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CONNECTION STARTS WITH TRUST

Your information. Clear choices.

This Privacy Policy explains how Cullinan Global Innovations handles personal information when you visit LumaPair or use a member account. It describes the current web service.

Updated September 15, 2026 · Cullinan Global Innovations

Share at your own pace. Publishing a profile makes the details you choose visible to eligible signed-in members. Chat is not end-to-end encrypted. A report can include recent messages if the reporting member chooses to share them.

We do not sell personal information or use private messages for advertising or monetization analytics.

On this page

  1. Your optional connection and AI choices
  2. 1. Who handles your information
  3. 2. Information we handle
  4. 3. Why we use information
  5. 4. Sensitive details and member visibility
  6. 5. Messages, calls, and reports
  7. 6. Verification information
  8. 7. Service providers and other disclosures
  9. 8. Cookies and browser storage
  10. Optional advertisements on public guides
  11. 9. Retention and deletion
  12. 10. Your choices and privacy requests
  13. 11. Adults only and security
  14. 12. Policy updates

Your optional connection and AI choices

Connection settings can store your introduction choice, values-scenario answers, available time windows, date budget, setting or accessibility preferences, translation language, and AI permissions. These are your declared choices. We do not infer sensitive traits from photos or messages. Introductions consider both members’ preferences; a conversation opens after mutual likes.

Eligible introductions may show shared approaches and whether your times overlap. Existing matches can see shared available windows and combined date preferences, not your full schedule. You can remove these choices in My profile → Connection settings. Introduction and skip records expire after 30 days. Expired availability is no longer used.

Optional introduction selection and conversation ideas send shared profile interests and selected common answers to Cloudflare Workers AI when both members opt in. Private profile coaching sends only your own bio, prompt and interests when you request it. On-demand translation requires both matched members to enable it; only the selected message and requested language are sent. The original message is unchanged. LumaPair does not store generated translations, coaching tips or conversation suggestions, or use messages for advertising. AI output can be inaccurate; review it before relying on or sending it. Turning off a feature stops future processing; it cannot recall content already seen or a request already processed.

1. Who handles your information

Cullinan Global Innovations operates LumaPair and is responsible for the personal information described here. Use Contact & requests to ask about your information or exercise privacy rights. Service providers process information needed to support the functions described below.

2. Information we handle

  • Account and sign-in: account identifiers, email address, sign-in provider information, account status, and authentication/session information. If you choose Google or Apple, we receive the information supplied by that provider for sign-in, such as your name and email. We do not receive your Google or Apple password.
  • Profile and preferences: name, date of birth, gender, city, biography, relationship intentions, interests, optional marital status, philosophies and lifestyle details, social handles, and discovery preferences such as age range, distance, or interests.
  • Location: your chosen city and location you choose to provide for nearby discovery. With permission, the browser supplies location coordinates, which the service uses in an approximate form for discovery. Member profiles show approximate location or distance, not your exact coordinates. For date ideas, a separate prompt after sign-in lets you share an approximate browser location or skip. Coordinates are rounded before upload, and only the latest shared area is retained for seven days. We do not continuously track movement. Your consent, update time and general accuracy are recorded. Authorized admins can review the shared area and latest date-search travel estimates; that access is logged. Manage location in Discovery settings to update it or stop sharing and remove the area and associated travel records.
  • Photos: images you upload and their account/storage references. The app resizes and crops images and removes image metadata during processing. Still photos are supported; profile video uploads are not.
  • Connections: likes, matches, message text, reactions, shared prompt answers, date plans, blocking choices, and reports. Call setup uses connection information and call status/timing records.
  • Safety and support: report descriptions, message context a reporter elects to include, moderation reasons, administrator access/action records, restriction records, and information you provide when asking for help.
  • Online status: while LumaPair is open, we record recent app activity, general browser/device type and an approximate connection city, region and country supplied by our hosting provider. Authorized administrators can review this for support and safety; access is logged. Network location can be inaccurate and is not GPS tracking. Only the latest activity per browser tab is kept, for up to seven days. Other members who can view your profile may see an online indicator; turn off “Show when I’m online” in Discovery settings to hide it. This does not hide activity from authorized administrators.
  • Technical information: IP address and request/network information handled by our hosting and sign-in services, device/browser information used for service delivery, session identifiers, and security or rate-limit records.

3. Why we use information

We use information to create and secure accounts, provide profiles and discovery, support mutual matching and conversations, deliver calls and shared activities, manage member choices, respond to requests, investigate abuse, enforce rules, and comply with legal obligations.

Discovery uses your preferences and profile information to filter or suggest members. It is not a background investigation, and does not establish relationship compatibility. Operational analysis uses aggregate counts, such as members, matches, or reports; private message content is excluded from monetization analytics.

