1. Who we are
BabyLumi (“we”, “us”) is an independent project that operates the Service at babylumi.app and the @BabyLumiBot Telegram bot. For GDPR purposes we act as the data controller for personal data processed through the Service. You can reach the controller at privacy@babylumi.app.
2. Data we collect
We collect only what is needed to run the Service:
- Account identifiers — your Telegram user ID and/or email, optional display name and avatar.
- Uploaded photos — the parent photos you submit for a generation. They show facial features and are processed only to produce your result. By uploading a photo you confirm that you are 18 or older and have the right to use it; the checkout screen asks you to tick this and we record the answer with your order.
- Childhood photo (optional) — a photo of yourself as a child, for the optional “Mom at 3 and the baby at 3” comparison card. You upload it yourself and confirm that it is a photo of you. It passes the same automated safety check as parent photos.
- Pet photo (optional) — if you add one to a Family or Album order, a photo of your pet.
- Generated content — the photos, videos, traits prediction and storytelling we generate for you, including a short growing-up video assembled from the generated portraits (no extra photos or data are involved).
- Friends poll (optional) — the owner of a result can turn on a poll on its shared page. A vote is stored as a one-way hash of a browser token (or, if the browser keeps none, of the IP address and user agent) together with the choice made. The names shown in the poll are typed by the owner and are public on that page. The poll shows no parent faces.
- Usage and technical data — request timestamps, IP address, approximate country, browser/device type, and credit balance.
- Payment metadata — order ID, amount, currency, status, and the last 4 digits of the card if applicable. We never see or store full card numbers.
- Support correspondence — messages you send us via email or the Telegram bot.
What we never collect or infer: health, medical or genetic data. The trait descriptions and “DNA profile” are built only from what is visible in the uploaded photos and are entertainment, not diagnostics — see how it works.
3. How we use your data
We use your data to deliver the Service: generate baby photos and videos, manage your credit balance, process payments, prevent abuse, and provide support. Aggregated, non-identifying statistics (e.g. average generation time) may be used for monitoring and capacity planning.
4. Photo storage & retention
Photos and generated outputs are stored encrypted in Cloudflare R2 (EU jurisdiction). Retention rules are enforced automatically:
- uploaded parent photos: deleted within 30 days after generation;
- your own childhood photos for the optional “Mom at 3 and the baby at 3” comparison card: you upload them yourself and confirm they are photos of you. They are kept for 30 days together with your parent photos and the card made from them, and deleted with them, or earlier when you remove a photo or delete your account. They are never used to train models or to generate portraits;
- pet photo (optional): deleted together with the parent photos, within 30 days after your order is created (an Album’s follows the Album’s schedule below);
- generated photos and videos (the short growing-up video included): kept for 30 days, then deleted automatically;
- Album pack, private family page: its photos and film are kept until you delete the page or 12 months after your last sign-in, whichever comes first (every sign-in extends it); we email you a week before deletion;
- optional “Called It” capsule: only if you choose to add a due date to a generation, we keep the date and a small (≤512px) thumbnail of the generated baby — never your uploaded photos — for 120 days after the due date, so you can compare the prediction with your real child. Reminder emails are sent only if you tick the reminder box (at most two, after the due date). You can delete the capsule at any time on the result page; if you made a comparison, its thumbnail stays with the comparison until you delete the capsule or your account;
- friends poll (optional): the votes are kept as long as the generation exists and are deleted with it;
- encrypted backups: 30 days, rolling;
- application logs: 3 days.
Account-level data (email, Telegram ID, credit balance, payment history) is kept for as long as your account is active and as required by accounting law after deletion.
5. We don’t train models on your photos
Your photos and the images we generate are never used to train, fine-tune, or evaluate AI models by us. The sub-processors listed below receive the photos only to produce your result. Facial features are processed for one purpose only: to generate your result. A childhood photo (see section 4) is never given to an image-generation model: it is only placed next to a portrait on the comparison card. The photos themselves are deleted automatically (see section 4), and you can delete your account and everything we hold at any time.
