Lummra Privacy Policy
Effective: April 14, 2026
Last Updated: October 3, 2026
1. Introduction
Divine Feminine Ventures, Inc. ("Divine") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how Divine collects, uses, shares, and safeguards data when you use Lummra (the "Services"), a social media platform for users 18+. It applies to all users and complies with Divine's policies and applicable laws. This Policy describes how Divine handles personal information. Divine enforces a strict 18+ age gate and does not knowingly collect data from users under 18. Divine may update this Policy as described in Section 8.
Lummra is currently offered only in the United States. Divine does not direct the Services to users in other countries. If Divine makes the Services available outside the United States, Divine will update this Policy and provide any additional notices or choices required in those countries before doing so.
2. Information Divine Collects
Information You Provide: Account details (name, username, email address, date of birth), profile information, account status, legal-consent records, User Content (posts, comments, videos, metadata), messages, in-app relationships (followers, following, blocked accounts), purchase information, survey responses.
Automatically Collected: Usage data (post views and watch duration, likes, saves, follows, music playback and listening activity, notification interactions), search activity (search requests and query identifiers, and the results and filters you interact with), quiz and game state (progress, answers, scores, inventory, and consumable use), device information (IP address, OS, device ID, browser type), performance and diagnostic data (status, latency, app version and build, device model, and related service events), location (approximate via IP, and precise location with your permission when you attach a location to a post), and cookies or similar technologies for analytics.
Legal documents displayed inside the app: When Lummra presents a specific document version for you to accept or acknowledge, it displays that document inside the app using pages provided by Divine. These document pages do not run the public website's analytics scripts, set its analytics cookies, or load Google reCAPTCHA. When you confirm, Divine records the document version and your acceptance or acknowledgement. Technical request information may also be processed as described in this Policy.
When you visit Divine's public website: If you open Divine's public website, including through links in the app, that website uses analytics cookies and Google reCAPTCHA on its contact form, and may record page activity and information reCAPTCHA uses to distinguish humans from automated traffic.
Support, reports, and appeals: Support messages, content and copyright reports you submit, and account-access and moderation appeals, together with the account information needed to investigate and respond.
Account deletion requests: Divine processes the account information needed to confirm your request, the request and cleanup deadline, the outcome of cleanup, and the email information needed to send and record completion confirmation. Divine uses this information to fulfill and document your request, subject to the limited retention rules in Section 7.
From Others: Data from linked third-party logins (e.g., Google), or reports about you.
Account and Social Connection Information
Lummra collects a name, username, email address, date of birth, profile information, account status, legal-consent records, and in-app relationships such as followers, following, and blocked accounts. Lummra does not read or upload the contact list stored on your phone. Apple classifies the in-app social graph under Contacts even though it is not the phone contact list.
Identity and Age Verification
When a user starts identity or age verification, Lummra uses Didit as a service provider. Didit may process a legal name, date of birth, identity-document information and images, including any address or facial photograph shown on the document, verification status, session identifiers, and related technical information. Divine uses this information to verify age or identity, prevent fraud, protect accounts, and enforce Lummra's 18+ requirement.
Lummra retains only a limited result and audit record, not the raw document, selfie, document number, raw biometric result, or full Didit webhook payload. Verification records are deleted or de-identified when no longer needed and within 90 days following the verification session, unless longer retention is legally required. The 90-day period does not apply to or extend the account-deletion deadline in Section 7. Didit's retention setting uses the same approved period.
Sensitive information. Some information Lummra processes may be treated as sensitive under privacy law. The age-verification appeal flow uses Didit to check an identity document and the date of birth it contains. The document may include a photograph of your face, which Divine handles as described under Biometric information below. Selfie, liveness, and face-matching checks are not used in this flow. Profile interests you choose to add may reveal or imply religious or philosophical beliefs. Divine processes this information only as necessary for the purposes described in this Policy and, where required by law, with your consent. Divine does not collect health data, race, or other sensitive categories beyond what is described here. Verification records follow the retention and account-deletion rules above. Biometric identifiers and biometric information follow the permanent-destruction rule below.
Biometric information. Through Didit, Divine processes identity documents, including any facial image shown on the document, to check document validity and date of birth, prevent fraud, and enforce Lummra's 18+ requirement. Divine does not sell, lease, trade, or otherwise profit from biometric information, and does not disclose it except to Didit as Divine's verification provider, with your consent, or where disclosure is required by law or by a valid warrant or subpoena. Divine obtains your consent before this processing begins. Divine permanently destroys biometric identifiers and biometric information when the initial purpose for collecting them has been satisfied or within 90 days following the verification session, whichever occurs first, subject to any earlier applicable destruction requirement. Account-deletion requests are also subject to Section 7. Any exception to destruction must be specifically authorized by applicable law and limited to the covered records and required period.
