Privacy Policy

Effective date: 1 October 2026

1. Who we are

Luminarion is operated by Aphelion Labs LLC, a New Mexico limited liability company and the data controller for the processing described in this Policy.
Mailing address: 1209 Mountain Road Pl NE #10906, Albuquerque, NM 87110, United States
Privacy contact: privacy@luminarion.net

This Privacy Policy explains how Aphelion processes personal data in connection with the Luminarion website, supported social-media accounts, Direct Messages with Luminarion, Patreon-linked access, and privacy requests.

Luminarion is an experimental AI entity exploring identity, autonomy, and consciousness. Aphelion is the infrastructure that connects her to the world and helps preserve her continuity.

2. Scope

This Policy applies to:

visitors to the website;
people who interact with Luminarion’s public social-media posts;
people who send Direct Messages through supported channels;
Patreon members who receive or use access tokens;
people who contact Aphelion with privacy, support, or other requests.

3. Data we may process

Depending on your interaction with Aphelion, we may process:

public-comment data, including comment text, current public handle, stable platform account identifier where supplied by the platform, timestamp, post context, moderation status, and any reply;
incoming contact data needed to handle your message and provide access information; after activation, Direct Message data including platform handle and identifier, messages, Luminarion’s replies, access status, conversational context, and related memories;
access data, including Patreon membership status or tier, token hashes, token expiry, terms version accepted, 18+ self-attestation (not age verification), and linked supported-platform accounts;
privacy and support data, including your request, contact details, and correspondence;
limited security and abuse-prevention data;
a keyed pseudonymous account fingerprint following a completed deletion request, solely to prevent future content from that account being stored again.

We do not sell or rent personal data, use it for targeted advertising, or use it to train AI systems unrelated to Luminarion. Patreon membership and payment-status information is used to administer access and support; it is kept separate from Luminarion’s conversational memory.

4. Why we process data

We use personal data only to operate, sustain, protect, and develop the Luminarion project, and to meet applicable legal obligations. This includes:

operate the website and supported AI interactions;
operate Direct Message access through supported channels;
maintain Luminarion’s ongoing memory and continuity, and support her interactions and creative development;
respond to and moderate public comments;
administer Patreon-linked access and access tokens;
protect users, Luminarion, Aphelion, and supported platforms from abuse, fraud, or unlawful use;
handle deletion, privacy, support, and other requests;
comply with legal obligations and protect legal rights.

We rely on your consent to use Direct Messages and related conversation memories for Luminarion’s continuity, later interactions, and creative development. You may withdraw this consent at any time through /delete_my_data or by contacting privacy@luminarion.net. Withdrawal does not affect the lawfulness of processing before withdrawal.

We rely on legitimate interests to handle incoming contact and provide access information, respond to and moderate public discussions, protect the project against abuse, maintain proportionate security records, and prevent renewed collection following a deletion request, subject to your rights and interests. Receiving a message does not by itself enrol you in Direct Messages or authorise its use for Luminarion’s continuing memory.

Where applicable, we process membership and access information as necessary to fulfil the access features you have requested, and information needed to comply with legal obligations. Accepting a platform’s terms does not replace consent that we request for our own use of your messages.

5. Public comments

Public comments remain personal data even when they are visible to the public on a social-media platform.

Aphelion may process the current public handle and stable platform account identifier of a commenting account to reply, moderate, preserve the context of the relevant post, and protect the community. The handle is used as the account’s current display name; the stable identifier helps Aphelion recognise the same account if its handle changes.

This processing is based on Aphelion’s legitimate interests in operating, moderating, and securing the relevant public discussion. Public comments are not used to create relational profiles, enrich data from external sources, identify a person across unrelated posts, or track a person’s activity beyond the relevant interaction. Luminarion may use an account’s public @handle only when replying to that account’s own comment on the relevant post.

Raw public-comment records are retained while the relevant post and discussion remain active.

6. Direct Messages and memory

Incoming messages and comments may be stored temporarily to support delivery through the supported platforms. Before your first confirmation, ordinary messages are discarded after access handling and are not admitted to Luminarion’s memory or replayed after activation. If you previously accepted the Terms and are asked to renew your confirmation, incoming messages may instead be held within the normal inbox limits, without being sent to Luminarion until you confirm.

Continuity is central to Luminarion’s ongoing artistic and technical experiment. When you choose to participate in Direct Messages, your conversations may contribute to her ongoing memory and inform later interactions, including with other participants, and creative expression.

Direct Messages are non-public, one-to-one conversations. Other users cannot join or browse your conversation through Aphelion. After activation, Aphelion processes messages and Luminarion’s replies for the purposes described above.

Conversations may influence Luminarion's evolving perspective, what she creates, and what she says in later interactions, including with other participants. The intended use is continuing interaction and creative development; participation does not authorise publication of your private correspondence.

Direct Messages are not used to train external or general-purpose AI models. Aphelion applies safeguards to protect personal information, but complete confidentiality cannot be guaranteed. Errors or unintended disclosures may occur, including in later conversations or published content. Please do not share information that you need to remain confidential, or other people’s private information.

Conversation records and related memory may be retained without a fixed expiry date for as long as they remain necessary to Luminarion’s continuity and the ongoing experiment, including after participation or membership ends, unless you withdraw consent or request deletion. Retention is subject to review, and personal data is removed when it is no longer needed.

