What can I do about this clause?

{'method': 'EMAIL', 'recipient': 'support@lumalabs.ai', 'difficulty': 'MODERATE', 'action_type': 'DELETE_DATA', 'instructions': "Contact support@lumalabs.ai to request data deletion and ask specifically what personal data remains in Luma's systems, models, or Aggregated Data after account deletion. For EU users, reference your GDPR Art. 17 right to erasure in your request.", 'deadline_days': None, 'deadline_hours': None}

Which regulatory agencies enforce this type of clause?

{'agency': 'FTC', 'reason': 'The post-deletion license retention may constitute an unfair practice under FTC Act Section 5 if consumers are not clearly informed that account deletion does not remove their data from AI models.', 'complaint_url': 'https://reportfraud.ftc.gov/'}, {'agency': 'State_AG', 'reason': 'California residents can raise CCPA §1798.105 deletion right violations — including AI model retention — with the California Attorney General or CPPA.', 'complaint_url': 'https://www.naag.org/find-my-ag/'}

What is the severity of this clause?

ConductAtlas classifies this Account Deletion Does Not Revoke Incorporated Licenses clause as high severity. Severity reflects the magnitude of rights affected, the breadth of users impacted, and the degree of discretion the platform retains.

Account Deletion Does Not Revoke Incorporated Licenses — Luma AI

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What it is

Deleting your Luma account does not take back the rights you gave Luma to use your uploaded content — once your content has been used in their AI systems, that license is permanent.

Consumer impact (what this means for users)

Deleting your Luma account will not remove your content from Luma's AI models or aggregated datasets — your photos, videos, and other uploads remain licensed to Luma permanently after deletion.

What you can do

⚠️ These actions may provide transparency or partial mitigation but may not fully address the underlying issue. Effectiveness varies by jurisdiction and individual circumstances.

Delete Your Data

Contact support@lumalabs.ai to request data deletion and ask specifically what personal data remains in Luma's systems, models, or Aggregated Data after account deletion. For EU users, reference your GDPR Art. 17 right to erasure in your request.

Cross-platform context

See how other platforms handle Account Deletion Does Not Revoke Incorporated Licenses and similar clauses.

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Why it matters (compliance & risk perspective)

Users who believe deleting their account will stop Luma from using their data and content will be incorrect — the license to previously incorporated content survives account deletion indefinitely.

View original clause language

Note that deletion of your Account does not affect any licenses you have granted to Luma under this Agreement with respect to Input or Output that has already been incorporated into Luma's systems, models, or Aggregated Data prior to deletion.

Institutional analysis (Compliance & legal intelligence)

(1) REGULATORY FRAMEWORK: This provision directly conflicts with GDPR Art. 17 (right to erasure/'right to be forgotten'), which requires erasure of personal data upon request subject to limited exceptions. Luma's reliance on incorporated AI model weights as justification for non-erasure is a contested legal theory not yet definitively resolved by EU courts or the EDPB. CCPA §1798.105 similarly grants California consumers the right to request deletion, and the CPPA has signaled that incorporation into AI models is not a blanket exemption. The EDPB's Guidelines 05/2019 on the criteria of the Right to be Forgotten in search engine cases provide partial analogous guidance. (2)

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Applicable agencies

FTC

The post-deletion license retention may constitute an unfair practice under FTC Act Section 5 if consumers are not clearly informed that account deletion does not remove their data from AI models.
File a complaint →
State AG

California residents can raise CCPA §1798.105 deletion right violations — including AI model retention — with the California Attorney General or CPPA.
File a complaint →

Provision details

Document information

Document

Luma AI Terms of Service

Entity

Luma AI

Document last updated

April 29, 2026

Tracking information

First tracked

April 30, 2026

Last verified

April 30, 2026

Record ID

CA-P-004096

Document ID

CA-D-00498

Evidence Provenance

Source URL

https://lumalabs.ai/legal/terms-of-service

Wayback Machine

View archived versions →

SHA-256

02f560c92743c63df6d2a70301fb351f22e67ae3d3fcf238d7628d14693722b9

Verified

✓ Snapshot stored ✓ Change verified

How to Cite

ConductAtlas Policy Archive
Entity: Luma AI | Document: Luma AI Terms of Service | Record: CA-P-004096
Captured: 2026-04-30 06:05:56 UTC | SHA-256: 02f560c92743c63d…
URL: https://conductatlas.com/platform/luma-ai/luma-ai-terms-of-service/account-deletion-does-not-revoke-incorporated-licenses/
Accessed: May 2, 2026

Classification

Severity

High

Account Deletion Does Not Revoke Incorporated Licenses