized Celebrations; and
• Other engagement features introduced in the future.

The availability of specific features may vary depending on your subscription plan, application version, device, region, or future Services.

18.2 Relationship Progress

Relationship progress is generated through your interactions with Lumi Buddy.

Depending on the Services, progress may be influenced by:

• Conversations;
• Activities;
• Completed achievements;
• Participation in events;
• Daily engagement;
• Memory interactions;
• Feature usage; and
• Other in-app activities.

Relationship progress is intended solely as a gamification feature to enhance user engagement.

18.3 Experience Points (XP)

Lumi Buddy may award Experience Points ("XP") for eligible activities within the Services.

XP may be awarded for activities including, but not limited to:

• Conversations;
• Daily interactions;
• Achievements;
• Milestones;
• Special events;
• Seasonal events;
• Relationship celebrations;
• Future engagement activities.

The amount of XP awarded for any activity may vary depending on:

• Your subscription plan;
• Promotional events;
• Temporary bonuses;
• Feature availability;
• System updates;
• Other factors determined by the Services.

XP values, earning methods, and reward systems may be modified from time to time without prior notice, subject to applicable law.

18.4 Achievements and Badges

The Services may award achievements, badges, titles, or other digital recognitions based on your activity and relationship progress.

Achievements and badges are intended solely as virtual engagement features.

They:

• Have no monetary value;
• Cannot be exchanged for cash;
• Cannot be transferred to another user;
• Do not constitute legal rights or ownership.

Lumi Buddy reserves the right to introduce, modify, replace, or discontinue achievements and badges as the Services evolve.

18.5 Rewards and Celebrations

Lumi Buddy may provide virtual rewards, celebrations, anniversary events, birthday events, seasonal activities, gifts, or other engagement experiences.

Examples may include:

• Friendship anniversaries;
• User birthdays;
• Lumi Buddy birthdays;
• Seasonal celebrations;
• Achievement rewards;
• Community events;
• Future engagement activities.

Participation in these features is intended solely to improve the user experience and does not create any legal entitlement to future rewards.

18.6 Virtual Nature

All relationship features, XP, achievements, badges, gifts, milestones, and similar engagement elements are virtual features provided solely within the Services.

Unless otherwise expressly stated:

• They have no cash value;
• They cannot be redeemed for money;
• They cannot be transferred;
• They cannot be sold;
• They cannot be inherited;
• They do not represent ownership of any property or asset.

18.7 Changes to Relationship Features

As Lumi Buddy evolves, relationship systems may be expanded, modified, suspended, or discontinued.

Examples may include changes to:

• XP calculations;
• Friendship levels;
• Reward systems;
• Badges;
• Achievements;
• Seasonal events;
• Gifts;
• Personalization;
• Future engagement features.

Such changes may occur to improve the Services, enhance user experience, maintain balance, support technical improvements, or comply with applicable law.

18.8 Loss of Relationship Data

Certain relationship-related information may no longer be available if:

• Your Account is deleted;
• Related memories are deleted;
• Your subscription changes;
• Certain Services are discontinued;
• Technical limitations require data removal; or
• Retention periods expire in accordance with this Privacy Policy.

Where applicable, relationship data will be handled in accordance with Section 10 (Data Retention) and Section 14 (Account Deletion).

18.9 Future Relationship Features

Lumi Buddy may introduce additional relationship and engagement features in the future, including new progression systems, virtual experiences, interactive events, AI companionship features, personalization technologies, or other gamification mechanisms.

Unless otherwise stated, such future features will also be governed by this Privacy Policy.

18.10 Our Commitment

Relationship and gamification features are designed to make Lumi Buddy more engaging, enjoyable, and meaningful while respecting user privacy.

We are committed to developing these features responsibly, transparently, and in a manner that supports long-term user trust, well-being, and enjoyment.

Artificial Intelligence ("AI") is an important part of the Services provided by Lumi Buddy.

While we strive to provide helpful, engaging, and accurate AI-powered experiences, AI-generated content is produced automatically and may not always be accurate, complete, current, or appropriate for every situation.

By using the Services, you acknowledge and understand the limitations of AI and agree to use AI-generated content responsibly and with your own judgment.

