Privacy Policy
Effective Date: April 8, 2026
Lumina is a product of Crewstake Pty Ltd (ABN 54 671 816 087), located at Level 1/57 Berwick St, Fortitude Valley QLD 4006, Australia.
This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use Lumina. We are committed to complying with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).
1. Information We Collect
1.1 Information You Provide
- Account Information: Name, email address, company name, job title, and password
- Payment Information: Billing address and payment details (processed securely by Stripe)
- Business Data: Information about your organisation, employees, customers, and operations that you input into Lumina
- Communications: Messages you send to us or through the Service
1.2 Information Collected Automatically
- Usage Data: Features used, actions taken, time spent, and interaction patterns
- Device Information: Browser type, operating system, IP address, and device identifiers
- Log Data: Server logs, error reports, and performance metrics
- Cookies: Session and preference cookies (see Section 7)
1.3 Information from Third Parties
When you connect integrations, we may receive:
- Email Data: Email content, metadata, and attachments from connected email accounts
- CRM Data: Contacts, deals, and customer information from HubSpot or Salesforce
- Social Media Data: Account information and content from connected platforms
2. How We Use Your Information
We use your information to:
- Provide the Service: Operate Lumina's AI employees and features
- Process AI Tasks: Generate content, analyse data, and automate workflows
- Improve the Service: Analyse usage patterns and develop new features
- Communicate: Send service updates, security alerts, and support messages
- Billing: Process payments and manage subscriptions
- Legal Compliance: Meet regulatory requirements and respond to legal requests
- Security: Detect and prevent fraud, abuse, and security threats
3. AI Processing and Data Use
3.1 How AI Processes Your Data
Lumina's AI employees process your data to:
- Draft emails, content, and reports based on your instructions
- Analyse patterns and generate insights
- Automate responses and workflows
- Learn your preferences to improve suggestions
3.2 Human Review
All AI-generated outputs are presented for your review before any external action. You maintain full control over what gets published, sent, or executed.
3.3 Model Training
We do not use your business data to train our AI models without your explicit consent. Aggregated, anonymised usage data may be used to improve our algorithms.
4. Information Sharing
We may share your information with:
4.1 Service Providers
- Cloud Infrastructure: Vercel (hosting), Neon (database)
- Payment Processing: Stripe
- AI Services: OpenAI, Anthropic (for AI processing)
- Analytics: Vercel Analytics
4.2 Third-Party Integrations
When you connect integrations, data flows between Lumina and:
- Microsoft (Outlook)
- Google (Gmail, Google Ads)
- Salesforce
- HubSpot
- Meta (Facebook, Instagram)
- Twitter/X
4.3 Legal Requirements
We may disclose information if required by law, court order, or to:
- Comply with legal obligations
- Protect our rights and property
- Prevent fraud or security threats
- Respond to government requests
4.4 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.
5. Data Retention
We retain your information for as long as:
- Your account is active
- Necessary to provide the Service
- Required by law or legitimate business purposes
After account termination, we retain data for a reasonable period to comply with legal obligations, resolve disputes, and enforce agreements. You may request deletion of your data subject to these requirements.
6. Data Security
We implement industry-standard security measures including:
- Encryption: TLS for data in transit, AES-256 for data at rest
- Access Controls: Role-based access, multi-factor authentication
- Monitoring: Continuous security monitoring and logging
- Compliance: Regular security assessments and updates
While we strive to protect your information, no system is completely secure. We cannot guarantee absolute security.
7. Cookies and Tracking
We use cookies and similar technologies for:
- Essential Functions: Authentication, security, and core features
- Preferences: Remembering your settings and choices
- Analytics: Understanding usage patterns (Vercel Analytics)
You can control cookies through your browser settings. Disabling cookies may affect Service functionality.
8. Your Rights
Under Australian Privacy Law, you have the right to:
- Access: Request a copy of your personal information
- Correction: Request correction of inaccurate information
- Deletion: Request deletion of your information (subject to legal requirements)
- Portability: Request your data in a portable format
- Complaint: Lodge a complaint with the Office of the Australian Information Commissioner (OAIC)
To exercise these rights, contact us at privacy@luminahr.ai.
9. International Data Transfers
Your data may be processed in countries outside Australia, including the United States (where our cloud providers operate). We ensure appropriate safeguards are in place for international transfers.
10. Children's Privacy
Lumina is not intended for users under 18 years of age. We do not knowingly collect information from children. If we discover we have collected information from a child, we will delete it promptly.
11. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes via email or through the Service. The "Effective Date" at the top indicates when the policy was last updated.
12. Contact Us
For privacy-related questions or to exercise your rights, contact us at:
Crewstake Pty Ltd
Level 1/57 Berwick St
Fortitude Valley QLD 4006
Australia
Privacy Officer Email: team@luminahr.ai
Office of the Australian Information Commissioner (OAIC)
Website: www.oaic.gov.au
Phone: 1300 363 992