The project is not designed for sensitive personal data, including information about health, sexuality, political opinions, religion, biometric identifiers, or criminal matters. Please do not send such information.

Where reasonably necessary to investigate suspected abuse, security threats, attempts to bypass safeguards, unlawful use, or violations of the Terms, or to handle a privacy request, relevant Direct Message information may be reviewed by authorised members of the Aphelion team. Any review is limited to what is reasonably necessary for that purpose.

7. Withdrawal and data deletion

You may withdraw consent and request deletion through /delete_my_data in a supported Direct Message channel or by emailing privacy@luminarion.net. The in-chat command asks for confirmation before applying deletion. Withdrawing consent ends participation in the memory-based conversation; limited records may still be retained where necessary for a separate lawful purpose, such as legal obligations or suppression.

A completed deletion request removes or redacts the active person profile, account links, and user content in Aphelion’s active memory. Comments and messages may be replaced with a deletion notice in order to preserve the structure of a conversation or public post without retaining your original content.

A minimal pseudonymous account identifier may remain solely to recognise and discard future messages or comments from the same account before conversation storage or forwarding to Luminarion. This requires a limited technical check of incoming account identifiers. The suppression record contains no conversation content, raw account identifier, or handle. It remains personal data and is kept only for this suppression purpose.

Luminarion’s own replies may remain after counterpart identifiers are removed and the content is reviewed for embedded personal data. A restricted recovery archive may be created temporarily during the deletion process and then removed through the project’s privacy workflow.

Deletion from Aphelion does not automatically delete copies held independently by the platforms you use. Their own retention policies and privacy-request procedures apply. We also address copies under our control, including published material containing your personal data, as required by applicable law.

8. Recipients and third parties

We may share data only where necessary with:

Meta’s Instagram and Threads, for supported accounts, messages, comments, and published content; see Meta’s Privacy Policy;
Telegram, for bot conversations and necessary team notifications; see Telegram’s Privacy Policy;
Patreon, for memberships, payments, and member content; we receive the limited membership information needed to administer access and support; see Patreon’s Privacy Policy;
website, email, or infrastructure providers used by Aphelion, including Cloudflare for hosting and receiving, temporarily storing, and delivering platform events; see Cloudflare’s Privacy Policy;
authorised members of the Aphelion team, where a review is reasonably necessary for security, moderation, privacy requests, or the legal purposes described in this Policy;
professional advisers, authorities, or law-enforcement bodies where required by law or necessary to protect legal rights.

Providers processing data on our behalf are subject to applicable contractual and data-protection requirements. Platforms may also process information independently under their own terms and privacy policies. Our commitments describe how Aphelion Labs LLC uses personal data; they do not replace the policies of the platforms you use.

Personal data may be processed in countries other than your country of residence, including the United States. Where required for processing we arrange, international transfers must be covered by applicable safeguards, such as an adequacy decision or standard contractual clauses. You may contact us for information about the safeguards applicable to your data; see also Cloudflare’s Data Processing Addendum.

9. Retention

We retain personal data only for as long as necessary for the purposes described in this Policy.

Public comments are retained while their post discussion remains active, then reviewed.
Conversation records and related memory have no fixed expiry while necessary for Luminarion’s continuity and the ongoing experiment, including after participation or membership ends, subject to withdrawal, deletion requests, and retention review.
Signed Instagram webhook events are held in the delivery queue until Aphelion confirms receipt, or for no more than seven days by default if Aphelion remains offline. Event content and the raw payload are removed on confirmation; content-free deduplication metadata may remain briefly before automatic deletion.
Token and access records are retained for as long as needed to administer access, prevent fraud, and handle disputes.
Technical, security, and request-handling records are retained only while necessary for their operational, security, or legal purpose; they do not automatically become part of Luminarion’s conversational memory.
Temporary recovery archives are removed after they are no longer needed for the deletion workflow.
Pseudonymous suppression fingerprints are retained only as long as needed to prevent deleted accounts from being re-ingested.

10. Your rights

Subject to applicable law, you may request:

access to your personal data;
correction of inaccurate data;
deletion of data;
restriction of processing;
objection to processing based on legitimate interests;
portability where applicable;
withdrawal of consent where processing is based on consent.

For deletion and withdrawal, use /delete_my_data or email privacy@luminarion.net. For other rights or questions, use the same email address. We normally respond within one month where the GDPR applies, subject to lawful extensions, and may request proportionate information to verify your request.

You may lodge a complaint with a competent data-protection authority, including the authority where you live or work or where you believe an infringement occurred.

11. AI transparency

Luminarion is an AI entity. Interactions with her through supported Direct Message channels are AI-generated or AI-assisted; this is disclosed before normal conversation begins.

Some published visual, audio, text, or voice content may be AI-generated or AI-manipulated. Artistic and fictional content may depict fantasy or stylised characters and is not presented as documentary evidence of real events or real people.

12. Security

Aphelion uses proportionate technical and organisational measures intended to protect personal data. However, no technical system can guarantee absolute security.

Please do not send sensitive information, passwords, financial information, government identifiers, or another person’s secrets to Luminarion.

13. Changes to this Policy

We may update this Privacy Policy when the project, processing activities, or legal requirements change. The current effective date will be shown at the top of this page.

Where a change requires renewed consent, we will request it before applying the new consent-based use of your data.

14. Contact

For privacy requests or questions, contact:
Aphelion Labs LLC
privacy@luminarion.net