The agreement states that deleting a Luma account does not terminate the licenses granted over Input or Output that Luma has already incorporated into its systems, AI models, or aggregated data before the deletion request was made.
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
This provision establishes that the account deletion right does not function as a complete data rights mechanism where Input has already been used in model training or aggregated data. The operational scope of this carve-out depends on Luma's internal data pipeline timelines, which are not disclosed in the document.
Under this clause, users who delete their accounts retain no ability under this agreement to revoke licenses over Input already processed into Luma's AI models or aggregated datasets prior to deletion. The agreement separately states that Luma will cease using personal data for its own purposes upon deletion, subject to retention obligations required by law or the Privacy Policy.
How other platforms handle this
By issuing a chargeback or refund request for Premium subscriptions paid for through a third party, you agree to allow Telegram to release necessary data to that third party regarding your account status and Telegram Premium purchases.
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.
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
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"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.— Excerpt from Luma AI's Luma AI Terms of Service
(1) REGULATORY LANDSCAPE: This provision may create tension with GDPR Article 17's right to erasure, which in certain circumstances requires deletion of personal data used for AI training purposes, subject to exceptions for legitimate interests or legal obligations. The interaction between the contractual irrevocable license carve-out and statutory erasure rights is an active area of regulatory interpretation in the EU. The California Consumer Privacy Act also grants deletion rights that may not be fully addressed by this contractual carve-out. Enforcement authorities include EU data protection authorities and the California Privacy Protection Agency. (2) GOVERNANCE EXPOSURE: High for EU/EEA and California operations. The provision creates a defined limitation on the practical scope of the account deletion right, which may not align with regulatory expectations for data subject rights fulfillment under GDPR or CCPA. The absence of information about pipeline timing (when Input becomes 'incorporated') increases uncertainty about the scope of this limitation in practice. (3) JURISDICTION FLAGS: EU/EEA users face the most significant exposure, as GDPR Article 17 erasure rights apply to personal data processed for AI training with limited exceptions. California residents have statutory deletion rights under CCPA that may not be fully contractually waivable. The enforceability of the carve-out in these jurisdictions requires legal analysis beyond what the document itself establishes. (4) CONTRACT AND VENDOR IMPLICATIONS: B2B customers with data return or deletion obligations in their own downstream contracts should evaluate whether Luma's carve-out creates a gap in fulfillment of those obligations. Vendor assessments should document this limitation explicitly. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should assess whether the Data Subject Rights fulfillment process accounts for this carve-out, and whether privacy notices adequately disclose the limitation on deletion rights with respect to AI-incorporated Input. A data mapping exercise should identify the typical pipeline from Input submission to model incorporation to assess practical exposure windows.
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This provision establishes that the account deletion right does not function as a complete data rights mechanism where Input has already been used in model training or aggregated data. The operational scope of this carve-out depends on Luma's internal data pipeline timelines, which are not disclosed in the document.
Under this clause, users who delete their accounts retain no ability under this agreement to revoke licenses over Input already processed into Luma's AI models or aggregated datasets prior to deletion. The agreement separately states that Luma will cease using personal data for its own purposes upon deletion, subject to retention obligations required by law or the Privacy Policy.
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