Privacy Policy

Last updated: September 19, 2025

This Privacy Policy explains how OpenLume (“OpenLume,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards information in connection with our websites, applications, voice-based learning features, and related services (collectively, the “Service”). Your use of the Service is also subject to our Terms of Use.

1) Scope

This Policy applies to information we process when you access or use the Service, contact us, or otherwise interact with us. It does not cover third-party services that are not under our control.

2) Categories of Information We Collect

1. Account & Profile Data: name, email, password or SSO identifiers, role/skills, learning goals, plan selections.
2. Learning Content & Submissions: prompts, messages, voice/audio inputs and transcriptions, code/files you upload or generate, assessments, mock interview answers and feedback.
3. Usage & Device Data: IP address, device and browser type, OS, app version, language, time zone, pages/screens viewed, clicks, session duration, referrer/UTM data.
4. Payment Data: billing name, email, limited payment details processed by our payment processor (we do not store full card numbers).
5. Cookies & Similar Technologies: identifiers to operate the site, maintain sessions, and—where you consent—measure analytics.

3) Sources of Information

We collect information you provide directly, information collected automatically through your use of the Service, and information from third-party services you connect (e.g., Google Sign-In).

4) How We Use Information

1. Provide, operate, and secure the Service, including authentication and fraud prevention.
2. Personalize learning (plans, explanations, assessments, mock interviews, voice responses).
3. Communicate about accounts, updates, security alerts, and support.
4. Research and improve features and performance, including model quality and UX.
5. Comply with law and enforce our Terms of Use.

5) AI & Voice Processing

To power AI features, we process your inputs (including voice/audio and transcripts), context (e.g., your learning plan), and outputs. We may use third-party AI providers as processors to generate responses. Do not include sensitive information in prompts or audio. Where required by law, obtain consent from all participants before recording or transmitting audio.

6) Legal Bases (EEA/UK)

• Performance of a contract (to deliver the Service you request).
• Consent (e.g., analytics cookies; certain communications).
• Legitimate interests (e.g., improving the Service, preventing abuse), balanced against your rights.
• Legal obligations (e.g., tax, accounting, compliance).

7) Sharing of Information

We do not sell your personal information. We may share information with:

• Service providers / processors (e.g., cloud hosting, databases, authentication, analytics, payments, AI providers) who process data on our behalf under contracts.
• Legal and safety purposes (to comply with law, enforce terms, protect rights, investigate abuse).
• Business transfers (in connection with a merger, acquisition, or asset sale).

Limited Use Policy (Google APIs)

OpenLume’s use and transfer of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

8) Cookies & Analytics

We use necessary cookies for core functionality. With your consent (where required), we use analytics cookies or similar technologies (e.g., Google Analytics) to measure usage. You can manage preferences via our cookie banner or your browser settings. We do not load non-essential cookies until you opt in.

9) Data Retention

• Account data: retained while your account is active and for up to 24 months after deletion for legal, security, and backup purposes (unless a longer period is required by law).
• Learning content & submissions: retained to provide your workspace/history; you can delete items within the app where available or request deletion.
• Analytics data: retained per our analytics provider’s default windows or as configured (typically 14–26 months).
• Payment records: retained as required for tax/accounting.

10) Security

We implement technical and organizational measures designed to protect your information. No method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

11) International Transfers

We may transfer, store, and process information outside your country. When we transfer personal data from the EEA/UK, we rely on appropriate safeguards (e.g., Standard Contractual Clauses) where required by law.

12) Your Rights

Depending on your location, you may have rights to access, correct, delete, restrict or object to processing, port data, or withdraw consent. To exercise rights, contact us at hello@openlume.com.

EEA/UK: you have the rights set out in the GDPR/UK GDPR and may lodge a complaint with your local supervisory authority. California: you have rights under the CCPA/CPRA (access, delete, correct, limit use of sensitive information, and opt out of “sale”/“sharing” for cross-context behavioral advertising). We do not sell personal information. To exercise rights or opt out of “sharing,” contact us or adjust cookie preferences.

13) Children’s Privacy

The Service is not directed to children under 13 (or the minimum age of digital consent in your jurisdiction). We do not knowingly collect personal information from children. If you believe a child has provided personal information, contact us to request deletion.

14) Third-Party Links

The Service may link to third-party sites or services. We are not responsible for their content or privacy practices. Review their policies before providing your information.

15) Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will provide notice (e.g., by posting here, in-app notices, or email). The “Last updated” date reflects the latest revision. Your continued use of the Service after changes take effect means you accept the updated Policy.

16) Contact Us

Data Controller: OpenLume • hello@openlume.com