Privacy Policy

Lumin AI ("the App", "we", "us", "our"), operated by Tranquil Mind Technology JSC, respects your privacy. This Privacy Policy explains what information we collect, how we use and share it, and the choices and rights you have. By using the App, you agree to this Policy.

Lumin AI is an AI-powered photo editor that lets you enhance old or low-quality photos, remove unwanted objects, expand images beyond their original frame, and generate AI artwork from your photos. You do not need to create an account to use it.

1. Information We Collect

1.1 Photos and images you submit for AI processing

When you use an AI editing feature, the following leaves your device:

• The photo or image you select (from your gallery or captured with the camera), together with any additional image you provide such as a mask or a second reference image.
• The style or text prompt associated with the effect you choose (for example the name of a preset or a generation prompt).

These images and prompts are sent to (a) our own AI processing backend, operated by us, for features such as background removal, object removal, and AI image generation, and (b) the third-party AI provider GetImg.ai for AI style transfer, upscaling, and image expansion. See Section 3 for details. The images are used only to perform the edit you requested and to return the result; per our implementation we do not build a profile from them or use them to identify you. Third-party AI providers process the images under their own privacy policies (see Section 3).

1.2 Information processed only on your device

Aside from the images you submit for AI processing (Section 1.1), the following is handled locally on your device and is not transmitted to us:

• Camera. With your permission, the App uses the camera so you can capture a photo to edit; the capture stays on your device unless you submit it to an AI feature (Section 1.1).
• Photos, media & storage. With your permission, the App reads the images and files you select and saves your exported results back to your device storage.
• Settings and preferences. Your in-app settings are stored only on your device.

You can delete on-device data at any time by clearing the App's data or uninstalling the App.

1.3 Information collected automatically by third-party services

When you use the App, the third-party services listed in Section 3 may automatically collect:

• Advertising & device identifiers (such as the Android Advertising ID) and basic device information (model, OS version, app version).
• Approximate location derived from your IP address (city/region level) — not GPS-based tracking.
• App activity & diagnostics such as feature usage, session data, and crash reports.

1.4 Information you provide

The App does not require account registration and does not ask for personal information such as your name, email, or phone number, unless you voluntarily contact support.

2. How We Use Information

• Provide and operate the App — including uploading the images and prompts you submit to our AI processing backend and third-party AI providers to perform the photo edit you request and return the result; remote configuration keeps the App's settings up to date.
• Advertising and measurement — to serve ads (which fund the free App) and measure ad performance and install attribution.
• Analytics and improvement — to understand how the App is used and improve features and stability.
• Fraud prevention, security and compliance — to detect invalid ad traffic and abuse.
• Legal compliance — to comply with applicable laws and enforce our terms.

3. Third-Party Services

The following third-party services are integrated in the App. The AI provider receives the images and prompts you submit for editing (Section 1.1); the advertising, attribution and analytics services may collect the data described in Section 1.3. Each processes data under its own privacy policy:

We are not responsible for the privacy practices of these third parties and recommend reviewing their policies. We do not sell or rent your personal information.

4. How We Share Information

We do not sell your personal information for money. Information is shared only:

• With AI image-processing providers — the photos, masks, and prompts you submit to an AI feature are transmitted to our own AI processing backend and to the third-party AI provider listed in Section 3 (GetImg.ai), for the sole purpose of performing the edit you requested and returning the result.
• With the ad, analytics, and attribution partners listed in Section 3, to the extent described above. Under some U.S. state privacy laws (for example the CPRA), the transfer of identifiers to advertising partners for personalized ads may be considered a "sale" or "sharing" — Section 7 explains how to opt out.
• For legal reasons, if required by law, regulation, legal process, or enforceable governmental request, or to protect our rights, users, or the public.
• In a business transfer, such as a merger, acquisition, or asset sale, in which case this Policy will continue to apply to previously collected data.

5. Legal Bases (EEA/UK — GDPR)

Where the GDPR or UK GDPR applies, we rely on:

• Consent — for personalized advertising and, where required, analytics. You may withdraw consent at any time via the in-app consent dialog or system settings.
• Legitimate interests — for core App operation, security, fraud prevention, non-personalized advertising, and improvement, balanced against your rights.
• Legal obligation — where processing is required by law.

6. Data Retention

We do not keep a user account database. The photos and prompts you submit to our AI processing backend (Section 1.1) are processed transiently to perform the requested edit and to return the result, and are not retained by us for longer than needed to deliver that result. Images sent to the third-party AI provider (GetImg.ai) are handled under its own retention policy. Our advertising, attribution, and analytics partners retain the data they collect for the periods stated in their own policies (for example, Google Analytics for Firebase retains user-level data for up to 14 months; crash logs are retained for around 90 days). Data processed only on your device (Section 1.2) remains until you clear the App's data or uninstall the App.

7. Your Rights

Depending on where you live, you may have the right to access, correct, delete, or port your data, to object to or restrict processing, to withdraw consent, and to lodge a complaint with your supervisory authority (GDPR/UK GDPR); or to know, delete, correct, and opt out of the "sale"/"sharing" of personal information and targeted advertising without discrimination (CCPA/CPRA and similar U.S. state laws); or equivalent rights under other laws (LGPD, PIPEDA, and others).

To exercise any right, email contact@tranquilmind.co. Because the App has no accounts, please include your Android Advertising ID (Settings → Google → Ads) and device model so we and our partners can locate data associated with your device. You can also act directly on your device: reset your Advertising ID, opt out of ads personalization, use the in-app consent dialog, or clear the App's data.

8. Children's Privacy

The App is intended for users aged 13 and older and is not directed to children under 13 (or the minimum age of digital consent in your country). We do not knowingly collect personal information from children. If you believe a child has provided us data, contact us at contact@tranquilmind.co and we will delete it. We do not knowingly serve personalized ads to children.

9. International Data Transfers

Our ad and analytics partners may process data in countries other than yours, including the United States. Where required, transfers are protected by safeguards such as the EU Standard Contractual Clauses or equivalent mechanisms maintained by those partners.

10. Data Security

Data transmitted to our advertising, analytics, attribution, and third-party AI partners is encrypted in transit using HTTPS/TLS. We and our partners apply reasonable technical and organizational measures to protect the images and information handled by the App; however, no method of transmission or storage is 100% secure.

11. Third-Party Apps, Content and Links

The App displays ads and may contain links that lead to third-party websites, apps, or services. Those services are governed by their own terms and privacy policies, and we are not responsible for them. Lumin AI is not affiliated with, endorsed, or sponsored by any third-party brands referenced in the App.

12. Changes to This Policy

We may update this Policy from time to time. Material changes will be posted in the App or on this page with a new "Last updated" date. Your continued use of the App after changes take effect constitutes acceptance of the updated Policy.

13. Contact Us

Tranquil Mind Technology JSC
No. 3, Alley 98, Vu Trong Phung Street, Thanh Xuan Ward, Hanoi City, Vietnam
Email: contact@tranquilmind.co