Privacy Policy

Last updated: April 23, 2026

Lumina Platform US, Inc., a Delaware corporation with its principal place of business at 800 North State Street, Suite 304, Dover, Delaware 19901, United States and its UK subsidiary Lumina Video Ltd, trading as ‘Kyoso’, a company incorporated and registered in England and Wales (together “Kyoso”, “we”, “us” or “our”) operate the Kyoso business. At its core, our business involves the development, promotion and licensing of a generative AI platform known as ‘Kyoso’ (our “Platform”), which may be used to create audio-visual materials (including advertising or promotional content) based upon user inputs or prompts. This Privacy Policy describes how Kyoso processes personal information that we collect through our digital and online properties or services that link to this Privacy Policy, as well as our marketing activities, live events, and other activities described in this Privacy Policy (collectively, the “Service”).

This Privacy Policy does not apply to:

Information that we process on behalf of our business customers while providing services to them. Our use of information that we process on behalf of our business customers is governed by our agreements with such customers. If you have concerns regarding your personal information that we process on behalf of our business customer, please direct your concerns to the business customer with which you have a relationship.
Information we process about our employees or independent contractors or job candidates.

NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section below for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly).

Personal information we collect
How we use your personal information
How we share your personal information
Your choices
Other sites and services
Security
International data transfer
Children and teens
Notice to European users

Personal information we collect

Information you provide to us. Personal information you may provide to us includes:

Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
Demographic data, such as your city, state, country of residence, postal code, gender, and age.
Profile data, such as account name, the username and password that you may set to establish an online account on the Service, and any other information that you add to your account profile.
User-generated content, such as photos, images, videos, and other content or information that you generate, transmit (including through inputs, prompts and connected data sources), or otherwise make available on the Service, as well as associated metadata (e.g., how, when, where and by what/whom a piece of content was collected and how that content has been formatted or edited). This may include any personal information you include in Workflow templates that you create within our Platform.
Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
Payment data needed to complete transactions, including payment card information or bank account number. We use a third-party vendor to directly collect and process your payment card information, as described further below.
Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via email, phone, chat features, social media, or otherwise.
Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Data about you we get from our users. We may receive personal information about you from our users (e.g., we might get the name, image, or likeness of a model or actor depicted in photos, images, videos, and other content or information users transmit (including through inputs, prompts and connected data sources) to the Service).

Third-party sources. We may combine personal information we receive from you with personal information of the kinds identified above that we obtain from other sources, such as:

Our users, we may obtain your Data about others from our users (please see above).
Private sources, such as data providers (e.g., data licensors/brokers, lead generators and cooperative databases), social media platforms (e.g., where you choose to log-in to the Service through a social media platform) and data licensors.
Service providers that provide services on our behalf or help us operate the Service or our business.
Marketing Partners, such as joint marketing partners and ad networks.

Automatic data collection. We, our service providers, and our advertising partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.
Location data, which will be approximate (for example, as inferred from network data or device settings).
Communication interaction data such as your interactions with our email, text, chat or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails enabling us to detect if you have opened or forwarded a message.
Online activity data, such as pages or screens you viewed, search history, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.

How we use your personal information

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

provide and operate the Service (including to process your orders and transactions);
establish and maintain your user profile on the Service;
enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
provide support for the Service, and respond to your requests, questions and feedback.

Service personalization. We may use your personal information to personalize the Service for you, which may include using your personal information to:

personalize your experience with the Service and our Service-related communications; and
remember your selections and preferences as you navigate the Service.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business, develop new products and services, and train our AI/ML models (where permitted).

Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section.

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.

Compliance and protection. We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, court orders, investigations or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Data sharing in the context of corporate events. We may share certain personal information in the context of actual or prospective corporate events – for more information, see the ‘How we share your personal information’ section.

