Effective Date: October 6, 2026

AlphaLuma Privacy Policy

This Privacy Policy ("Policy") aims to inform you about the content you should be aware of when using the AlphaLuma APP (hereinafter referred to as "Product" or "Service"):

  1. How We Collect and Use Your Personal Information
  2. How We Share, Transfer, and Disclose Your Personal Information
  3. How We Protect Your Personal Information
  4. Your Rights
  5. How We Handle Minors' Personal Information
  6. How Your Personal Information is Transferred Globally
  7. Applicable Law and Jurisdiction
  8. How This Policy is Updated
  9. To California Residents
  10. To European Users
  11. Our Contact Information

Important: We highly value the protection of your personal information and are committed to maintaining your trust in us. We promise to adopt appropriate security measures to protect your personal information in accordance with widely applicable industry security standards. It is important to note that this Policy does not apply to products or services provided to you by other third parties. Before using our products and services, please be sure to read and fully understand this Policy.

1. How We Collect and Use Your Personal Information

1.1 Signing In to AlphaLuma

The sign-in methods available depend on your device and the app version you use:

When you register with an email address, we collect your email address and the password you choose (stored only in hashed form). After you sign in, you can access the full features of the Product and Service. If you do not sign in, certain features may not be available. By signing in, you agree to the AlphaLuma Terms of Use and this Privacy Policy.

1.2 Providing You with Other Related Product Features or Services

To achieve the following product features or services, we may need to collect corresponding personal information from you. If you refuse to provide such information, you will not be able to use those specific services.

a. Customer Service: When you lodge complaints, inquiries, or appeals with AlphaLuma, we may need you to provide your name, phone number, email address, and other valid contact information to facilitate communication or help resolve your issues. If you refuse to provide such information, we may be unable to provide timely feedback on relevant processing results.

b. Usage Statistics (No Advertising): To understand how the App is used and to improve it, we use Google Firebase Analytics and Mixpanel to collect in-app usage events together with basic device information (device model, OS version, language, and an app-instance or random identifier), as described in Section 1.9. We use this information only in aggregate to measure and improve the Product. We do not use it for advertising, do not build advertising profiles, do not read the list of apps installed on your device, and do not sell it.

c. Maintaining Product Security and Troubleshooting: To maintain the normal operation of our services, ensure the security of your account, troubleshoot product faults, and improve and optimize our services, we will collect your EXIF data, device model information, login IP address, and operational log information. This information is necessary to provide the service and will be anonymized upon collection, not used to identify any specific user.

d. Ensuring Account Security: When you use functions such as password changes, security verification, or appeals, and abnormal operations are detected, we may ask you to provide valid identity information to ensure the security of the aforementioned operations.

e. Additional Features — Other Third-Party Provided Features: This Product may integrate other products or features launched by external partners. We will only store and manage your related information for the purpose of providing those features and will not use it for other purposes.

1.3 No Sale of Personal Information

We commit not to sell your personal information, including but not limited to any identity-related content you submit while using AlphaLuma. This includes, but is not limited to, your name, email address, phone number, and any content or data that can directly or indirectly identify you.

If you have any questions about how we handle your personal information or wish to exercise your privacy rights, please contact us through our provided contact details.

1.4 Indirectly Obtaining Your Personal Information from Third Parties

a. When you log in to AlphaLuma using a third-party account (Apple ID on iOS, or Google account on Android), you can choose to authorize AlphaLuma to read and obtain the public information (including nickname, avatar, and, for Google, your email address) that you have registered on that third-party platform.

b. AlphaLuma needs your authorization to obtain the above information from third parties to recognize you as an AlphaLuma user and provide you with better products or services. After logging in with a third-party account, your third-party account will be bound to your AlphaLuma account, but you can choose to "unbind" to cancel the account binding.

1.5 AlphaLuma's Use of Your Personal Information in Other Specific Situations

a. If you believe your related rights have been violated, you can file a complaint or report through our published contact methods. During this process, we will require you to provide valid personal identification information to verify the authenticity of the complaint or report.

b. Please understand that the functions and services we provide to you are continuously updated and developed. If we intend to use your personal information for purposes not specified in this Policy, we will inform you in a reasonable manner and obtain your consent again before using it.

1.6 Use of Google Sign-In and Google User Data

Note: This section applies to Android users only, since Google Sign-In is not available on iOS.

