Privacy Policy

Last updated: 18 October 2026

This Privacy Policy explains how Lumy collects, uses, shares and protects personal data when you use Lumy, the AI game builder at luminary.gg, and the choices and rights you have. It applies to visitors, guests, signed-in makers, players of published projects, people on our waitlist and anyone who contacts us. It should be read with our Terms of Service and our Cookie and Storage Policy.

We keep this short where we can and precise where it matters. We never sell personal data and we do not run advertising.

1. Who we are

Lumy makes and operates Lumy and is the controller of the personal data described in this policy, except where Section 12 says we act as a processor for makers.

You can reach us about privacy through a ticket at /support under "Privacy or data request", or at our notices address, hello@luminary.gg.

2. What we collect

Account and profile. Your player name (taken from your Google account at first, and changeable in Settings), your email address, your settings (such as how the builder talks to you, default model, default look, tutorials, phone preview, self-improvement), your early-access code, and your referral link and referral history.

Sign-in data. Google is the only way to sign in to Lumy. When you sign in with Google, we receive your Google account identifier and the name, email address and picture Google shares with us. We never see your Google password. We store sign-in keys in hashed form.

Your age. Lumy is for people 18 and over. Google does not share your birthday with us, so the first time you sign in we ask for your date of birth. We keep your date of birth, the age it gives, where it came from (you or your sign-in provider) and when you gave it, with your account. We use it only to check that you are 18 or over. If you tell us you are under 18, we do not open the account and we keep only your email address and the date, so the account cannot be opened later with a different answer.

Your technical level. Right after your date of birth, we ask how much you would like us to explain: I'm new to this, I know my way around, or I'm a pro. We keep the answer and when you gave it, with your account, and use it only to explain things at the right level (for example, how detailed our steps are in the studio and in help answers). You can change it any time in Settings.

Guest identity. Every visitor, guest or signed in, has an account record on our servers, not only in the browser. If you look around without signing in, we create a random guest identifier for that record. Guests can look around but cannot build: building needs a Google sign-in. If you type a first prompt as a guest, it waits while you sign in.

Sessions. We keep a record of your signed-in sessions on our servers. Sign out in Settings > Account ends the session on our servers, and Sign out everywhere ends every session on every device.

Projects and building activity. Your prompts, chat messages with the builder, answers to intake questions, references (uploaded images, screenshots, links and @-tagged product names), game rules, every version of your project and its code, generated art, thumbnails, names, descriptions, Wow Scores, the history of what you asked and what changed, the thumbs up or down you give, which versions you keep or roll back, and Autopilot activity.

Your agreement to our terms. The version of the Terms of Service and Privacy Policy you agreed to at sign-in, and when.

Tokens and usage. Every step you run, its token hold and final cost, your balances, allowances, top-ups, your plan and billing period and expiry dates, and rate-limit events.

Plan, bonuses and savings. Your plan and billing period, the total tokens your account has received and the sum for each kind (starting tokens, plan tokens, packs, streak tokens, referral tokens and refunded purchases). We also keep the figure behind "You've saved" on your Billing page, worked out from your own steps.

Published projects and gameplay. When people play a published project, we record scores and leaderboard entries, cloud saves (up to 300 KB per player per game) and online room activity. If a visitor presses Accept on the cookie banner, we also record analytics for the maker's Data page: a private ID per person (or the account, for signed-in people), sign-ins, whether they come back the next day, time per visit, the screens they visit, device type, the referring site, visits per day, the actions the app reports, errors, and wins and losses for games. If a visitor presses Reject, no analytics events are sent and they are not counted. For apps built with Lumy, we store the records, files and Google sign-ins that the app's own users create, on behalf of the app's maker (see Section 12).

Connected services. If you connect your own Stripe account, a GitHub token or another tool to a project (a webhook link, a Google Sheet or Calendar you share with us, your phone number for chat links, a Twilio, Mailchimp or Brevo account, or your Google Analytics or Plausible ID), we store the keys and settings you give us, encrypted, and the minimum details needed to use them. When the app does what you set up, we send the data it sends to the service you chose (for example a booking to your webhook, sheet or calendar, a phone number and message to Twilio, an email address to your mailing list). For a Google Sheet or Calendar we only open the one you shared with us, and your app sees only when you are busy, never your event names.

Payments. Real payments are not open yet. Today, the waitlist stores your email address, the pack or offer you chose and the price shown, and invited testers use a test checkout where no card is asked for and nothing is charged. When real payments open, a certified payment provider will process your card; we will receive only limited details such as the pack you bought, the last digits and expiry of your card, your billing country and the status of payments. We never see or store full card numbers.

