Privacy Policy

Privacy Policy ("Policy") explains who we are, how we collect, share, and use your personal information, and how you can exercise your privacy rights. This Privacy Policy applies only to the personal information we collect through the services provided on our Lumio APP.

By agreeing to this Policy or continuing to use Lumio services, you are deemed to consent and authorize us to collect, use, store, and process your personal information in accordance with this Policy. We may update this Policy from time to time and will notify you through push notifications, announcements, or pop-ups, among other methods.

Please read this Privacy Policy carefully and fully understand its contents before using our services. If you have any questions or concerns about how we use your personal information, please contact us using the contact information provided at the bottom of this Privacy Policy.

1.  Information We Collect and Process About You
2.  Use of Your Personal Information
3.  Sharing Your Personal Information
4.  Use of Cookies and Similar Technologies
5.  Protection of Your Personal Information
6.  International Data Transfers
7.  Retention of Your Personal Information
8.  Your Data Protection Rights
9.  Information Related to Children
10.  Updates to This Privacy Policy
11.  How to Contact Us

1. Personal Information We Collect and Process About You

1. Information You Provide Voluntarily

Certain parts of our services may require you to voluntarily provide personal information. For example, we may ask you to provide your contact details to register an account with us. The personal information you are asked to provide, and the reasons for requesting this information, will be explained to you when we request it.

  (1) Registering as a User of Our Services

You can register as a user of our services. Note that registration is not a prerequisite for using our services. When you register and log in to your Lumio account, you need to complete a series of registration steps as instructed. During this process, you will be asked to provide device information, and a user ID will be generated for you on Lumio. You can fill in information such as your nickname and profile picture during or after registration. You should ensure the accuracy of this information. We collect this information to provide account registration and login services, protect your account, and prevent security risks.

  (2) Creating Your Profile on Lumio

You can provide additional personal information about yourself in account settings, such as birth data, nickname, profile picture, and personal signature. Note that this step is entirely optional for using our services.

2.Information We Collect Automatically   (1) When Using Our Services

We may automatically collect certain information from your device when you use our services. In some cases, the use of your personal information may result in automated decisions (including understanding your preferences and recommending relevant videos based on your viewing preferences). Automated decisions mean decisions about you are made automatically based on computer algorithms, without manual review by us. You can express your preferences for certain videos on Lumio, and the algorithm will record your choices and reduce the frequency of sharing similar videos with you accordingly.

  (2) Security, Administrative, and Management of Our Platform

1.  While providing our services, we automatically collect device information (including hardware model, operating system version, MAC address, network device hardware address, unique device identifier, IP address, software version, network access method and type, network quality data, operation logs, usage and service, device name, system language) and your IP address, application crash messages, login times and attempts, and your behavior information. We collect this information to (i) ensure your security, including reviewing UGC, messages, and related metadata for violations of our platform's user conduct guidelines and other inappropriate content; (ii) help us detect and combat abuse, harmful activities, fraud, spam, and illegal activities on Lumio; (iii) perform data analysis and testing of the platform to ensure its stability and security; (iv) provide user support.

2.  Data Analysis

When you enter search terms to search for videos, we analyze your search terms and search logs among other users of our service to find relevant content. Rest assured, your search terms are not disclosed to anyone in our analysis, and you can choose to delete search terms.

3.  Video Display and Playback

You can use video display and playback on Lumio, and we collect your device information, including IP address, device type, model, device name, universal unique identifier, operating system, language settings, app version, and your behavior information, to record your pause position on specific videos.

3.Information We Obtain from Third-Party Sources

1. From Third-Party Sources

Sometimes, we may receive personal information about you from third-party sources (including certain SDK providers who record potential IP addresses or device IDs identified as potential security issues if such IP addresses or device IDs have initiated cybersecurity attacks). Our professional security team will strengthen the security of personal information (including reporting sensitive information, encrypted storage of sensitive information, access control, etc.).

2. Importance and Legitimate Interests

Maintaining the operation of the Lumio APP and the security of our services is an important and legitimate interest for us, such as operating our platform and, when necessary, communicating with you to provide our services and maintain our legitimate commercial interests, such as responding to your queries, improving our platform recommendations, performing marketing, or detecting or preventing illegal activities. In some cases, we may also have a legal obligation to collect personal information from you or require this information to protect your or others' vital interests.

