Privacy Policy

Last updated: 25 October 2026

How this website and the Luma service handle personal data, written to be read, not to be survived.

1. Where we stand

Luma is built privacy-first. This marketing website collects no personal data at all. The Luma service does handle guest information, because a concierge cannot bring towels to room 412 without knowing it is room 412, but it handles that information on the hotel's behalf and under the hotel's instruction, never for our own purposes. We do not sell data, we do not run advertising, and we operate in line with the EU General Data Protection Regulation (GDPR).

2. What this website collects

Nothing. There are no tracking cookies, no advertising pixels, and no hidden analytics building a profile of you. You can read every page without giving us anything about yourself.

If you choose to contact us or book a demo, you share only what you type, typically your name, your hotel, and your email. We use that solely to reply and arrange the demo.

3. The Luma service: our role, and the hotel's

When a hotel runs Luma, the hotel is the data controller, it decides why guest data is collected and what happens to it. Luma is the data processor: we hold and process that data only to deliver the service the hotel asked for, and only on its instruction.

That distinction matters, so we will be precise about it rather than claim more than is true: the service does process personal data. It is not repurposed, not profiled for anyone else, not sold, and not used for advertising. The full processing detail is in our Data Processing Agreement.

4. What Luma holds about a guest

Only what is needed to answer the guest and get the request to the right team:

• The guest's name, room number and email, which the guest enters once so Luma can match them to their reservation
• The dates of the stay, from the hotel's own reservation system
• A phone number, only if the guest chooses to give one (for example, to be called back)
• The language the guest chooses to speak
• What the guest asked for, and the outcome: a request, an order or a booking
• Preferences the guest volunteers, so a returning guest does not have to repeat themselves

The guest reaches Luma by scanning the QR code on their key-card holder. Nothing to download, no password to create.

5. Consent, and what a guest can ask for

Before anything is stored, a guest confirms they have read the hotel's privacy notice, and the service enforces that on the server, not only in the interface. Receiving offers is separate: marketing consent is its own optional tick box, never assumed, never inferred from the first. Health details, such as an allergy, are kept for the stay only if the guest explicitly says yes, and the guest can remove them at any time. The guest is always told they are talking to an AI.

A guest can ask to see, correct, or delete what is held about them at any time, and to object to its use. We act on those requests promptly and free of charge, together with the hotel.

6. No one reads what guests say to Luma

This is worth stating on its own. No one at the hotel, and no one at Luma, reads a guest's conversation. There is no screen for it, for any role. Hotel staff see only the outcome: the request with its room and team, the order, the booking, and summary numbers.

The one exception is an investigation the hotel asks for in writing, such as a guest complaint. Conversation text may then be shared with named hotel managers only, on request, within the retention period. The request is confirmed by phone, the report carries no guest name, it cannot be downloaded, every opening is logged, and it is deleted after 72 hours.

The text of a conversation is kept only so Luma can follow it during the stay and note the guest's preferences, and it is deleted after 7 days. If a guest wants to speak to a person, they ask to be called back, and the front desk calls them.

7. What we never do

We do not sell, rent, or trade data. We do not share it with third parties for marketing or any other commercial purpose. There is no data broker anywhere in our business model, and there never will be. Guest content is sent to our technology providers only to produce the guest's answer, and for no other purpose.

8. Security

Data is encrypted in transit. Guests' names, email addresses and phone numbers are encrypted at rest with AES-256-GCM, and conversation text is encrypted with its own separate key. The database is hosted in the EU (Ireland). Each hotel is isolated at the database row level, so one hotel can never see another's data, and staff access is scoped to the role and department a person actually works in.

Some things are deliberately kept away from the AI model entirely. The Wi-Fi password and the room safe code are shown on the guest's screen only, they are never spoken aloud and never sent to the model.

9. Who else is involved

Running a voice concierge means using specialist providers, for the language model, for speech, for hosting and for messaging. Every one of them is named, with what it does and where it runs, in our Data Processing Agreement. We will tell a hotel before we add or change one.

10. How long data is kept

We keep guest data only as long as the hotel needs it for the purpose it was given, and delete it on request. The text of conversations is deleted after 7 days. A guest's profile is deleted 12 months after their last check-out, unless the hotel sets a different period. When a hotel stops using Luma, it gets a full export and we delete its data from live systems within 30 days, and from backups on their normal rotation.

11. Contact

If you send us an enquiry through the contact form on our website, we use what you enter (your name, work email, company and message) only to reply to you. Form submissions are stored with our website host, Netlify, and are never shared or used for marketing lists.

Questions about privacy, or a request about your data? Reach us at ari@hey-luma.com and we will respond quickly.