Support and help. Tickets you open (topic, messages, attachments, your email if you give it, the project link and the reference number), chats with the "Ask Lumy" help agent, and any chat attached when you hand a conversation over to our team. Abuse reports, copyright and trademark notices, counter-notices, appeals and security reports, including the contact details and statements they contain.

Device and visit data. IP address, browser and device type, operating system, screen size, language, pages visited, the site that referred you, timestamps and technical logs. Our hosting keeps security logs. While you use Lumy, we also keep an activity log on every page: the pages and screens you open, what you click, sign-in and sign-out, which steps run, how long they take and any errors, together with the requests you type in the chat. We use it only to find and fix problems. It never contains passwords or payment details. Analytics about how Lumy is used are collected only if you allow them.

Cookies and browser storage. The items listed in our Cookie and Storage Policy.

We do not ask for, and you should not give us, special categories of personal data (such as health, religion, sexual orientation or biometric data) or government identity numbers.

3. Where it comes from

• From you, when you use Lumy, build, publish, contact us or join the waitlist.
• From your devices, automatically, when you visit or use Lumy.
• From Google, when you sign in with it.
• From other users, for example when someone reports your project, remixes it, refers you with their link, or plays your game.
• From makers' apps, when you use an app built with Lumy (the app's maker controls that data, see Section 12).
• From payment providers, once real payments open.
• From public sources and authorities, occasionally, for fraud prevention, safety or legal matters.

4. Why we use it, and our legal bases

Where the EU or UK General Data Protection Regulation applies, we rely on the legal bases below.

Purpose	Examples	Legal basis
Provide Lumy	Accounts, sign-in, building, saving, versions, publishing, hosting, the game and app backend, downloads, custom domains	Performance of our contract with you
Explaining at your level	Keeping the technical level you picked, so our replies, next steps and help answers explain things at the right level	Performance of our contract with you
Age check	Asking your date of birth at first sign-in, and keeping the email and date of anyone under 18 who was turned away	Legitimate interests (keeping Lumy for adults); legal obligation where it applies
Tokens and billing	Holding and settling tokens, allowances, plans, top-ups, waitlist, invoices when payments open	Contract; legal obligation for tax and accounting records
Plan perks and savings	Working out which plan perks apply to you, the tokens you received, and showing "You've saved"	Performance of our contract with you
Safety, security and abuse prevention	Rate limits, multi-account and referral abuse detection, fraud checks, content moderation, security logs	Legitimate interests in keeping Lumy safe and fair; legal obligation where applicable
Support	Answering tickets, the help agent, appeals, takedowns	Contract; legitimate interests
Improve Lumy	Measuring quality using usage signals (versions kept, ratings, errors) and de-identified or aggregated content, to improve our quality systems, prompts and game kit	Legitimate interests in making Lumy better, balanced against your rights
Visit analytics	Understanding how visitors use our pages	Consent, which you can withdraw at any time
Service messages	Important changes, security notices, ticket replies	Contract; legitimate interests
Legal and compliance	Responding to valid legal requests, enforcing our Terms, handling copyright notices, defending claims	Legal obligation; legitimate interests
Players and leaderboards	Showing names and scores on published projects, cloud saves, online rooms	Contract with the player; legitimate interests of makers and players

We will not use your personal data for a new purpose that is incompatible with these without telling you first and, where required, asking for your consent.

5. How AI processing works

Lumy uses a mix of leading AI systems, chosen and tuned by us, to build what you ask for. When you run a step, we send the AI systems the parts of your prompt, chat, references and project that the step needs, and they return code, text or art.

• No training by our AI providers. Our AI providers are contractually barred from training their models on your content.
• Our own improvement. We may use usage signals and de-identified or aggregated content to improve Lumy's quality systems, prompts and game kit, as described in Section 8 of our Terms of Service. We do not use your identifiable projects to create public showcases without the permissions in our Terms. We also analyse projects in aggregate, including measured design facts and whether a version was kept, edited, published or followed by a purchase, to improve how Lumy builds; this analysis is internal, never shown to other users and never changes what you pay.
• No decisions with legal effects. Lumy does not make decisions about you based solely on automated processing that produce legal or similarly significant effects. Automated safety systems may flag or hold content or activity; a person reviews appeals.
• Please do not put other people's personal information, secrets or keys into prompts, references or projects.
• Photos you choose to upload. Lumy does not ask for or encourage sharing private or personal information, including photos of people. If you choose to upload a photo to make a character or profile from it, that is solely your decision, with your consent and at your responsibility, including the consent of every person shown. The photo is sent once to the AI system for that step and is not stored, logged or reused by us; only the resulting character is saved in your project.

