Privacy Policy

Effective date: July 29, 2026

1. Introduction

lumingon ("we", "our", or "us") operates the lumingon mobile application (the "App") and the lumingon web portal (lumingon.com). This Privacy Policy explains how we collect, use, and protect your personal information when you use our Services.

lumingon is operated in the Republic of the Philippines and acts as the Personal Information Controller (PIC) for your personal data under the Data Privacy Act of 2012. Our registered business details will be published here upon completion of our Philippine business registration. You may contact our Data Protection Officer (DPO) at any time at dpo@lumingon.com.

By using lumingon, you agree to the collection and use of information as described in this policy.

2. Information We Collect

We collect the following types of information:

• Name — Used for your account profile and displayed on your property listings.
• Email address — Collected through Google Sign-In or Apple Sign-In for authentication purposes.
• Phone number (optional) — If you choose to provide it, your phone number is displayed on your property listings so that interested parties can contact you.
• Photos — Property images you upload or capture when creating listings, and your profile avatar photo.
• Listing content — The details, title, and description you write for a listing, including any text you paste in from elsewhere.
• User ID — A unique identifier generated for authentication and account management.
• Device Data — System information, device identifiers, and attestation tokens collected automatically to protect against fraud, bots, and platform abuse.
• Notification token — If you allow notifications, we store the push token issued by Firebase Cloud Messaging together with your app's Firebase Installation ID, so we can send service notifications to your device and so the same device is not messaged more than once. Declining notifications does not affect any other feature.
• Crash logs & Analytics — Collected automatically to help us identify and fix technical issues and track feature usage to improve app stability and user experience.

Publicly Sourced Board-Passer Registry Data

The App includes a searchable directory of professional licensure-examination passers (for example, the Real Estate Brokers Licensure Examination). This data is not collected from you; it is compiled from examination results officially published by the Professional Regulation Commission (PRC), which are publicly available records.

• What it contains: The passer's name as published, the examination title, and the examination date — nothing more. We do not add contact details, addresses, or any other personal data to these entries.
• Purpose: To help users find licensed real estate professionals and support due diligence in property transactions.
• Your rights as a listed passer: If you appear in this directory and believe your entry is inaccurate, or you wish to object to its inclusion, contact our DPO at dpo@lumingon.com and we will review and act on your request in accordance with the Data Privacy Act of 2012 (see Section 9).

Publicly Sourced License-to-Sell Registry Data

The App includes a searchable directory of projects with a License to Sell, together with the associated developer names, compiled from lists officially published by the Department of Human Settlements and Urban Development (DHSUD). This information is not collected from you; it is drawn from publicly available records and is provided for general information and due-diligence support only. If a developer name in this directory identifies you as an individual and you wish to request a correction or its removal, contact our DPO at dpo@lumingon.com.

Face Data

When you complete identity verification, lumingon temporarily accesses your device camera to capture a short video. This video is used exclusively to confirm that you are a live person (liveness detection) and is permanently deleted from our servers immediately after the verification check is complete, regardless of the result. We do not generate, store, or share any facial recognition template, biometric identifier, or face embedding. The only data retained is a verified/unverified status flag associated with your account.

• What we collect: An 8-second face video recorded on your device.
• Purpose: Liveness detection only — confirming you are a real person. It is not used for facial recognition or identification.
• Where it is stored: Uploaded to a temporary, encrypted location on Google Firebase servers.
• How it is analyzed: The automated check is performed by Google's Gemini AI service, which processes the video (and your scanned ID image) solely to complete the verification.
• Retention: Permanently and automatically deleted immediately after verification completes (whether it passes or fails).
• Sharing: Never shared with advertisers, data brokers, or any third party. Not retained by us.

AI Assistance in the Listing Composer

When you post a listing, you can ask lumingon to help you write it. These features are optional — you can always type a listing yourself — and they work as follows:

• "Improve with AI" / "Write it for me": the title and description you have written (if any), together with the structured facts already entered for that listing (such as location, price, size, and features), are sent to Google's Gemini AI service, which returns suggested listing copy.
• "Paste your listing": if you paste an existing write-up (for example from a Facebook Marketplace post), the pasted text is sent to Gemini so its fields can be read out and pre-filled into the form. Contact details are stripped from the copy that is returned into the listing.
• Purpose and retention: the text is processed only to fulfil that single request. We do not use it to train AI models, and we do not retain the request beyond ordinary short-term operational logging.
• Your responsibility: please do not paste other people's personal information into the composer. You remain responsible for the accuracy of any listing you publish, including copy that was drafted or pre-filled with AI assistance.