Where laws require a legal basis, ordinary account and communication processing is used to provide the service you request; proportionate security and abuse prevention serve our legitimate interests; legal compliance rests on applicable obligations; and optional uses requiring consent depend on that consent. You may object to processing based on legitimate interests or withdraw consent as applicable. Withdrawing consent does not invalidate earlier lawful processing.

4. Sensitive details and member visibility

Philosophical or religious beliefs, relationship preferences, and details revealing sexual orientation can be sensitive personal information. Optional fields can be left blank or removed. Do not include details you are uncomfortable sharing with other members. Where explicit consent is legally required for sensitive processing, it must be obtained separately; simply reading this policy is not that consent.

A saved profile is not made discoverable until you choose to publish it. A discoverable profile shares the selected profile details and photos with eligible signed-in members. Other members see your age rather than your full date of birth. Your account email and verification number are not shown in profile badges. Social handles are shared only when you enable their sharing.

Messages and shared activities are visible to the participants. Members can copy, screenshot, or disclose information outside the service; we cannot guarantee they will keep it confidential. Pausing discovery limits future discovery exposure, but is not account deletion and does not erase existing conversations or copies.

5. Messages, calls, and reports

Messages are stored to provide your conversation history and are not end-to-end encrypted. Authorized operational access may be necessary to maintain or secure the service, meet legal obligations, or address a support or safety issue.

The administrator interface shows message excerpts submitted with reports, rather than providing unrestricted inbox browsing. When filing a conversation report, the reporter can choose whether to include up to 20 recent messages. Such a report may contain messages from either participant. Access to reported context is recorded in an audit log.

Audio/video calls use WebRTC and may use Cloudflare relay infrastructure. You control browser microphone and camera permissions. LumaPair has no built-in call-recording feature. Connection metadata, such as IP/network information and call timing or status, is processed to establish and support a call. Direct peer connections can disclose a participant’s IP address to the other endpoint. Participants could record using tools outside LumaPair; obtain consent before recording.

6. Verification information

At this policy’s publication, optional SMS verification has been prepared but is not activated. Government-ID and live-selfie checks are not connected. Do not send identity documents, verification codes, or sensitive identifiers by email or chat.

If phone verification is made available, its screen will explain the active method before you choose it. The number is sent to the verification provider to deliver and check a code. LumaPair’s phone-verification design stores a protected number fingerprint, last four digits, verification status, and limited challenge/abuse-prevention records rather than displaying your full number to members. A materially different verification service or biometric/ID process requires updated notice before collection.

Member badges show only which checks have actually completed. They do not show the underlying document or phone number and do not indicate a criminal background screening.

7. Service providers and other disclosures

We use Clerk for authentication and account management, and Cloudflare for hosting, database and photo storage, live connections, security, and call relay infrastructure. Providers receive information needed for those functions. A Google or Apple account is involved if you choose that sign-in method. An external social website receives information when you choose to follow a link to it.

When both matched members have chosen to share location, Geoapify receives their rounded starting areas and public venue locations to calculate nearby suggestions and driving estimates. Your match sees approximate distances and estimated drive times for both people, but not your starting coordinates. Estimates use approximate locations and modeled traffic, not live traffic. Public place results are cached for up to 24 hours without member identifiers. A private route cache lasts up to one hour; only the latest date-search estimates per match are retained for up to 24 hours for administrator review. Location withdrawal clears these associated records. If you select the optional AI helper when available, Cloudflare Workers AI receives only shared interest tags, reviewed activity choices, venue categories and approximate distances and drive times for both members. We do not send names, private chats, profile biographies, philosophies or exact location to that AI helper. You can search without AI. Opening a map link takes you to an external map provider under its own privacy policy.

We may disclose relevant information when legally required, to respond to valid legal process, or where law permits and it is necessary to address fraud, abuse, or threats to safety. If the business is reorganized or transferred, relevant information may transfer with the service, subject to applicable safeguards and notice requirements.

If you subscribe to promotional or product-update emails, our email provider Resend receives your email address, first name, and the message to deliver. We record your subscription choices, delivery results, and unsubscribe requests. You can opt out in your profile or through an email unsubscribe link. We do not automatically subscribe existing members. We also offer optional in-app promotions that can be dismissed or disabled in your profile. When you select an offer button while signed in, we record that interaction and may associate a subsequent Plus purchase within 30 days with the offer for campaign reporting. These campaign emails do not include tracking pixels. Delivery details are removed after 90 days; minimal hashed suppression records remain to honor unsubscribes and delivery restrictions. Member deletion removes linked campaign preferences and activity.

