Privacy Policy

Effective as of May 1st, 2026.                                                                                               

This “Privacy Policy” describes the privacy practices of Luminary Cloud, Inc. and our subsidiaries and affiliates (collectively, “Luminary”, “we”, “us”, or “our”) and how we process personal information that we collect through our digital properties that link to this Privacy Policy, including the www.luminary.ai website, (the “Luminary Sites”), as well as through social media, our marketing activities, our events and other activities described in this Privacy Policy. This Privacy Policy also describes the rights and choices available to individuals with respect to their information.  Luminary may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. These supplemental privacy policies will govern how we may process the information in the context of the specific product or service.

This Privacy Policy applies to the personal information we process as a data controller, that is, as the party that determines what personal information to collect and for what purposes. You provide some of this information directly, and we get some of it by collecting information about your interactions, use, and experiences with the Luminary Sites as further explained in this Privacy Policy.

Luminary provides its platform (the “Platform”) as software as a service for high-performance computing, simulation, and analytical services in the fields of engineering and science.  This Privacy Policy does not apply to information that we process on behalf of our enterprise customers while providing the Platform to them. Our use of that information is restricted by our agreements with those enterprise customers. If you use the Luminary Platform through an enterprise customer of Luminary, such as your employer, the processing of your personal information is determined by that customer.  Our enterprise customers are considered data controllers and when we process information on their behalf, it is in accordance with their instructions.  If you use the Platform through a Luminary enterprise customer, the relevant customer’s privacy policy and the agreement between the customer and Luminary apply to the processing of your data, rather than this Privacy Policy.   If you have questions regarding your personal information that we process on behalf of a Luminary enterprise customer, please refer to such customer’s privacy policy and direct your inquiries to such customer or its administrator.

The Luminary Sites are primarily designed for enterprise customers and their representatives. We do not offer products or services for use by individuals for their personal, family or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as business representatives and not their individual capacities.

NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area or United Kingdom (which we refer to as “Europe”, and “European” should be understood accordingly) below.


Table of Contents

Personal Information We Collect

We collect personal information from users (including, as applicable, authorized account administrators) for a variety of reasons, and not all of the below categories of information or sources of information will be relevant to all users.  Rather, the scope and sources of information are dependent upon your engagement and relationship with Luminary.

Information you provide to us.  Personal information you provide to us through the Luminary Sites may include:

Information we obtain from social media platforms. We may maintain pages for the Luminary Sites on social media platforms, such as LinkedIn, Twitter, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

If you choose to login to the Luminary Sites via a third-party platform or social media network, or otherwise connect your account on the third-party platform or network to your account through the Luminary Sites, we may collect information from that platform or network. For example, this information may include your Google or Microsoft usernames. You may also have the opportunity to provide us with additional information via the third-party platform or network, such as a list of your friends or connections and your email address.  You can read more about your privacy choices in the “Third-party platforms or social media networks” portion of the “Your Choices” section.

Information we obtain from other third parties.  We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in learning specifically about our products or services, or the types of products or services we offer. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources (for example, public records) and private sources (for example, social-media platforms and data providers).

Cookies and Other Information Collected by Automated Means

For information about our processing of your personal data via cookies or similar technologies, please see our Cookie Policy.

Referrals

Users of the Luminary Sites may have the opportunity to refer contacts to us. If you are an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

How We Use Your Personal Information

We may use your personal information for the following purposes and as otherwise described in this Privacy Policy or as described at the time of collection:

To operate the Luminary Sites.  We use your personal information to:

For research and development.  We analyze use of the Luminary Sites to improve the Luminary Sites and to develop new products and services, including by studying your use of the Luminary Sites.

To send you marketing and promotional communications.  We may send you Luminary-related marketing communications as permitted by law. You will have the ability to opt-out of our marketing and promotional communications as described in the “Opt out of marketing communications section below.

To comply with law. We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety.  We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Luminary Sites; (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; and (d) audit our internal processes for compliance with legal and contractual requirements or our internal policies.

With your consent.  In some cases we may specifically ask for your consent to collect, use or share your personal information, such as when required by law. 

To create anonymous, aggregated or de-identified data.  We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you.  We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Luminary Sites and promote our business. 

How We Share Your Personal Information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection. 

Corporate Affiliates.  We may share your personal information with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers.  We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate the Luminary Sites (such as customer support, chat providers, hosting, analytics, email delivery, marketing, and database management services).

Affiliated Customers. We may share your personal information with our customers with whom you are affiliated. Your employer may be one of our customers. We do not control how the affiliated customer uses your personal information. Please review the affiliated customer’s privacy policy or enterprise agreement with Luminary to learn more about how it handles your personal information.

Third-party platforms and social media networks. If you have enabled features or functionality that connect the Luminary Sites to a third-party platform or social media network (such as by logging into the Luminary Sites using your account with the third-party, providing your API key or similar access token for the Luminary Sites to a third-party, or otherwise linking your account with the Luminary Sites to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.

Other Users of the Luminary Sites. We may provide functionality that enables you to disclose personal information to other users of the Luminary Sites. You may also be able to submit content to the Luminary Sites, and we may display your name, or username with the content you submit. We do not control how other users or third parties use any personal information that you make available to such users.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance with legal requirements and fraud prevention/safety purposes described above.

