Privacy Policy
Last updated: 22.10.2026
Lumen is operated by Bruo Systems Limited, 2c Grangegorman Lower, Smithfield, Dublin, Ireland (Reg. 765033) ("we"). We are the data controller for the personal data described in this policy, and we respect your privacy. This policy explains what we collect and why.
What we collect
- Your email address, for sign-in.
- Your name, if you add it on your profile page. It is optional and is shown on your invoices.
- Your credit balance and purchase history.
- When you buy credits: the cardholder name and billing address you enter at checkout. We pass them, with your card details, to our payment provider to process and verify the payment. We do not store your card number or security code.
- The prompts you submit, any reference images you upload, and the images you generate.
- What you send through the contact form: your name, email address and message.
- Your IP address and the country it indicates, when you sign up, sign in, pay, apply as a specialist or contact us, to check that the Service is available where you are and to prevent fraud and abuse.
- Your language and currency choices, kept in cookies on your device (see the Cookie Policy).
- Basic technical logs needed to run the Service.
Specialists and hires
If you apply as a specialist, or hire one, we also collect:
- Your application answers: first name, headline, bio, portfolio link (optional), minimum price, the services (skills) you picked, your quiz answers and score, your country of residence, the time you accepted the Specialist Agreement and confirmed you do not live in or work from a sanctioned country, and the fact that the age check passed. Your date of birth is checked when you apply and is not stored.
- Your public profile, once approved: first name, headline, bio, services and prices. Anyone who visits the catalogue can see it.
- Your payout card: the cardholder name and the card number (never the expiry date or security code). The card number is stored encrypted and used only to pay you your earnings; you and the Lumen team see it only as its last 4 digits, and the full number is opened only by the Lumen team when making a payout, with every such access recorded.
- Hire records, thread messages and the files attached to them. Only the two parties to the hire and the Lumen team can see them.
- The emails we send you about your application, your hires and your payouts.
We use this data to review applications, list approved specialists, run hires (holding and releasing credits, delivery, changes and disputes), pay specialists their earnings and keep the records accounting law requires. We process it to perform our contract with you (the Terms of Service (/legal/terms) or the Specialist Agreement (/specialist-agreement)) and to meet our legal obligations.
How we use it
We use this data to authenticate you, provide the Service, process credit purchases, and prevent abuse. We do not sell your data.
Legal basis
We process your data to perform our contract with you and on the basis of our legitimate interest in operating the Service securely, in line with EU data protection law (GDPR).
Third parties
We use an image-generation provider to render your images, which receives your prompts and any reference images you upload, and a payment provider to process purchases. They process only the data needed for those tasks. Our team receives notices of sign-ups, sign-ins, purchases and contact-form messages through a third-party messaging service; a notice can include your name, email address, IP address and country, and the text of your message.
Your rights
You can access, correct, export, or delete your personal data. From Settings you can download a machine-readable copy of your account data at any time (Export your data), or permanently delete your account, which removes your data. For any request Settings doesn't cover, email us at studio@lumen.deals.
Retention
We keep each kind of data only as long as it is needed:
- Account and sign-in data (your email address, sessions, one-time codes): while your account is active. One-time sign-in codes expire within minutes of being issued.
- Prompts, conversations and generated images: while your account is active, so you can find your work again.
- Credit ledger, orders and invoices: while your account is active, for the same reason.
- Technical logs: for a short operational period, then discarded.
- Payout card: until you remove it on your specialist desk or close your account.
- Specialist application and profile: while your account exists. When you delete your account, your application is deleted and your profile is anonymised and no longer listed.
- Hire and payout records from specialist work (service, price in credits, status and dates): as long as accounting law requires. After you delete your account they are no longer linked to it.
When you delete your account from Settings, all of the above, including your credit ledger, order and invoice history, is permanently removed with it, with two exceptions: the hire and payout records from specialist work that accounting law requires us to keep, and, if you were a specialist, your anonymised profile that those records refer to (no name, headline, bio, country or payout details, and no longer listed). Neither is linked to your account any more, and nothing else is kept in a separate archive after deletion.
Where your data is stored
The Service, its database and its file storage run on infrastructure located in the United States. The providers that generate your images and deliver our emails also process data in the United States.
International transfers
We are established in Ireland, and your data is stored and processed in the United States, so using the Service involves transferring personal data outside the European Economic Area. We make these transfers only under a safeguard recognised by the GDPR:
- where the recipient is certified under the EU-U.S. Data Privacy Framework, the European Commission's adequacy decision for that framework (Article 45 GDPR);
- otherwise, the Standard Contractual Clauses adopted by the European Commission (Article 46(2)(c) GDPR), included in our data processing agreement with that provider.
You can ask for a copy of the safeguards that apply to your data by emailing studio@lumen.deals.
Contact
Email studio@lumen.deals for any privacy request, or write to Bruo Systems Limited, 2c Grangegorman Lower, Smithfield, Dublin, Ireland.