Privacy Policy
Last updated: June 28, 2026
Lumelle transforms your photos using artificial intelligence. Because those photos may contain your face, we take special care to protect your data. This policy explains, in plain terms, what we collect, why, who we share it with, and what your rights are.
1.Who is responsible for your data
The data controller is Arnaud Gheysen, publisher of the Lumelle application, [legal form — e.g., sole proprietorship], [postal address].
For any questions about your data: contact@lumelle.studio.
2.The data we process
Lumelle is designed for data minimization: you can use it with an anonymous account, without providing a name or an email address.
- Photos and images you upload or take in the app to transform them. They may contain your face (see Section 3).
- Generated images produced by the AI from your photos (“your creations”).
- Onboarding preferences: your answers to the personalization questions (desired style, goal, intended audience).
- Account: an anonymous technical identifier created automatically to link your creations to your device.
- Subscription: your subscriber status (active / trial / expired), managed through Apple and our billing provider. We never receive your credit card number.
- Technical and usage data: device identifier, technical logs, styles used, and aggregated usage statistics, to operate and improve the service.
3.Your face — sensitive data
When you transform a photo of a face, the image may constitute sensitive personal data (a special category under Article 9 of the GDPR). We use it only to produce the result you request — never to identify you, profile you, or train models.
This processing is based on your explicit consent, collected in the app through a dedicated screen before your first face photo upload. You can withdraw this consent at any time by deleting your account (see Section 9) or by writing to us.
4.Why we process this data (legal bases)
| Purpose | Legal basis (GDPR) |
|---|---|
| Transforming your photos with AI | Performance of the contract (Art. 6(1)(b)) and, for faces, explicit consent (Art. 9(2)(a)) |
| Managing your subscription and access | Performance of the contract (Art. 6(1)(b)) |
| Security, fraud and abuse prevention | Legitimate interest (Art. 6(1)(f)) |
| Improving the service and producing statistics | Legitimate interest (Art. 6(1)(f)), on minimized data |
| Complying with our legal obligations | Legal obligation (Art. 6(1)(c)) |
5.Who we share it with (categories of recipients)
We never sell your data. To operate, Lumelle relies on technical providers that act as processors, only on our instructions. We present them by category:
| Recipient category | Role | Location |
|---|---|---|
| Hosting & database | Service accounts and data | European Union |
| Media storage | Storing images | European Union |
| AI inference | Image generation | Outside the EU (United States) |
| Subscription management | Purchase validation | Outside the EU (United States) |
| Distribution & payment | App Store (Apple) | EU / United States |
Providing this information by category complies with the GDPR; the named list of our processors is available on request at contact@lumelle.studio.
6.Transfers outside the European Union
Some operations — in particular AI image generation and subscription management — are carried out by providers located in the United States. These transfers are protected by the safeguards provided for by the GDPR: the European Commission's standard contractual clauses and/or certification under the EU–U.S. Data Privacy Framework, depending on the provider.
7.How long we keep your data
- Source photos you upload: deleted shortly after processing (scheduled automatic deletion, within 24 to 72 hours).
- Your creations: kept for as long as your account exists, so you can find them again.
- Account and preferences: until your account is deleted.
- Technical logs: kept for a limited time, for security purposes.
8.Your rights
Under the GDPR, you have the rights of access, rectification, erasure, restriction, objection, and portability, as well as the right to withdraw your consent at any time (without affecting processing already carried out).
To exercise them, write to contact@lumelle.studio. You may also lodge a complaint with the CNIL (the French supervisory authority).
9.Deleting your account and your data
You can delete your account directly in the app: Profile → Delete my account. This action erases your account, your creations, and the associated files from our servers, and instructs our processors accordingly. Deletion is permanent.
10.Security
Your data is encrypted in transit, hosted with reputable providers, and accessible only to the processing needed to run the service. No system is infallible, so we encourage you to transform only photos you hold the rights to.
11.Children
Lumelle is not intended for children under 13. If you are a minor, use the app with the consent of your parents or legal guardian. We do not knowingly collect data from children under 13.
12.Content generated by artificial intelligence
Images produced by Lumelle are artificially generated. They carry a visible “AI” label, in line with our transparency obligations (the European AI regulation, or “AI Act”). We strive to preserve the provenance metadata provided by the models.
13.Changes to this policy
We may update this policy. If we make a significant change, we will inform you by an appropriate means in the app. The date of the latest update appears at the top of this page.
14.Contact us
Questions about your data? Write to us at contact@lumelle.studio.