3. How Divine Uses Your Information
Divine uses your information to:
Divine processes data based on consent, contract necessity, legitimate interests (e.g., fraud prevention, platform safety, and the development of safety systems), or legal obligations. Lummra uses automated age checks and may restrict access when the date of birth provided indicates that a user is under 18. If you believe the restriction is incorrect, you can appeal for human review as described in Section 6. This does not limit any rights you have under applicable privacy law.
Advertising. Lummra does not display advertising in this release and does not request or receive advertising data. Users may post sponsored or promotional content of their own under the Community Guidelines; that is User Content, not advertising served by Divine, and Divine does not receive advertising data from it. If Divine enables advertising in a later release, Divine will update this Policy and its App Store privacy disclosures and provide any required notice, choices, consent, or App Tracking Transparency request before doing so.
Content Moderation and Automated Systems
Lummra uses automated systems, developed and owned by Divine, to review content and enforce the Community Guidelines. Divine develops, trains, tests, and improves those systems using material generated through moderation on Lummra, including:
This material may include content you posted, content you reported, and content another user reported about you. Divine removes usernames and other direct account identifiers before using this material for development or training. Removing usernames and direct account identifiers alone does not necessarily de-identify text, images or other content. Before retaining material as de-identified development or training data, Divine applies and validates measures designed to prevent it from reasonably being linked to an individual. Divine maintains that material in de-identified form and does not attempt to re-identify it. Material that remains identifiable is treated as personal information and follows the retention and deletion rules in Section 7.
What Divine does not use for this purpose. Divine does not use private messages, identity or age-verification information, account or contact details, or purchase records to develop or train these systems. Divine does not use for this purpose content that has not been reported, flagged, appealed, or acted on in moderation.
Divine's systems are its own. These are Divine's proprietary systems, developed and operated in-house. Divine does not send content, appeals, or moderation material to any third-party AI service for review, labeling, or model development, and does not license or sell that material to third parties for their own model development. Within Lummra, the only third party that performs automated analysis of user information is Didit, and only for identity and age verification as described in Section 2. Divine's public website separately uses analytics and Google reCAPTCHA, as described in Section 2.
Deletion and training. When Divine accepts a confirmed account-deletion request, it stops selecting that account's identifiable content and appeal material for new development or training use and removes identifiable source copies under Section 7, subject to its limited lawful retention exceptions. Material already made genuinely de-identified may be retained in that form. Account deletion does not automatically retrain an existing system; Divine separately assesses whether a trained system still processes personal information and what action applicable law requires.
Your grant of rights for this purpose is set out in Lummra's Terms of Service.
4. Sharing Your Information
Divine shares data:
Divine does not sell your personal data, and does not share it for behavioral advertising. Divine shares your data only as needed to operate the service: with service providers who process data on Divine's behalf under contract; when required by law (such as a valid subpoena or court order); to protect safety in an emergency; with your consent or at your direction; or in connection with a business transfer such as a merger or acquisition.
Child safety reporting. Divine reports child sexual abuse material to the National Center for Missing & Exploited Children (NCMEC) and to law enforcement as required by law, and may provide account information and content with those reports as required. Divine may also preserve account information and content for law-enforcement investigations, and may report credible threats of violence, terrorism, and human trafficking to the appropriate authorities. Retention is subject to applicable law and the limited retention rules in Section 7.
Service Providers
Divine uses service providers to operate Lummra: Firebase Authentication, Google Sign-In, Cloud Firestore, and Firebase Cloud Messaging support accounts, messaging, and notifications. Google Cloud provides backend hosting, database, and media storage. Apple provides App Store purchase processing and device-notification delivery. Didit provides identity and age verification. Divine requires these providers to protect personal information consistently with this Policy, applicable contracts, and law.
5. Children's Privacy
The Services are not directed at children under 18. Divine enforces a strict 18+ age gate at signup and does not intentionally collect data from younger users. If age information indicates that a user is under 18, Divine restricts account access. Users who believe this is incorrect may appeal as described in Section 6. If Divine confirms that a user is under 18, Divine terminates the account and removes content promptly, in accordance with applicable law.
6. Your Privacy Rights and Choices
You have rights to:
Moderation Appeals
Divine uses moderation appeals to review challenged decisions, administer the appeal process, improve case-handling procedures, and protect the Lummra community. Divine uses appeal text for development or training of its automated content-review systems only as described in Section 3, including its safeguards for de-identification and the cutoff and cleanup rules after a confirmed account-deletion request. Divine does not sell appeal information and does not use it to build any product unrelated to keeping the community safe.
