AkiLora

LUZARN SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ ("Akilora", "we", "our", or "us") respects your privacy. This Privacy Policy explains how we collect, use, store, disclose, and otherwise process personal data when you use the Akilora website, application, checkout flows, and related services (collectively, the "Services").

Akilora is a service that allows users to order training and generation of LoRA models for selected generative image and 3D/video-related base models. This document explains how order-related data may be processed by external infrastructure providers, including providers and hosts located in multiple countries.

By using the Services, you acknowledge this Privacy Policy. Your use of the Services is also subject to our Terms and Conditions.

1. Controller

The controller of your personal data is:

LUZARN SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ
ul. Władysława Jagiełły 16/1
02-495 Warsaw
Poland
KRS: 0000340901
NIP: 1231190797
REGON: 141912737

If you have questions about this Privacy Policy or our processing of personal data, you can contact us at: hello@akilora.com.

2. Scope of this Privacy Policy

This Privacy Policy applies to personal data processed in connection with:

browsing our website,
creating or using an account,
making purchases or using billing features,
submitting training jobs or other order-related requests,
uploading files and entering prompts, trigger words, concept descriptions, and similar job data,
contacting us,
using cookie or tracking preferences,
security, anti-abuse, and compliance activities.

This Privacy Policy does not govern third-party websites, tools, or services that we do not control, even if they are linked from our Services. Please review the privacy policies of those third parties separately.

3. Personal data we collect

We may collect personal data from or about you in the following categories.

A. Data you provide to us directly

Depending on how you use the Services, you may provide us with:

your email address,
account details,
billing-related information,
support messages and any information included in them,
information you submit in connection with orders or jobs, including:
- selected model family or base model,
- concept description,
- concept type information,
- trigger words,
- uploaded files,
- job settings and parameters,
- generated outputs and related workflow data.

Important: Akilora is designed for fictional characters and other materials for which the user has full rights. However, if a user uploads content relating to a real person or other unlawful content, that content may still be processed by us and our service providers to the extent technically necessary to receive, inspect, moderate, block, investigate, or remove it.

B. Data we collect automatically when you use the Services

We may automatically collect certain technical and usage data, such as:

IP address,
browser type and version,
device type,
operating system,
approximate location inferred from IP address,
referring pages,
pages viewed,
timestamps and session activity,
diagnostic, log, and security information,
cookie and consent-preference information.

C. Data we receive from payment providers

If you make a purchase or save a payment method, we and our payment providers may process information related to the transaction, such as:

Stripe customer ID,
payment intent or checkout session identifiers,
transaction status,
subtotal, applicable tax, and total amounts,
billing country or similar billing metadata,
limited billing details made available to us by Stripe,
information about whether a payment method was set up for future off-session charges.

We do not store full payment card numbers in our own systems. Payment card data is handled by Stripe or other payment providers acting on their own systems and according to their own privacy documentation.

D. Data we receive from account and workflow events

When an account is created automatically from checkout or when a job is finalized, we may create and store internal records such as:

internal account identifiers,
generated usernames,
order and workflow payloads,
job identifiers,
billing profile data,
coin balance and top-up events,
refund and dispute-related records,
internal moderation, fraud-prevention, and incident records.

4. Cookies and similar technologies

We use cookies and similar technologies for core functionality, security, and storing your consent preferences. We may also use optional cookies or similar technologies for analytics and advertising if you allow them through our cookie controls.

Based on the current product setup, the cookie categories presented to users may include:

Mandatory cookies: required for security, session handling, and saving your cookie preferences.
Analytics cookies: help us understand usage and improve the Services.
Advertising cookies: may support marketing or campaign measurement if enabled.

Where optional cookies are used, we rely on your consent where required by law. You can manage your cookie preferences through our cookie settings interface.

5. How we use personal data

We may use personal data for the following purposes:

to provide, operate, maintain, and improve the Services,
to create and manage user accounts,
to process purchases, payments, refunds, and billing operations,
to provide coins, auto top-up features, and related billing functionality,
to receive, queue, route, execute, and complete training or generation jobs,
to transmit job-required data to infrastructure or model providers involved in performing your order,
to communicate with you about your account, orders, billing, support, or legal notices,
to personalize or restore workflow state where relevant,
to secure the Services and prevent fraud, abuse, or unauthorized use,
to monitor reliability, debug errors, and maintain system integrity,
to enforce our Terms and other policies,
to investigate complaints, disputes, chargebacks, moderation issues, or legal claims,
to comply with legal obligations,
to establish, exercise, or defend legal claims,
to carry out corporate transactions if our business structure changes.

We may also use aggregated or de-identified information for analytics, product improvement, reporting, and other lawful business purposes.

