Privacy Policy

Last updated: Luminal AI

This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use the Luminal AI learning platform located at luminal.gg and related services (the “Service”). By using the Service, you agree to this Policy.

Who we are

The Service is operated by MynaLabs Inc. (“Company”, “we”, “us”, “our”), 769 Monterey Blvd., Suite #5A, San Francisco, CA 94127, USA. For purposes of the EU/UK GDPR, we are the data controller.

Scope

This Policy applies to information we process about visitors, account holders, learners, content authors, and partners who interact with the Service. It does not apply to third-party websites, services, or integrations we do not control.

Information we collect

Information you provide

Information we collect automatically

Information from third parties

How we use information

AI features and your content

When you use AI features (e.g., assistants, generators, evaluations), your prompts, uploads, and interaction data may be processed by our infrastructure and trusted AI providers to deliver the feature, ensure safety, and improve quality (e.g., de-identified aggregates). We do not use your prompts or outputs to train public foundation models unless you expressly opt in, and we apply access controls and retention limits appropriate to the feature and legal requirements.

Legal bases (EEA/UK)

We process personal data under GDPR on these bases: consent, contract performance, legitimate interests (e.g., security, product improvement, limited marketing), legal obligation, and vital/public interest where applicable.

Sharing and disclosure

We share information with:

International transfers

We may transfer data to countries outside your own (including the US). When we do, we rely on appropriate safeguards, such as Standard Contractual Clauses, adequacy decisions, and technical/organizational measures.

Retention

We keep personal data only as long as necessary for the purposes described above (e.g., the life of your account, legal retention periods, dispute resolution). We may anonymize data for longer-term analytics.

Security

We use administrative, technical, and physical safeguards to protect personal data. No method of transmission or storage is 100% secure, but we continually improve our protections.

Cookies and tracking

We use necessary cookies to run the Service and optional cookies for analytics/marketing. Where required, we will present a consent banner. You can change preferences at any time via the cookie settings on the site or your browser. “Do Not Track” signals are not responded to due to industry standards variability.

Analytics

Payments

We process payments through third parties such as Apple/Google in-app billing (where applicable), Paddle, Centrobill, or Unlimit. Payment details are submitted directly to these providers and handled under their policies and PCI-DSS rules. We receive limited transaction metadata (e.g., subscription status, amounts, timestamps).

Your rights

EEA/UK

You can request access, correction, deletion, restriction, objection (including to direct marketing), and portability, and withdraw consent where processing is based on consent.

California (CCPA/CPRA)

California residents have rights to know, delete, correct, opt out of “selling” or “sharing” personal information (as defined by law), and non-discrimination. We do not sell personal information for money. Some advertising/analytics may be considered “sharing” under CPRA; you can opt out via cookie preferences or by contacting us.

Exercising your rights

Submit requests or questions using the contact details below. We may need to verify your identity. Authorized agents may act on your behalf where permitted by law.

Children

The Service is not directed to children under 13 (or the age required by your jurisdiction). We do not knowingly collect personal data from children; if you believe a child has provided data, contact us to remove it.

Third-party links and integrations

The Service may link to or integrate third-party content and tools (e.g., YouTube embeds, AI providers). Their privacy practices are governed by their own policies.

Changes to this Policy

We may update this Policy from time to time. Material changes will be notified via the Service or by email before they take effect. The “Last updated” date at the top shows the latest version.

Contact us

Email: privacy@luminal.gg
Postal: MynaLabs Inc., 769 Monterey Blvd., Suite #5A, San Francisco, CA 94127, USA


If this English version differs from localized versions, the English version controls, except where local law requires otherwise.