When you choose to sign in to AlphaLuma with your Google account (available on Android), we only receive your Google account ID, name, email address, and profile picture (if available) from Google. We use this information solely to create and authenticate your AlphaLuma account, display your profile information inside the app, and help keep your account secure.

We do not access your Gmail, Google Drive, Calendar, contacts, or any other Google data. We do not sell your Google user data or share it with third parties for their own marketing or advertising purposes.

AlphaLuma's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

1.7 Purchases and Subscriptions

AlphaLuma Pro is sold through the app store you downloaded the App from: the Apple App Store on iOS, and Google Play on Android. Payment is handled entirely by Apple or Google. We never receive or store your card number or other payment credentials.

To unlock Pro features, restore purchases, and keep your membership status in sync across devices, we and our subscription-management provider RevenueCat receive purchase information from the store, such as the product purchased, purchase and expiry dates, renewal and cancellation status, trial status, the store's transaction or purchase token identifiers, the country/currency of the store account, and an app user ID that links the purchase to your AlphaLuma account. We do not receive your Apple ID or Google account password.

1.8 Device Permissions (Android)

The Android app asks for the following permissions only when you use the related feature. You can decline them or turn them off at any time in your system settings; only the related feature will stop working.

1.9 Third-Party SDKs and Service Providers

We use the following third-party services to operate the App. Each receives only the data needed for the purpose listed, and processes it under its own privacy policy.

We do not use advertising SDKs, do not show ads, and do not collect advertising identifiers (we do not collect the Android advertising ID, and on iOS we do not request App Tracking Transparency permission or collect the IDFA).

1.10 Where Your Data Is Stored

Your account information and the content you publish are stored on servers operated by established cloud infrastructure providers. Those servers, and the systems of the third-party service providers listed in Section 1.9 (such as Google Firebase, Mixpanel, RevenueCat, and Cloudflare, which are based in the United States), may be located outside the country or region where you live. We may change where data is hosted as our service grows, and will update this Policy where required. See Section 6 for cross-border transfers.

2. How We Share, Transfer, and Disclose Your Personal Information

2.1 Sharing

We will not share your personal information with any company, organization, or individual, except in the following circumstances:

a. Other Creators and the Public: Your profile and content are publicly visible and can be seen and used by others.

b. Sharing with explicit consent: With your explicit consent, we may share your personal information with others.

c. Sharing under legal conditions: We may share your personal information in accordance with laws, regulations, dispute resolution needs, or mandatory requirements from competent government departments or judicial authorities.

d. To protect the interests of AlphaLuma and its users or the public: To the extent required by law, we may provide your personal information to third parties when necessary to protect the interests, property, or safety of AlphaLuma, its users, or the public.

e. Sharing with authorized partners: Certain services will be provided by authorized partners solely to achieve the purposes stated in this Policy. We will only share personal information necessary for the provision of services and sign strict confidentiality agreements with partners.

2.2 Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following circumstances:

a. With your explicit consent: We may transfer your personal information to others with your explicit consent.

b. In case of mergers, acquisitions, or bankruptcy liquidation: If personal information transfer is involved, we will require the new entity holding your personal information to continue to be bound by this Privacy Policy.

2.3 Public Disclosure

We will only publicly disclose your personal information in the following situations:

i. With your explicit consent: With your explicit consent, we may publicly disclose your personal information.

ii. Based on legal regulations: We may disclose your personal information as required by law, regulations, judicial authorities, or administrative authorities.

3. How We Protect Your Personal Information

We will work hard to protect your personal information. We will provide corresponding security measures as follows to protect your information according to existing technology and provide reasonable security guarantees.

1. Security Measures: We have used security measures that comply with industry standards to protect the personal information you provide, preventing unauthorized access, public disclosure, use, modification, damage, or loss of data. All data exchanged between the App or your browser and our servers is encrypted in transit using HTTPS (TLS); we use encryption technology to ensure data confidentiality; we use trusted protection mechanisms to prevent malicious attacks on data.

2. Data Minimization: We will take all reasonable and feasible measures to ensure that no irrelevant personal information is collected. We promise to keep your personal information storage time within the period required by law or necessary to realize the product's functions and services.

3. Secure Communication: The internet is not an absolutely secure environment. We strongly recommend that you use a complex password to help ensure the security of your account.

4. Incident Notification: In the unfortunate event of a personal information security incident, we will promptly inform you of the basic situation and potential impact of the security incident, and the measures we have taken or will take to handle it.

