Privacy Policy

1. Introduction

Welcome to Lumen Landmark. This Privacy Policy explains how we collect, use, disclose, and protect information that applies to our service.

For the purposes of this Privacy Policy and applicable data protection laws (including the General Data Protection Regulation or "GDPR"), the Data Controller is Adrien Vandekerckhove, doing business as Lumen Landmark ("Lumen Landmark," "we," "our," or "us"), an enterprise registered in Belgium with the Crossroads Bank for Enterprises (BCE) under number BE 1028.717.860.

Applicability

This Policy applies to:

• Our website located at www.lumenlandmark.com (the "Site");
• Our mobile application Lumen Landmark available on Android (the "App");
• Our AI generation and content organization tools; and
• Any related services provided by us (collectively, the "Service").

We provide a platform that allows users to organize AI-generated content and generate new imagery using artificial intelligence. By accessing or using the Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Privacy Policy and our Terms of Service.

2. Information We Collect

We collect information to provide the Service, improve your experience, and secure our platform. This includes information you provide to us, information collected automatically, and information from third-party sources.

2.1 Information You Provide

When you use Lumen Landmark, you may provide the following information:

• Account Information: When you register, we collect basic details such as your email address to set up your account.
• User Content & Inputs: This includes the text prompts you enter, the parameters you select, and the resulting Creations generated through the Service.
• Organization Data: We collect data on how you organize your content within the app, such as the Maps you create, and the Landmarks you save to manage your Creations.
• Support and Communications: If you contact us directly (e.g., for support or feedback), we collect the content of your messages and any contact details you provide.

2.2 Information We Collect Automatically

When you access the Service via our App or Website, we automatically record data about your usage:

• Usage and Analytics Data: We track how you interact with the Service, including the screens you view, the features you use, and the time spent on the application. This helps us understand user preferences and improve the Service.
• Device and Log Information: Our servers automatically record information sent by your device, such as your IP address, browser type, operating system, device model, and crash reports.

2.3 Information We Receive from Third Parties

We connect with third-party partners to handle specific functions of the Service:

• Authentication Providers: When you log in using a third-party account (e.g., Google), we receive authentication tokens and basic profile information permitted by that provider to verify your identity.
• Payment Processors: We utilize third-party payment services to process subscriptions and purchases. We do not store your financial information (such as credit card numbers) directly. We receive only transaction confirmations and subscription status to facilitate your access to premium features.

2.4 Use of Content for AI Training

We do not use your User Content (including images you generate, text prompts, or uploaded media) to train, fine-tune, or improve our artificial intelligence models. Your content is processed solely for the purpose of generating the requested output and providing the Service to you.

3. How We Use Your Information

Under the General Data Protection Regulation (GDPR), we must have a lawful reason to use your data. Here is how and why we process your information:

• To Provide the Service (Contractual Necessity): We use your data to create your account, generate images upon your request, and save your "Landmarks" and "Maps". Without this processing, we cannot fulfill the Terms of Service or provide the core functionality of the App.
• To Improve and Secure the App (Legitimate Interest): We process anonymized analytics and usage logs (via tools like PostHog) to understand how the App is used, fix bugs, and prevent fraud or abuse. It is in our legitimate interest to ensure the App is secure and functions correctly.
• To Communicate with You (Contractual Necessity & Legitimate Interest): We use your email to send important service updates (e.g., security alerts, changes to this Policy). We may also respond to your support requests.
• For Compliance and Legal Obligations: We may retain transaction records (if you purchase credits or subscriptions) to comply with Belgian tax and accounting laws.

Note on AI Training: We do not use your personal data, private Landmarks, or private Maps to train our artificial intelligence models. Your generated content remains yours (subject to our Terms) and is not used to improve our generation algorithms.

3.1 Visibility of Your Content (Maps and Landmarks)

Lumen Landmark allows you to organize content into "Maps." You control the visibility of these Maps:

• Private Maps: Content within a Private Map is visible only to you. It is not indexed by our internal search engine and is not visible to other users.
• Public Maps: Content within a Public Map is visible to all users of the App and may be indexed by our internal search engine and potentially by external search engines (such as Google or Bing) if you share the web link publicly.

4. Sharing Your Information

We respect your privacy and do not sell your personal data to third parties. We may share your information in the following limited circumstances:

• Service Providers: We share information with third-party vendors and partners who perform services on our behalf to help us operate the App, including Cloud Hosting (Stockholm), AI Providers (US/Global), Analytics (PostHog), Payment Processing, and Authentication. These providers are authorized to use your personal information only as necessary to provide these services to us.
• Legal Obligations: We may disclose your information if required to do so by law or in the good-faith belief that such action is necessary to comply with legal requirements (such as a subpoena or court order), protect our rights, or investigate fraud or security violations.
• Business Transfers: If we are involved in a merger, acquisition, financing, reorganization, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.
• Aggregated or Anonymized Data: We may share non-personal, aggregated, or anonymized data (which does not identify you individually) with third parties for research, marketing, or analysis purposes.