Business transferees.  Acquirers and other relevant participants in business transactions (or negotiations and diligence for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Luminary or our affiliates (including, in connection with a bankruptcy or similar proceedings). 

Your Choices

In this section, we describe the rights and choices available to all users.

Access or Update Your Information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.

Opt out of marketing communications.  You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at privacy@luminary.ai.  You may continue to receive service-related and other non-marketing emails. 

Cookies & Browser Web Storage.  We may allow service providers and other third parties to use cookies and similar technologies to track your browsing activity over time and across the Luminary Sites and third-party websites. Most browsers let you remove or reject cookies.  To do this, follow the instructions in your browser settings.  Many browsers accept cookies by default until you change your settings.  Please note that if you set your browser to disable cookies, the websites may not work properly.  Similarly, your browser settings may allow you to clear your browser web storage.  

Privacy settings. We may make available certain privacy settings on the Luminary Sites. Your platform settings may provide the ability for you to make certain content private, and other content accessible to other platform users.

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the Luminary Sites to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services.  We will tell you what information you must provide to receive the Luminary Sites by designating it as required at the time of collection or through other appropriate means.

Third-party platforms or social media networks. If you choose to connect to the Luminary Sites via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third party at the time you login to the Luminary Sites using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third party.

Other Sites, Mobile Applications and Services

The Luminary Sites may contain links to other websites, mobile applications, and other online services operated by third parties.  These links are not an endorsement of, or representation that we are affiliated with, any third party.  In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third-party websites, mobile applications or online services, and we are not responsible for their actions.  Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your personal information.  We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security Practices

The security of your personal information is important to us.  We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect.  However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International Data Transfers

We are headquartered in the United States and may have service providers in other countries, and your personal information may be transferred to the United States or other locations outside of your state, province, or country where privacy laws may not be as protective as those in your state, province, or country.

Children

As a general rule, children are not allowed to use the Luminary Sites, and we do not collect personal information from them. We define "children" as anyone under 13 years old. If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it.  We encourage parents with concerns to contact us.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Luminary Sites. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email (if you have an account where we have your contact information) or another manner through the Luminary Sites.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the Luminary Sites (or as otherwise indicated at the time of posting). In all cases, your continued use of the Luminary Sites after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to privacy@luminary.ai. You may also write to us via postal mail at:

Luminary Cloud, Inc.

Attn: Legal – Privacy

101 S Ellsworth Avenue, Suite 250

San Mateo, CA 94401

Notice to European users

General

Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in the United Kingdom and the European Economic Area (i.e., “Europe” as defined at the top of this Privacy Policy).

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” (as defined in the GDPR) – i.e., information about individuals from they are either directly identified or can be identified.

Controller. Luminary is the controller in respect of the processing of your personal information covered by this Privacy Policy for purposes of European data protection legislation (i.e., the EU GDPR and the so-called ‘UK GDPR’ (as and where applicable, the “GDPR”)). See the ‘How to contact us’ section above for our contact details.

Our legal bases for processing

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

We have set out below, in a table format, the legal bases we rely on in respect of the relevant Purposes for which we use your personal information – for more information on these Purposes and the data types involved, see ‘How we use your personal information’

Purpose Categories of personal information involved Legal basis
To operate the Luminary Sites.
  • Contact information

  • Profile information

  • Financial information

  • Transaction information

  • Information we obtain from other third parties

  • Information we obtain from social media platforms

  • Contractual Necessity

For research and development purposes.
  • Profile information

  • Feedback or correspondence

  • Transaction information

  • Usage information

  • Information we obtain from social media platforms

  • Legitimate interest. We have legitimate interest, and believe it is also in your interests, that we are able to take steps to ensure that our Services and how we use Personal Information is as un-privacy intrusive as possible.

  • Consent, in respect of any optional cookies used for this purpose.

To send you marketing and promotional communications.
  • Contact information

  • Profile information

  • Marketing information

  • Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organisation, including sending through promotional information and other communications.

  • Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given communications, including our newsletter.

To comply with law.
  • Any and all data types relevant in the circumstances

  • Compliance with Law.

  • Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.

For compliance, fraud prevention, and safety.
  • Any and all data types relevant in the circumstances

  • Compliance with Law.

  • Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.

To create anonymous, aggregated or de-identified data.
  • Any and all data types relevant in the circumstances

  • Legitimate interest. We have legitimate interest, and believe it is also in your interests, that we are able to take steps to ensure that our Services and how we use Personal Information is as un-privacy intrusive as possible.

Further uses
  • Any and all data types relevant in the circumstances

  • The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the Personal Information was collected.

  • Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Retention

We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for Compliance and protection purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other info

No sensitive personal information. We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the services, or otherwise to us. If you provide us with any sensitive personal information to us when you use the services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our services.

No Automated Decision-Making and Profiling. As part of our products and services, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.

Your rights

General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

Exercising These Rights. You may submit these requests by email to privacy@luminary.ai or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.

For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en

For users in the UK – the contact information for the UK data protection regulator is below:

The Information Commissioner’s Office

Water Lane, Wycliffe House

Wilmslow - Cheshire SK9 5AF

Tel. +44 303 123 1113

Website: https://ico.org.uk/make-a-complaint/