2. Use of Your Personal Information

1.  We will use the information we collect about you in the following ways:

  1.To enforce our terms, conditions, and policies;
  2.To provide, process, maintain, develop, and improve our services;
  3.To deliver content to you;
  4.To communicate with you, including sending promotional information, operational activity notifications, and updates to agreements;
  5.To ensure your safety and protection, including reviewing user content, messages, and related data to ensure compliance with our community guidelines and other inappropriate content;
  6.To provide location-based services (if such services are available in your jurisdiction);
  7.To conduct market research and trend analysis, and to perform comprehensive statistics, data analysis, processing, and investigation related to our services.

2.  Generally, we will only use the personal information collected from you for the purposes described in this Privacy Policy or for the purposes we explained to you when collecting your personal information. However, where legally permitted, we may also use your personal information for other purposes that do not conflict with the purposes we have disclosed to you (e.g., for public interest, scientific or historical research, or archival purposes).

3. Sharing Your Personal Information

1.  You may share your personal information or other information with any third party (including unspecified entities) based on our services. For example, when using the sharing feature of our services, you can choose to share information with social apps (such as WhatsApp, Facebook, etc.) or other applications. Information you share with any third-party application will be controlled and processed by that third party, subject to their terms of service and privacy policy. Any disclosure, misuse, or similar issues resulting from your sharing are your responsibility, and we bear no responsibility for such issues.

2.  We may disclose your personal information to the following categories of recipients:

1.  Business Partners: If you choose to register for the platform using your social network account details (including Facebook, Google, Apple), you will provide or allow your social network to provide us with your username and public profile. If you choose to share content on social media platforms, videos, usernames, and accompanying text will be shared on those platforms, or in the case of sharing via instant messaging platforms like WhatsApp, the content link will be shared.

2.  Service Providers: We provide information and content to service providers who support our business, such as cloud service providers and content moderation service providers, to ensure Lumio is a safe and enjoyable platform.

3.  Analytics Providers: We use analytics providers to help us optimize and improve our services.

4.  Law Enforcement, Regulatory Authorities, Government Agencies, Courts, or Other Third Parties: We may disclose your personal information to any such entities if (i) required by applicable laws or regulations, (ii) to exercise, establish, or defend our legal rights, or (iii) to protect your or any other person’s vital interests, (iv) to detect, prevent, or address security, fraud, or technical issues; (v) to protect the rights, property, or safety of us, our users, third parties, or the public (including sharing information with other companies and organizations to prevent fraud and reduce credit risk); (vi) to enforce our service terms and other agreements, policies, and standards, including investigating any potential violations.

5.  Any Other Parties With Your Consent.

4. Cookies and Similar Tracking Technologies

1. We, along with our vendors and service providers, may use cookies and other similar technologies (such as web beacons, flash cookies, etc.) ("cookies") to automatically collect information, measure and analyze which web pages you click on and how you use our services, enhance your experience with Lumio, and improve our services.

Cookies are small files placed on your device that enable the platform to provide certain features and functions. Web beacons are very small images or bits of data embedded in images, also known as "pixel tags" or "transparent GIFs," that can recognize cookies, view the time and date of page views, and describe the page where the pixels are placed, as well as similar information from your computer or device. For example, we use cookies and similar tracking technologies provided by Google.

5. Protection of Your Personal Information

1. We will use appropriate technical and organizational measures to protect the personal information we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risks associated with processing your personal information. For example, we use SSL to encrypt and protect data; we have established access control mechanisms to ensure that only authorized personnel can access our users' personal information; and we regularly conduct security and privacy training to increase employee awareness of the importance of protecting personal information.

2. To prevent security incidents, we have established a dedicated data security department and developed appropriate early warning mechanisms and emergency plans. In the event of a personal information security incident, we will notify you in a timely manner in a manner sufficient to draw your attention, in accordance with applicable laws and regulations, and immediately implement our emergency plans to minimize losses. Unfortunately, transmitting information over the internet is not completely secure. Although we protect your personal data, for example through encryption, we cannot guarantee the security of information transmitted through the platform; any transmission is at your own risk.

6. International Data Transfers

1. Your personal information will be stored and retained in Japan and may be transferred to and processed in countries/regions outside of your country of residence. The data protection laws in these countries/regions may differ from those in your country. This is for security maintenance, business intelligence, and other necessary purposes. However, we have taken appropriate protective measures to ensure that your personal information is protected in accordance with this Privacy Policy. Internally, we have data transfer agreements with service providers or business partners outside Japan, requiring them to protect your personal information while processing it to provide you with services.

