Luma AI · Luma AI Privacy Policy · View original document ↗

Broad Device and Usage Data Collection

Medium severity High confidence Explicitdocumentlanguage Unique · 0 of 325 platforms
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Document Record

What it is

Luma collects detailed technical information about your device, including advertising identifiers, installed applications, CPU usage, and network type, every time you use its services.

This analysis describes what Luma AI's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

The collection of advertising identifiers and application installation data alongside usage behavior enables detailed user profiling that goes beyond basic service delivery.

Consumer impact (what this means for users)

Luma automatically collects a detailed set of device signals, including identifiers used for advertising, your installed applications, and network details. This data, combined with usage and location information, could support detailed user profiling for advertising or analytics purposes, though the policy does not specify all downstream uses.

How other platforms handle this

Robinhood Medium

Geolocation data, such as device location. Internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer's interaction with an internet website, application, or advertisement. Device identifiers, such as IP address, unique d...

PlanetScale Medium

When you visit the Careers portion of our websites, we collect the information that you provide to us in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history and other in...

American Airlines Medium

American does not knowingly collect personal information directly from children – persons under the age of 13, or another age if required by applicable law – other than when required to comply with the law or for safety and security reasons. Due to the nature of our Services, we may collect travel i...

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▸ View Original Clause Language DOCUMENT RECORD
"
Device data. We receive information about the device and software you use to access our Services, such as your computer's or mobile device's operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier and manufacturer, radio/network information (e.g., WiFi, LTE, 4G), application installations, and push notification tokens.

— Excerpt from Luma AI's Luma AI Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

REGULATORY LANDSCAPE: The collection of advertising identifiers engages GDPR Article 6 and the ePrivacy Directive for EEA users, particularly regarding consent for device-based tracking. CCPA's definition of personal information encompasses unique identifiers and device data. The FTC Act is relevant to representations about how advertising identifiers are used. The EU AI Act may require evaluation if device data contributes to automated profiling that has significant effects on users. GOVERNANCE EXPOSURE: Medium. The breadth of device data collected, particularly advertising identifiers and application installation lists, is on the more expansive end of common industry practice for a creative AI platform. The policy references a Cookie Policy for further detail on tracking technologies but does not fully specify the purposes for which advertising identifiers are used. JURISDICTION FLAGS: EEA and UK users have the strongest rights regarding consent for advertising identifier use under the ePrivacy Directive and GDPR. California users may exercise CCPA rights to opt out of sharing unique identifiers with third parties for advertising purposes. Illinois and other states with biometric or device privacy laws may also engage depending on the nature of identifiers collected. CONTRACT AND VENDOR IMPLICATIONS: Enterprises should assess whether employee device data collected through Luma apps is disclosed appropriately in internal privacy notices and whether acceptable use policies address Luma's device data collection practices. COMPLIANCE CONSIDERATIONS: Legal teams should review whether the Cookie Policy referenced in this document provides adequate supplemental disclosure for tracking and advertising identifier use. Consent mechanism audits should verify that device-based tracking consent flows comply with applicable law in key jurisdictions.

Full compliance analysis

Regulatory citations, enforcement risk, and due diligence action items.

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Applicable agencies

  • FTC
    The FTC's authority over unfair or deceptive data practices and its oversight of advertising identifier use in consumer-facing platforms is relevant to the breadth of device data collection described.
    File a complaint →

Applicable regulations

EU AI Act
European Union
California AB 2013 AI Training Data Transparency
US-CA
CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
ePrivacy Directive
European Union
FTC Act Section 5
United States Federal
GDPR
European Union
Indiana Consumer Data Protection Act
US-IN
Kentucky Consumer Data Protection Act
US-KY
Universal Opt-Out Mechanism Expansion 2026
US

Provision details

Document information
Document
Luma AI Privacy Policy
Entity
Luma AI
Document last updated
May 5, 2026
Tracking information
First tracked
May 10, 2026
Last verified
May 10, 2026
Record ID
CA-P-009639
Document ID
CA-D-00497
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
6b82cdbfd54f761eeed99a77810eb14dd07a0dbf17a465726af4f6edc82cd38f
Analysis generated
May 10, 2026 20:49 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Luma AI
Document: Luma AI Privacy Policy
Record ID: CA-P-009639
Captured: 2026-05-10 20:49:39 UTC
SHA-256: 6b82cdbfd54f761e…
URL: https://conductatlas.com/platform/luma-ai/luma-ai-privacy-policy/broad-device-and-usage-data-collection/
Accessed: May 14, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

Other risks in this policy

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Frequently Asked Questions

What does Luma AI's Broad Device and Usage Data Collection clause do?

The collection of advertising identifiers and application installation data alongside usage behavior enables detailed user profiling that goes beyond basic service delivery.

How does this clause affect you?

Luma automatically collects a detailed set of device signals, including identifiers used for advertising, your installed applications, and network details. This data, combined with usage and location information, could support detailed user profiling for advertising or analytics purposes, though the policy does not specify all downstream uses.

Is ConductAtlas affiliated with Luma AI?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by Luma AI.