Privacy Policy

Lumio 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.

Lumio AI is an AI media-generation app that turns your text prompts and the photos you choose into AI-generated videos and images. You do not need to create an account to use it. To generate content, the prompt text and any image you select are sent to our AI processing providers; the App otherwise works without you providing personal details.

1. Information we collect

We collect only the data that actually leaves your device:

• Content you submit for generation — the text prompts you write and the photos/images you pick from your device to be turned into AI videos or images. These are transmitted to our AI generation providers (see §3) solely to produce your result.
• Device and advertising identifiers — including the Android Advertising ID, used for ads, attribution, and measurement.
• Approximate (IP-derived) location — coarse location inferred from your IP address by our advertising partners for ad delivery and measurement.
• App activity — in-app interactions, features used, and generation requests, used for analytics and to improve the App.
• Purchase status — records of in-app purchases/subscriptions processed through Google Play Billing (Google processes the payment; we do not receive your card details).
• Crash logs and diagnostics — technical data about crashes and performance to keep the App stable.

We do not require an account, and we do not ask for your name, email, or contacts to use the App. Photos are accessed only when you pick them for a generation; the App does not scan or upload your photo library in the background.

2. How we use information

• Provide and operate the App and generate the videos/images you request.
• Show and measure advertising (including through mediation partners).
• Measure marketing attribution (which campaign led to an install).
• Analytics and product improvement.
• Fraud prevention and security.
• Process in-app purchases and subscriptions.
• Comply with legal obligations.

3. Third-party services

The App integrates the following data-transmitting services. Each processes data under its own privacy policy:

When you generate content, your prompt text and any selected image are sent to one of the AI generation providers above (fal.ai, Alibaba Cloud DashScope, or BytePlus) to produce your output. These providers process the content to return your result and are located outside your country (see §9).

Ad consent (UMP). Where required (e.g. the EEA/UK), the App shows a Google User Messaging Platform (UMP) consent form governing personalized ads and related data use. You can change your choice later in the App's settings/consent options.

Reset or opt out of your advertising ID. You can reset or delete your Android Advertising ID, or opt out of ad personalization, in your device settings (Settings → Google → Ads).

4. How we share information

We do not sell your personal information for money. We share data with:

• The third-party services listed in §3, for the purposes described.
• Legal and safety recipients, where required by law or to protect rights and safety.
• A successor entity in the event of a merger, acquisition, or asset transfer.

Because the App serves personalized advertising, some U.S. state privacy laws treat the sharing of advertising identifiers with ad networks as a "sale" or "sharing" for targeted advertising. You can opt out via the ad-personalization controls described in §3 and the rights in §7.

5. Legal bases (EEA/UK — GDPR)

• Consent — personalized ads and analytics where consent is required (via the UMP form).
• Legitimate interests — core functionality, security, fraud prevention, and product improvement.
• Contract / legal obligation — processing purchases and meeting legal duties.

6. Data retention

We keep data only as long as necessary for the purposes above or as required by law. Prompts and images sent for generation are retained by the AI providers per their own retention periods to deliver and support the service. Advertising and attribution identifiers are retained by those partners per their policies. Crash and diagnostic data are kept for a limited period.

7. Your rights

• GDPR (EEA/UK): access, correction, deletion, portability, objection, restriction, withdrawal of consent, and the right to complain to a supervisory authority.
• CCPA/CPRA (California): know, delete, correct, and opt out of the "sale"/"sharing" of personal information and targeted advertising; non-discrimination for exercising rights.
• Other regions (LGPD, PIPEDA, etc.): equivalent rights under your local law.

Because the App has no account, when you contact us to exercise a right please include your Android Advertising ID and relevant device details so we can locate any associated data. Contact us at the address in §13.

8. Children's privacy

The App is intended for users aged 16 and over and is not directed to children. We do not knowingly collect personal information from children under the applicable age of digital consent. If you believe a child has provided us data, contact us and we will delete it.

9. International data transfers

Your data — including prompts and images sent for AI generation — may be processed in countries other than yours, including the United States, Singapore, China (Alibaba Cloud / BytePlus infrastructure), and elsewhere. Where required, we and our providers rely on appropriate safeguards such as Standard Contractual Clauses.

10. Data security

We use encryption in transit (HTTPS/TLS) and reasonable technical and organizational measures to protect your data. No method of transmission or storage is 100% secure.

11. Third-party content

The App generates and displays AI-produced media based on your input and may link to third-party services. We are not responsible for third-party content or the practices of external sites; review their policies before use.

12. Changes to this Policy

We may update this Policy. Material changes will be posted here with a new "Last updated" date; continued use of the App means you accept 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

© 2026 Tranquil Mind Technology JSC (@Tranquil Mind Technology JSC). All rights reserved.