19.1 AI-Generated Content

Responses generated by Lumi Buddy are produced automatically using Artificial Intelligence.

AI-generated content may include:

• Conversations;
• Recommendations;
• Summaries;
• Suggestions;
• Images;
• Voice responses;
• Personalized content; and
• Other AI-generated outputs.

Although we continuously improve our AI systems, we do not guarantee that AI-generated content will always be accurate, complete, reliable, or suitable for your particular circumstances.

19.2 No Professional Advice

The Services are provided for informational, educational, entertainment, and companionship purposes.

AI-generated content should not be considered professional advice and should not replace consultation with qualified professionals.

This includes, but is not limited to:

• Medical advice;
• Legal advice;
• Financial advice;
• Investment advice;
• Tax advice;
• Mental health treatment;
• Emergency assistance; or
• Any other professional services.

Always seek appropriate professional guidance when making important decisions.

19.3 User Responsibility

You are solely responsible for evaluating, interpreting, and relying upon any AI-generated content.

Before making decisions based on information provided by Lumi Buddy, you should independently verify the accuracy and suitability of the information where appropriate.

Lumi Buddy is intended to assist users, not to replace independent judgment or professional expertise.

19.4 No Emergency Services

Lumi Buddy is not an emergency service.

The Services should not be used to report emergencies or obtain immediate assistance in situations involving:

• Medical emergencies;
• Crimes;
• Fire;
• Natural disasters;
• Personal safety;
• Suicide or self-harm emergencies;
• Any situation requiring immediate assistance from emergency services.

If you are experiencing an emergency, you should immediately contact your local emergency services or other appropriate authorities.

19.5 AI Availability

The availability, quality, speed, and functionality of AI features may vary depending on factors including:

• Subscription plan;
• Internet connectivity;
• Platform availability;
• Third-party AI providers;
• System maintenance;
• Technical limitations;
• Regional availability; and
• Future service updates.

Certain AI features may be modified, suspended, or discontinued without prior notice where reasonably necessary.

19.6 User Content

You are responsible for the prompts, messages, images, voice recordings, and other content that you submit to the Services.

You should not submit content that:

• Violates applicable laws;
• Infringes the rights of others;
• Contains malicious software;
• Includes confidential information that you are not authorized to disclose; or
• Violates our Terms of Service or Community Guidelines.

19.7 Continuous Improvement

Lumi Buddy continuously improves its AI systems to enhance:

• Accuracy;
• Reliability;
• Personalization;
• Safety;
• Performance;
• User experience; and
• Responsible AI practices.

As a result, AI behavior, responses, and available features may change over time.

19.8 Limitation of Reliance

To the fullest extent permitted by applicable law, Lumi Buddy shall not be responsible for decisions made solely on the basis of AI-generated content.

Users remain responsible for their own actions, decisions, and use of information provided through the Services.

19.9 Our Commitment

Lumi Buddy is committed to developing AI responsibly and transparently.

We continuously work to improve the quality, safety, fairness, and reliability of our AI-powered Services while respecting user privacy and promoting a positive user experience.

Lumi Buddy is designed to provide a safe, respectful, and enjoyable AI companion experience.

By accessing or using the Services, you agree to use the Services responsibly and in accordance with this Privacy Policy, our Terms of Service, applicable laws, and any other policies published by Lumi Buddy.

You are solely responsible for your use of the Services and for any content you submit through your Account.

20.1 Lawful Use

You agree to use the Services only for lawful purposes and in a manner that does not violate the rights of others or interfere with the operation of the Services.

You may not use the Services to engage in activities that are illegal, fraudulent, harmful, or otherwise prohibited by applicable law.

20.2 Prohibited Activities

You agree not to use the Services to:

• Violate any applicable law or regulation;
• Harass, threaten, intimidate, abuse, or exploit others;
• Promote violence, terrorism, or criminal activities;
• Distribute malware, viruses, or other malicious software;
• Engage in phishing, scams, fraud, or identity theft;
• Upload or distribute unlawful, defamatory, obscene, or otherwise illegal content;
• Infringe the intellectual property rights or privacy rights of others;
• Interfere with or disrupt the operation, security, or availability of the Services;
• Attempt unauthorized access to any system, Account, or network associated with Lumi Buddy; or
• Use the Services for any purpose that may reasonably cause harm to Lumi Buddy, other users, or third parties.

