Privacy Policy

Welcome to Lumi AI Chat (package name: com.jcm.lumi), an AI chat application developed and operated by JC Media Agency Limited LLC ("JC Media", "we", "us", or "our"). This Privacy Policy ("Policy") describes how we collect, use, store, disclose, and protect your personal information when you use the Lumi AI Chat application on your mobile device. By downloading, installing, or using Lumi AI Chat, you acknowledge that you have read, understood, and agreed to the terms set forth in this Policy. If you do not agree, please discontinue use of the application.

2.1 Information You Provide Directly • Account Information: Display name, email address, password (encrypted), profile picture • Chat Content: Messages, questions, and prompts you send to the AI, along with AI-generated responses • Uploaded Content: Images, files, or data you voluntarily share with the AI during conversations • Feedback and Support: Support emails, bug reports, reviews, and suggestions 2.2 Information Collected Automatically • Device Information: Device model, operating system version, language, time zone, device identifiers (Android Advertising ID) • Usage Data: Features you use, session duration, interaction counts, screens viewed • Log Data: IP address, access times, crash reports, error logs • Performance Data: Response times, load speeds, diagnostic information 2.3 Information We Do NOT Collect We do NOT collect the following sensitive data unless you voluntarily provide it within a conversation: • Precise location (GPS) • Contacts, calendar, SMS, call logs • Photos/videos from gallery (unless you actively select and upload them) • Credit card payment information (handled by third-party processors) • Biometric data

We use your information for the following purposes: Service Delivery • Processing and responding to AI conversations • Creating, managing, and authenticating your account • Storing chat history so you can revisit conversations • Personalizing your user experience Product Improvement • Analyzing usage patterns to enhance AI quality • Detecting and fixing bugs, improving performance • Developing new features based on user feedback • Conducting research and anonymized statistical analysis Safety and Compliance • Detecting and preventing abuse, spam, and fraud • Enforcing our Terms of Service • Complying with legal obligations • Protecting user rights and safety Communications • Sending important account notifications • Providing customer support when requested • Notifying you of policy changes (not for advertising) We do NOT use your personal chat content for targeted advertising purposes.

We only share your information in the following circumstances: 4.1 AI Service Providers To deliver the AI chat feature, your message content may be sent to leading AI model providers (such as OpenAI, Anthropic, Google AI) for processing and response generation. These parties handle data according to their own privacy policies and only to the extent necessary to generate responses. 4.2 Infrastructure Providers • Cloud hosting services (e.g., Supabase, AWS, Google Cloud) • Anonymized analytics services (Google Analytics for Firebase) • Crash reporting services (Crashlytics, Sentry) • Transactional email providers 4.3 Legal Requirements We may disclose information when necessary to: • Comply with court orders or requests from authorized government entities • Protect the rights, property, or safety of JC Media, our users, or the public • Investigate, prevent, or address fraud or security violations 4.4 Business Transfers In the event of a merger, acquisition, or asset sale, your information may be transferred to the successor entity. We will notify you before this occurs. We commit to NEVER selling your personal information to third parties for advertising purposes.

We implement industry-standard technical and organizational measures to protect your data: Technical Safeguards • Encryption of data in transit using TLS/HTTPS protocols • Encryption at rest for sensitive data • Passwords hashed using one-way algorithms (bcrypt/argon2) • Regular backups and disaster recovery procedures Organizational Measures • Role-based access control (RBAC) for employees • Security training for team members • 24/7 system monitoring • Security incident response procedures While we make every effort, no system is 100% secure. You are responsible for keeping your password confidential and notifying us immediately if you detect unauthorized access.

6.1 Retention Periods • Account data: Retained for the duration of your service use • Chat history: Retained until you actively delete it or delete your account • System logs: Maximum 90 days • Anonymized statistical data: May be retained longer for analytics purposes 6.2 Data Deletion You can delete your data in the following ways: • Delete individual conversations directly within the app • Delete your entire account under Settings → Account → Delete Account • Submit a data deletion request via email: Contact@jcmedia.agency When you delete your account, we will delete or anonymize your personal data within 30 days, unless retention is required by law (e.g., accounting records, legal investigations). 6.3 Backups Data in backups may persist for up to 90 additional days after official deletion, after which it will be permanently removed.

You have the following rights regarding your personal data: • Right of Access: Request a copy of the data we hold about you • Right to Rectification: Update or correct inaccurate information • Right to Erasure: Request deletion of all your personal data • Right to Object: Decline certain forms of data processing • Right to Restrict Processing: Request temporary suspension of data processing in specific cases • Right to Data Portability: Receive your data in a machine-readable format • Right to Withdraw Consent: Withdraw your consent at any time To exercise these rights, please contact Contact@jcmedia.agency. We will respond within 30 days. Users in the EU/EEA (GDPR), United Kingdom (UK GDPR), and California (CCPA) have additional rights protected under applicable laws.

Lumi AI Chat is NOT intended for children under the age of 13 (or under 16 in certain jurisdictions). We do not knowingly collect personal information from children. If you are a parent or guardian and become aware that your child has provided us with personal information without your consent, please contact us immediately at Contact@jcmedia.agency. We will delete that information as soon as possible. We recommend that parents supervise minors' use of the application and use parental control tools (such as Google Family Link) when necessary.

Lumi AI Chat requires certain device permissions to function properly. You can grant or revoke these permissions at any time through your device Settings: • Internet: Required, to send/receive messages with AI servers • Push Notifications: Optional, to receive update and reply notifications • Storage/Photos: Optional, only when you want to upload images during a conversation • Camera: Optional, only when you want to capture photos directly to send • Microphone: Optional, only when you use the voice input feature We only use these permissions for the stated purposes and do not access data beyond the scope you have consented to.

Our servers and AI service providers may be located in the United States, EU, or other countries. When you use Lumi AI Chat, your data may be transferred to and processed in these jurisdictions. For EU/EEA/UK users, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission and implement additional safeguards as needed.

We may update this Policy from time to time to reflect changes in our practices, technology, or legal requirements. When we make changes: • The "Last Updated" date at the top of this page will be revised • For material changes, we will notify you via email or in-app notification at least 7 days in advance • You should review this Policy periodically Continued use of Lumi AI Chat after changes take effect constitutes your acceptance of the updated Policy.

If you have questions, concerns, or requests regarding privacy, please contact us: JC Media Agency Limited LLC Developer of Lumi AI Chat (com.jcm.lumi) 30 N Gould St Ste N, Sheridan, WY 82801 Wyoming, United States Email: Contact@jcmedia.agency Website: https://jcmedia.agency We are committed to responding to all privacy-related inquiries within 30 business days.