Legal · Privacy

Privacy Policy

App: Lumio AI Last Updated: July 12, 2026

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 video generator that turns your text prompts and photos into short AI-generated videos. You do not need to create an account to use it.

1. Information We Collect

We collect only the data described below. Much of what happens in the App (browsing effects, editing before generation, storing your generated videos in the on-device gallery) stays on your device and is not collected by us.

a) Content you provide for video generation

Photos. If you use Image-to-Video or a photo-based effect, the photo you select is sent to our AI video-generation provider (fal.ai) to render your video. Photos are used only to generate your requested video and are not used by us to build a profile of you.
Text prompts. Text you type to generate a video is sent to the same provider to produce the video.

b) Information collected automatically

Device and advertising identifiers (including the Android Advertising ID / Apple IDFA and similar device IDs).
Approximate location derived from your IP address (coarse, not GPS) for advertising and analytics.
App activity and usage (features used, effects selected, screens viewed, generation events, ad interactions).
Diagnostics and crash logs (device model, OS version, app version, crash traces, performance data).
Purchase status (whether a purchase or subscription succeeded), processed through Google Play Billing.

We do not collect your name, email address, contacts, precise GPS location, phone number, or microphone audio. We do not require you to log in.

2. How We Use Information

To provide and operate the App and generate the videos you request.
To display and measure advertising, including personalized ads where permitted.
For analytics, to understand usage and improve the App.
To detect, prevent, and address fraud, abuse, and security issues.
To process and validate in-app purchases and subscriptions.
To comply with legal obligations.

3. Third-Party Services

The App uses the following third-party services, which may receive data as described. Each processes data under its own privacy policy:

Service	Purpose	Data involved	Policy
Google Firebase (Analytics, Crashlytics, Remote Config)	Analytics, crash reporting, configuration	Device IDs, app activity, diagnostics, crash logs	firebase.google.com/support/privacy
Google AdMob	Advertising (incl. rewarded ads)	Advertising ID, approximate location, app activity	policies.google.com/privacy
Meta Audience Network (ad mediation)	Advertising	Advertising ID, approximate location, device data	facebook.com/about/privacy
AppsFlyer	Mobile attribution / marketing analytics	Device and advertising identifiers	appsflyer.com/legal/privacy-policy
Google Play Billing	Process purchases and subscriptions	Purchase status	policies.google.com/privacy
fal.ai (AI video generation)	Generate videos from your prompts/photos	Your text prompts and selected photos	fal.ai/privacy

Advertising ID and ad consent. Our advertising and analytics partners use your device's advertising ID. You can reset or delete this ID, or opt out of ad personalization, in your device settings (Android: Settings → Privacy → Ads; iOS: Settings → Privacy & Security → Tracking / Apple Advertising). Where required (e.g., in the EEA/UK), we present a consent request (an IAB TCF / Google UMP-style consent form and, on iOS, App Tracking Transparency) before serving personalized ads or tracking; you may decline or change your choice.

We do not sell your personal information for money. We share information only with the third-party services listed in Section 3, for the purposes described, and as required by law (e.g., to comply with a legal request), or in connection with a business transfer (merger, acquisition, or asset sale).

U.S. state privacy note. Because our advertising partners may use identifiers to serve personalized ads, this activity may be considered a "sale" or "sharing" (targeted advertising) under certain U.S. state laws (e.g., California's CCPA/CPRA). You can opt out via the device ad-settings and consent controls described in Section 3, and by the rights in Section 7.

5. Legal Bases (EEA/UK — GDPR)

Consent — personalized advertising and any analytics/tracking that requires consent.
Legitimate interests — core functionality, security and fraud prevention, non-personalized measurement, and improving the App.
Performance of a contract / legal obligation — processing your purchases and meeting legal requirements.

You may withdraw consent at any time via the in-app consent controls or device settings.

6. Data Retention

We keep data only as long as necessary for the purposes above or as required by law. Photos and text prompts are processed to generate your video and are retained by our generation provider only for the limited period needed to deliver the result and for their operational/abuse-prevention purposes. Advertising and analytics identifiers are retained per each partner's retention schedule; crash and diagnostic data are kept for a limited period to fix issues.

7. Your Rights

EEA/UK (GDPR): access, rectification, erasure, portability, restriction, objection, withdrawal of consent, and the right to lodge a complaint with your data protection authority.

California and other U.S. states (CCPA/CPRA and similar): the right to know, delete, and correct personal information, to opt out of sale/sharing and targeted advertising, and not to be discriminated against for exercising your rights.

Other regions (e.g., Brazil's LGPD, Canada's PIPEDA): equivalent local rights.

To exercise any right, contact us at the email in Section 13. Because the App has no account or login, please include your device's advertising ID and device details in your request so we (and our partners) can identify the relevant data.

8. Children's Privacy

The App is intended for users 16 years of age or older and is not directed to children. We do not knowingly collect personal information from children under 16 (or the applicable age of digital consent in your country). If you believe a child has provided us information, contact us and we will delete it. AI-generation features are not designed for use by children.

9. International Data Transfers

We and our service providers may process your data in countries outside your own, including the United States. Where required, we rely on appropriate safeguards (such as the EU Standard Contractual Clauses) for these transfers.

10. Data Security

We use encryption in transit (HTTPS/TLS) and other reasonable technical and organizational measures to protect your data. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

11. AI-Generated Content

Videos are produced by artificial intelligence based on the prompt or photo you provide. You are responsible for the content you submit: only upload photos you own or have permission to use, and do not use the App to impersonate real people or create misleading, unlawful, or harmful content. Generated results may be inaccurate or unrealistic.

12. Changes to This Policy

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

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