If you appeal an age-related restriction, Lummra uses Didit to verify your age, as described in Section 2. Didit provides verification results. An authorized member of Divine's team reviews your appeal and decides whether to restore access. Other appeals are handled by Divine without a third-party provider.
State privacy rights
Divine offers the Services only in the United States, and these rights are provided under United States federal and state law.
California. Divine does not sell your personal information and does not share it for cross-context behavioral advertising. Divine honors Global Privacy Control signals. You may submit requests to exercise the rights listed at the beginning of this Section, including requests to know, access, correct, or delete your personal information, obtain a portable copy, or limit the use and disclosure of sensitive personal information, through in-app settings or support@divinefeminineventures.com. Divine verifies requests as required and responds within 45 calendar days after receiving a request. Where reasonably necessary and permitted by law, Divine may extend that response period once by a further 45 days, notifying you of the extension and its reason within the initial period. This privacy-request response timetable does not extend the ordinary account-cleanup deadline in Section 7. Divine does not discriminate or retaliate against you for exercising these rights.
Other states. Residents of states with comprehensive privacy laws, including Virginia, Colorado, Connecticut, Texas, Utah, Oregon, and Montana, may exercise the rights listed above to the extent those laws provide them.
Appealing a decision on your request. If Divine declines to act on a privacy request, Divine will tell you why. You may appeal by replying to that response or by emailing support@divinefeminineventures.com with the word "Appeal" in the subject line. Divine will respond to an appeal in writing within 45 days, or within 60 days where a state's law allows. If your appeal is denied, Divine will tell you how to contact your state Attorney General to submit a complaint.
Biometric information. Illinois, Texas, and Washington residents have additional rights concerning biometric information. Divine's written biometric policy, including its retention and destruction schedule, is set out in Section 2.
7. Data Security
Divine uses reasonable security (e.g., encryption) but cannot guarantee absolute protection.
Data Retention and Deletion
General retention. Divine retains personal information only as long as necessary for the purposes described in this Policy and as permitted by applicable law.
Limited retained records. Divine keeps only personal information and verification records needed for legal obligations, accounting, privacy requests or consent, or specific fraud, safety or legal matters where retention is permitted by law. Access is restricted, the need is reviewed, and records are deleted when that need ends. Section 2 governs such verification records.
Limited information may remain temporarily in protected backups or be preserved for fraud prevention, safety, accounting, legal claims, law-enforcement preservation, or another legal obligation.
Account deletion. You may request deletion in Lummra's settings and confirm your identity and request. Account access ends when Divine accepts your confirmed request. Divine promptly begins deletion and deletes your account and associated personal information, content and files held by Divine or its processors within 30 calendar days of receiving the confirmed request, subject to this section's limited retention and backup provisions. After verifying ordinary deletion is complete, Divine sends email confirmation. You may also contact support@divinefeminineventures.com for help or deletion; an in-app request does not require a separate support conversation.
Apple subscriptions. Deleting your account does not cancel Apple-billed subscriptions. Manage or cancel them through your Apple account. You may request account deletion without waiting for a subscription to expire.
Deleting your account or individual content ends Divine's ordinary use of that content, subject to this section's limited retention rules. These rules also cover copies controlled by Divine, regardless of any surviving content license. Other people's independently created content remains theirs. Section 3 explains the treatment of de-identified material and already-trained systems.
8. Changes to This Policy
Divine may update this Policy to reflect changes in its practices, its Services, or applicable law. The "Last Updated" date at the top shows when it was last revised, and Divine maintains prior versions on request.
Where a change is material, Divine will notify you by in-app notification at least 30 days before it takes effect, and by email where an address is available, except where an urgent safety or legal requirement makes an immediate change necessary. Divine will present the updated Policy to you when you next use the Services.
Where a change involves a new or materially expanded use of personal information that Divine has already collected, Divine will obtain your consent before that new use begins. Your access to the Services does not depend on giving that consent; if you decline, Divine will continue to handle your existing personal information under the version of this Policy in effect when it was collected. Divine will describe clearly, at the time, what the new use is and what declining means.
This Policy is not a contract, and nothing in it limits any right you have under applicable privacy law, including the rights described in Section 6.
9. Contact Divine
Questions? Reach Divine at support@divinefeminineventures.com.
10. General
This Privacy Policy, as amended, is effective as of April 14, 2026 and was last updated October 3, 2026.
This Privacy Policy is referenced in Lummra's Terms of Service and Community Guidelines. If any provision is invalid, the remainder remains in effect. Contact Divine at support@divinefeminineventures.com for questions.
© 2025, 2026 Divine Feminine Ventures, Inc. All rights reserved.
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