6. Who we share it with

We share personal data only as described here.

• Service providers (processors) who work for us under contract, confidentiality and data protection terms, in these categories:
  • our cloud hosting provider (hosting, storage, databases, logs);
  • AI systems that generate code, text and art;
  • Google, which confirms who you are when you sign in;
  • email delivery providers (ticket replies, service messages, and email your apps send);
  • a certified payment provider, once real payments open;
  • support and ticketing tooling.
• The public, for what you publish on purpose: a published project is open to anyone with its link, and shows its title, description, your player name and picture, play count, and the names and scores on its leaderboard. It is listed in Explore only if you turn on "Show it in Explore", which is off by default. Public listings never show the project ID or your account. Remixes show that they were remixed from your project, and copy only the published game and its public details, never your prompt or answers.
• Makers, when you play a published project or use an app: if you accepted analytics, the maker sees analytics under Numbers in Backstage, and an app's maker can see the data you give their app.
• Connected services you choose to connect, such as your own Stripe, GitHub, Google Sheets, Google Calendar, Twilio, Mailchimp or Brevo account, an automation tool such as Zapier, Make or n8n, or your own Google Analytics or Plausible, when you use those features. Each one handles that data under its own privacy policy, and you are responsible for the services you connect to your app.
• Rightsholders and reporters, where required to process a copyright or trademark notice or counter-notice (for example, a counter-notice with your contact details is sent to the person who filed the notice).
• Authorities and others, when we believe in good faith that the law requires it, in response to valid legal process, to protect the safety of any person, to prevent fraud or abuse, or to enforce our Terms. See our Law Enforcement Guidelines.
• A buyer or successor, if Lumy is involved in a merger, acquisition, financing, reorganisation or sale of assets, subject to this policy.
• Our affiliates, who follow this policy.

We do not sell personal data, and we do not share it for cross-context behavioural advertising. We do not allow other companies to track you on Lumy for advertising.

7. International transfers

Lumy is hosted in the United States by our cloud hosting provider, and our service providers may process data in other countries. When we transfer personal data from the European Economic Area, the United Kingdom or Switzerland to a country that has not been found to provide adequate protection, we use the Standard Contractual Clauses approved by the European Commission, with the UK Addendum or Swiss adaptations where needed, and additional safeguards where appropriate. You can ask for more information through /support?cat=legal.

8. How long we keep it

We keep personal data only as long as needed for the purposes in this policy, then delete or de-identify it.

Data	How long we keep it
Account and projects	Until you delete them or delete your account
Date of birth and age record	With your account, until you delete it. For someone under 18 who was turned away: the email address and the date only, kept so the account cannot be opened later
Technical level	With your account, until you change it or delete your account
Plan, tokens received and "You've saved"	With your account, until you delete it
Deleted projects	Offline at once. Support can restore them for 30 days, then a daily clean-up removes every file (versions, chat, thumbnail, app data, files, leaderboards and stats). Removed from backups within 90 days
Deleted accounts	Every project offline and every session ended at once. Projects can be restored by Support for 30 days, then all their files are removed. Removed from backups within 90 days
Token use record of a deleted account's email	Kept, so free tokens cannot be reset. Signing in again with the same Google account reopens that empty account
Gameplay events from published projects	For the data history of the maker's plan (30 days on Free and, once paid plans open, 6, 13 or 24 months on Starter, Pro and Studio), then deleted or kept only as totals
Guest identities never used again	Removed after 12 months of inactivity
Security logs	Up to 90 days
Activity log	30 days
Help agent ("Ask Lumy") chats	12 months
Support tickets, abuse reports, notices and appeals	3 years from the last message
Waitlist entries	Until real payments open and your place is used, or until you ask us to remove you
Billing and tax records, once payments open	As long as tax and accounting law requires
Data we must keep for legal reasons	For as long as the legal requirement, dispute or investigation lasts

Remixes that other users made of your published projects stay with their makers after you delete your own projects. De-identified or aggregated data may be kept for longer.

9. How we protect it

• Data in transit is encrypted with HTTPS. Stored data is encrypted at rest by our cloud hosting provider.
• Keys you connect (such as Stripe, GitHub, Twilio, Mailchimp and Brevo, and webhook secrets) are stored with an additional layer of encryption.
• Sign-in keys are stored hashed.
• Games and apps run in a sandbox, separated from the studio and from your account.
• Before a project is published, its backend (data, files and AI calls) answers only its owner.
• Staff access to user data is limited to what is needed and is logged.