Listing Engagement Measurement

So that property owners can see how their listings perform, lumingon records engagement events when you interact with a listing — both in the app and on listing pages at lumingon.com (including visits that arrive through a shared listing card or by scanning a listing's QR code).

• What is recorded: the listing involved, the kind of interaction (for example: viewed, saved, shared, contacted the owner, or visited the owner's profile), the date and time, your device platform, how you arrived at the listing (for example: the app, the website, a shared card, or a QR scan), and — in the app — your approximate location (city, region, and country, estimated from your network connection). Website visits do not record your location.
• What the listing's owner sees: aggregate statistics (counts, rates, and city-level summaries). For contact events, the owner also sees the time of the contact and the approximate city it came from — which corresponds to the conversation you are choosing to start with them. Owners are never shown your name, account, or any direct identifier through these statistics.
• Your identity: if you are signed in, your interactions are linked to your account internally (for example, so repeat views are not over-counted), but they are only ever presented to owners in pseudonymous or aggregate form. An owner's own interactions with their own listing are excluded.
• Purpose: providing listing owners with performance insights, improving search and feed relevance, and protecting the platform against abuse. This data is not sold or shared with advertisers.

3. Camera and Media Access

The App requests camera and photo-library access for two separate purposes:

• Identity verification: the camera records the short liveness video and captures your ID. Nothing from this session is stored beyond the verification check itself (see Face Data above).
• Property listings and your profile: you can capture a photo with the camera or choose one from your photo library to attach to a listing or to use as your profile avatar. These images are stored, and listing images are published publicly with the listing (see Section 4).

4. Information Sharing and Public Visibility

We do not sell, trade, or share your personal information with third parties for advertising or marketing purposes.

When you create a property listing, your contact details (phone number and/or WhatsApp number) are visible to other users so that buyers can reach you about your property.

Your listings and public profile are published on the open web. lumingon is not an app-only marketplace. Content you publish is also served as a public page on lumingon.com:

• Listings — every active, visible listing has a public page at lumingon.com/property/… showing its photos, details, and the name, avatar, role, and verification status of the broker or agent who posted it.
• Broker and agent profiles — verified brokers and agents have a public page at lumingon.com/broker/… showing their name, avatar, company, areas served, and active listings. Your PRC licence number appears only if you switch on "Show license number publicly" — it is off by default.
• Search engines and AI answer engines — these pages are intended to be found. They are listed in our sitemap and may be indexed by search engines and read by AI assistants and answer engines, which may reproduce or summarise them.
• Shareable cards and links — listings can be shared as an image card or QR code that links back to the public listing page.

How to limit this. Switching off "List me in the directory" removes you from the in-app directory, from broker search, and from our sitemap, so your profile is no longer surfaced or submitted for indexing. Your profile page and your listings remain reachable to anyone who has a direct link, so that buyers who open your listing can still contact you. Deleting a listing removes its public page; deleting your account removes both (see Section 6).

Public-record directories. The board-passer, License to Sell, and developer directories described above are also published as public pages on lumingon.com (for example lumingon.com/board-passers/…), one per record, and are similarly indexable. These pages reproduce only what the PRC or DHSUD has officially published, and each carries its source and a correction contact. If you are named on one of these pages and wish to request a correction or removal, contact our DPO at dpo@lumingon.com.

We may share information if required by law or to protect the rights and safety of our users.

5. How We Use Your Information

We use the information we collect to:

• Create and manage your account
• Display your property listings to other users
• Allow potential buyers to contact you about your listings
• Perform identity and liveness checks to ensure listing safety and authenticity
• Moderate property listings using automated moderation tools (e.g., analyzing description texts and images for placeholders, compliance, and safety policy violations)
• Protect our platform against security threats, spam, and abuse
• Send you transactional (service) emails — for example a welcome/verification confirmation, verification-renewal reminders, listing status updates, inquiry notifications, and broker–agent link updates. These are operational messages about your account and activity; we do not send marketing email without your consent.
• Send you push notifications about the same kinds of events (for example when a listing is approved or rejected, when a buyer enquires, when a broker–agent link changes, or when your verification is about to expire), if you allowed notifications. You can turn notifications off at any time in your device settings; doing so does not affect anything else in the App.
• Generate or improve listing copy on request, and read a listing write-up you paste in so its fields can be pre-filled (see AI Assistance in the Listing Composer, above)
• Conduct A/B testing and analyze feature usage to improve the user experience
• Provide customer support

The short face video used for liveness detection is processed only to confirm that you are a real, live person, and is permanently deleted immediately after the check completes. We do not create, store, or share any facial-recognition template or biometric identifier.

