DRAFT for internal review. Highlighted items are placeholders or depend on firmware and backend fixes (FIX-xx). Remove before publishing.
LuminaOS · Legal English 中文

Data Retention and Data Requests

Version 2026-11 · 2026-11-20 · Applies to all services in the Lumina Privacy Policy

This page lists how long each Lumina service keeps data, and how we handle requests to access, export, share or delete data under the GDPR and the EU Data Act.

1. Retention schedule

At the end of each period, data is deleted automatically or irreversibly anonymised. Backups are overwritten within 35 days after that. FIX-12

ServiceDataRetentionReason
Software updatesUpdate check records (hashed serial number, installation ID, version, result, time, IP)90 daysTroubleshooting failed updates
Latest record per device (serial number, model, firmware version)Support period + 12 monthsTargeting security updates, warranty
Activation / DRMChip ID, serial number, certificate request, first-connection dateSupport period + 12 monthsWarranty, DRM, counterfeit prevention
App StoreRequest logs90 daysOperation and security
Install records (package, version, size, installation ID)24 months, then aggregated counts onlyDownload statistics, app compatibility
DiagnosticsDiagnostic report file30 days after upload, or earlier on request with the ticket numberInvestigating the reported problem
Ticket: description, contact details, analysis notes, without the report12 months after the ticket is closedFollow-up questions, quality statistics
LuminaHomeDevice configuration record (installation ID, partner, model, country, last seen)13 months after last useDelivering the correct home screen layout
Usage statistics and crash reports (Firebase, only with consent)14 monthsProduct improvement
Error counters (no identifiers)30 daysAutomatic fallback when a configuration fails
LuminaAuraWeather requests (only with consent)Not stored; in-memory cache 30 minutes—
LuminaVoiceAudio and recognised textNot stored after the reply—
Usage counters (installation ID, feature, duration)13 monthsCapacity and cost planning
Lumina GoApp statistics90 daysConnection quality
AI assistant answer ratings30 daysImproving answers
Cloud link records (installation ID, tokens, linked assistant account ID, last state)Deleted at once when unlinked or switched off (backups within 35 days); tokens expire after 30 days without useProviding the voice-assistant link
All servicesWeb server and security logs (IP, time, request, result)30 days (security incidents: until resolved, max. 12 months)Operation and protection against misuse
SupportEmail correspondence24 months after the last messageHandling follow-up requests and legal claims
ConsentConsent receipts (installation ID, purpose, policy version, time, screen)3 years after the consent endsProof of consent (GDPR Art. 7(1))
RequestsRecord of privacy and data requests and our answer3 yearsProof of compliance

The support period is stated in the EU Data Act Information.

2. How to make a request

  1. On the projector (fastest): Settings › Privacy offers Export my data and Delete server data. Requests made there are signed with the projector's own key, so no further proof is needed. In Lumina Go: Settings › Privacy › Delete account and data. FIX-12
  2. By email to privacy@luminago.app. Include:
    • the installation ID (Settings › Privacy) or the serial number (Settings › About); for Lumina Go, the projector ID shown in the app;
    • what you want: access, export, deletion, correction, restriction, objection, or sharing with a third party (name and contact of the recipient);
    • proof of purchase or a photo of the label on the projector, so we can check that the device is yours.

You can also authorise someone to make the request for you.

3. How we handle requests

StepWhat we doTime
AcknowledgementConfirm receipt and request missing informationWithin 3 business days
VerificationMatch the serial number with the proof of purchase or device label. We ask only for what we need to verify you.—
SearchOur identity service keeps a register of which services hold records for an installation ID or hashed serial number. It forwards the request to every service listed (updates, store, diagnostics, voice, relay, statistics, activation) and collects the answers. FIX-12—
AnswerAccess/export: a ZIP with one JSON file per service and a summary, available on the projector as a QR code and one-time link valid 7 days, or by email. Deletion: confirmation and a list of what was deleted and what we must keep, with the reason. Sharing: transfer to the recipient in JSON.Within 30 days. Up to 2 more months for complex requests, in which case we tell you why within the first month.

Requests are free. We may refuse or charge a reasonable fee only for manifestly unfounded or excessive requests, and we will explain why.

4. What deletion means

5. Complaints

If you are not satisfied with our answer, you can complain to your data protection authority or, for Data Act matters, to the competent authority listed in the EU Data Act Information.