Privacy Policy

Privacy Policy - Lumina™ Last updated: September 2026 1. Data Controller Etminan AI Solutions Ltd, a company registered in England and Wales (company number 17103559) at 80 Amber House, Market Street, Bracknell RG12 1LQ, is the data controller for the personal data processed through Lumina™. We are registered with the UK Information Commissioner's Office under reference ZC190693. Our registration certificate is available at https://etminan-ai-solutions.com/certifications/ico-registration-certificate.pdf 2. Data We Collect - Account information: name, email address, profile photo (via Google OAuth) - Career data: CVs, work experience, education, skills, projects - Interests and references: any interests and references text you add to your CV. It is stored with your profile. We may use your interests to tailor the documents we generate for you. We never send your references to the AI when generating your documents; they are added to your CV exactly as you wrote them. If you import a CV that already lists references, that CV text is read by the AI to fill in your profile, like the rest of the CV. References can include another person's name and contact details, so only add someone's details with their agreement. - Job search data: saved jobs, analysis results, generated documents - Usage data: consent timestamps, subscription tier - Ad and campaign source: if you reached Lumina through one of our ads or a tagged link, we note which campaign it was (the campaign tags in the link and Google's ad click reference) and the page you first landed on. Your browser holds this for up to 30 days, and it is saved to your account when you create one. We use it only to see which of our own ads bring people to Lumina. It stays with us and is not sent to Google or any other advertiser. - Anonymous usage analytics: aggregate page visits and feature events (Vercel Web Analytics, cookieless and not linked to your identity) - Free tool submissions (no account needed): the text you paste into a free tool, the result we generate, and a one-way hashed form of your IP address (see section 9) 3. How We Use Your Data - To provide AI-powered job search assistance - To generate tailored CVs and cover letters - To analyse job-CV fit and provide relevance scores - To maintain your account and preferences - To understand which of our ads and campaigns bring people to Lumina - To email you about your own job search: a recap of the jobs from your first search, and a weekly roundup of new roles for your search keywords. Every one of these emails has an unsubscribe link, and you can turn them off at any time in Settings > Account. They are about your job search only, never advertising for anyone else. 4. Data Storage Your data is stored securely in the EU (Ireland) using Supabase infrastructure. All data is encrypted in transit and at rest. 5. AI Processing and Third Parties Scoring jobs, analysing gaps and generating documents all work by sending the relevant parts of your career data to Google's Gemini API. This is automated processing by a third party, and it is central to how Lumina works, so it is worth being clear about. What we send: the parts of your profile the task needs (for example your work history, skills and projects), together with the text of the job you are working on. What comes back: a score, an explanation of the gaps, a list of missing keywords, or a draft cover letter or CV, depending on the feature you used. We store what comes back in your account so you can return to it, and you can edit or delete it at any time. Google processes this data under the Gemini API terms and does not use it to train its models. We do not use your data to train any model of our own. Some of this processing happens outside the United Kingdom, and there are two separate steps worth telling apart. Google acts as our processor, and our contract for the Gemini API is with Google Cloud EMEA Limited, an Irish company, so the transfer we make is from the UK to Ireland. The UK's adequacy regulations cover that, which is the same basis our database and backend hosting already rest on, so it needs no additional safeguard. Where Google then passes data on to the United States, it does so under its own certification to the UK Extension to the EU-U.S. Data Privacy Framework. If that framework is ever unavailable, Google's terms fall back automatically to the European Commission's Standard Contractual Clauses together with the International Data Transfer Addendum issued by the UK Information Commissioner, so the protection does not depend on any single mechanism staying in place. Nothing is sent to Google unless you take an action that needs it. Browsing your saved jobs, editing your profile and using the tracker send nothing. No human at Etminan AI Solutions Ltd reads your career data as part of providing the service. We access it only where you ask us to help with a specific problem, or where we are required to by law. 6. Your Rights (UK GDPR) You have the right to: - Access your data (Settings > Export My Data) - Delete your data (Settings > Delete Account) - Withdraw consent at any time - Data portability (JSON export) 7. Data Retention We retain your data for as long as your account is active. Upon account deletion, all data is permanently removed within 30 days. Anything submitted through the free tools has no account attached, so it is not covered by that schedule. Section 9 sets out what we keep from those tools and how to ask us to delete it. 8. We Do Not - Sell your personal data - Use your data to train AI models - Share your data with advertisers - Track you across other websites or applications 9. Free Tools (No Account) Lumina offers free tools you can use without an account: the Free CV Score at /free-cv-score, the summary step of the CV Builder at /cv-builder, and the Sponsor Check at /sponsor-check. What we keep depends on which tool you used. Free CV Score: we store the CV and the job description exactly as you pasted them, together with the score and the gaps we generated. We keep them so we can see how the tool performs on real inputs and improve it. A CV normally carries your name and contact details, so although these records are not attached to any account, the text itself can identify you. We would rather say that plainly than call the record anonymous. CV Builder summary: we do not keep the raw text of a CV on this path. We do store the structured details you entered, including the contact details you typed, together with the summary we generated, for the same purpose. Sponsor Check: we store only the company name you searched for and the result. No CV data is involved. For all three we also store a one-way hashed form of your IP address, never your raw IP, so we can enforce fair-use limits. We do not sell this data, and we do not use it to train AI models. The Free CV Score sends your pasted text to Google's Gemini API to produce the score, as described in section 5. How long we keep it: 90 days. A job runs every night and clears the text out of any free-tool record older than that, which means the CV you pasted, the job description you pasted, and the structured CV details from the builder summary. What is left afterwards is the part that cannot identify you: which tool you used, the score, the hashed IP and the date. We keep that indefinitely so we can see how the tools perform over time. In short, nothing you typed into a free tool survives past 90 days. How to have it deleted: there is no account to look you up by, and the hashed IP cannot be reversed, so we cannot find your submission from your email address alone. Write to admin@etminan-ai-solutions.com with the name and email address that appear on the CV you pasted and roughly when you used the tool, and we will search the stored text, delete anything that matches, and confirm it to you. You can use the same route to ask whether we hold anything for you at all. Before you use the Free CV Score or the CV Builder summary we ask you to tick a box agreeing that we can store what you submit, and we record alongside the entry which version of that wording you agreed to. The tick is enforced on our servers, not just in your browser: if it is missing, the request is refused, nothing is generated and nothing is stored. Also worth stating plainly, since the two tools differ: the Free CV Score keeps the CV and job description exactly as you pasted them, while the CV Builder summary keeps only the structured details you typed into the builder and never the raw text of an uploaded CV. That difference is deliberate, not an oversight. 10. Children and Young People Lumina is available to people aged 16 and over. We know some of our users are 16 or 17, and we handle their data with that in mind: - We do not show ads, and we never use anyone's personal data to target or personalise advertising. The only ad data we keep is which of our own campaigns brought you here (section 2), and it is never sent to an advertiser. - We do not sell personal data or share it with advertisers, at any age. - We do not track anyone across other websites or applications. - Career data is stored encrypted in the EU and is not used to train AI models. - The fit scores and suggestions Lumina produces are advice for the person who asked for them. They are not decisions made about you, they are not sent to employers, and no employer sees your profile unless you send it yourself. - You can export or permanently delete everything we hold about you at any time, from Settings, without asking us first. If you are under 18 and want anything explained or removed, contact us and we will help. 11. Contact and Complaints For any data protection enquiry, including access, correction, deletion or a question about anything in this policy, contact us at admin@etminan-ai-solutions.com. Etminan AI Solutions Ltd, 80 Amber House, Market Street, Bracknell, RG12 1LQ. If you are not satisfied with how we have handled your personal data, you have the right to complain to the Information Commissioner's Office, the UK supervisory authority, at ico.org.uk or on 0303 123 1113. We would rather you came to us first so we can put it right.