Further uses. In some cases, we may specifically ask for your consent to collect, use or share your personal information for further purposes not set out above, such as when required by law (e.g., if the law requires this where those further purposes are not compatible with the initial purpose for which that personal information was collected).

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates. In some cases, our corporate parent, subsidiaries, and affiliates might have access to personal information.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, internet service providers, information technology, order fulfillment, customer support, online chat functionality providers, email delivery, marketing, consumer research and website/data analytics).

Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, available at https://stripe.com/gb/privacy.

Artificial intelligence platforms. We use third-party artificial intelligence (AI) providers to power certain aspects of the Services, such as those listed in our Sub-Processor Page. To learn more about how those providers process your information, please refer to their privacy policies.

Advertising partners / ad networks. Third-party advertising companies for the interest-based advertising purposes described above. This may include certain ‘social networks’ where we use their ad services to display ads to our customers, or other people like them, on social media.

Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties in litigation, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.

Corporate transactions. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Kyoso, financing of Kyoso, public stock offerings, the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization). For example, we may need to share certain personal information with prospective counterparties and their advisers. We may disclose your personal information to an acquirer, successor, or assignee of Kyoso or a portion of our business assets as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Other users and the public. Your user-generated content (including your Workflow Templates) may be visible to other users of the Service and the public. For example, other users of the Service may have access to your information if you choose to make your personal information available to them through the Service when you share your user-generated content (including Workflow Template(s)), or share other content that contains your personal information. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information. Once you publish content, it may be copied and stored on third party systems where you might not have the ability to have it deleted.

Your choices

In this section, we describe the choices available to all users. Users who are located in Europe can find additional information about their rights below in the ‘Notice to European Users’.

Access or update your information. You may have the right to access and update personal information we hold about you.

Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. It may take time for your opt-out to be effective. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails. You may opt-out of text messages by texting “STOP” in response to a text that you receive or by other reasonable means.

Cookies. For information about cookies employed by the Service and how to control them, see our Cookie Policy.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Retention period for personal information. We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the length of time we have an ongoing relationship with you and provide services to you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise. When we no longer require the personal information we have collected about you, we may either delete it or de-identify it.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security

We employ technical, organizational and physical safeguards that are designed to protect the personal information we collect. However, security risk is inherent in all Internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the U.S., but our subsidiary located in the UK, and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country. Users in Europe should read the information provided below about the transfer of personal information outside of Europe.

Children and teens

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a minor from whom you believe we have collected personal information, or if information was provided on your behalf when you were under 18, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. We reserve the right to modify this Privacy Policy at any time. We will notify you by updating the “Last Updated” date. Depending on the kind of change we make, we may also notify you directly or ask for your consent to the change. Any modifications to this Privacy Policy will be effective upon our posting the modified version or as otherwise indicated at the time of posting.

How to contact us

If you have questions about our practices or if you would like to exercise any privacy-related right that may be available to you depending upon applicable law, please contact us.

Email: privacy@kyoso.com
Website: https://kyoso.com

Notice to European users

General

Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

Controller. Kyoso is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)). See the ‘How to contact us’ section above for our contact details.

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from they are either directly identified or can be identified.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

Where we need to perform a contract we have entered into with you or are about to enter into with you (“Contractual Necessity”).
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each Purpose we use your personal information for is set out in the table below.
Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
Where we have your specific consent to carry out the processing for the Purpose in question (“Consent”).

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’.

Purpose	Categories of personal information involved	Legal basis
Service delivery and operations	Contact data Demographic data Profile data User-generated content Transactional data Payment data Data about you we get from our users Device data	Contractual Necessity. Legitimate Interests. We have a legitimate interest in ensuring the proper operation of our Service and the performance of our contracts with our users (including with respect to the processing of Data about you we get from our users), as well as the ongoing security of the Service, our business and associated IT services, systems and networks.
Service personalization	Demographic data Profile data Device data User-generated content Online activity data	Legitimate Interests. We have a legitimate interest in providing you with a good service via the Service, which is personalized to you and that remembers your selections and preferences. Consent, in respect of any optional processing relevant to personalization (including processing directly associated with any optional cookies used for this purpose).
Research and development	Any and all data types relevant in the circumstances	Legitimate Interests. We have legitimate interest in understanding what may be of interest to our users, and understanding how our users use our Service. Consent, in respect of any optional cookies used for this purpose.
Direct marketing	Contact data Demographic data Profile data User-generated content Communications data Transactional data Marketing data Communication interaction data	Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organization and sending marketing communications for that purpose. Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications.
Service improvement and analytics	Demographic data Communications data Profile data User-generated content Data about others Device data Online activity data Communication interaction data	Legitimate Interests. We have a legitimate interest in providing you with a good service and analysing how you use it so that we can improve it over time, as well as developing and growing our business. Consent, in respect of any optional cookies used for this purpose.
Compliance and protection	Any and all data types relevant in the circumstances	Compliance with Law. Legitimate Interests. Where Compliance with Law is not applicable, we have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We may also have a legitimate interest in ensuring the protection, maintenance, and enforcement of our rights, property, and/or safety.
To create aggregated, de-identified and/or anonymized data	Any and all data types relevant in the circumstances	Legitimate Interests. We have legitimate interest in taking steps to preserve our users’ privacy as we research how they use our Service.
Data sharing in the context of corporate events	Any and all data types relevant in the circumstances	Legitimate Interests. We have a legitimate interest in pursuing and consummating actual or prospective corporate events and providing information to relevant third parties who are involved in an actual or prospective corporate event (including to enable them to investigate – and, where relevant, to continue to operate – all or relevant part(s) of our operations).
Further uses	Any and all data types relevant in the circumstances	The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Other info

No obligation to provide personal information. You do not have to provide personal information to us. However, where we need to process your personal information either to comply with applicable law or to deliver our Service to you, and you fail to provide that personal information when requested, we may not be able to provide some or all of our Service to you. Where required to do so by law, we will notify you if this is the case at the time.

No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, information related to sex life or sexual orientation, trade union membership, or information pertaining to criminal convictions) on or through the services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

No automated decision-making and profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.

Your rights

General. European data protection laws may give you certain rights regarding your personal information in certain circumstances. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

Access. Provide you with information about our processing of your personal information and give you access to your personal information.
Correct. Update or correct inaccuracies in your personal information.
Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
Transfer. Transfer to you or a third party of your choice a machine-readable copy of your personal information you have provided to us that we process based on Consent or Contractual Necessity.
Restrict. Restrict the processing of your personal information, for example if you want us to establish its accuracy or the reason for processing it.
Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we process your personal information for direct marketing purposes.
Withdraw consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising these rights. You may submit these requests by email to privacy@kyoso.com. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month of receipt. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.

Your right to lodge a complaint with your supervisory authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en
For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/

Data processing outside Europe

We are a U.S.-headquartered business and many of our service providers, advisers, partners or other recipients of data are also based in the U.S. This means that, if you use the Service, your personal information will be accessed and processed in the U.S. It may also be provided to recipients in other countries outside Europe.

It is important to note that that the US is not the subject of an ‘adequacy decision’ under the GDPR – basically, this means that the U.S. legal regime is not considered by relevant European bodies to provide an adequate level of protection for personal information, which is equivalent to that provided by relevant European laws.

Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it by making sure one of the following mechanisms is implemented:

Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time) or under specific adequacy frameworks approved by the European Commission or UK Government (as and where applicable) (from time to time), such as the EU-U.S. Data Privacy Framework or the UK Extension thereto.
Transfers to territories without an adequacy decision. We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection (e.g., the U.S., see above). However, in these cases:
- we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorise for this purpose; or
- in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.

You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. You may have the right to receive a copy of the appropriate safeguards under which your personal information is transferred by contacting us at privacy@kyoso.com.