Privacy Policy

We obtain explicit consent for any biometric processing (face/voice) of your submitted content.

We retain biometric identifiers no longer than 3 years after your last interaction or until the purpose is met, then delete or irreversibly de-identify them. See our Biometric Policy for details.

When you upload content, we automatically extract:

• File duration and technical specifications
• Content type and format information
• Quality metrics and analysis results
• Deduplication hashes (SHA256 content hash and perceptual hash) for content matching
• Automated content quality assessment and technical validation
• Content categorization and tagging for marketplace discovery

To ensure transparency, here is how your content flows through our system:

We retain different types of data for varying periods:

• User accounts: Until deletion request
• Uploaded content: Until sold to buyers, then transferred to purchasing companies
• Content metadata and QA results: Retained for record-keeping even after content sale
• Biometric identifiers: No longer than 3 years after last interaction
• Analytics data: 2 years maximum
• Payment records: 7 years (tax compliance)
• Account data after deletion: 30 days

Note: Once content is sold to an AI company, we no longer control that content. The purchasing company becomes the data controller for that content and is responsible for its retention and use in accordance with their own policies and applicable laws.

We use the following tracking technologies:

• Essential cookies for authentication and session management
• Session storage for upload progress tracking
• Local storage for user preferences and settings
• Google Analytics for aggregate usage statistics (optional)

We detect and honor Global Privacy Control (GPC) signals for applicable opt-outs.

• Facilitate the sale of your content to AI companies for training purposes
• Process payments and manage earnings through Venmo, PayPal, and Stripe
• Analyze content quality through automated systems and human review
• Enable real-time conversation recording with explicit participant consent
• Prevent duplicate submissions and maintain marketplace integrity through content hashing
• Match contributors with relevant AI company listings
• Honor privacy choices, including GPC and "Do Not Sell/Share" requests where required
• Record and enforce consents for biometric data and model releases
• Handle DMCA notices and repeat-infringer policy
• Comply with KYC/sanctions and tax obligations for payouts

We protect your data with:

• Encryption in transit (TLS) and at rest
• Secure cloud storage infrastructure
• Access controls and least-privilege access
• Regular security audits and updates
• Magic byte validation and file security scanning

Service Providers: We use trusted third-party payment processors:

• Venmo and PayPal: Payment processing for contributor payouts
• Stripe: Payment processing infrastructure

All service providers operate under strict data processing agreements and are required to protect your data in accordance with applicable laws.

Important: As a data marketplace, we facilitate the sale of your content to AI companies. This is the core function of our platform.

We share data in these circumstances:

• Content Sales: Your uploaded content is sold to verified AI companies for training purposes
• Quality Assurance: Content is processed through automated systems for quality assessment and content validation
• Payment Processing: Through Venmo, PayPal, and Stripe for secure payment processing
• Legal Compliance: To comply with legal requirements or court orders
• Privacy choices: We treat some transfers as "sale" or "sharing" under state law and provide opt-outs/GPC
• Biometric data: Disclosed only to service providers and buyers for permitted AI uses, not sold for unrelated marketing

Content Ownership and Sales: When you upload content to Luel:

• You grant Luel a perpetual, worldwide, transferable, sublicensable, exclusive license to sell your content to AI companies
• You consent to the sale of your content, including all personal information, biometric data, voice, likeness, and identifiable information contained within it, to AI companies for training purposes
• Luel sells your content (including personal data/biometric information) to AI companies who may use it for training, evaluation, and creating derivatives (embeddings, model weights, synthetic data)
• AI companies are prohibited from re-identifying individuals or using content for biometric identification unless expressly permitted
• Where required, you provide model/voice/likeness releases for identifiable people in your content
• After content is sold, buyers receive all data including personal information, and Luel transfers ownership to the purchasing company
• Once content is sold, the sale is final and irrevocable. You cannot revoke consent, request removal of your data from trained AI models, or demand return or deletion of sold content.

Subject to applicable laws, you have the right to:

• Access and download your personal data
• Correct inaccurate information
• Delete your account and associated data (30 days after request)
• Request data portability
• Withdraw consent for future data processing (before content is sold)
• Opt out of sale/sharing and limit use of sensitive personal information (where available under applicable state laws)
• Object to certain types of processing
• Submit requests via our privacy choices form or send a GPC signal in your browser
• Use an authorized agent where permitted
• Lodge a complaint with your local data protection authority

Important Limitations:

• After Content Sale: Once your content is sold to an AI company, you cannot withdraw consent, request deletion from trained models, or demand return of sold content. The sale is final and irrevocable.
• Conversation Recordings: For real-time conversation recordings, consent must be given before recording begins. Once a recording is submitted and approved for sale, the same limitations apply as upload submissions.
• Biometric Data: Once biometric data (voice, face) is embedded in content sold to AI companies, we cannot retrieve or delete it from their systems or trained models.

To exercise these rights (where applicable), contact us at support@luel.ai

Your data may be transferred to and processed in various locations:

• United States: Primary data storage and processing
• Payment Processors: Stripe, PayPal, and Venmo may process payment data in their respective operating regions

Where applicable, we rely on approved transfer mechanisms such as:

• EU-U.S. Data Privacy Framework for certified providers
• Standard Contractual Clauses (SCCs) as approved by relevant authorities
• Adequacy decisions where available
• Supplementary measures to ensure appropriate safeguards

For EEA, UK, and Swiss residents: Your data is transferred to the United States and other jurisdictions where our service providers operate. These transfers are subject to appropriate safeguards as required by applicable data protection laws.

AI Training Use: Your content will be used to train artificial intelligence models for:

• Machine learning model training and development
• AI system improvement and optimization
• Creation of synthetic media and AI-generated content

Ethical Guidelines: We work only with AI companies that commit to ethical AI development. We prohibit buyer re-identification of individuals and biometric identification uses unless expressly permitted with appropriate consent.

Residents of certain U.S. states have additional privacy rights under state law:

To exercise state-specific rights, contact us at support@luel.ai or use our privacy choices form. We will respond within the timeframes required by applicable state law.

Luel is not intended for users under 18 years of age. We do not knowingly collect personal information from children under 13 (COPPA) or under 16 without verifiable parental consent where required. If we become aware of such collection, we will take immediate steps to delete the information.

Age Verification: By using Luel, you represent that you are at least 18 years old. For conversation recordings, all participants must confirm they are 18+ before recording begins.

We may update this Privacy Policy periodically. We will notify you of significant changes via email or platform notification. Continued use of Luel after changes constitutes acceptance of the updated policy.

We implement industry-standard security measures to protect your data:

• TLS encryption for all data in transit
• Encryption at rest for stored data
• Magic byte validation to prevent malicious file uploads
• Content Security Policy (CSP) headers to prevent XSS attacks
• Regular security audits and penetration testing
• Access controls and least-privilege principles
• Multi-factor authentication for administrative access

Breach Notification: In the event of a data security incident that affects your personal information, we will notify you and relevant authorities as required by applicable laws, typically within 72 hours of discovery. Notifications will be sent to the email address associated with your account.

If you have questions about this Privacy Policy or our data practices, please contact us:

We will respond to your inquiry within the timeframes required by applicable law (typically 30-45 days depending on jurisdiction).