20.3 Misuse of AI Features

You agree not to misuse AI-powered features, including by attempting to:

• Circumvent safety measures;
• Manipulate or abuse AI systems;
• Generate unlawful or harmful content;
• Conduct spam campaigns or mass automated messaging;
• Generate malicious code or instructions intended to harm others;
• Use automated systems to overload or interfere with the Services;
• Misrepresent AI-generated content as verified factual information where doing so may cause harm; or
• Engage in any activity intended to compromise the integrity, reliability, or security of AI features.

20.4 User Content

You remain responsible for all prompts, messages, images, voice recordings, files, and other content that you submit through the Services.

You represent and warrant that you have the necessary rights or permissions to submit such content.

You should not submit content that:

• Violates applicable law;
• Infringes another person's intellectual property rights;
• Violates another person's privacy;
• Contains confidential information that you are not authorized to disclose; or
• Otherwise violates this Privacy Policy or our Terms of Service.

20.5 Security

You agree not to:

• Attempt to bypass authentication or security measures;
• Probe, scan, or test vulnerabilities without authorization;
• Reverse engineer, decompile, or otherwise attempt to extract source code except where expressly permitted by applicable law;
• Interfere with the security or integrity of the Services.

20.6 Fair Use

The Services are intended for normal personal use unless otherwise authorized by Lumi Buddy.

You agree not to engage in excessive, abusive, automated, or fraudulent usage that may negatively affect other users, system performance, or the availability of the Services.

Where appropriate, Lumi Buddy may apply reasonable usage limits, rate limits, or other technical measures to protect the stability and security of the Services.

20.7 Enforcement

If Lumi Buddy reasonably believes that your use of the Services violates this Privacy Policy, our Terms of Service, applicable law, or threatens the security, integrity, or operation of the Services, we may take appropriate action, including:

• Issuing warnings;
• Limiting access to certain features;
• Removing or restricting content where appropriate;
• Suspending or terminating your Account; or
• Taking other actions reasonably necessary to protect the Services, our users, or third parties.

Any enforcement action will be carried out in accordance with applicable law.

20.8 Reporting Concerns

If you become aware of misuse, abuse, security vulnerabilities, or other activities that may negatively affect the Services or other users, you are encouraged to report the matter to Lumi Buddy using the contact information provided in this Privacy Policy.

We appreciate responsible reporting and will make reasonable efforts to investigate legitimate reports.

20.9 Future Services

As Lumi Buddy introduces new AI capabilities, communication methods, integrations, or future Services, additional acceptable use requirements may apply.

Unless otherwise stated, such future Services will also be governed by the principles described in this Section.

20.10 Our Commitment

Lumi Buddy is committed to maintaining a safe, respectful, and trustworthy environment for all users.

We continuously review and improve our policies, technical safeguards, and AI safety measures to promote responsible use while supporting innovation and a positive user experience.

Lumi Buddy is an evolving AI companion platform. As technology advances and user needs change, we may introduce new features, products, services, technologies, and experiences to improve the overall functionality of the Services.

Unless otherwise stated, any future Services introduced by Lumi Buddy will be subject to this Privacy Policy.

21.1 New Features

From time to time, Lumi Buddy may introduce new features or enhancements designed to improve user experience, personalization, accessibility, security, or overall functionality.

New features may include, but are not limited to:

• Enhanced AI capabilities;
• New personalization tools;
• Improved memory systems;
• Expanded relationship features;
• New communication options;
• Productivity tools;
• Accessibility improvements; and
• Other feature enhancements.

The availability of new features may vary depending on your subscription plan, device, platform, region, or applicable law.

21.2 Future AI Capabilities

As Artificial Intelligence technologies continue to evolve, Lumi Buddy may introduce additional AI-powered capabilities, including but not limited to:

• AI agents;
• Multi-step task assistance;
• Advanced reasoning;
• Improved contextual understanding;
• Enhanced personalization;
• Future generative AI technologies; and
• Other intelligent assistance features.