Providers may process information in countries other than your own. Where required, international transfers must use an applicable legal safeguard, such as approved contractual terms. Contact us for information about arrangements relevant to your request. We do not claim that all information stays in your home country or that a particular international-transfer certification applies to us.

When web subscriptions are enabled, Stripe processes your payment details and billing contact information. LumaPair stores a random billing reference, provider customer/subscription identifiers, payment status and access dates, but does not store card or bank account numbers. These minimal billing records can remain after profile deletion to support cancellation, disputes and required accounting. Daily like counters are retained for up to seven days. We do not sell personal information or share it for cross-context behavioral advertising.

8. Cookies and browser storage

Sign-in and security services use cookies or similar storage to maintain sessions and prevent abuse. LumaPair also stores a device-level preference to avoid repeatedly showing a dismissed verification reminder. This preference is separate from your account’s verification status.

We do not use third-party behavioral analytics in the member workspace. The public dating guides have a separate optional advertising integration, described below. Advertising is off until the provider approves the site and setup is completed.

You can clear cookies and site storage through your browser, which may sign you out or reset local preferences. Browser settings also control location, camera, and microphone permissions. Blocking necessary sign-in storage can prevent account features from working.

Optional advertisements on public guides

When enabled, public guide articles may show a clearly labeled Google AdSense advertisement. These placements are separate from profiles, matching, messages, calls, sign-in and account settings. We do not send Google member identifiers, private messages, profile details, relationship preferences or member location data to select advertisements.

Optional ads are off by default. If you choose Allow ads, the Google consent service can load to collect applicable privacy choices. After those choices permit it, Google may process your IP address, public page information, browser/device data and cookies or similar storage to deliver and measure advertisements, prevent fraud and limit repeated ads. We request non-personalized advertisements and restricted data processing. Non-personalized does not mean that no information or storage is used.

Use Turn ads off on a guide to stop advertising on this browser, or Privacy choices to review the provider’s consent settings. A Global Privacy Control signal keeps these placements off. Your on/off choice is saved locally under lumapair-guide-ads-v1; it is not linked to your member account. You can read the guides and use member features without allowing ads. Google describes its processing at How Google uses information from sites that use its services.

9. Retention and deletion

We retain account, profile, photo, and conversation information while needed to provide your account and requested features. We retain reports, support correspondence, security records, and audit information for as long as reasonably needed for their purpose, applicable legal obligations, fraud prevention, or resolving a dispute. We assess the type of information, the reason for keeping it, and legal requirements rather than promising one deletion period for every record.

Contact-form requests are stored for administrative handling and are scheduled for removal 180 days after being marked resolved. A request kept under review for an ongoing matter is retained while needed. Minimal access/action audit records are separate from the request’s text and reply email.

Account deletion removes the account, associated profile/photo records, and associated conversations from active service storage through our deletion process. Safety-report copies, audit records, or limited restriction records may remain where retention is necessary and lawful. Provider recovery copies or backups may persist for their applicable lifecycle; deletion is not a promise of instantaneous removal from every backup. Copies independently retained by another member remain outside our control.

Expired call-setup signals and verification challenges are cleaned up periodically. Call-status records are scheduled for removal after their expiry and a 30-day cleanup window. Deletion failures are queued for retry rather than being treated as a completed deletion.

10. Your choices and privacy requests

You can edit profile details, remove photos, pause discovery, adjust optional sharing and permissions, block or report a member, and use Export my data in your signed-in workspace.

Depending on your location and which laws apply, you may have rights to access, correct, delete, or receive a copy of personal information; withdraw consent; object to or restrict processing; limit certain uses of sensitive information; or appeal a decision about a request. Where applicable, you may use an authorized agent and complain to your privacy regulator. We will not unlawfully discriminate against you for exercising these rights.

Use Contact & requests to request help or account deletion. We may need proportionate information to verify account ownership, protect others’ information, or establish an agent’s authority. We respond within the periods required by applicable law and explain any lawful reason a request cannot be fully fulfilled. Do not send an ID document or password as an initial request.

Because we do not currently sell personal information or share it for cross-context behavioral advertising, there is no such sale or sharing to opt out of. If that practice changes, we must first provide legally required notices and choices, including handling applicable opt-out preference signals.

11. Adults only and security

LumaPair is for adults 18 and older. We do not knowingly permit minors to hold accounts. Report a suspected underage account through the member’s reporting controls or contact us so it can be reviewed and appropriate removal taken.

We use access controls, private media storage, session security, and administrative safeguards to protect information. No service can promise absolute security. Protect your account and devices and tell us about suspected unauthorized access.

12. Policy updates

We will update the date on this page when practices change. Material changes will receive additional notice and fresh consent where required before new processing begins. Contact Cullinan Global Innovations with questions about this policy.

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