6. Legal bases for processing under GDPR

If GDPR or similar laws apply, we process personal data on one or more of the following legal bases:

performance of a contract or taking steps at your request before entering into a contract, including account creation, checkout handling, billing, and performing ordered jobs;
our legitimate interests, including operating and securing the Services, preventing abuse, improving the product, maintaining logs, handling support, enforcing our Terms, and protecting our rights;
compliance with legal obligations, including tax, accounting, consumer protection, and law enforcement response obligations;
your consent, where required, including for optional cookies or specific optional processing activities;
establishment, exercise, or defense of legal claims.

If we rely on consent, you may withdraw it at any time, but this will not affect the lawfulness of processing carried out before withdrawal.

7. Who we disclose personal data to

We may disclose personal data to the following categories of recipients, when reasonably necessary for the purposes described in this Privacy Policy:

payment processors and billing providers, including Stripe,
hosting, cloud, storage, compute, and infrastructure providers,
providers and hosts used to execute AI-related workloads and similar infrastructure providers,
software vendors supporting authentication, email delivery, logging, monitoring, security, and internal operations,
professional advisors such as lawyers, auditors, accountants, and insurers,
authorities, regulators, courts, law enforcement, or other third parties where required by law or necessary to protect rights and safety,
acquirers, investors, advisors, or counterparties in connection with an actual or proposed merger, acquisition, financing, sale of assets, or corporate restructuring.

Important note on order execution and external hosts

To perform a user's order, we may disclose not only uploaded files, but also all order-related data reasonably necessary to execute that order. Depending on the workflow, this may include:

reference images or other uploaded materials,
trigger words,
concept descriptions,
selected model or model family,
job parameters,
technical workflow metadata.

These data may be processed by third-party providers and hosts located in multiple jurisdictions. Those providers may not receive your Stripe payment details or your full billing relationship with us, but they may receive the data technically needed to execute your job.

8. International transfers

Akilora is operated from Poland, but our service providers, infrastructure providers, and execution hosts may be located in the European Economic Area, the United States, and other countries.

As a result, your personal data may be transferred to and processed in countries outside your country of residence, including countries that may not provide the same level of data protection as your home jurisdiction.

Where required by law, we take steps intended to provide appropriate safeguards for such transfers, such as:

entering into contractual safeguards where appropriate,
using providers that offer recognized transfer mechanisms,
limiting the scope of transferred data to what is reasonably necessary,
applying technical and organizational measures designed to reduce risk.

Because Akilora may use globally distributed compute and hosting resources to execute jobs, cross-border processing is a material part of how the Services work.

9. Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including:

while your account is active,
while needed to provide the Services,
while needed for billing, tax, accounting, and record-keeping obligations,
while needed to investigate disputes, fraud, abuse, or legal claims,
while required by applicable law,
for a reasonable backup, logging, and security period.

Different categories of data may be retained for different periods. For example:

billing and transaction records may be retained for accounting and tax purposes,
support records may be retained for service and dispute handling,
logs may be retained for security and diagnostics,
uploaded job data and outputs may be retained only as long as operationally needed or as provided in the product and related policies.

If you close your account or request deletion, we may still retain certain data where we have a legal obligation or another lawful basis to do so.

10. Your rights

Depending on the laws that apply to you, you may have the right to:

request access to your personal data,
request correction of inaccurate or incomplete personal data,
request deletion of your personal data,
request restriction of processing,
object to certain processing,
request data portability,
withdraw consent where processing is based on consent,
lodge a complaint with a competent supervisory authority.

You may also be able to delete or modify certain information from within your account, depending on the features made available in the Services.

To exercise your rights, contact us at hello@akilora.com. We may need to verify your identity before responding to your request.

If you are located in Poland, you may lodge a complaint with the President of the Personal Data Protection Office (UODO), or with another competent supervisory authority in your jurisdiction.

11. Children's privacy

The Services are not intended for children, and we do not knowingly collect personal data from children in violation of applicable law. If you believe that a child has provided us with personal data, please contact us at hello@akilora.com so that we can review and take appropriate action.

12. Security

We use reasonable technical and organizational measures designed to protect personal data. These may include access controls, encryption in transit, logging, credential protections, and other security practices appropriate to the nature of the Services.

However, no method of transmission over the Internet or method of electronic storage is completely secure. Therefore, we cannot guarantee absolute security.

13. Third-party services and links

The Services may contain links to third-party websites, products, or services. We are not responsible for the privacy practices of those third parties. Their processing of your data is governed by their own terms and privacy policies.

In particular, payment providers and some infrastructure providers operate under their own privacy frameworks in addition to our own.

If Cloudflare Turnstile is used as part of our security and anti-abuse controls, you can review Cloudflare's Turnstile Privacy Policy here: https://www.cloudflare.com/en-gb/turnstile-privacy-policy/

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make changes, we will post the updated version on this page and update the "Last updated" date above. Where required by law, we may also notify you by e-mail, through the Services, or by other appropriate means.

15. Contact

If you have questions, requests, or concerns regarding this Privacy Policy or our processing of personal data, contact us at:

hello@akilora.com