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Lumi privacy notice
Version dated 20 October 2026.
This notice covers the heylumi.ru landing page, the waitlist application and the hana.heylumi.ru app.
1. Operator and contact
The operator is Vladislav Dmitrievich Kuzmichev, an individual; tax status: professional income tax payer (self-employed, Russia), tax ID 332911559884, postal address Vladimir, Russia; written requests to prosky33@gmail.com, privacy and support email prosky33@gmail.com. Domains: heylumi.ru and hana.heylumi.ru. Roskomnadzor notification: the personal data processing notification was filed on 20 October 2026, No. 100466703; the registry number will be shown here once issued.
2. Data, purposes and proposed grounds
Previously submitted access application and requested invitation Data: Email, language, application status/time, consent evidence, minimal technical metadata Proposed ground: Separate application consent; launch emails require a separate optional choice Login, age eligibility and account service Data: Email, ID, name/pseudonym if collected, date of birth, document acceptance, language/timezone, session data Proposed ground: Performance of the agreement, Article 6(1)(5); minimise date of birth after age eligibility is established Conversation, memory, topics and proactive messages Data: Messages/replies, memory facts, preferences, interests, profile, identifiers and times Proposed ground: Agreement for necessary functions. Additional processing requiring consent is accepted separately. Requested voice Data: Speech audio, transcript, synthesis text, voice/language selection, session metadata Proposed ground: Requested function under the agreement, with a separate informed step before microphone activation Optional notifications Data: Email or a push endpoint and subscription keys, consent version and time, the message-preview setting, companion name and delivery events. If message previews are enabled, this also includes the start of the message. Push notifications pass in encrypted form through the browser’s push service — Google, Apple, Microsoft or Mozilla. Message text may appear on the lock screen; you can turn previews off. Proposed ground: Separate consent; this beta does not include advertising Security, quotas, support and rights Data: IP, browser, minimal events/errors, usage volume, support requests/replies Proposed ground: Agreement, legal duty or an assessed legitimate interest; not unrestricted conversation logging Data comes from you, your browser and our own authentication service. We do not use Telegram IDs, Telegram account linking or a shared Telegram-product database. Ready-made companion faces are not your photos. Camera/voice are not used to identify you; the beta does not offer your custom likeness or voice cloning. Do not submit passwords, identity documents, payment credentials, other people's personal data or special-category data such as health, intimate life, political or religious beliefs. Free text may nevertheless contain and undergo processing of such information. A prohibition alone does not prevent its receipt.
3. Processing, storage and security
Processing includes collection, recording, organisation, accumulation, storage, updating, retrieval, use, disclosure to the contractors listed in section 4, blocking, deletion and destruction. Conversations are never published. Processing is automated; the operator accesses data manually only for support, to fulfil your rights and to investigate incidents, and only to the extent necessary. Where data is stored: the app and sign-in databases, files and logs are on the operator’s server in a Selectel JSC data centre in Moscow; encrypted backups are in Selectel JSC object storage in Russia. Only the operator has access to the server and databases. Connections to the site and app are encrypted (HTTPS), and backups are encrypted before they are sent to external storage. Conversations are not end-to-end encrypted: the server and the contractors in section 4 process text and audio in order to reply.
