【Lumina】Privacy Policy and Cookie Policy

Effective Date: November 2025

A. Privacy Policy

Wuhan Aiwujiwu Technology Co., Ltd ("Company," "we," or "us") operates the Lumina app ("App"). We are committed to protecting your personal information and ensuring compliance with applicable data protection laws. This Privacy Policy ("Policy") explains how we collect, use, and safeguard your data when you use our App. If you do not agree with this Policy, please do not use the App.

Updates to This Policy
 We may update this Policy to reflect changes in law, business operations, or other legitimate reasons. Changes take effect immediately once published in the App. We encourage you to review this Policy periodically, as the latest version will always be available in the App settings.

Scope of This Policy
 This Policy applies to all personal data we collect and process when you:

• Access or use the Lumina mobile application.
  
• Use any services, features, or functionalities provided by the App.
  

User Eligibility
 You must be of legal age of majority in your jurisdiction (country, state, or territory) to use the App.

Personal Data We Collect

“Personal Data” refers to information that directly or indirectly identifies you. Examples include:

• Device identifiers (e.g., hardware model, operating system).
  
• App usage patterns (e.g. which modules you use: AI homework, study plans, schedule, notices, growth records).
  
• IP address and approximate location.
  
• Email address for payment confirmations or support.
  
• Cookie data as described in our Cookie Policy.
  
• Images/content you voluntarily upload to use App features (e.g. homework photos, photos of school notices, growth/learning photos).
  

Data Collection and Use

We only collect data necessary for the App’s core functions, including:

• Device information (in aggregated, non-identifiable form) to maintain App performance.
  
• Access to camera or photo library when you choose to upload homework questions, school notices, or growth photos. This content is used to provide the service (e.g. AI recognition) and is not used beyond the stated purpose.
  
• Network and usage data to enable AI processing, reminders, and synchronization.
  
• Location data, collected via IP address for service optimization, only with your explicit consent.
  
• Third-party data collection through ad networks and Apple/Google platforms, per their policies.
  

For features like AI homework recognition, your uploaded image may be sent to our servers or trusted processors solely to generate a reference answer and return it to you.

User Obligations

By using the App, you confirm that:

• Information you provide is accurate and complete.
  
• For any third-party information you upload (e.g. a school notice with personal data), you have the right to upload it.
  
• You are not under the age of 13 (COPPA compliance), or you use the App under parental consent where required.
  

Purposes of Data Processing

We process personal data for the following purposes:

• Delivering App functionality (AI homework assistant, study plans, family schedule, digitalized notices, growth records).
  
• Processing subscription payments.
  
• Sending in-App or system notifications (e.g. reminders).
  
• Responding to support inquiries.
  
• Complying with legal obligations.
  
• Preventing fraud and unauthorized use.
  
• Improving the App and user experience.
  
• Serving limited advertisements (with opt-out rights, where applicable).
  

Legal Basis for Processing

We process data under the following legal bases:

• Consent: For AI image processing, advertising, and analytics.
  
• Contractual necessity: To provide services as outlined in our Terms of Service.
  
• Legal compliance: To meet regulatory requirements.
  
• Legitimate interests: To improve performance, prevent fraud, and defend legal claims.
  

Data Retention

We retain personal data only as long as necessary to fulfill processing purposes. Data related to homework images, notices, or growth records may be kept as long as you keep them in the App or until you delete them. Data may be stored longer if required by law, for fraud prevention, or to resolve disputes. When retention ends, data is securely deleted or anonymized.

Data Sharing

We may share data with:

• Apple/Google for payment and app distribution.
  
• Third-party processors (e.g., RevenueCat, Firebase, Amplitude) under binding agreements.
  
• AI/annotation or recognition service providers strictly for the purpose of providing the AI feature.
  
• Government authorities when legally required.
  
• Legal counsel in case of disputes.
  

International transfers comply with applicable safeguards (e.g., Standard Contractual Clauses, encryption).

Data Protection and Security

We implement strict safeguards, including:

• Encryption in transit (TLS 1.3+) and at rest (AES-256).
  
• Role-based access controls with MFA.
  
• Firewalls, intrusion detection, and DDoS protection.
  
• Regular vulnerability testing and audits.
  

Despite these measures, no system is completely secure.

User Rights

You may exercise the following rights:

• Access and request a copy of your data.
  
• Rectify inaccurate information.
  
• Request deletion of your data (including uploaded content).
  
• Restrict or object to processing.
  
• Opt out of targeted advertising where available.
  

Requests will be addressed within one month, extendable for complex cases. You may escalate concerns to your local Data Protection Authority.

For privacy-related inquiries, you may contact us at: cleanupai.team@gmail.com.

B. Cookie Policy

This Cookie Policy explains the use of cookies and similar technologies in the App. By using the App, you agree to our use of cookies as described here.

What Are Cookies?

Cookies are small data files stored on your device to help recognize your device, improve navigation, retain preferences, personalize services, and generate usage statistics.

Types of Cookies We Use

• Session Cookies: Authenticate users during sessions and expire when the App or browser closes.
  
• Persistent Cookies: Keep you logged in and remember preferences across sessions.
  
• First-Party Cookies: Set by us for core App functions.
  
• Third-Party Cookies: Set by partners (e.g., payment processors, analytics providers).
  
• Technical Cookies: Enable essential features like subscriptions, reminders, or sync.
  
• Analytical Cookies: Provide aggregated usage insights (e.g. which features are most used).
  
• Preference Cookies: Store language and customization settings.
  

Cookie Consent and Control

We request your consent before placing cookies, except those essential for service delivery. You can manage or withdraw consent anytime via device/browser settings. For third-party cookies, please review their respective privacy and cookie policies.