Jun 10, 2025

Your privacy is important to us. Please read this policy carefully to understand how we will collect, use, and disclose your personal information, and what choices you have with respect to your personal information.

1. Who We Are

We are Lumos AI, an expert platform enabling people to work when and where they want to enable the acceleration of artificial intelligence. A reference to “Labela”, “Labela AI,” “we,” or “us” is a reference to Lumos AI, Inc. and its affiliates involved in the collection, use, sharing, or other processing of personal information. Where applicable, Labela AI is the controller.

2. Scope and Applicability

This policy describes how Labela AI collects, uses, shares or otherwise processes personal information when you access or use our website (https://labela.ai/) (the “Labela AI Site”) and any other associated mobile or web services, software, platforms or applications made generally available by Labela AI (collectively, Labela AI Systems), attend a Labela AI event, or otherwise interact with us.

3. Personal Information We Collect

As we work with health and life science companies, we take serious consideration of the data. While the laws are different around the world, we define data as any information that is used to identify an individual person. Here’s what we do:

Personal Information You Provide Us Directly. We may collect the following personal information you provide directly to us:

Registration information - Personal information we collect when you register for a user account to access Labela AI Systems (your “Account”). This may include your name, address, country of residence, mobile phone number, email address, postal address, and other demographic information, which includes things like background information related to your experience and education. In certain instances, you may be asked to provide proof of your identity, such as a driver’s license, social security number, or other government-issued ID, and location to access or use Labela AI Systems or task on certain projects.
Identity verification information - We and our service providers, like Persona, verify users’ identities and skills to help protect the integrity of the Labela AI Systems and reduce fraud. For this purpose, when you sign up to use Labela and at regular intervals thereafter, we may collect, store, and analyze images and video or audio recordings of you—including selfies and images of your government-issued ID—and use those images and recordings to check your skills or generate information and measurements about your face (“Verification Data”), which may be considered “biometric” data or “sensitive” data under the laws of some jurisdictions. Under certain circumstances, you may have a choice between verification provided by our service provider using your Verification Data and an alternative for verifying your identity. We do not sell, lease, trade, or profit from Verification Data. Your Verification Data will be retained for up to two years after your last interaction with Labela or as required by law. We retain your government identification, the images, and video or audio recordings you provide in accordance with the “Retention and Deletion of Information” section of this Privacy Policy. To request deletion of your images, recordings, or Verification Data, email us at compliance@labela.ai
Your activity when you use our services - Personal information we collect when you use Labela AI Systems and how you use them. We might know, for instance, that you completed the security review or that you undertook and/or completed a task for third-party customers (“Customers”) or performed support services related to such tasks (collectively, “Tasks”). If you submit, upload, publish or otherwise make available text, audio, and/or visual content and information, including commentary, questions, and feedback on Labela AI Systems related to Tasks, support requests, and submission of entries for competitions and promotions (collectively, “User Content”), we may collect your User Content. Depending on the nature of the Tasks you complete, User Content may include information about the qualities and characteristics of your voice, face, and eyes, which may be considered ‘biometric” data and/or “sensitive” data under the laws of some jurisdictions, and may be subject to a separate written data collection agreement between you and us or between you and an Labela client.
Marketing, events, and communications information – Personal information we collect when you express interest in obtaining information about Labela AI Systems, such as by signing up for emails or other communications. This may include things such as your name, email address, mailing address, phone number, title, or company name.
Feedback and support information - Personal information we collect when you contact us for support with your Account, or to notify us of any suspected misuse of Labela AI or violations of applicable law, the Terms of Use, the Community Guidelines, or other applicable policies, including when you contact us at: compliance@labela.ai
Survey Information - Personal information we collect in response to surveys that we may conduct in order to improve Labela AI Systems.
Financial and payment information - Personal information we collect in order to process payment to you or provide tax documentation.

B. Personal Information We Collect From You Automatically. We use tools and services commonly used on the internet, such as log files, cookies, pixel tags, and similar technologies to automatically collect personal information from your devices while you navigate the Labela Site or interact with emails we send to you. In this context, we collect things like IP address, browser or device type, operating system, the website you visited before the Labela Site, and identifiers of your devices. For more information, please also visit our Cookies Policy.

C. Personal Information We Collect From Third Parties. We may also collect personal information from third-party sources. For example: if you create or log into your Account using your Google or Linkedin account credentials, we will access and collect your name, email address, country of residence, and age range from these third parties. if one of our business partners provisioned you an Account, we will access and collect the information you provided to them for this purpose. if you submit, upload, publish or otherwise make available User Content on other platforms related to Tasks, we may collect your User Content. if you opt-in for an identity verification or a background check, our screening vendor may provide us with certain personal information, such as your name, date of birth, address, government-issued ID, results of identity verification, phone number, email address, and picture our payment facilitation vendor may provide us with tax documentation, which includes things like your taxpayer identification number, related to payments made to you

4. How and Why We Use Information

We use personal information to operate our services, communicate with you, improve product functionality, ensure legal compliance, and for other legitimate business purposes based on your consent, our contractual obligations, or our legal interests.