No system is perfectly secure. If you believe your account or data is at risk, tell us immediately through /security. See our Security and Responsible Disclosure page.

10. Your rights

Depending on where you live, you may have the right to:

• access the personal data we hold about you and get a copy;
• correct data that is inaccurate or incomplete;
• delete your data;
• port your data, in a structured, commonly used, machine-readable format;
• object to processing based on legitimate interests, including for improvement purposes;
• restrict processing in certain cases;
• withdraw consent at any time, for example to analytics through "Cookie preferences" in every page footer, without affecting processing already done;
• complain to a data protection authority where you live or work.

How to use them. You can do the most common requests yourself:

• Download my data in Settings > Your data gives you a file with your account, settings, token history and project list. Each project's code downloads from the studio.
• Delete my account in Settings > Your data deletes your account once you type DELETE to confirm.

For anything else, open a ticket at /support under "Privacy or data request", signed in or from the email on your account, or write to hello@luminary.gg. Our reply always appears on the page where you made the request, under My requests at /support, even if we cannot email you. We may need to confirm your identity before acting. We reply within 30 days at most and aim for 7 days. Where the law allows, we may extend this by up to two further months for complex requests, and we will tell you why.

You can download any of your projects as a single HTML file, or push it to GitHub, at any time without asking us. We recommend doing so before you delete your account.

We may refuse or limit a request where the law allows, for example where it would affect other people's rights, where we must keep data for legal reasons, or where a request is manifestly unfounded or excessive.

11. Children

Lumy is for people 18 and over, and we do not knowingly collect personal data from anyone under 18. We ask your date of birth when you first sign in. If you tell us you are under 18, we do not open the account and keep only your email address and the date. If we learn that we hold personal data of someone under 18, we delete it and close the account. If you believe a child has given us personal data, tell us through /support or /abuse.

Makers whose apps or games are directed at children are responsible for getting verified parental consent where the law requires it (see our Acceptable Use Policy and Data Processing Addendum).

12. Apps built with Lumy and their users

When a maker builds an app or game with Lumy that collects data from its users (for example sign-ins, records, files or saves), the maker is the controller of that data and Lumy processes it on the maker's behalf as a processor, under our Data Processing Addendum.

If you use an app built with Lumy, the maker's own privacy notice applies, and you should contact the maker to exercise your rights. If you cannot reach the maker, contact us through /support and we will pass your request on where we can. Makers must give their users their own terms and privacy notice and follow the law.

13. Cookies and browser storage

We use a small number of necessary cookies and browser storage items to keep you signed in and remember your choices. The cookie banner shows Reject and Accept side by side. Analytics events are sent only after you press Accept. The full list, with names, purposes and durations, is in our Cookie and Storage Policy. You can change your choice at any time with "Cookie preferences" in every page footer.

14. Notice for California and other US states

This section applies to residents of California and other US states with comprehensive privacy laws.

• Categories collected in the last 12 months: identifiers (name, email, account IDs, IP address); customer records (waitlist and, once open, limited billing details); commercial information (plans, top-ups, tokens, usage); internet and network activity (visits, device data, logs); inferences limited to abuse and fraud signals; and user-generated content (prompts, projects, messages). Sources, purposes and recipients are described in Sections 3, 4 and 6.
• Sensitive personal information: we collect account sign-in credentials only to let you sign in. We do not use sensitive personal information to infer characteristics about you.
• No sale or sharing. We do not sell personal information and do not share it for cross-context behavioural advertising. We honour Global Privacy Control signals as an opt-out where the law requires.
• Your rights. You may request to know, access, correct and delete your personal information, and to receive it in a portable format. We will not discriminate against you for exercising your rights. You may use an authorised agent, and we may ask the agent for proof of authority and ask you to verify your identity. If we deny your request, you may appeal by replying to our decision; we will answer the appeal within the time the law requires.
• Retention: see Section 8.

15. Changes to this policy

We may update this policy. For material changes, we will tell you in Lumy or by email at least 14 days before they take effect, unless a change is required sooner for legal or security reasons. The date at the top shows the latest version.

16. Contact

• Privacy requests: a ticket at /support under "Privacy or data request"
• Legal notices: /support?cat=legal, or our notices address hello@luminary.gg
• Security concerns: /security

Lumy, the maker of Lumy.