7. Retention of Your Personal Information

1. Generally, we will only need to retain your personal information for the shortest period necessary within the duration of our service provision. After this period, we will delete or anonymize your personal information in accordance with relevant laws and regulations. If we share such information with any third parties, we will also require them to do the same. However, in the following cases, we may modify the retention period of information due to legal requirements:

1.To comply with applicable laws and regulations;
2.To adhere to court judgments, rulings, or other legal processes;
3.To follow the requirements of relevant government agencies or legally authorized organizations;
4.To comply with what we consider necessary under relevant laws and regulations.

8. Your Data Protection Rights

1.  As a user of our services, you have the following data protection rights:

  1) Right of Access

  You can query or access your relevant personal information within our services, including:

    a. Account Information: You can log into your personal account through the relevant product pages at any time to access personal information in your account, including your avatar, nickname, date of birth, etc.

    b. Usage Information: You can view some of your usage information, including collection history, viewing history, and downloads, through the relevant product pages at any time.

  2) Right to Rectification

  You can correct/change some of your personal information according to the operation guide and settings on Lumio's relevant product pages, or you can contact us directly to modify or change your data.

  3) Right to Erasure

    a. You can request the deletion of your personal information by sending an email to [developer@vrbthn.com]. If you want to delete information related to your third-party accounts within our services, you can follow our URL data deletion instructions. You can also voluntarily delete some of your personal information through the account security - account cancellation settings on our product settings page.

    b. If we have collected, used, or shared your personal information in violation of relevant laws and regulations, you can directly request us to delete your personal information or notify the receiving third parties to delete it, unless such data has been anonymized or otherwise provided by applicable laws and regulations.

    c. You understand and agree that once you delete your personal information from our services on your own or with our assistance, we may not immediately delete your information from backup systems under applicable laws, regulations, and relevant security technologies. In such cases, we will securely separate your personal information from any further data processing until the information is deleted or anonymized during our backup system updates.

  4) Right to Restrict or Object to Processing

  If your jurisdiction grants you the right to restrict or object to the processing of some of your personal information, we will handle your request in accordance with the applicable laws based on your situation.

  5) Right to Cancel Your Account

  You may also cancel your account. We will contact you through the contact channels and terminate our account termination agreement. After verifying your identity and obtaining your confirmation, we will delete or anonymize all relevant personal data generated in Lumio in accordance with relevant laws and regulations, unless otherwise provided by laws and regulations. You can also exercise this right by sending an email to [developer@vrbthn.com].

  6) Right to Obtain a Copy of Your Personal Information

  You can contact us using the contact details provided in this policy. After verifying your identity, we will provide a copy of such information within the specified period in accordance with our regulations, except as otherwise provided by laws and regulations or this policy.

  7) Right to Lodge a Complaint

  You have the right to lodge a complaint with data protection authorities regarding our collection and use of your personal information. For more information, please contact your local data protection authority.

2.  To exercise your above rights, you can also contact us using the information provided under the “How to Contact Us” section. We will respond to all requests from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. To protect the security of your account and personal information, we may request additional information to verify your identity before responding to your request.

9. Information Related to Children

1. Children under the age of 14 are not permitted to register for our services or create their own accounts. If you are under 14 but considered a minor in your country or region, you must have your parent or legal guardian read this Privacy Policy with you, and you must declare that you have obtained permission from your parent or legal guardian to create your Lumio account. With parental or legal guardian consent, children of all ages may use the service. If you are a parent or legal guardian of a minor in your country or region, please ensure you have read this Privacy Policy before allowing your child to create their own account or use the service. You agree to comply with this Privacy Policy and take responsibility for your child's activities while using the service. You agree to supervise your child's use of the service and ensure that your child only views content suitable for their age.

10. Updates to This Privacy Policy

1. We may periodically update this Privacy Policy to address changing laws, technologies, or business developments. When we update our Privacy Policy, we will take appropriate measures to notify you based on the significance and impact of the changes we have made. If required by applicable data protection laws, we will obtain your consent for any material changes to this Privacy Policy.

11. How to Contact Us

If you have any questions or concerns about this Privacy Policy or our use of your personal information, please contact us at [developer@vrbthn.com].