Privacy Policy

This Privacy Policy describes how PyxonData Inc. ("Lumina", "we", "us", or "our") collects, uses, and discloses your information when you use the Lumina Analytics platform at lumina.express ("Service"). This policy is designed to comply with the Personal Information Protection Act (Alberta) ("PIPA"), the Personal Information Protection and Electronic Documents Act (Canada) ("PIPEDA"), and applicable provisions of Canada's Anti-Spam Legislation ("CASL") and the U.S. CAN-SPAM Act.

1. Information We Collect

• Account Information: When you register, we collect your name, email address, and encrypted password via Firebase Authentication.
• Payment Information: Processed securely via Stripe. We do not store your full credit card details. Stripe may store payment method details in accordance with their privacy policy.
• LUM Token & Wallet Data: Your LUM token balance, transaction history (credits, debits, purchases, and rewards), and subscription status are stored in Google Firebase Firestore.
• Usage Data: Metrics regarding your use of the Service, including queries executed, agents used, features accessed, file types uploaded, and compute consumption (LUM spent per feature).
• User Data (Your Datasets): Lumina operates on a "Client-Side First" architecture. Your raw data files (CSV, Excel, etc.) are processed in your browser's memory using DuckDB-WASM. We do not persist your raw datasets on our servers. Only metadata (column names, data types, row counts) is used for AI processing.
• Campaign & Challenge Data: If you participate in a beta campaign or challenge, we collect your challenge progress, mission completions, agent ratings (1-5 stars), draw entries, and LUM spending within the challenge.
• Lead Data: If you subscribe to our newsletter, join a campaign via invitation, or sign up through a popup, we collect your email address, name, and company (if provided). Leads imported via CSV by our team for campaign invitations are stored with implied consent status until you respond.
• Agent Ratings: If you rate an AI agent, your rating (1-5 stars) is stored and aggregated. Individual ratings are associated with your user ID internally but displayed publicly only as aggregated averages.

2. How We Use Your Information

We use your information to:

• Provide, maintain, and improve the Service, including AI-powered analytics and the Agent Marketplace.
• Process transactions, manage your subscription, and maintain your LUM token wallet.
• Send transactional emails (verification, password reset) from support@lumina.express.
• Send commercial emails (welcome messages, campaign invitations, challenge reminders, marketing broadcasts) from lumina@pyxondata.com. You may unsubscribe from these at any time.
• Administer beta campaigns, including the 30-Day Data Challenge, weekly prize draws, and leaderboards.
• Generate aggregated, anonymized usage metrics to share with Agent developers (e.g., install counts, average ratings).
• Comply with legal obligations and enforce our Terms of Service.

3. AI Analysis & Data Sharing

To provide AI-powered insights, metadata (column names, data types) and a small sample (first 5-20 rows) of your data are transmitted via encrypted connection (TLS) to the Google Gemini API for natural language processing. The full dataset remains in your browser and is never sent to our servers or to Google.

Different features may transmit varying amounts of metadata:

• Chat queries: Column names, data types, and a data sample.
• Boardroom / Simulation: Additional context such as statistical summaries may be included.
• Agent-specific queries: The paired agent's system prompt and knowledge base are included alongside your data sample.

By using the AI features, you consent to this limited data sharing for analysis purposes only. Google's use of transmitted data is governed by Google's API Terms of Service.

4. Data Storage & International Transfers

Your account information, LUM wallet, transaction history, and preferences are stored in Google Firebase Firestore. While PyxonData Inc. is based in Alberta, Canada, our cloud infrastructure and third-party service providers may process and store your data outside of Canada:

• Google Cloud Platform (Firebase): Account data, wallet, transactions, preferences, challenge progress.
• Google Gemini API: Metadata and data samples transmitted for AI analysis (not persisted by Google under current API terms).
• Stripe: Payment processing and billing records.
• SendGrid (Twilio): Email delivery for transactional and commercial emails.

Data stored outside Canada is subject to the laws of those jurisdictions. By using the Service, you consent to these international transfers.

5. Marketplace & Third-Party Developers

When you install an Agent from the Marketplace created by a Third-Party Developer:

• The Developer provides the logic (SQL Macros) and Persona definitions. These run locally in your browser.
• Your data is NOT shared with the Developer. All data processing occurs in your browser's DuckDB engine.
• We share aggregated, anonymized usage metrics with the Developer, including: install counts, query counts, and average star ratings. Individual user identifiers are never shared.
• If you rate an agent, your rating is aggregated into the agent's public average score. The Developer sees the aggregate rating and count, not your individual rating.

6. Email Communications & Unsubscribe

• Transactional Emails: Verification, password reset, and account alerts are sent from support@lumina.express. These are not marketing and cannot be unsubscribed from while your account is active.
• Commercial Emails: Welcome emails, campaign invitations, challenge reminders, and marketing broadcasts are sent from lumina@pyxondata.com. All commercial emails include a physical mailing address and a one-click unsubscribe link.
• Unsubscribe: You can unsubscribe from commercial emails at any time by clicking the unsubscribe link in any email. Unsubscribe requests are processed immediately and apply to all future commercial emails. Your preference is stored securely.

All commercial emails comply with CASL (Canada) and CAN-SPAM (U.S.) requirements, including physical address disclosure and unsubscribe mechanisms.

7. Data Retention & Deletion

• Account Data: Retained for as long as your account is active. You may request deletion by contacting privacy@lumina.express.
• Transaction History: LUM token transactions are retained for a minimum of 7 years for financial record-keeping purposes.
• Lead Data: Campaign lead records are retained for 24 months after last engagement. Unsubscribed leads are marked but retained for suppression list purposes.
• User Datasets: Since raw datasets are processed in your browser and not stored on our servers, there is nothing for us to delete. Clearing your browser data removes all local data.

To exercise your right to access, correct, or delete your personal information under PIPEDA or PIPA, contact our Privacy Officer at the address below.

8. Security

We protect your information using industry-standard measures including: TLS encryption for all data in transit, AES-256 encryption for sensitive credentials stored at rest (e.g., API keys), Firebase Authentication for identity management, and Stripe's PCI-DSS compliant payment processing. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security.

9. Contact Us

For privacy-related inquiries or data subject access requests, please contact our Privacy Officer: