Privacy Policy

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This Privacy Policy describes how Atech Engineering Solutions SRL ("we," "us," or "our") collects, uses, and protects your personal information when you use the Lumi AI mobile application (the "App"). We are committed to protecting your privacy and ensuring transparency about our data practices.

1. Information We Collect

1.1 Information You Provide Directly

• Chat Messages: The messages you send to our AI assistant to provide personalized responses
• Profile Information: Optional profile pictures and display preferences you choose to set
• Account Data: Information necessary for account creation and authentication
• Subscription Information: Payment and subscription status for premium features

1.2 Information Collected Automatically

• Usage Data: App usage statistics, feature interactions, and performance metrics
• Device Information: Device type, operating system, app version, and unique device identifiers
• Technical Data: IP address, crash reports, and error logs for app improvement

1.3 Camera Access

We request camera access solely for the purpose of allowing you to take profile pictures. Camera access is only activated when you explicitly choose to take a photo for your profile. We do not access your camera for any other purpose.

2. How We Use Your Information

2.1 Primary Uses

• AI Responses: Processing your messages to provide intelligent, contextual responses
• App Functionality: Enabling core features like message history, preferences, and synchronization
• Subscription Management: Processing payments and managing premium features access
• Customer Support: Responding to your inquiries and providing technical assistance

2.2 App Improvement

• Analyzing usage patterns to enhance user experience
• Fixing bugs and improving app performance
• Developing new features based on user needs
• Ensuring app security and preventing abuse

3. Information Sharing and Disclosure

3.1 We Do Not Sell Your Personal Information

We do not sell, rent, or trade your personal information to third parties for monetary or other valuable consideration.

3.2 Limited Sharing

We may share your information only in the following circumstances:

• Service Providers: With trusted third-party services that help us operate the app (Firebase for data storage, RevenueCat for subscription management, DeepSeek for AI processing)
• Legal Requirements: When required by law, court order, or to protect our rights and safety
• Business Transfers: In connection with a merger, acquisition, or sale of assets (with user notification)
• Consent: When you explicitly consent to sharing for specific purposes

4. Third-Party Services

4.1 Firebase (Google)

We use Firebase for data storage and synchronization. Your data is processed according to Google's Privacy Policy and stored securely in their infrastructure.

4.2 RevenueCat

We use RevenueCat for subscription management. Payment information is processed securely and is subject to RevenueCat's privacy policy.

4.3 DeepSeek AI

Your messages are processed by DeepSeek AI to generate responses. This processing is necessary for the core functionality of the app.

5. Data Storage and Security

5.1 Data Storage

• Chat messages are stored locally on your device and synchronized with our secure servers
• Profile pictures are stored securely and only accessible to you
• All data transmission uses industry-standard encryption

5.2 Security Measures

• End-to-end encryption for data transmission
• Secure server infrastructure with regular security updates
• Access controls and authentication mechanisms
• Regular security audits and monitoring

6. Your Rights and Choices

6.1 European Union (GDPR) Rights

If you are in the EU, you have the following rights:

• Right to Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data
• Right to Portability: Receive your data in a structured, machine-readable format
• Right to Restrict Processing: Limit how we process your data
• Right to Object: Object to data processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent for data processing at any time

6.2 California (CCPA) Rights

If you are a California resident, you have the right to:

• Know what personal information we collect, use, and share
• Request deletion of your personal information
• Opt-out of the sale of personal information (we don't sell your data)
• Non-discrimination for exercising your privacy rights

6.3 How to Exercise Your Rights

To exercise any of these rights, please contact us using the information provided below. We will respond to your request within 30 days.

7. Children's Privacy

Our app is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If we become aware that we have collected personal information from a child under 13, we will take steps to delete such information promptly.

8. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that are different from the laws of your country. We ensure that such transfers are made in accordance with applicable data protection laws and with appropriate safeguards in place.

9. Data Retention

We retain your personal information for as long as necessary to provide you with the app's services and as required by applicable laws. When you delete your account, we will delete your personal information, except where we are required to retain it by law.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy in the app and updating the "Last Updated" date. Your continued use of the app after any changes constitutes your acceptance of the updated Privacy Policy.

11. Legal Basis for Processing (EU Users)

We process your personal information based on the following legal bases:

• Contract Performance: To provide the app services you've requested
• Legitimate Interests: To improve our app and provide customer support
• Consent: For optional features like profile pictures
• Legal Obligation: To comply with applicable laws and regulations