These capabilities may change over time as our Services continue to evolve.

21.3 Future Communication Features

Lumi Buddy may expand communication methods available through the Services.

Future communication features may include:

• Voice Calls;
• Video Calls;
• Voice Messages;
• Real-time conversations;
• Live interactions;
• Screen sharing;
• Multimedia communication; and
• Other communication technologies.

The availability of these features may vary depending on technical, legal, or operational considerations.

21.4 Future Integrations

Lumi Buddy may integrate with additional third-party platforms, applications, or services to improve functionality and user experience.

Examples may include:

• Calendar services;
• Email services;
• Cloud storage providers;
• Productivity tools;
• Smart devices;
• Wearable devices;
• Home automation systems; and
• Other compatible technologies.

Any such integrations will be implemented in accordance with this Privacy Policy and applicable law.

21.5 Subscription Enhancements

We may introduce additional subscription plans, premium features, digital products, usage packages, promotional offers, or other paid Services.

Subscription benefits, pricing, feature availability, and usage limits may change over time.

Any future subscription offerings will be governed by this Privacy Policy, our Terms of Service, and any additional terms applicable to those offerings.

21.6 Service Improvements

Lumi Buddy continuously evaluates opportunities to improve the Services.

Improvements may include:

• Performance enhancements;
• Security improvements;
• AI safety enhancements;
• User interface updates;
• Infrastructure upgrades;
• Reliability improvements;
• Accessibility enhancements; and
• Other operational improvements.

Such improvements may be implemented without prior notice where reasonably necessary to maintain the quality, security, or reliability of the Services.

21.7 Availability of Future Services

Certain future Services may:

• Be introduced gradually;
• Be available only in selected regions;
• Require compatible devices;
• Require an active subscription;
• Be subject to technical limitations;
• Be modified, suspended, or discontinued; or
• Be subject to additional terms and conditions.

Lumi Buddy reserves the right to determine the availability and scope of future Services.

21.8 Our Commitment

As Lumi Buddy continues to grow, we remain committed to developing innovative, responsible, and user-focused AI experiences.

We will continue to improve the Services while respecting user privacy, maintaining appropriate security measures, and supporting transparency in how future technologies are introduced and operated.

Lumi Buddy may update or modify this Privacy Policy from time to time to reflect changes in our Services, technologies, business practices, legal obligations, or other operational requirements.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, protect, and manage your personal information.

22.1 Reasons for Updates

We may update this Privacy Policy for reasons including, but not limited to:

• Introducing new features or Services;
• Expanding AI capabilities;
• Adding or modifying subscription plans;
• Improving security practices;
• Updating our data handling practices;
• Complying with applicable laws or regulatory requirements;
• Responding to technological developments; or
• Improving the clarity and transparency of this Privacy Policy.

22.2 Effective Date

The "Effective Date" displayed at the beginning of this Privacy Policy indicates the date on which the current version became effective.

Unless otherwise stated, updates to this Privacy Policy become effective on the Effective Date specified.

22.3 Notification of Material Changes

If we make material changes that significantly affect how your personal information is collected, used, shared, or otherwise processed, Lumi Buddy may provide additional notice where appropriate.

Depending on the nature of the changes, such notice may be provided through:

• In-app notifications;
• Email communications;
• Notices on our website;
• Service announcements; or
• Other reasonable communication methods.

The method of notification may vary depending on the nature of the update and applicable law.

22.4 Continued Use of the Services

Your continued use of the Services after the Effective Date signifies that you have been informed of the updated Privacy Policy. Where applicable law requires your consent for specific changes, Lumi Buddy will obtain such consent before those changes take effect. If you do not agree with the updated Privacy Policy, you may discontinue your use of the Services at any time and, where applicable, request deletion of your Account in accordance with Section 14 (Account Deletion).

22.5 Previous Versions

Lumi Buddy may maintain previous versions of this Privacy Policy for internal record-keeping, legal compliance, or operational purposes.

Where appropriate, previous versions may be made available upon request or through other reasonable means.

