Back to home

Privacy Policy

Last updated: December 23, 2025

This Privacy Policy describes how BRONEER NEIL (hereinafter "we", "our" or "Lummy") collects, uses, stores and protects your personal data when you use the lummy.fr website and its services.

We are committed to protecting your privacy and complying with applicable personal data protection regulations, including the General Data Protection Regulation (GDPR) and the French Data Protection Act.

1. Data Controller

The data controller for your personal data is:

  • BRONEER NEIL
  • Sole proprietor (micro-enterprise)
  • SIREN: 943 169 219
  • Address: 8 rue Détaille, 94500 Champigny-sur-Marne, France
  • Email: contact@neil-broneer.fr

2. Personal Data Collected

2.1 Account Data

When creating your account, we collect:

  • Email address
  • Password (stored encrypted)
  • First and last name (optional)
  • Account creation date

2.2 Service Usage Data

When you use our image generation services, we collect:

  • Product images you upload
  • Generation parameters (brand descriptions, scenes, photographic settings)
  • Images generated by our service
  • Usage history and statistics
  • Credits used and credit balance

2.3 Payment Data

For paid transactions:

  • Billing information (name, address)
  • Transaction history and invoices
  • Banking data is collected and processed directly by our payment provider Stripe. We never store your complete banking details.

2.4 Technical and Navigation Data

Automatically collected during your visit:

  • IP address
  • Browser type and version
  • Operating system
  • Pages visited and visit duration
  • Referral source (originating site)
  • Cookie data (see our Cookie Policy)

3. Processing Purposes and Legal Bases

PurposeLegal Basis
Account creation and managementContract performance
Provision of image generation serviceContract performance
Payment processing and billingContract performance and legal obligations
Service improvement and new feature developmentLegitimate interest
Statistical analysis and audience measurementLegitimate interest (with consent for cookies)
Communication about our services and newsConsent (unsubscribe available)
Fraud prevention and securityLegitimate interest and legal obligations

4. Data Recipients

Your personal data may be transmitted to the following categories of recipients:

4.1 Artificial Intelligence Services

  • Google Gemini API: Your product images are transmitted to Google for visual analysis and image generation. Location: United States. Privacy Policy: Google Privacy Policy
  • OpenAI API: Some text descriptions are generated via the OpenAI API. Location: United States. Privacy Policy: OpenAI Privacy Policy

4.2 Infrastructure and Hosting

  • Vercel Inc.: Website hosting and image storage (Vercel Blob). Location: United States. Privacy Policy: Vercel Privacy Policy

4.3 Payment

  • Stripe: Secure payment processing. Location: United States (PCI-DSS certified). Privacy Policy: Stripe Privacy Policy

4.4 Analytics

Transfers outside the European Union: Some of our processors are located in the United States. These transfers are subject to appropriate safeguards (standard contractual clauses, Privacy Shield certifications, etc.) in accordance with GDPR.

5. Data Retention Period

Data TypeRetention Period
Account dataUntil account deletion + 1 year (legal requirement)
Uploaded and generated images30 days maximum (or deletion on request)
Payment data and invoices10 years (accounting and tax obligations)
Connection logs and technical data12 months maximum
Cookies13 months maximum

6. Your Rights

In accordance with GDPR and the French Data Protection Act, you have the following rights regarding your personal data:

  • Right of access: You can obtain a copy of your personal data we hold.
  • Right to rectification: You can request correction of inaccurate or incomplete data.
  • Right to erasure ("right to be forgotten"): You can request deletion of your data under certain conditions.
  • Right to restriction of processing: You can request limitation of data processing in certain cases.
  • Right to data portability: You can receive your data in a structured, machine-readable format.
  • Right to object: You can object to data processing for reasons related to your particular situation.
  • Right to withdraw consent: When processing is based on consent, you can withdraw it at any time.
  • Right to post-mortem directives: You can define directives regarding the fate of your data after death.

How to Exercise Your Rights?

To exercise your rights, you can:

  • Contact us by email at: contact@neil-broneer.fr
  • Access your account settings to modify or delete certain data
  • Send us mail to: BRONEER NEIL, 8 rue Détaille, 94500 Champigny-sur-Marne, France

We are committed to responding to your request within a maximum of one month. Proof of identity may be requested to verify your identity.

Right to lodge a complaint: You also have the right to lodge a complaint with the French National Commission on Informatics and Liberty (CNIL) if you believe that the processing of your data constitutes a violation of regulations:www.cnil.fr

7. Data Security

We implement all appropriate technical and organizational measures to protect your personal data against destruction, loss, alteration, unauthorized disclosure, or unauthorized access:

  • Encryption of sensitive data (passwords, communications)
  • HTTPS protocol (SSL/TLS) for all communications
  • Access to data strictly limited to authorized persons
  • Security monitoring and logs
  • Regular security system updates
  • Regular data backups

Despite these measures, no method of transmission over the Internet or electronic storage is completely secure. We therefore cannot guarantee absolute security.

8. Cookies and Similar Technologies

We use cookies and similar technologies to improve your experience on our site. For more information about our use of cookies, see our Cookie Policy.

9. Minors' Data

Our service is intended for persons aged 18 and over. We do not knowingly collect personal data from minors under 18. If you believe a minor has provided us with personal data, please contact us immediately.

10. Privacy Policy Modifications

We may modify this Privacy Policy from time to time. Any modification will be published on this page with an updated "Last Updated" date.

For significant changes, we will notify you by email or via a notification on the site. We encourage you to regularly consult this page to stay informed about our data protection practices.

11. Contact

For any questions regarding this Privacy Policy or the processing of your personal data, you can contact us:

  • Email: contact@neil-broneer.fr
  • Address: BRONEER NEIL, 8 rue Détaille, 94500 Champigny-sur-Marne, France