6. Sub-processors
We rely on a small set of vetted providers. Each receives only the minimum data needed for its function:
- Hetzner Online GmbH (Germany) — primary hosting and database.
- Cloudflare, Inc. — DNS, CDN, bot protection, and R2 object storage (EU jurisdiction). Cloudflare Turnstile may receive your IP and a verification token during anti-bot checks.
- Black Forest Labs (FLUX.2 Klein) — image generation. Receives the parent photos (and the pet photo, if any) and a generation prompt for the duration of inference. No account identifiers are sent. Per provider policy, content is processed for inference only and is not retained or used for training.
- Anthropic (Claude) — analysis of facial traits to build the generation prompt. Receives the parent photos for inference only; no account identifiers. The same model runs the automated safety check on every uploaded photo, a childhood or pet photo included.
- Kling AI — video generation, used only when you purchase a video pack. Receives the cover photo and a generation prompt for the duration of inference.
- Whop, Inc. — payment processing for card checkout on the web. We receive only order metadata, never card details.
- Telegram Messenger Inc. — when you authenticate via Telegram or pay with Telegram Stars, Telegram processes the corresponding identifiers and payment per its own policy.
We do not use third-party analytics, advertising, or retargeting services. All product metrics are computed from our own database.
7. International transfers
Primary processing happens in the European Economic Area. Some sub-processors (Cloudflare, Black Forest Labs, Anthropic, Kling AI, Whop, Telegram, Google) operate globally, including in the United States. Where data leaves the EEA, we rely on EU Standard Contractual Clauses and the EU–US Data Privacy Framework where the receiving party is certified.
8. Cookies & local storage
We use a minimal set of cookies and browser localStorage entries — see the Cookie Policy for the full list and how to manage your consent.
9. Your rights (GDPR)
If you are in the EEA, the UK, or Switzerland, you have the following rights regarding your personal data:
- Access — request a copy of the data we hold about you.
- Rectification — ask us to correct inaccurate data.
- Erasure — delete your account (see below) or ask us to remove specific data.
- Portability — receive your data in a structured, machine-readable format. Self-service: “Download my data” in the profile menu gives you a zip with every photo, result and record we hold, immediately and without writing to us.
- Objection / restriction — object to or restrict certain processing.
- Withdraw consent — at any time, without affecting earlier lawful processing.
- Lodge a complaint with your local supervisory authority.
To exercise any right, write to privacy@babylumi.app. We respond within 30 days. We may ask for additional information to verify your identity.
10. Account deletion · right to erasure
You can permanently delete your BabyLumi account at any time — there’s a “Delete account” button in the profile menu (download a copy first with “Download my data” if you want to keep it). On confirmation, within one minute we:
- erase all uploaded photos from R2 storage;
- delete all generations, videos, and trait predictions;
- clear personal identifiers from your profile (email, Telegram ID, display name, avatar);
- retain payment records in anonymised form, as required by accounting law, with no link to your identity.
Deletion is irreversible. The same Telegram ID or email can be used to register a new account, but the old data will not return.
11. Lawful bases
We process personal data on the following bases:
- Contract — providing the Service, payments, support.
- Consent — processing of biometric data (face features) for generation; analytics cookies. You can withdraw consent at any time.
- Legitimate interest — preventing fraud and abuse, maintaining technical stability of the Service.
- Legal obligation — accounting and tax law for payment records, responding to lawful requests.
12. Security
All traffic is encrypted in transit (TLS). Storage is encrypted at rest. Access tokens are short-lived JWTs with refresh-token rotation. We apply rate limiting, anti-enumeration on auth endpoints, and bot protection on payment forms. No system is perfectly secure, so we encourage you to use a unique password if you sign in with email.
13. Age requirement
The Service is for users aged 18 and over. We do not knowingly collect personal data from minors. If you believe a minor has used the Service, contact privacy@babylumi.app and we will delete the account.
14. Changes to this Policy
We may update this Policy. Material changes will be announced on this page and, where appropriate, by email or in-app notice at least 14 days before they take effect.
15. Contact
Privacy questions and rights requests: privacy@babylumi.app. General support: support@babylumi.app, or via the Telegram bot.