22.6 Our Commitment

We are committed to maintaining transparency regarding our privacy practices.

Whenever we update this Privacy Policy, we will seek to communicate changes clearly and continue protecting your personal information in accordance with applicable law and our commitment to responsible AI and user privacy.

This Privacy Policy and the processing of personal information in connection with the Services shall be governed by and construed in accordance with the laws of the Kingdom of Thailand, without regard to its conflict of law principles.

Nothing in this Privacy Policy is intended to limit or exclude any rights or protections that you may have under applicable law.

23.1 Applicable Law

The collection, use, disclosure, storage, and protection of personal information by Lumi Buddy shall be governed by the applicable laws of the Kingdom of Thailand, except where mandatory laws of another jurisdiction apply.

Where required by applicable law, Lumi Buddy will comply with legal obligations applicable to the Services in the jurisdictions in which they are offered.

23.2 Jurisdiction

Subject to applicable law, any dispute, claim, or legal proceeding arising out of or relating to this Privacy Policy or the processing of personal information shall be subject to the jurisdiction of the competent courts of the Kingdom of Thailand.

Nothing in this Section limits any mandatory legal rights or protections that cannot be waived under applicable law.

23.3 Compliance with Applicable Laws

Lumi Buddy is committed to operating its Services in accordance with applicable privacy and data protection laws.

Where the Services are made available in additional countries or regions, Lumi Buddy may implement additional privacy practices, notices, or legal requirements as necessary to comply with applicable law.

23.4 Severability

If any provision of this Privacy Policy is determined to be invalid, unlawful, or unenforceable under applicable law, that provision shall be enforced to the maximum extent permitted by law, and the remaining provisions of this Privacy Policy shall remain in full force and effect.

23.5 No Waiver

The failure of Lumi Buddy to enforce any provision of this Privacy Policy shall not constitute a waiver of that provision or of any other provision.

Any waiver shall be effective only if made expressly in writing by an authorized representative of Lumi Buddy.

23.6 Our Commitment

Lumi Buddy is committed to respecting user privacy while complying with applicable legal and regulatory requirements.

As our Services continue to expand internationally, we will continue to review and update our privacy practices to support responsible AI, user trust, and legal compliance.

If you have any questions, concerns, requests, or feedback regarding this Privacy Policy, our privacy practices, or the processing of your personal information, please contact us using the information below.

Lumi Buddy values your privacy and will make reasonable efforts to respond to privacy-related inquiries in a timely and appropriate manner.

24.1 Privacy Inquiries

You may contact us regarding matters including, but not limited to:

• Questions about this Privacy Policy;
• Requests relating to your personal information;
• Account deletion requests;
• Privacy concerns;
• Data correction requests;
• Security concerns;
• AI-related privacy questions;
• General privacy inquiries.

24.2 Contact Information

Operator: Lumi AI

Service: Lumi Buddy

Email: support@lumiai.pro

Website: https://lumiai.pro/products/buddy

24.3 Response Time

We will make reasonable efforts to review and respond to privacy-related requests within a reasonable period.

The time required to respond may vary depending on:

• The nature of the request;
• Identity verification requirements;
• Applicable legal obligations;
• Technical complexity; and
• Operational requirements.

Additional information may be requested where reasonably necessary to verify your identity or process your request.

24.4 Reporting Security or Privacy Issues

If you believe that your Account, personal information, or the Services may have been affected by a privacy or security issue, we encourage you to contact Lumi Buddy as soon as reasonably possible.

Prompt reporting helps us investigate potential issues, protect users, and improve the security of the Services.

24.5 Business Communications

General business inquiries, partnership requests, media inquiries, or other non-privacy-related communications may be directed to the appropriate contact channels published on our official website.

24.6 Updates to Contact Information

From time to time, Lumi Buddy may update its contact information to reflect changes in our operations or support channels.

The most current contact information will always be available through our official website.

24.7 Our Commitment

Lumi Buddy is committed to respecting your privacy and providing clear, transparent, and accessible communication regarding our privacy practices.

We appreciate your trust and will continue working to protect your personal information while delivering a safe, responsible, and personalized AI companion experience.