5. Data Retention

We will retain your personal information, including your Creations, Maps, and Landmarks, for as long as your account is active or as needed to provide you with the Service. We may also retain your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

When we have no ongoing legitimate business need to process your information (for example, if you delete your account), we will either delete or anonymise it. If this is not immediately possible (for example, because your information has been stored in backup archives), then we will securely store your information and isolate it from any further processing until deletion is possible.

6. Security of Your Information

We take commercially reasonable security measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. This includes technical and organizational measures to secure the data we store on our servers.

However, please be aware that no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. You are also responsible for maintaining the confidentiality of your device and login credentials.

7. Cookies and Tracking Technologies

We use a Consent Manager on our Site. 'Essential' cookies are loaded automatically, but 'Analytics' cookies (PostHog) are only activated if you give your explicit consent via our cookie banner. We use the following types of technologies:

• Essential Cookies: Necessary for the App to function (e.g., keeping you logged in).
• Analytics Cookies (PostHog): We use PostHog to understand how users interact with our App (e.g., which features are used most). This helps us improve the user experience. PostHog captures data such as your device type, session duration, and feature usage patterns. This data is anonymous and is used strictly for analytical purposes.

8. International Data Transfers

Lumen Landmark is based in Belgium. To provide our Service, we use third-party infrastructure (such as cloud hosting and AI providers) that may be located in the United States.

We take steps to ensure your data remains protected when processed abroad. We rely on the compliance measures provided by these vendors in their Terms of Service, which typically include:

• The EU-U.S. Data Privacy Framework: For providers who are actively certified under this framework.
• Standard Contractual Clauses (SCCs): The European Commission’s approved legal clauses, which are embedded in the Data Processing Agreements we have accepted with our service providers.

By using the Service, you acknowledge that your information may be transferred to the United States under these safeguards.

9. Your Rights

Depending on your location, you have certain rights regarding your personal information. As we are based in Belgium, we adhere to the General Data Protection Regulation (GDPR), which grants you the following rights:

• Right to Access: You have the right to request a copy of the personal information we hold about you.
• Right to Correction: You can update your profile information directly within the App. If you notice other inaccuracies, you may request that we correct them.
• Right to Erasure ("Right to be Forgotten"): You have the right to request that we delete your account and all associated data, including your Creations and Maps. You can perform this action directly in the App settings (Profile > Settings > Delete Account). External Request: If you cannot access the App (e.g., if you have uninstalled it), you may request account deletion by emailing us at privacy@lumenlandmark.com. We will process your request within 30 days.
• Right to Object: You have the right to object to our processing of your data for specific purposes, such as direct marketing.
• Right to Portability: You can request a copy of your data in a structured, commonly used machine-readable format.
• Withdraw Consent: If we process your data based on your consent, you have the right to withdraw that consent at any time.

To exercise any of these rights, you may contact us using the details provided in the "Contact Us" section below. We will respond to all requests in accordance with applicable data protection laws.

If we are unable to resolve your request, or if you are concerned about a potential violation, you have the option to report the issue or make a complaint to the data protection authority in your jurisdiction.

10. Children’s Privacy

Children may not access or use the Service. For purposes of this Policy, a child is a person under the age of 13 (or the minimum legal age required to provide consent for processing of personal data in the country where the child is located).

The Service and our content are not directed at children. Children are not permitted to sign up for the Service by themselves. We do not knowingly collect or solicit personal information from children. If we become aware that we have collected personal information from a child without verification of parental consent, we will take steps to remove that information from our servers.

11. Additional Information for Users in the United States

This section applies to individuals located in the United States. In certain U.S. states (such as California), individuals have specific rights regarding their personal information.

Rights in respect of your personal information

Depending on the state in which you reside, you may have the following rights:

• Request Access: You have the right to request access to the personal information we have collected about you.
• Request Deletion: You have the right to request that we delete your personal information, subject to certain exceptions (such as maintaining your account or legal obligations).
• Request Correction: You have the right to ask us to correct inaccurate personal information.
• Opt-out of "Sale": We do not sell your personal information to third parties for monetary consideration.

Exercising Your Rights. To exercise any of these rights, please contact us at privacy@lumenlandmark.com. We will verify your request using the email address associated with your account.

12. Updates to this Policy

We reserve the right to modify this Privacy Policy at any time to reflect changes in our App, legal requirements, or business practices.

Any updates will be effective immediately upon posting. We will indicate the date of the latest revision at the top of this page. If we make significant changes that materially affect your privacy rights, we will notify you through the App or via email. We encourage you to review this page periodically to stay informed about how we protect your information.

13. Contact Us

If you have questions about this Policy, or if you wish to exercise your data privacy rights (such as deleting your account or accessing your data), please contact us using the details below: