Privacy Policy

This Privacy Policy applies to Luma services (the “Services”), which include Luma apps, websites, software, and related services, accessed via any platform or device, that link to this Privacy Policy, as well as Luma Ad Network. The Services are operated by FIREPOWER TECHNOLOGY LIMITED (“FIREPOWER”, “we” or “us”).

We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, share, and otherwise process the personal information of users and other individuals in connection with the Services. For information about how we collect, use, share, and otherwise process consumer health data as defined under Washington’s My Health My Data Act and other similar state laws, please refer to the Consumer Health Data Privacy Policy. If you are a teen, please see the Privacy Policy - Teen Summary for a summary of this Privacy Policy.

Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in the Terms of Service.

Information We Collect

We collect your information in three ways: information that you provide, automatically collected information, and information from other sources. More detail is provided below.

Information You Provide

When you create an account, upload content, contact us directly, or otherwise use the Services, you may provide some or all of the following information:

• Account information, such as date of birth, username, password, email, phone number, and profile image.
• User content, including comments, photographs, livestreams, audio recordings, videos, and text that you choose to create, import, upload, or publish through our apps and websites. Even if you are not a user, information about you may appear in user content created or published by users on our apps and websites. We may collect user content through pre-uploading at the time of creation, import, or upload, regardless of whether you choose to save or publish that user content, for example, to recommend audio options, provide an effect, generate captions, and provide other personalized recommendations.
• Messages, including content you compose, send, or receive through our messaging functionalities, including messages you send through our chat functionality when using our shopping features to communicate with sellers.
• AI interactions, including prompts, questions, files, and other types of information that you submit to our AI-powered interfaces, as well as the responses they generate.
• Clipboard content, such as text and images, accessed through your device’s clipboard when you choose to use certain functions such as initiating information sharing with third-party services, or copying and pasting clipboard content onto our apps and websites.
• Purchase information, including payment card information, billing, delivery, and contact information, and purchase history when you make a purchase, payment, or other transaction on or through the Services, including when you buy Luma Diamonds or purchase products or services through our shopping features.
• Your phone and social network contacts, with your permission. If you choose to sync your contacts, we will collect information, such as names, phone numbers, and email addresses from your device’s phone book, and friends list from your social network, and match that information to users who have Luma accounts. We also collect information about the accounts you follow and that follow you.
• Your account settings and communication preferences.
• Information to verify an account such as proof of identity or age.
• Information in correspondence you send to us, including when you contact us for support.
• Information you share if you fill in advertisers’ forms on our app, or through your participation in surveys, research, promotions, marketing campaigns, events, or contests.

Information You Provide may include sensitive personal information, as defined under applicable state privacy laws. We process such information in accordance with applicable law, such as to provide the Services and other permitted purposes under state privacy laws. You may choose whether or not you include sensitive personal information in your user content or in other information you voluntarily submit. The type of information that state privacy laws have identified as sensitive personal information include the following: racial or ethnic origin, national origin, religious beliefs, mental or physical health diagnosis, sexual life or sexual orientation, status as transgender or nonbinary, citizenship or immigration status, or financial information. Luma does not require you to provide this type of information. However, if you choose to publish user content about these topics, please keep in mind that such content may be visible to other users and the public, depending on your privacy settings.

In other situations, we may process your financial information in order to provide you the goods or services you request from us; your driver’s license number in order to verify your identity; and information from users under the relevant age threshold in order to provide an age-appropriate experience. We may also collect precise location data, depending on your settings and as explained below.

Automatically Collected Information

We automatically collect certain information from you when you use the Services, including:

• Usage information, including information regarding your use of the Services, such as information about how you interact with content and ads, the duration and frequency of your use of the Services, and your engagement with other users. We also collect certain information about your interactions with websites when you use our in-app browser.
• Technical information from your device, network, and application, including your IP address, user agent, mobile carrier, time zone settings, identifiers for advertising purposes, model of your device, the device system, network type, your screen resolution and operating system, app and file names and types, keystroke patterns or rhythms, battery state, audio settings and connected audio devices. We automatically assign device IDs and user IDs, and may use this and other information to identify your activity across devices.
• Location information about your approximate location based on your device and network information, such as SIM card region, IP address, and device system settings. We also collect information, such as tourist attractions, shops, or other points of interest, if you choose to add the location to your user content. Also, if you choose to enable location services for the Luma app within your device settings, we collect approximate or precise location information from your device. You can turn off location services from your device settings at any time.
• Content characteristics and features, including about the videos, images and audio recordings that are part of your user content, for example, by identifying objects and scenery; the existence and location of a face and other body parts; and the text of words spoken in your user content. We may collect this information to enable special video effects, for content moderation, for demographic classification, for content and ad recommendations, and for other non-personally-identifying operations. We may collect biometric identifiers and biometric information as defined under US laws, such as faceprints and voiceprints, from your user content. Where required by law, we will seek any required permissions from you prior to any such collection.
• Metadata that is automatically uploaded in connection with your user content, messages, or AI interactions, such as how, when, where, and by whom the user content was created, or message or prompt was sent. Metadata may also include information, such as your username, that enables your user content to be traced back to your account by other users.
• Cookies and other similar technologies (e.g., web beacons, flash cookies, pixels, SDKs, etc.) that we and our service providers and business partners use to provide certain features and functionalities, including to measure and analyze how you use the Services, including which pages you view most often and how you interact with content; enhance your experience using the Services; improve the Services; provide you with advertising; and promote the Services on other websites and apps. To learn how to disable certain Cookies, see the Your Rights and Choices section below.

Information From Other Sources

We may receive the information described in this Privacy Policy from other sources, such as:

• If you choose to sign up or log in to the Services using, or link your Luma account to, a third-party service, we may collect information from the third-party service, such as your public profile information and email.
• Advertisers, publishers, and measurement and other partners provide us with information about you and the actions you have taken outside of our websites and apps, including the pages you visit, products or services you purchase, and apps you download. These partners also provide information such as mobile identifiers for advertising, hashed email addresses and phone numbers, and cookie identifiers, which we use to help measure the effectiveness of ads we serve and to better deliver ads to you on our websites and apps, or through Luma Ad Network elsewhere online, depending on your ads settings.
• We receive information about you from sellers as well as payment and transaction fulfillment providers, such as payment confirmation details, and information about the delivery of products you have purchased through our shopping features.
• We may obtain information about you from affiliates controlled by, or under common control with, us.
• We may receive information about you from others, such as where you are included or mentioned in user content, messages, in a complaint, appeal, request or feedback submitted to us, or if your contact information is provided to us.
• We may also collect or receive information about you from professional organizations, businesses, government authorities, and others, including publicly-available sources.

How We Use Your Information

We use the Information We Collect for the following purposes:

• To operate and administer the Services, such as enabling you to create, share, and consume content and to interact with other users and their content, and providing user support.
• To review, support, improve, and develop the Services, and train, test, and improve technology, such as machine learning models and algorithms, including by analyzing how people are using the Services; conducting research; soliciting feedback; monitoring your activity and usage across the devices you use to access the Services; and scanning, analyzing, and reviewing user content, messages, AI interactions, and associated metadata.
• To personalize and customize certain features and content, such as providing your “For You” feed and content creation tools.
• To provide our shopping features and facilitate the purchase and delivery of products, goods, and services.
• To promote our and third-party products and services through marketing campaigns, including communications, contests, and events. We may also use user content as part of our marketing campaigns, with your permission.
• To provide and improve our advertising services and measure the effectiveness of the ads we serve.
• To support the social functions of the Services, including to permit you and others to connect with each other (for example, through our Find Friends function), to suggest accounts to you and suggest your account to others, and for you and others to share, download, and otherwise interact with user content.
• To infer additional information about you, such as your age, gender, and interests.
• To maintain and enhance the safety, security, and stability of the Services by identifying and addressing technical or security issues or problems (such as technical bugs and spam accounts), and detecting abuse, fraud, and illegal activity.
• To verify your identity or age in order to use certain features, such as livestream or verified accounts or in other instances where verification may be required.
• To communicate with you, including to notify you about changes in our services.
• To enforce our Terms of Service, Community Guidelines, and other conditions and policies that apply to you and to protect the safety of our community and integrity of the Services, including by scanning, analyzing, and reviewing user content, messages, AI interactions, and associated metadata.
• To comply with our legal obligations and defend our legal rights and commercial interests, and those of our affiliates, users, and the public.
• For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
• To combine Information We Collect for any of the foregoing purposes.
• To aggregate or de-identify Information We Collect.

Profiling: We do not engage in profiling which results in legal or similarly significant effects, as defined under applicable law.

How We Share Your Information

We are committed to maintaining your trust, and while we do not sell your personal information or share your personal information with third parties for purposes of cross-context behavioral advertising where restricted by applicable law, we want you to understand when and with whom we may share the Information We Collect for the purposes described below. Please note that information disclosed to certain third parties may be processed in accordance with their privacy policies.

