Effective Date: August 1, 2025
This Privacy Policy describes how Lumina Orbit Limited ("Lumina Orbit" or "Company") collects, uses, and handles your personal data ("Personal Data"), and what choices you have when you use our voice agent platform, applications, and services that facilitate calls to businesses for information (collectively, the "Services"). By using the Services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree to the practices described in this Privacy Policy, please do not access or use the Services. Any capitalized terms not defined herein have the meaning ascribed to them in our Terms of Service.
We collect several different types of information for various purposes to provide and improve our Services, including Personal Data and Usage Data as set forth below. If you do not provide your information when requested, you may not be able to use some or all of our Services if that information is necessary to provide you with our Services or we are legally required to collect it.
While using our Services, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personal Data may include without limitation:
We may collect information related to your interaction with or usage of the Services, including without limitation: your IP address, device type, browser type and version, pages of our Services that you visit, the time and date of your visit, the time spent on those pages, device language, unique device identifiers, system logs, performance metrics, call duration, businesses contacted, types of inquiries made, and other diagnostic data related to your interaction with the Services ("Usage Data"). When you access the Services with a mobile device, Usage Data may also include information such as the type of mobile device, mobile device unique ID, mobile IP address, mobile operating system, mobile Internet browser type, and other diagnostic data.
We collect Customer Content that you provide to us in order to use the Services. This includes:
This content is processed solely to deliver the Services. If you opt to share your content with us for model training, we may also collect anonymized voice data and call patterns to improve the performance of our voice agent for all users. More information about how we use Customer Content is available in our Data Controls Page.
We may collect information when you connect to your account using an account maintained by a third party, such as a social media account ("Third-Party Account"). The Services may collect information about you from your Third-Party Accounts in accordance with your permissions. When you connect to us through a Third-Party Account like Facebook or Google, we receive information from that third party identifying your account. We collect and store this information and use it to help you connect to the Services. Connecting your account to a Third-Party Account is completely optional, and you will have the opportunity to grant permission when you attempt to connect. You can revoke permission by logging into the Third-Party Account and disconnecting Lumina Orbit from there, and through the native applications on your smartphone. We may retain the information we collected previously from you.
Our app requires access to your device's camera to take photos or videos within the app. We request your permission before accessing the camera. You may choose to grant or deny this access, and you can revoke consent at any time through your device settings. We do not collect or use your camera data for any purposes other than those explicitly stated.
Our Services may require access to protected resources on your device to perform actions at your instruction. The app acts on your behalf, and this data is used solely to fulfill your requests. Examples include:
Access to these resources is requested only when needed to perform a specific action you have initiated. You will be prompted for permission, and you can manage these permissions through your device's settings.
When you sign up for any of our Paid Services, our third-party payment processor, Stripe, Inc. ("Stripe"), collects and processes your payment-related information, such as your name, email, billing address, credit/debit card or banking information, or other financial information. Stripe's privacy policy is available at https://stripe.com/privacy.
You may have the option to submit additional information as you use our Services. For example, you may choose to participate in surveys where you can provide feedback on our voice agent's performance or suggest businesses to add to our directory.
Lumina Orbit may use Personal Data and Usage Data for the following purposes:
Our lawful basis to collect and use your Personal Data and Usage Data will depend on the type of information and the context in which we process it. We may process your information to enter into or perform a contract with you, for the purposes of our legitimate interests (unless your rights and freedoms override those interests), with your consent, or to comply with our legal obligations (e.g. to comply with applicable laws and regulations or a court or other legal order).
Lumina Orbit, and the third parties we work with, use cookies and other tracking technologies on the Services to collect information about your usage of the Services and your device. Our use of such technologies is described in our Cookie Policy.
We may use third-party web analytics services on the Services, such as those of Google Analytics. These vendors use the sort of technology described in the "Information Collection and Use" section above to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by such technology will be disclosed to or collected directly by these vendors, who use the information to evaluate your use of the Services. We also may use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for web analytics, you may install the Google Analytics Opt-Out Browser Add-on.
We engage in advertising for our own products and services and track ad attributions to measure effectiveness. We may use cookies or similar technologies to collect information about your use of our Services to optimize and serve our marketing content based on your interactions with our website and Services. We do not sell your data or use it to optimize ads for other companies. Currently, we do not allow unaffiliated parties to serve tailored marketing through our Services. However, you may still receive our advertising content, which may not always be personalized to your interests. If you wish to learn more about controlling cookies for marketing purposes, you can visit the Network Advertising Initiative's (NAI) Consumer Opt-Out Link or the Digital Advertising Alliance's (DAA) Consumer Opt-Out Link. To exercise choices about how Google personalizes Display Advertising or to customize Google Display Network ads, you can visit the Google Ads Settings page. Please note that we do not control these opt-out mechanisms and cannot guarantee their continued availability or effectiveness.
We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We retain your Personal Data for different periods of time depending on what it is, how we use it, and how you configure your settings. Voice recordings and call transcripts are retained for 90 days unless you request earlier deletion. We will either delete or anonymize Personal Data once it is no longer needed or after expiration of the applicable retention periods. If we anonymize, aggregate, or de-identify Personal Data, we may use and disclose it for any business purpose. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.
Your information, including Personal Data, may be transferred to -- and maintained on -- computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
Lumina Orbit will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
This section describes when we may disclose Personal Data:
The security of your data is important to us. We implement technical, administrative and physical safeguards to protect the information we collect from loss, misuse and unauthorized access, disclosure, alteration, or destruction. However, no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. You can learn more about GDPR at https://gdpr.eu/. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at support@resolveai.app.
In certain circumstances, you have the following data protection rights to:
Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not be able to provide Services without some necessary data.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
To use the Services, you must be at least 13 if you reside in the United States, and 16 if you reside anywhere else. If you are under the age of 18, depending on where you live, you may need to have your parent or guardian's consent to these Terms and they may need to enter into these Terms on your behalf. If you are a parent or guardian and become aware that your child provided us with Personal Data, you should contact us at support@resolveai.app.
We may use third-party companies, vendors, personnel and other service providers to facilitate our Services, provide Services on our behalf, analyze how our Services are used, and provide similar third-party services (collectively, "Service Providers"). These Service Providers may have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
The Services may contain links to third-party websites or services. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information by third parties will be subject to the privacy policies of the third-party websites or services, and not this Policy. We urge you to read the privacy and security policies of these third parties before providing information to them.
We'll update this Privacy Policy from time to time. When we make changes, we'll update the date at the top of the Privacy Policy. If a modification meaningfully reduces your rights, we will notify you (by, for example, sending you an email or displaying a prominent notice within the Services). The notice may designate a reasonable period after which the new terms will take effect. Modifications will not apply retroactively. We encourage you to check back periodically to review this Privacy Policy for any changes since your last visit. This will help ensure you better understand your relationship with us, including the ways we process your Personal Data.
If you have any questions about this Privacy Policy, please contact us by email at support@resolveai.app.
If you are a California resident, please review this supplemental notice.