Effective Date: April 27, 2026
Thunder Matrix, Inc. ("Company," "we," "us," or "our") operates the Lumi Studio mobile application (the "App"). This Privacy Policy explains how we collect, use, store, disclose, and protect your information when you use the App.
BY USING THE APP, YOU ACKNOWLEDGE THAT WE COLLECT, USE, DISCLOSE, AND PROCESS YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.
1.1. Information Collected Automatically
- Anonymous User ID: A unique identifier generated when you first launch the App. No email, password, or personal login credentials are required.
- Device & Usage Data: We may collect general device information, such as device model and operating system version, and usage analytics, such as features used and session duration, to operate, improve, and protect the App.
1.2. Information You Provide
- Display Name: An optional name you may set in your profile. It may be stored on your device and in our database as needed to provide the App.
- Face Data and Uploaded Photos: Photos containing your face that you choose to upload for AI makeup generation.
- Referral Codes: If you use or share referral codes, we may store the code, usage count, and associated anonymous user IDs.
1.3. Information Generated by the App
- AI-Generated Images: Makeup images produced by our AI processing may be stored in secure cloud storage linked to your anonymous user ID.
- Generation History: Records of your AI generations, such as timestamps and template selections, may be stored in our database.
Because the App processes photos of your face to apply virtual makeup, we specifically disclose the following regarding Face Data:
(a) What we collect: We collect only the photos that you actively choose to upload to the App. We do not intentionally collect Apple TrueDepth data, volumetric face maps, or biometric templates used to uniquely identify you.
(b) How we use it: Your uploaded photos are processed solely to provide the requested AI makeup generation and related App functionality.
(c) Who we share it with: Your uploaded photos are transmitted securely to Google LLC for processing by Google's Gemini 2.5 Flash Image model (accessed via the Gemini API), solely for the purpose of generating the requested virtual makeup result. Under our current commercial arrangement with Google, your uploaded photos are processed only to provide the requested image-generation functionality and are not used by Google to train its general-purpose AI models.
Before any photo is sent to Google for processing, the App displays an in-app notice describing this data sharing and obtains your explicit consent. You may revoke that consent at any time by stopping use of the AI generation feature; revocation does not retroactively delete previously processed photos, which are governed by the retention rules described below.
(d) Data retention: Uploaded original photos and generated images may be stored in your App history through our infrastructure only for as long as your account remains active, unless a longer retention period is required by law. We do not use your uploaded photos or Face Data to train our own machine learning models. Upon account deletion, we will delete the associated Face Data and images from our active systems within 30 days.
We may use the information we collect to:
(a) provide, operate, and maintain the App and its core functionality;
(b) manage your credits, subscriptions, purchases, and referral codes;
(c) display beauty product recommendations related to the makeup template or look you selected;
(d) improve, maintain, troubleshoot, monitor, and optimize the App;
(e) detect, prevent, and address fraud, abuse, security incidents, and unauthorized access;
(f) comply with legal obligations and enforce our Terms of Service; and
(g) communicate with you regarding support, policy updates, or operational matters.
If you are located in the EEA or UK, we process your personal data where necessary to provide the App to you, to comply with legal obligations, for our legitimate interests in operating and improving the App, or based on your consent where required by law.
Lumi Studio integrates with third-party services that may process information on our behalf or in connection with your use of the App. These services are governed by their own privacy policies and terms.
(a) Supabase. Authentication, database, and secure file storage. Anonymous user IDs, generation records, and uploaded or generated images may be stored on Supabase infrastructure.
(b) Google LLC (Gemini 2.5 Flash Image, accessed via the Gemini API). AI-driven virtual makeup image generation. Your uploaded photos are sent to this service solely to produce the requested look. Under our current commercial arrangement with Google, photos are processed only to provide the image-generation functionality and are not used to train Google's general-purpose AI models. The App displays an in-app notice and obtains your explicit consent before any photo is sent to Google for processing.
