Who is responsible?
Lumo Wallet LLC operates Orvra at 1603 Capitol Ave, Suite 413G-2406, Cheyenne, Wyoming 82001, United States. We determine how account, billing, security and support information is used. When a business directs processing of its workspace content, our role and obligations may also be governed by a separately agreed data processing agreement.
Information we handle
Account information includes name, email, workspace membership, password hashes, authentication settings and invitation or verification records. Workspace content includes prompts, conversations, uploaded files, generated outputs, project changes and feedback you submit.
We handle request counts, service errors, access and security logs, IP addresses, device/browser information supplied with requests, and support messages or attachments. Payment records may contain customer and subscription references, invoice amounts, currency and status. Card details are handled by the payment provider; do not send card numbers or wallet recovery phrases to Orvra.
Why we use it
We use information to supply your account and requested AI features, authenticate access, manage subscriptions and support, prevent misuse, investigate problems and meet applicable legal obligations. Where GDPR applies, the legal bases are performance of a contract, legitimate interests in operating and securing the service, legal obligation, or consent when a separate optional choice requires it. You may ask about or object to legitimate-interest processing.
AI processing and improvement
Enabled AI workloads are designed to run on models hosted for Orvra. Prompts and relevant project context are sent to the configured inference service to answer your request. This is not end-to-end encryption; authorized operators can access data where necessary for support and administration.
Ordinary conversations do not automatically retrain the models. Submitting general feedback is not blanket permission to reuse every file or message for model training. Any optional training programme must explain which examples are used, the choice available to you and retention before collection. We do not sell personal information or use it for advertising profiles.
Sharing and international processing
Service providers help with hosting, security, email and payments; see Service Providers for the current setup and planned integrations. We share the data necessary for those functions, with authorized workspace administrators where appropriate, and when lawfully required. Connecting an external app shares the data and permissions you authorize.
Hosting or provider access can involve countries outside yours. Where a transfer requires a specific legal safeguard, that safeguard must be arranged for the applicable service. We do not claim EU-only storage or a certified transfer mechanism for every provider. Businesses with regional or regulated-data requirements should agree them with us first.
Retention and security
Account and workspace records are retained while needed for the service, support and security. Billing, dispute or legal records may need longer retention. We review deletion requests and explain any data we must retain. Backup copies may persist until their retention cycle ends; deleting a visible item is not a promise of immediate removal from every backup.
Access controls, authentication, encrypted transport and restricted administration reduce risk. No system is perfectly secure. We do not yet offer a universal automatic deletion schedule or promise an unimplemented fixed retention period.
Your rights and requests
Depending on where you live, you can request access, correction, deletion, portability, restriction or object to certain processing; withdraw optional consent; and complain to your relevant data protection authority. We will verify identity proportionately and respond within applicable deadlines. Exercising rights will not itself lead to discrimination.
Use the Contact page for privacy requests, or send a written request to our registered address. Workspace users may also need to contact their employer or workspace owner. Orvra is for adults; contact us if a child has supplied personal information. Updated 2026-10-21.