Skip to content

Security and data

Your hotel's material stays your hotel's

All of it is in place today.

Everything leaves through one gate

Your team holds it. Nothing reaches your website that somebody there has not read.

What Lumina holds

The material you connect

Guest reviews, the brand book, approved photography, the events calendar, your live pages, and the analytics and ad accounts you connect. If you did not connect it, Lumina does not have it.

What the product writes

Pages, search copy, newsletters, offers and ads, and a record of which source each line came from, so a brand team can check any sentence against its source.

Who signed in, and when

The accounts your team uses, and who approved each asset. Approval is a field in the product, so it is on the record.

How Lumina uses AI

Swiss Made Software +AI

Developed and operated in Zurich by Lumina Frontier AG.

AI is the product

Lumina reads your reviews, brand book, photography and pages, and writes your pages, newsletters, ads and campaign briefs from them. It also measures whether your hotel is named when guests ask ChatGPT, Claude, Gemini or Perplexity where to stay.

The models it calls

Large language models from Anthropic (Claude), OpenAI (GPT) and Google (Gemini, through Vertex AI) read and write. Generative image models, GPT Image and FLUX from Black Forest Labs, make images, ElevenLabs Scribe transcribes speech, and Jev from TypeSafe checks text. All are closed-source models made by those companies, reached through their APIs or through fal.ai.

What we build

The layer around the models: versioned prompts, checks, the approval step, and retrieval-augmented generation, which gives a model the passages it needs from your own material before it writes. We do not fine-tune or train the models, on your material or on anything else.

Where it runs

Lumina is software as a service, hosted in the European Union on Vercel and Supabase in Ireland and on Fly.io in France. For clients in Switzerland, we can host Lumina and its data in Switzerland on request.

Your material and the models

Anthropic, OpenAI and Google receive your material through their business APIs, and their terms for those APIs exclude it from training their models. Our privacy notice lists every provider, where it processes and the safeguard that applies.

The EU AI Act

The EU AI Act sets its strictest duties for high-risk uses such as hiring, credit and education. Writing hotel marketing is a limited-risk use, whose duty is transparency: this page, and a person at your hotel or agency approving every piece before it is published.

Questions a vendor review asks

One, and only for counting visits. It holds a random string, no personal data, and no other site can read it. It lasts thirteen months, does not renew itself, and can be switched off from our privacy notice. Google Analytics, Meta, Google Ads, LinkedIn and OpenAI Ads load only if you accept them in the cookie banner.

Not without your consent. Nothing of ours works outside this website. The Meta, LinkedIn and OpenAI Ads tags load only if you accept marketing in the cookie banner. Google Ads can recognise a browser only after you accept. Before that it works without cookies or advertising identifiers. How many people return and who has written to us are held in two separate places, with no key joining them.

No, and not on anybody else’s. Your material writes your work and nothing else. It never trains a model, ours or a supplier’s, and never becomes part of the product.

No. Each property’s material stays with that property. Two hotels in the same group never read each other, and corporate sees a property only where the group has given itself that access.

Not yet. We are evaluating both, before starting the audits. Today we complete your vendor security questionnaire line by line and sign it. Every commitment above holds whether or not a certificate is on the wall. If a certificate is a condition of signing, tell us early and we will tell you whether we can meet your date.

Ask us and we will confirm it in writing, per supplier and for the environment we would set up for your property. The suppliers are listed in the privacy notice. If residency is a condition of signing, raise it before a walkthrough.

Only what someone at your hotel has approved. Lumina publishes on WordPress and Webflow, on your agency’s CMS or as pages ready for the agency to upload, or on a new site it builds and runs. Nothing goes live without that approval, and every approval is on the record.

Everything written for you is yours and stays yours. The access to your website and accounts is yours to withdraw at any time. Write to us and we delete what we hold, and confirm when it is done.

Two people, Marco Di Cesare and Giampiero Virago, and only to set the property up or to fix something you have reported. Every one of those accesses is on the record in the product.

Procurement, without another portal

The current status and the documents your reviewer needs, on the same page as the controls they describe.

SOC 2 Type II and ISO 27001

Status
Evaluation of both under way, before the audits start. Lumina is not certified today.

GDPR and Swiss nFADP

Role
Lumina Frontier AG is the controller for this website and a processor for a licensed hotel’s material.

Data processing agreement

Document
Available on request, signed. It travels with the licence agreement.

Vendor questionnaire

Turnaround
Completed line by line and signed within a week.

Sub-processors and residency

Current list
Every supplier is named in the privacy notice. Residency is confirmed in writing for the environment set up for your property.

Send us the questionnaire

Send it over and you get it back completed and signed within a week.

Write to us Current sub-processors