5. Information Sharing and Disclosure

We may share your personal information as follows, subject to the limitations described in this Privacy Policy and any other written agreements between you and us:

We do not share personal information (including NPI number) publicly.
Affiliates - We may share your personal information with our affiliates to provide, improve, protect, and promote Labela AI Systems, or communicate with you.
Business partners - If your Account was provisioned by a business partner, the business partner’s administrator (“admin”) may have access and control over the information associated with your Account. The business partner may have its own policies governing access and use of information in your Account.
Service providers - We contract with certain trusted third-party service providers to help us provide, improve, protect, and promote Labela AI Systems. These third parties may have access to your personal information to perform these services on our behalf and are contractually obligated to process your personal information on our behalf and in compliance with this Privacy Policy.
Customers - We may share your personal information with Lumos Clients in order to demonstrate that we have confirmed your identity before undertaking any Tasks. We may also share your User Content related to a Customer’s Tasks. You may also choose to share with Customers your personal information in order to match you with opportunities to work on projects. Your personal information may include your name, location, biography, experience, education, languages, certifications, skills, qualifications, and other information from your resume or activity when you use our services. Through your settings, you can control the personal information you share with Customers. Customers include researchers and developers of artificial intelligence (“AI”) and others to whom we or our parent company Lumos AI Labs Corp. provide products and services.
Other users - We may share your User Content with other Labela users to enable you and other users to complete Tasks.
Third-party networks and websites - We share personal information with third-party social media networks, advertising networks, and websites, so that we can market and advertise on third-party platforms and websites. The use of such personal information by the third-party networks and websites will be governed by that third party’s privacy policy. We have no control over, do not review, and cannot be responsible for, these third-party networks and websites. Learn more by visiting our Cookies Policy.
Law enforcement or other third parties in connection with legal requests - We may disclose your information to third parties, such as law enforcement, if we determine such disclosure is reasonably necessary to: (a) comply with applicable law, regulation, legal process, or a government request, (b) protect any person from death or serious bodily injury, (c) prevent fraud, abuse, or security issue of the Labela Site or other users, and (d) to protect our or our licensors’ rights, property, safety, or interest.
Third parties involved in a corporate transaction - We may disclose your personal information if we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of your personal information to an unaffiliated third party.

6. Retention and Deletion of Information

We will retain your personal information only for as long as is necessary to fulfill the purposes set out in Section 4 of this Privacy Policy and to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), to resolve disputes, or enforce our legal agreements and policies.

Because the needs can vary for different types of information in the context of different services, actual retention periods can vary. We determine the appropriate retention period for personal information based on the amount, nature and sensitivity of your personal information processed, the potential risk of harm from unauthorized use or disclosure of your personal information and whether we can achieve the purposes of the processing through other means, as well as applicable legal requirements.

After expiry of the applicable retention periods, your personal information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of that information.

See the Identify Verification Information section above for information about how long we retain Verification Data.

7. Security

We employ reasonable physical, technological, and administrative security measures to safeguard your personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

8. International Transfers

If you are visiting the Labela Site from outside the United States, please be aware that you are sending personal information to the United States where our servers are located. That information may then be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how it is stored by us. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence; however, our collection, storage and use of your personal information will at all times continue to be governed by this Privacy Policy.

9. Your Privacy Rights and Choices

Depending on where you reside, and subject to applicable law, you may have the following rights with regard to the personal information we control about you:

You may have the right to access, correct, amend, and delete your personal information by contacting us at complaince@labela.ai. We may request specific information from you to help us confirm your identity and process your request. Please note that if your account was provisioned by a business partner, and if you seek to access, correct, amend, or delete data associated with your account, you should direct your requests to the business partner’s admin.
Where you give your consent to the processing of your personal information, you may withdraw that consent at any time.
You may have the right to object to processing of your personal information, ask us to restrict processing of your personal information, or request portability of your personal information by contacting us at complaince@labela.ai.
You may have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. If you are based in the EEA or UK, the contact details for data protection authorities are available here: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

If you decide at any time that you no longer wish to receive marketing communications from us, please follow the unsubscribe instructions provided in any of the communications. If you choose to no longer receive marketing communications, we may still communicate with you about security updates, responses to service requests, or other service related, non-marketing purposes.

10. Your Privacy Rights and Choices

Labela AI Systems are not directed to individuals under 18, or a higher age depending on your jurisdiction (“Required Age”). If we become aware that a child under the Required Age has submitted information to us, we will delete the information. If you believe that we may have any information from a child under the Required Age, please contact us at compliance@labela.ai.

11. Modification of Privacy Policy

We may modify this Privacy Policy from time to time as our services change and privacy laws evolve. If we update the Privacy Policy, we will do so online, and if we make material changes, we will let you know through the Labela Site or by some other method of communication, like email. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the website. We encourage you to periodically review this notice for the latest information on our privacy practices.

12. Modification of Privacy Policy

Labela AI may modify this Privacy Policy periodically, including in response to changing legal, regulatory, technical or business developments. The “Last Updated” legend at the top of this page indicates when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on the website.

If we make any material changes to this Privacy Policy, we will take appropriate measures to provide you with additional notice, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if, and where, required by applicable data protection laws.

We encourage you to review this Privacy Policy from time to time to inform yourself of any changes.

13. Contacting Us

If you have questions about this Privacy Policy, please contact us at complaince@labela.ai.