(c) RevenueCat. Subscription and in-app purchase management. RevenueCat may receive your anonymous user ID and subscription or transaction-related information in order to manage entitlement and subscription status.
(d) Apple App Store. Payment processing for in-app purchases and subscriptions. We do not receive or store your payment card details, billing address, or other full payment information for App Store transactions.
(e) Sephora, RapidAPI, or similar catalog/data providers. Product catalog and recommendation support. We do not share uploaded photos or Face Data with these services for product recommendation purposes.
5.1. Your data may be stored on secure cloud servers, including infrastructure located in the United States.
5.2. We implement reasonable administrative, technical, and organizational safeguards designed to protect your information, which may include:
- encrypted data transmission using TLS/HTTPS;
- database access controls, including Row Level Security where applicable;
- time-limited signed URLs or similar access-control mechanisms for stored images; and
- separation of public-facing and administrative credentials.
5.3. While we take reasonable steps to protect your information, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security.
6.1. We retain personal information for as long as reasonably necessary to provide the App, maintain your account, comply with legal obligations, resolve disputes, and enforce our agreements.
6.2. You may delete your account through the App if that functionality is available, or by contacting us at customer@lumistudio.live. Upon account deletion:
- your profile, generation history, and associated account records will be deleted or deactivated in accordance with our retention practices;
- original photos and AI-generated images associated with your account will be deleted from our active systems within 30 days, unless a longer retention period is required by law or reasonably necessary for security, fraud prevention, or legal compliance; and
- if you continue using the App after deletion, a new anonymous account or session may be created.
6.3. We may retain anonymized or aggregated information that does not identify you for analytics, service improvement, and business purposes.
We do not sell, rent, or trade your personal information to third parties for their own marketing purposes.
We may share your information only in the following circumstances:
(a) with service providers and vendors that help us operate the App, solely for business and operational purposes;
(b) if required by law, regulation, legal process, or governmental request;
(c) to investigate, prevent, or address fraud, abuse, security issues, or violations of our Terms of Service;
(d) to protect the rights, property, or safety of Thunder Matrix, Inc., our users, or the public; or
(e) in connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business or assets, subject to applicable legal requirements.
8.1. California Residents
If you are a California resident, you may have the right under applicable California law to:
- know what personal information we collect, use, disclose, or retain;
- request deletion of your personal information, subject to legal exceptions;
- correct inaccurate personal information;
- opt out of the sale or sharing of personal information, if applicable; and
- not receive discriminatory treatment for exercising your privacy rights.
We do not sell your personal information for monetary consideration.
8.2. EEA and UK Residents
If you are located in the EEA or UK, you may have the right, subject to applicable law, to:
- access your personal data;
- correct or update inaccurate personal data;
- request deletion of your personal data;
- restrict or object to certain processing;
- request data portability;
- withdraw consent where processing is based on consent; and
- lodge a complaint with your local data protection authority.
8.3. Exercising Your Rights
To exercise any of these rights, please contact us at customer@lumistudio.live. We will respond within the time required by applicable law. We may need to verify your identity before processing certain requests.
Lumi Studio is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will take reasonable steps to delete it. If you believe a child under 13 has provided personal information to us, please contact us at customer@lumistudio.live.
If you access the App from outside the United States, your information may be transferred to, stored, and processed in the United States and other jurisdictions where we or our service providers operate. By using the App, you acknowledge that your information may be transferred to, stored, and processed in the United States and other jurisdictions as described in this Privacy Policy. We take reasonable steps to help ensure that your information is handled securely and in accordance with applicable law.
We may update this Privacy Policy from time to time. If we do, we will post the updated version within the App or otherwise make it available through the App, and we will revise the Effective Date above. Changes will become effective as of the updated Effective Date, subject to applicable law. We encourage you to review this Privacy Policy periodically.
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:
Thunder Matrix, Inc.
Email: customer@lumistudio.live