For Legal Reasons

We may share Information We Collect to comply with the law, including to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries. We may also disclose Information We Collect to enforce any terms applicable to the Services, and to protect and defend our rights, interests, safety, and security, and those of our affiliates, users, or the public.

Users and the Public

Based on your privacy settings, your information, including certain of your account information, user content, and usage information, may be visible to other users and the public. For example, if you have a public account and have not restricted the visibility of your posts individually, your account information and user content can be viewed or shared by anyone, whether or not they have a Luma account, and may also appear on search engines, content aggregators, and news sites. Please use caution in disclosing personal information, especially sensitive personal information, while using the Services. We are not responsible for the information you choose to publicly disclose.

Your Rights and Choices

You may submit a request to know, access, correct or delete the information we have collected from or about you by contacting us at https://www.firepower.live or by sending your request to the physical address provided in the Contact Us section below. You may appeal any decision we have made about your request through these same methods. Through your in-app settings, you can directly update your account information, request a copy of your data, or deactivate or delete your account. We will not retaliate against you for exercising your rights and choices, although some aspects of the Services may no longer be available to you.

You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise choices on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We will respond to your request consistent with applicable law and subject to proper verification. We will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account.

You can also control the information we collect and opt out of certain activities in the following ways:

• You may be able to control some of the Information We Collect by refusing or disabling cookies through your device browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of cookies. In addition, your choice to disable cookies is specific to the particular browser that you are using when you disable cookies, so you may need to separately disable cookies for each type of browser. Some browsers transmit “do-not-track” signals to websites. Because of differences in how browsers incorporate and activate this feature, we currently do not take action in response to these signals. Please be aware that if you choose to refuse, disable, or delete cookies, some of the functionality of the Services may no longer be available to you. Without this information, we are not able to provide you with all of the requested services.
• If you have a Luma account, you can navigate to “Ads” in your in-app settings to manage how your activity elsewhere online is used to serve you ads on our websites and apps. Using your in-app settings, you can also manage the ads that Luma Ad Network serves you elsewhere online. If you do not have a Luma account, you can manage the ads that Luma Ad Network serves elsewhere online by contacting us at https://www.firepower.live, or through the ad notice that appears along with ads that are delivered by the Luma Ad Network. Your device may have controls that determine what Information We Collect. For example, you can control whether we access your phone contacts in your device settings.
• You can opt out of receiving marketing emails by using the “unsubscribe” link or mechanism noted in those emails.

Data Security and Retention

We use reasonable measures to help protect information from loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.

We retain information for as long as necessary to provide the Services and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Services, and enhancing its safety, security and stability), and for the exercise or defense of legal claims.

The retention periods are different depending on different criteria, such as the type of information and the purposes for which we use the information. For example, when we process your information such as your account registration information to provide you with the Services, we keep this information for as long as you have an account, subject to your updates of such information. If you violate our Terms of Service, Community Guidelines, or other conditions or policies, we may remove you from the Services immediately, but may keep information about you to process the violation.

Subject to applicable laws, including Executive Order 14352 and any compliance obligations thereunder, we may transmit your information outside of HONGKONG, for purposes of sharing with recipients as described in this Privacy Policy.

Children and Teens

The privacy of children is important to us. We provide a separate experience for users under age 18 (“Child” or “Children”) in HONGKONG, in which we collect and process only limited information. Please see our Children’s Privacy Policy to learn more.

If we become aware that a Child’s personal information has been collected outside of this separate experience for Children, we will delete this information in accordance with applicable law and terminate the Child’s account. If you believe there is a user of the Services who is below the age of 18 (excluding any users of this separate experience for Children), please contact us at https://www.firepower.live.

As a parent or guardian, you can also request to delete the account of your Child or to download their data, by contacting us at https://www.firepower.live. Depending on your state of residence, you may also have the ability to exercise these rights over your teen’s account, or to exercise other rights in connection with your Child or teen by contacting us at https://www.firepower.live. We will address these requests in accordance with applicable law.

If you are a parent or guardian of a teen, our Guardian’s Guide contains information and resources to help you understand the Services and the tools and controls you can use.

Privacy Policy Updates

We may update this Privacy Policy from time to time. When we update this Privacy Policy, we will notify you by updating the “Last Updated” date at the top of the new Privacy Policy, posting the new Privacy Policy, or providing any other notice required by applicable law. We recommend that you review this Privacy Policy regularly to stay informed of our privacy practices.

Contact Us

Questions, comments and requests regarding this Privacy Policy should be addressed to: