Privacy Policy

Last Updated: October 13, 2025

1. Introduction

Lumay ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our digital legacy and will creation platform (the "Service"). Please read this policy carefully.

2. Information We Collect

2.1 Information You Provide

We collect information that you voluntarily provide when using our Service:

  • Account Information: Name, email address, password, profile photo
  • Personal Information for Will Creation: Full legal name, date of birth, address, marital status, SSN (last 4 digits)
  • Executor and Beneficiary Information: Names, relationships, contact information for individuals you designate
  • Digital Asset Information: Platform names, account identifiers, access instructions, estimated values
  • Special Instructions: Funeral wishes, personal messages, burial preferences
  • Memory Content: Text, photos, videos, audio recordings, and other content you create or upload
  • Payment Information: Billing address, payment method details (processed securely by third-party payment processors)
  • Communications: Messages you send to us, including support requests and feedback

2.2 Information Collected Automatically

  • Usage Data: Pages viewed, features used, time spent on the Service, search queries
  • Device Information: IP address, browser type, operating system, device type
  • Cookies and Similar Technologies: We use cookies, web beacons, and similar technologies to enhance your experience
  • Location Data: General location based on IP address

2.3 Information from Third Parties

  • Authentication Providers: Information from Clerk for authentication services
  • AI Services: We process your content through OpenAI's services for AI-powered features
  • Payment Processors: Payment information processed through Stripe

3. How We Use Your Information

We use the information we collect to:

  • Provide, maintain, and improve the Service
  • Create, store, and manage your digital will and estate planning documents
  • Process your transactions and manage your account
  • Provide AI-powered features such as memory capture and conversation analysis
  • Send you important notifications about your account, service updates, and security alerts
  • Respond to your comments, questions, and support requests
  • Analyze usage patterns to improve user experience
  • Detect, prevent, and address technical issues and security threats
  • Comply with legal obligations and enforce our Terms of Service
  • Send marketing communications (with your consent, where required)

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf:

  • Clerk: Authentication and user management
  • OpenAI: AI-powered features (conversation analysis, memory extraction)
  • Stripe: Payment processing
  • Cloud Storage Providers: Secure data storage and backup
  • Email Service Providers: Transactional and marketing emails

These providers are contractually obligated to protect your information and use it only for the purposes we specify.

4.2 Legal Requirements

We may disclose your information if required by law, court order, or legal process, or to protect the rights, property, or safety of Lumay, our users, or others.

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

4.4 With Your Consent

We may share your information with third parties when you give us explicit consent to do so.

5. Data Security

We implement industry-standard security measures to protect your information, including:

  • Encryption of data in transit (TLS/SSL) and at rest
  • Secure authentication via Clerk with multi-factor authentication options
  • Regular security audits and vulnerability assessments
  • Access controls limiting employee access to personal information
  • Secure cloud infrastructure with redundancy and backup systems
  • Password hashing and secure credential storage

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

6. Data Retention

We retain your information for as long as necessary to provide the Service and fulfill the purposes described in this Privacy Policy. Specifically:

  • Account Information: Retained while your account is active and for a reasonable period after account closure
  • Will and Estate Documents: Retained indefinitely or until you request deletion, as these are critical legal documents
  • Memory Content: Retained based on your settings and family access permissions
  • Transaction Records: Retained for at least 7 years for legal and tax compliance
  • Usage Data: Aggregated and anonymized data may be retained indefinitely for analytics

7. Your Privacy Rights

Depending on your location, you may have the following rights:

7.1 All Users

  • Access: Request a copy of your personal information
  • Correction: Update or correct inaccurate information
  • Deletion: Request deletion of your information (subject to legal retention requirements)
  • Opt-Out: Unsubscribe from marketing communications
  • Export: Download your data in a portable format

7.2 California Residents (CCPA)

California residents have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information is collected, sold, or disclosed, and the right to opt-out of the sale of personal information (note: we do not sell personal information).

7.3 European Residents (GDPR)

If you are in the European Economic Area, you have rights under the General Data Protection Regulation (GDPR), including the right to data portability, the right to restrict processing, and the right to object to processing.

Exercising Your Rights

To exercise any of these rights, please contact us at privacy@leavesfromthevine.com. We will respond to your request within the timeframe required by applicable law.

8. Children's Privacy

Our Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately, and we will take steps to delete such information.

9. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. We ensure that such transfers comply with applicable laws and that your information receives adequate protection.

10. Cookies and Tracking Technologies

We use cookies and similar technologies to:

  • Keep you signed in
  • Remember your preferences
  • Analyze usage patterns
  • Improve site performance
  • Provide personalized content

You can control cookies through your browser settings, but disabling cookies may affect your ability to use certain features of the Service.

11. Third-Party Services and Links

Our Service integrates with and may contain links to third-party services:

  • Clerk: See Clerk's privacy policy at https://clerk.com/privacy
  • OpenAI: See OpenAI's privacy policy at https://openai.com/privacy
  • Stripe: See Stripe's privacy policy at https://stripe.com/privacy

These third parties have their own privacy policies, and we are not responsible for their practices. We encourage you to review their policies before providing them with information.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and updating the "Last Updated" date. We encourage you to review this policy periodically.

13. Do Not Track

Some browsers have a "Do Not Track" feature that lets you tell websites you do not want to have your online activities tracked. We currently do not respond to Do Not Track signals.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:

Email: privacy@leavesfromthevine.com

Data Protection Officer: dpo@heirloom.ai

Address: [Your Business Address]

For privacy-related requests, please include "Privacy Request" in your subject line and provide sufficient detail so we can properly address your inquiry.

Your Consent

By using our Service, you consent to the collection, use, and sharing of your information as described in this Privacy Policy. If you do not agree with this policy, please do not use the Service.