4. Providers and international processing
The service uses external contractors for replies, safety checks, memory, voice and topic search. Each receives only the part of text or audio needed for its function; replacing identifiers does not make text anonymous. Language models and memory OpenRouter, Inc., United States, routes model requests. The main DeepSeek model is served by StreamLake Pte. Ltd. (Singapore) or DeepInfra, Inc. (United States), the fallback by DeepInfra or SiliconFlow Labs Pte. Ltd. (Singapore). Memory vectors are computed by Parasail, Inc. (United States) or DeepInfra. Short checks of voice conversation fragments use a Google Gemini model (Google LLC, United States). Providers receive the current message and the relevant part of history and memory. Safety checks TypeSafe AI, Inc., United States: message text and context to detect crisis signals, check reply grounding and interpret requests. Speech synthesis Cartesia AI, Inc., United States: reply text to be voiced. Speech recognition Deepgram, Inc., United States: microphone audio in voice conversations; OpenRouter, Inc., United States (Whisper model): recorded voice messages. Video conversation Tavus Inc. and Daily, Co., United States: reply audio and the video stream, only in video conversation mode and for no more than 2 minutes per session. Outside this mode the companion face is played from our server and nothing is sent anywhere. Conversation topics search AlphaAI Technologies Inc. (Tavily), United States: short search queries about your interests, without your name or contacts. Email, notifications and CDN emails: Resend (Plus Five Five, Inc., United States); push notifications, if you enable them: your browser’s push service (Google, Apple, Microsoft or Mozilla, United States); the landing page background video loads from Amazon CloudFront (Amazon Web Services, United States), which receives your IP address and technical browser data Other recipients Selectel JSC, Russia: hosting and data storage. Robokassa: payment details when you pay; card details are entered on the Robokassa page and are not passed to the operator. Google LLC (Gmail), United States: emails you send to the support address. Transfers outside Russia Contractors in the United States and Singapore receive data outside Russia. Cross-border transfer takes place with your consent and after notifying Roskomnadzor. We do not use conversations for advertising and do not train our own models on them; model providers reached through OpenRouter are barred from collecting data for training by the request settings.
5. Retention and destruction
Data is kept no longer than the purpose of processing requires or the law demands. Application: until you are invited or withdraw, but no longer than 180 days from submission; the application is then deleted automatically Account, history and memory: while the account exists; after a deletion request, removed from active systems within 30 days Audio: not stored: audio is processed in memory during the conversation and only the text remains in the history Logs and support: technical logs are overwritten as they fill up and on every service update; support correspondence is kept for 1 year from the last email in the request Consents and payments: consent records are kept with the application or account; payment records and acceptance of paid terms for 4 years after the payment (the retention period for tax records); a minimal account deletion record for as long as backups containing that account exist Backups: locally, the 7 latest daily copies; encrypted offsite copies for 30 days. When restoring from a backup, deleted accounts are deleted again before access reopens Contractors: under each contractor’s terms: OpenRouter does not store requests, Resend keeps emails for 30 days, others for as long as needed to provide the service, for security and to comply with the law. Deleting data in Lumi does not automatically delete contractor records; on request we will forward a deletion demand to them A voice message transcript is kept as part of the conversation history.
6. Rights and working contact
You can request processing information, access, correction, restriction, cessation, deletion or consent withdrawal. The service also accepts requests for a machine-readable export of conversations, memory and profile. Contact prosky33@gmail.com. Account ownership is checked without requesting passwords/OTP; additional identification is sought only where justified by law. Legal deadlines depend on the request and applicable law; not all actions share one 30-day deadline. We explain any retention exception and ground. Account export and deletion are currently handled on request by email, as the account interface has no buttons for them yet. We reply to information requests within 10 working days and complete deletion or cessation of processing within 30 days. Forgetting one memory does not delete everything. You may decline optional voice/notifications and withdraw a particular consent without withdrawing all others. A function may stop where its necessary processing ends. Legal duties and processing on another valid ground may continue. Complaints can be addressed to Roskomnadzor and courts, or the appropriate foreign regulator where applicable.
7. Cookies, children, territory and changes
Necessary cookies/local settings support login, session protection, language and interface choices. The service is for adults aged 18+. If a child is identified, access stops and unlawfully collected data is reviewed for deletion. Countries served: Russia. English does not determine location. EEA/UK and other territories may require additional grounds, notices and rights; this notice does not declare GDPR inapplicable. Changes carry a date/version. Continued use alone does not authorise material new purposes or recipients requiring consent. Material changes require notice and separate consent where necessary. The landing has no analytics; selection and language live in page memory, without cookies or localStorage for these purposes. The server and CDN receive technical data to deliver the page. This does not claim the app, Keycloak or third-party resources have no cookies.