6. Data Retention

We retain your personal data only for as long as your account remains active and for as long as needed to provide the Services. Verification media is deleted immediately upon completion of the check. You may delete your account and all associated data at any time from within the App.

You can delete your account and all associated data at any time from within the App. When you delete your account, the following data is permanently removed:

• Your profile information (name, email, phone number, avatar)
• All property listings you have created
• All property images you have uploaded
• Your saved properties list
• Your notification tokens, so the deleted account can no longer be messaged

If you are an agent linked to a supervising broker, that link is cleared and your broker is notified before the account is removed, so their team list stays accurate.

All personal identifiers and verification status flags tying you to the account are permanently erased or fully anonymized to ensure your privacy. This action is irreversible.

Some data has its own lifecycle:

• Unfinished listing drafts are stored on your own device, not on our servers. They are removed when you publish or discard the draft, and when you delete the App.
• Notification tokens are removed when a device stops being used (we prune tokens that have gone unused for 30 days, and any token the notification service reports as invalid).
• Moderation and rate-limit records — a minimal record of listing-review outcomes and request counts is kept so the daily caps and the temporary posting pause described in our Terms can be enforced.

7. Third-Party Services

lumingon uses the following third-party services to support security, authentication, and analysis:

• Firebase Authentication — for secure user authentication (Google and Apple Sign-In)
• Firebase Data Connect — for storing application data
• Firebase Storage — for storing images
• Firebase App Check — for securing our API endpoints and verifying authentic app requests
• Firebase Analytics — for collecting anonymous app usage stats
• Firebase Remote Config — for dynamically updating app content and behavior
• Firebase Cloud Messaging and Firebase Installations — for delivering push notifications to your device and identifying that installation so it is not messaged twice
• Google Gemini (AI) — for automated analysis during identity verification (reading your scanned ID and checking the liveness video), automated listing moderation, and the optional listing-copy assistance described in Section 2. Verification media is processed solely for the check and is not used to identify you across other services.
• Resend — for delivering transactional emails (e.g., verification confirmations and reminders, listing status updates, inquiry notifications). Resend processes your email address, name, and the content of these service messages solely to deliver them.

These services are operated by Google or their respective providers and are subject to their own Privacy Policies. Google Firebase, Google Gemini, and Resend act as data processors on our behalf and process personal data only on our instructions.

8. Data Storage and Security

Your data is stored securely using Firebase services provided by Google. All data is encrypted in transit using HTTPS/TLS.

Authentication is handled through secure social providers (Google/Apple) via Firebase Authentication, which provides industry-standard security.

Property images and profile photos are stored in Firebase Storage with access controls in place.

Cross-border data transfer: Our infrastructure is provided by Google Firebase, and your data may be stored or processed on servers located outside the Philippines (for example, in Singapore and other Google data center regions). Where personal data is transferred abroad, lumingon remains accountable for its protection and takes reasonable steps to ensure it is handled in accordance with the Data Privacy Act of 2012 and the standards described in this policy. By using lumingon, you consent to this cross-border processing.

9. Your Rights under the Data Privacy Act of 2012

Under the Philippine Data Privacy Act of 2012 (R.A. 10173), you have the following rights regarding your personal data:

• Right to be informed: You have the right to know how your data is being processed.
• Right to object: You can object to the processing of your personal data.
• Right to access: You can request a copy of the personal data we hold about you.
• Right to rectification: You can correct any inaccurate or incomplete data.
• Right to erasure or blocking: You can request the suspension, withdrawal, or removal of your personal data.
• Right to damages: You may claim compensation if you suffered damages due to a violation of your data privacy rights.
• Right to data portability: You can obtain and electronically move, copy, or transfer your data in a secure manner.

If you believe your rights have been violated, you have the right to file a complaint with the National Privacy Commission (NPC).

10. Children's Privacy

lumingon is not intended for use by children under the age of 18. We do not knowingly collect personal information from children. If we become aware that a child under 18 has provided us with personal information, we will take steps to delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy within the App and updating the effective date above.

We encourage you to review this Privacy Policy periodically.

12. Contact Us

If you have any questions about this Privacy Policy or your data, please contact us at:
General Inquiries: support@lumingon.com
Data Protection Officer (DPO): dpo@lumingon.com