Everything you upload or submit to Luma during a paid subscription can be used to train Luma's AI models under a license that never expires and cannot be revoked, even if you later delete your account.
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
The perpetual and irrevocable nature of this license means users cannot meaningfully withdraw consent to AI training use once their Input has been incorporated into Luma's systems or models.
If you upload photos, videos, or text prompts to Luma on a paid plan, Luma can use that content to train its AI indefinitely, and this right persists even after you close your account or request deletion of your data.
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Writer does not use Customer Data to train its AI models without explicit customer permission. Customer Data means the data, content, and information that customers and their end users submit to or through the Services.
We may use the content you provide to us, including prompts and generated images, to train and improve our AI models and services.
Training Datasets. In some cases, we access datasets provided by third parties for our model training purposes. These datasets may include personal data (even if such third parties and Mistral AI use good practices to filter out such personal data), proprietary data, or public data. [...] Data publi...
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"You hereby grant to Luma a worldwide, non-exclusive, irrevocable, royalty-free, fully paid right and license (with the right to sublicense through multiple tiers) to use, host, and store Input provided during an active Subscription Term, solely as reasonably necessary to: (1) provide the Services; (2) derive or generate Usage Data or Output; (3) create and compile Aggregated Data; (4) improve the Services and develop new products and services; (5) create, test, improve, train, or otherwise develop the artificial intelligence or machine learning models, systems, architecture, weights, or related technology used by Luma in connection with the Services; or (6) as otherwise required by Laws, agreed to in writing by the parties, or otherwise permitted herein. The foregoing license will be perpetual and irrevocable with respect to any Input contained, incorporated, embodied, or otherwise reflected in Output, Usage Data, or Aggregated Data.— Excerpt from Luma AI's Luma AI Terms of Service
(1) REGULATORY LANDSCAPE: This provision directly engages GDPR Article 17 (right to erasure) and CCPA deletion rights. The assertion that the license is irrevocable with respect to Input already incorporated into models or Aggregated Data creates a direct tension with these statutory deletion rights. The relevant enforcement authorities are the European Data Protection Authorities and the California Privacy Protection Agency. Where Input constitutes personal data, the assertion that the license survives deletion may conflict with these frameworks, and applicable law may constrain the enforceability of the irrevocability assertion in these jurisdictions. (2) GOVERNANCE EXPOSURE: High. The combination of irrevocability, perpetual duration, and AI model training scope creates significant exposure for organizations deploying Luma in contexts where employees or users submit personal data as Input. The provision's assertion that even post-deletion the license persists for incorporated Input is operationally difficult to reconcile with GDPR erasure obligations and may require specific legal analysis of whether a legitimate interest or contractual necessity basis can sustain continued processing. (3) JURISDICTION FLAGS: EU/EEA users face the highest exposure given GDPR Article 17 tensions. California residents have parallel exposure under CCPA. Illinois users may face additional considerations if biometric data is embedded in submitted images under BIPA. The irrevocable license assertion may be unenforceable as applied to personal data in these jurisdictions, but this depends on enforcement context and has not been judicially determined with respect to this specific agreement. (4) CONTRACT AND VENDOR IMPLICATIONS: Enterprise procurement teams should flag this provision as a potential data processing agreement gap. The sublicensing right through multiple tiers means Input may be shared with undisclosed third-party model vendors. Organizations in regulated industries including healthcare and financial services should evaluate whether their data governance policies permit submission of organizational data under these terms. Standard vendor assessment processes should specifically address this perpetual training license scope. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should conduct a data mapping exercise to identify what categories of personal data may be embedded in Input submitted to Luma. A consent mechanism audit should evaluate whether users are given adequate notice of the AI training use at the point of submission. If Luma is deployed in an EU context, a legitimate interest assessment or explicit consent mechanism may be required to support this processing beyond account deletion. Organizations should evaluate whether a Data Processing Agreement with Luma is required under GDPR Article 28.
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The perpetual and irrevocable nature of this license means users cannot meaningfully withdraw consent to AI training use once their Input has been incorporated into Luma's systems or models.
If you upload photos, videos, or text prompts to Luma on a paid plan, Luma can use that content to train its AI indefinitely, and this right persists even after you close your account or request deletion of your data.
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