Privacy Policy

Effective: April 14, 2026
Last Updated: September 10, 2026

Lummra Privacy Policy 

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 Social (the "Services"), a social media platform for users 18+. It applies to all users and complies in accordance with Divine’s policies and applicable laws. By using the Services, you consent to this Policy. Divine enforces a strict 18+ age gate and does not knowingly collect data from users under 18. Divine may update thisPolicy. Check in-app notifications for changes. 

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. 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. 
• 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, an address shown on the document, facial images, liveness or face-match results, 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 retained for 90 days and then deleted or de-identified unless longer retention is legally required. Didit's retention setting will use the same approved period. 

Sensitive information. Some information Lummra processes may be treated as sensitive under privacy law. The age and identity verification flow processes facial images and liveness or face-match signals through Didit, which may constitute biometric information. 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, including any biometric signals processed during verification, are retained for the period stated above and then deleted or de-identified. 

Biometric information. Through Didit, Divine collects and processes facial images and liveness or face-match results for the sole purpose of verifying identity and age, preventing fraud, and enforcing 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 retainsverification records, including any biometric signals processed during verification, for 90 days following the verification session, and then permanently destroys or de-identifies them, unless a longer period is required by law or is necessary to resolve a pending legal claim. 

3. How Divine Uses Your Information 

Divine uses your information to: 

• Provide and improve Services (e.g., personalize feeds, moderate content via AI). 
• Communicate (e.g., updates, support). 
• Analyze usage and develop features (e.g., aggregated trends). 
• Ensure safety, including reviewing reported and flagged content and moderation appeals. 
• Develop, train, evaluate, and improve Divine's automated content-moderation systems, as described below. 
• Comply with laws (e.g., respond to requests). 
• Facilitate sharing (e.g., with friends). 

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. No automated decisions with legal effects are made without the option to opt out. 

Advertising. Lummra does not display advertising in this release and does not request or receive advertising data. 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: 

• content that is reported by a user or flagged by Lummra's automated systems, whether or not it is ultimately found to violate the Community Guidelines; 
• moderation decisions, enforcement outcomes, and associated labels or categories; and 
• the text of moderation appeals. 

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 this material is used for development or training. 

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 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. Divine may retain moderation and training material in de-identified form, and systems already trained on it remain trained, after an account or the underlying content is deleted. Once a system has learned from material, removing an individual example from it is not technically feasible. Deleting your account stops future material from being used. 

Your grant of rights for this purpose is set out in Lummra's Terms and Conditions. 

4. Sharing Your Information 

Divine shares data: 

• With users: Public posts visible to others; private messages to recipients. 
• Service Providers: For hosting, analytics, storage, and operations, under strict agreements; no selling data. Divine's content-moderation systems are built and run in-house and are not operated by a third-party AI vendor. 
• Affiliates/Partners: For operations (aggregated/anonymized). 
• Legal/Business: In mergers, acquisitions, transfers of business assets, court orders, or to protect rights/safety. 
• Third Parties: With consent (e.g., login providers) or for features (e.g., sharing to external apps). 

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. 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. 

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 knowingly collect data from younger users. If Divine learns of underage data, Divine removes content promptly and terminates accounts, in accordance with Divine’spolicies and applicable law. 

6. Your Privacy Rights and Choices 

You have rights to: 

• Access, correct, update, or delete your data via in-app settings or support@divinefeminineventures.com. 
• Download/port your data. 
• Appeal content decisions (see Moderation Appeals below). 
• Confirm whether Divine processes your personal information, and obtain a copy of it. 
• Correct inaccurate personal information Divine holds about you. 
• Delete your personal information. 
• Limit Divine's use and disclosure of sensitive personal information. 
• Appeal a denial of any request described above, as set out under State privacy rights below. 

Moderation Appeals 

Divine uses moderation appeals to review challenged decisions, administer the appeal process, improve case-handling procedures, and protect the Lummra community. Divine also uses appeal text, with usernames and direct account identifiers removed, to train and improve its automated content-review systems, as described in Section 3. Divine does not sell appeal information and does not use it to build any product unrelated to keeping the community safe. 

If you appeal a decision about your age or eligibility to use Lummra, resolving that appeal requires identity or age verification, and your information is processed by Didit for that purpose as described in Section 2. 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. Submit verified requests through in-app settings or support@divinefeminineventures.com; Divine responds within 45 days and may extend once by a further 45 days where reasonably necessary. Divine does not discriminate 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 

Divine retains personal information only as long as reasonably necessary to operate and protect Lummra, provide requested features and purchases, comply with law, resolve disputes, and enforce its agreements. Account information is generally retained while the account is active, and user content until the user or Divine deletes it. Purchase, consent, fraud, security, moderation, and safety records may be retained as reasonably necessary for those purposes. Verification records follow the period stated above. 

Users may delete their account in Lummra's settings or contact support@divinefeminineventures.com. After deletion, Divine deletes or de-identifies information when it is no longer required. 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. 

De-identified moderation and training material described in Section 3, and automated systems already trained on it, are not reversed by account or content deletion. 

Deleting your account or your content ends Divine's ordinary use of that content going forward. As set out in Lummra's Terms and Conditions, a limited license survives deletion for content other users have reshared, for copies held in backups until they expire, and for copies Divine must retain for legal, safety, or law-enforcement purposes. 

8. Changes to This Policy 

Divine may update this Policy. material changes will be announced in-app or by email at least 30 days before they take effect, except where an urgent safety or legal requirement makes an immediate change necessary. Continued use after changes take effect constitutesacceptance. 

9. Contact Divine 

Questions? Reach Divine at support@divinefeminineventures.com. 

10. General 

These Guidelines as amended are effective as of April 14, 2026 and were last updated August 31, 2026. 

This Privacy Policy, together with the Community Guidelines and the Terms and Conditions are the entire agreement between you and Divine. Divine may assign rights without your consent. If any provision is invalid, the remainder remains enforceable. Contact us at support@divinefeminineventures.com for questions. 

© 2025, 2026 Divine Feminine Ventures Inc. All rights reserved.