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

Open-Ended Affiliate and Partner Data Sharing

Medium severity Unique · 0 of 343 platforms
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Document Record

What it is

Luma can share your personal data with any current or future business partners and affiliates for any purpose listed in the policy, including AI training, marketing, and analytics — without naming those parties.

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)

This clause establishes a broad authorization framework for information sharing with third parties without requiring advance notice or user consent for each disclosure. The operational significance depends on how extensively the Privacy Policy defines permissible purposes and which entities qualify as partners or affiliates.

Change history

removed Jun 10, 2026

Removal of explicit partner and affiliate data sharing clause may represent narrowing of permitted disclosures or reframing under different provisions.

View full change record →

Consumer impact (what this means for users)

Your personal data including images, videos, and conversation content can be shared with unnamed future business partners for any purpose in the policy, which consumers cannot meaningfully evaluate or object to at the time of collection.

How other platforms handle this

Target Medium

Loyalty and partner program companies. We share information with our loyalty and partner program companies, like Ulta Beauty and Marriott.

DocuSign Medium

We may share your personal information with third parties in the following circumstances: with service providers who perform services on our behalf; with business partners with whom we jointly offer products or services; in connection with, or during negotiations of, any merger, sale of company asse...

MetaMask Medium

We may share your personal information with our affiliates, meaning entities that control, are controlled by, or are under common control with Consensys. We also share information with service providers who assist in operating our services, subject to confidentiality obligations.

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Monitoring

Luma AI has changed this document before.

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▸ View Original Clause Language DOCUMENT RECORD
"
Partners and Affiliates. We may disclose information we receive to our current or future partners and affiliates for any of the purposes described in this Privacy Policy.

— Excerpt from Luma AI's Luma AI Privacy Policy

ConductAtlas Analysis

Institutional analysis (Compliance & governance intelligence)

(1) REGULATORY FRAMEWORK: This provision implicates GDPR Art. 13(1)(e) (requirement to identify recipients or categories of recipients at time of collection), Art. 6(1)(f) (legitimate interests balancing for third-party sharing), and Art. 44-49 (international transfers if affiliates are outside EEA); UK GDPR equivalent provisions; CCPA/CPRA §1798.115 (right to know categories of third parties with whom data is shared) and §1798.120 (opt-out rights); FTC Act Section 5. Enforced by EU supervisory authorities, UK ICO, CPPA, and state AGs. (2)

Full compliance analysis

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

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Applicable agencies

  • FTC
    The FTC enforces against unfair or deceptive data sharing practices under Section 5 of the FTC Act, including overly broad third-party data sharing authorizations.
    File a complaint →
  • State AG
    California's CPPA and state AG enforce CCPA/CPRA requirements around disclosure of third-party data sharing and opt-out rights.
    File a complaint →

Applicable regulations

CCPA/CPRA
California, USA
Connecticut Data Privacy Act Amendments
US-CT
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
April 30, 2026
Last verified
April 30, 2026
Record ID
CA-P-004291
Document ID
CA-D-00497
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
67674aa1a904b7c68bd20d464b6be4c1e518b1fe7e03c01dfdb4e87cfd26cb78
Analysis generated
April 30, 2026 07:54 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: Luma AI
Document: Luma AI Privacy Policy
Record ID: CA-P-004291
Captured: 2026-04-30 07:54:18 UTC
SHA-256: 67674aa1a904b7c6…
URL: https://conductatlas.com/platform/luma-ai/luma-ai-privacy-policy/open-ended-affiliate-and-partner-data-sharing/
Accessed: June 16, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does Luma AI's Open-Ended Affiliate and Partner Data Sharing clause do?

This clause establishes a broad authorization framework for information sharing with third parties without requiring advance notice or user consent for each disclosure. The operational significance depends on how extensively the Privacy Policy defines permissible purposes and which entities qualify as partners or affiliates.

How does this clause affect you?

Your personal data including images, videos, and conversation content can be shared with unnamed future business partners for any purpose in the policy, which consumers cannot meaningfully evaluate or object to at the time of collection.

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.