5. Data Retention: We keep personal information only for as long as it is needed for the purposes described in this Policy:

4. Your Rights

Under applicable laws of your jurisdiction, you may have one or more of the rights to your personal information.

4.1 Access, Deletion, and Correction of Your Personal Information

a. Access and Correction: You can access and correct your personal information, nickname, gender, avatar, region, and birthday in your AlphaLuma account through the editing personal information option.

b. Opt-out of marketing communications: You can opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of a marketing email, or by contacting us.

c. Content Sharing and Deletion: You can share or delete the information you have published at any time.

d. Request Deletion: You can request us to delete your personal information in the following circumstances:

4.2 Withdraw Your Authorization

If you wish to withdraw your consent to our collection, use, and disclosure of your personal information, you can contact us using the contact information in this Policy. We will process your request within a reasonable time after receiving your email.

4.3 Account Deletion

You can ask us to delete your AlphaLuma account and the personal data associated with it at any time, whether you use the iOS or the Android app. Step-by-step instructions, the list of data that is deleted, and the data we keep (and for how long) are on our account deletion page. Once deletion is complete, we will stop providing products or services to you and delete or de-identify your personal information in accordance with applicable laws. Deleting your account does not cancel an App Store or Google Play subscription; cancel it in the store.

4.4 Response to Your Rights Requests

To ensure security, when you make the above rights claims, you may need to provide a written request or prove your identity in other ways. We will process your request after verifying your identity. Generally, we will respond within 15 days.

5. How We Handle Minors' Personal Information

1. Protection of Minors: Our Services are intended for a general audience and are not directed toward children under 13 years of age. If we learn that we collected data through our Services from a child under 13 without the consent of the child's parent or guardian as required by law, we will delete it.

2. Termination of Services: If your guardian does not agree with your use of our services or the provision of personal information to us in accordance with this Policy, please immediately stop using our services and notify us promptly.

3. Contact Us: If you have any questions about the use of our products/services by minors under your guardianship or their provision of user information to us, please contact us promptly.

6. How Your Personal Information is Transferred Globally

As described in Section 1.10, our servers and those of our service providers may be located in countries other than where you live, including the United States. Your data may therefore be processed or stored in countries outside of where you live, which may have data protection laws that are different from those in your country. When we transfer data across borders, we take measures to comply with the relevant data protection laws governing the transfer.

7. Applicable Law and Jurisdiction

If any provision of this agreement is invalid due to conflict with applicable laws, these terms will be interpreted as closely as possible to the original purpose of this agreement, and other provisions of this agreement shall still have full effect. If you have a dispute with us, both parties should try their best to resolve it through friendly negotiation. If the negotiation fails, you agree to submit the dispute to the court with jurisdiction in the defendant's domicile.

8. How This Policy is Updated

Our Privacy Policy may be amended in due course based on business adjustments, legal or policy changes. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any changes to this Policy on a dedicated page. For significant changes, we will notify you through pop-up windows, push notifications, or other means within the product or service.

9. To California Residents

Under the applicable California Consumer Privacy Act ("CCPA"), you have certain rights with respect to your personal information collected by us for business purposes. Your rights include:

  1. The right to know about the personal information a business collects about you, how it is used and shared
  2. The right to delete the information collected from you
  3. The right to opt-out of the sale or sharing of your personal information (we do not sell your personal information or share it for cross-context behavioral advertising)
  4. The right to non-discrimination for exercising your CCPA rights

10. To EU Users

Under the applicable General Data Protection Regulation ("GDPR"), you have certain rights with respect to your personal information. Your rights include:

  1. The right to obtain certain information about our processing
  2. The right to receive a copy of any personal data which we process about you, in a commonly used and machine-readable format
  3. The right to delete
  4. The right to restrict data processing of your personal data
  5. The right to object to the processing of your personal data
  6. The right to withdraw your consent you have granted to us
  7. The right to raise a complaint with the relevant data protection authority
  8. The right not to be subject to automated decision-making in relation to your personal data
  9. The right to be notified in the event of a personal data breach

11. Our Contact Information

If you have any questions, opinions, suggestions, or complaints about the content of this Policy, please send an email to the Personal Information Protection Officer at sonyalphainfo@126.com.

The services and software are provided 'AS-IS.' To the maximum extent permitted by law, we disclaim all warranties, express or implied, including the implied warranties of non-infringement, merchantability, and fitness for a particular purpose.