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Your GDPR Rights

Last Updated: March 1, 2025  |  Applicable to EEA, UK, and Switzerland residents

Your rights at a glance: If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, the General Data Protection Regulation (GDPR) gives you specific rights over your personal data. You can access, correct, delete, restrict, or export your data at any time — and we must respond within 30 days.

1. Who Is the Data Controller?

Limora, Inc. is the data controller responsible for your personal data. Our contact details are:

  • Company: Limora, Inc.
  • Address: 2261 Market Street #4667, San Francisco, CA 94114, USA
  • Email: privacy@limora.app
  • Data Protection Officer (DPO): dpo@limora.app
  • EU Representative: eu-rep@limora.app

2. Your Rights Under GDPR

2.1 Right of Access (Article 15)

You have the right to obtain confirmation of whether we process your personal data and, if so, to receive a copy of that data along with information about:

  • The purposes of the processing
  • The categories of data concerned
  • The recipients or categories of recipients
  • The planned retention period
  • Your rights to rectification, erasure, restriction, and objection
  • The right to lodge a complaint with a supervisory authority
  • Any available information about the source of the data

How to exercise: Go to Settings → Privacy → My Data → Download My Data in the app, or email privacy@limora.app with "Data Access Request" in the subject line.

2.2 Right to Rectification (Article 16)

You have the right to have inaccurate personal data corrected without undue delay. You also have the right to have incomplete personal data completed.

How to exercise: Update your details directly in Settings → Account in the app, or contact us at privacy@limora.app.

2.3 Right to Erasure / "Right to Be Forgotten" (Article 17)

You have the right to request deletion of your personal data where:

  • The data is no longer necessary for the purpose it was collected
  • You withdraw consent and there is no other legal basis for processing
  • You object to processing and there are no overriding legitimate grounds
  • The data has been unlawfully processed
  • Erasure is required to comply with a legal obligation

How to exercise: Go to Settings → Privacy → My Data → Delete My Account, or email privacy@limora.app with "Erasure Request" in the subject line. We will complete deletion within 30 days and confirm once done.

Note on photos: Uploaded photos are automatically deleted 30 days after portrait generation. You can request immediate deletion at any time from within the app.

2.4 Right to Restriction of Processing (Article 18)

You have the right to request that we restrict (pause) the processing of your personal data in certain circumstances:

  • While you contest the accuracy of the data
  • Where processing is unlawful but you prefer restriction over erasure
  • Where we no longer need the data but you require it for legal claims
  • While we assess your objection to processing

How to exercise: Email privacy@limora.app with "Restriction Request" in the subject line.

2.5 Right to Data Portability (Article 20)

You have the right to receive your personal data in a structured, commonly used, and machine-readable format (JSON or CSV), and to transmit that data to another service, where:

  • Processing is based on your consent or a contract
  • Processing is carried out by automated means

How to exercise: Go to Settings → Privacy → My Data → Export My Data in the app. Your data export will be available to download within 7 days.

2.6 Right to Object (Article 21)

You have the right to object to processing of your personal data where it is based on legitimate interests or for direct marketing purposes. If you object to direct marketing, we will stop processing your data for that purpose immediately.

How to exercise: Unsubscribe from marketing emails using the link at the bottom of any email, or contact us at privacy@limora.app.

2.7 Rights Related to Automated Decision-Making (Article 22)

You have the right not to be subject to a decision based solely on automated processing — including profiling — that produces significant legal or similarly significant effects on you. Our AI portrait generation is a creative service and does not make legally significant decisions about you.

2.8 Right to Withdraw Consent

Where we rely on your consent to process your data (e.g., AI training opt-in, marketing emails), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

How to exercise: Settings → Privacy → Consent Management in the app, or email privacy@limora.app.

3. Legal Bases for Processing

We rely on the following legal bases to process your personal data:

  • Contract (Article 6(1)(b)): Processing necessary to provide our AI portrait service, manage your account, and process payments.
  • Legitimate Interests (Article 6(1)(f)): Analytics, fraud prevention, product improvement, and security — balanced against your rights and interests.
  • Consent (Article 6(1)(a)): AI training contributions, marketing communications, and non-essential cookies — where you have given us specific, informed consent.
  • Legal Obligation (Article 6(1)(c)): Where required to comply with applicable laws.
  • Vital Interests (Article 6(1)(d)): In rare circumstances where necessary to protect life.

For biometric data (facial photos), we rely on your explicit consent under Article 9(2)(a) of the GDPR.

4. International Data Transfers

As a US-based company, we transfer personal data from the EEA, UK, and Switzerland to the United States and other countries that may not provide the same level of data protection as your home country.

We rely on the following mechanisms to ensure adequate protection:

  • Standard Contractual Clauses (SCCs): EU Commission-approved clauses incorporated into our agreements with service providers.
  • UK International Data Transfer Agreements (IDTAs): For transfers from the United Kingdom.
  • Adequacy Decisions: Where the destination country has been granted an adequacy decision by the European Commission.

5. Data Retention

  • Photos uploaded: Deleted within 30 days of portrait generation, or immediately on request
  • Generated portraits: Retained until you delete them or close your account
  • Account data: Deleted within 30 days of account deletion
  • Transaction records: Retained for 7 years for financial and legal compliance
  • Support communications: Retained for up to 3 years
  • Anonymised analytics: Retained for up to 26 months

6. Lodging a Complaint

If you are unhappy with how we have handled your personal data or your rights request, you have the right to lodge a complaint with your local data protection supervisory authority:

  • EU: Find your national authority at edpb.europa.eu
  • UK: Information Commissioner's Office (ICO) — ico.org.uk
  • Switzerland: Federal Data Protection and Information Commissioner (FDPIC) — edoeb.admin.ch

We would appreciate the opportunity to address your concerns before you contact a supervisory authority, so please reach out to us first at privacy@limora.app.

7. How to Submit a Rights Request

Fastest route: Most actions (download data, delete photos, delete account, manage consent) can be completed directly in the app under Settings → Privacy → My Data.

To submit a formal GDPR request by email:

  1. Email privacy@limora.app with the subject line that matches your request (e.g., "Data Access Request," "Erasure Request")
  2. Include your full name and the email address associated with your Limora account
  3. Describe your request in detail
  4. We may need to verify your identity before processing the request
  5. We will respond within 30 days (this may be extended by up to 2 additional months for complex requests, with notification)

There is no charge for submitting a rights request unless requests are manifestly unfounded or excessive, in which case we may charge a reasonable fee or refuse the request.

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