Lumina AI — Privacy Policy

Effective date: August 16, 2026 · Last updated: September 29, 2026

1. Overview and scope

Lumina AI, available at practicalnurseprep.com, is a CPNRE exam-preparation platform and a product of NGN Simulation Labs Ltd. ("we", "us"), an Alberta corporation. This Policy explains how we collect, use, disclose, and safeguard personal information in connection with Lumina AI, under Alberta's Personal Information Protection Act ("PIPA"), the federal Personal Information Protection and Electronic Documents Act ("PIPEDA"), and other applicable privacy laws.

2. Privacy Officer

3. Information we collect

• Account data: name, email address, salted password hash, role (student / instructor / administrator), institution or self-serve tenant, program details, and Alberta region.
• Learning activity data: quiz and exam responses and scores, clinical-case and simulation transcripts, AI tutor conversations, study notes, flashcard and spaced-repetition records, study-plan progress, and readiness analytics.
• Voice data: transient microphone audio captured during voice OSCE stations and speaking practice, the resulting transcripts, and delivery metrics (pace, pauses, clarity). See section 6.
• Newsletter and contact data: if you subscribe to updates or submit the contact form on our site or guides, we keep your email address, the page you subscribed from, the time of your consent, your message, and — for subscribers — a per-address unsubscribe token. This is our record of your consent under Canada's anti-spam law (CASL).
• Technical data: IP address, browser and device metadata, and security logs.
• Payment data (when paid plans are offered): subscription records processed by Stripe. We store at most the card brand, expiry, and last four digits — never full card numbers.

4. How we use personal information

We use personal information to: (1) deliver the Services — exams, cases, the AI tutor, study plans, and voice practice; (2) compute readiness and progress analytics, including instructor dashboards for institutional cohorts; (3) operate our AI features; (4) process payments where applicable; (5) send messages you have requested; (6) detect and prevent abuse and security threats; and (7) improve the platform using de-identified, aggregated data. We display no third-party advertising, use no third-party ad-tracking cookies, and never sell personal information.

5. AI features and your data

Inputs to AI features are processed on enterprise Google Cloud (Vertex AI) infrastructure. Under our enterprise terms, the AI provider is contractually restricted from using inputs or outputs to train public or general-purpose foundation models. AI conversations and generated study materials are stored in your learning record so the platform can function (for example, resuming a tutoring conversation or refreshing study notes).

6. Voice audio and biometrics

Microphone audio from voice practice is processed transiently to produce a text transcript and delivery metrics; raw audio is not retained after the session. Transcripts and scorecards are saved to your learning record. We do not create or store biometric voiceprints and do not use audio for speaker identification.

7. Service providers and cross-border processing (PIPA s. 13.1 notice)

In accordance with s. 13.1 of PIPA, notice is given that personal information collected in connection with Lumina AI is transferred to, stored, and processed by service providers located outside Canada, primarily in the United States:

Information processed outside Canada is subject to the laws of those jurisdictions, including lawful access by foreign courts and authorities. Questions about our service providers' policies may be directed to the Privacy Officer.

8. Institutional relationships (FOIP)

Where access is provisioned by an Alberta public post-secondary institution or other public body subject to FOIP, NGN Simulation Labs Ltd. acts as a service provider to that institution. Learner records are disclosed to authorized Institutional Personnel solely for academic administration and evaluation, and the institution is responsible for its own FOIP notices and consents.

9. Retention and deletion

Personal information is retained only as long as necessary for the purposes above. On a verified account-deletion request, personal data is purged within thirty (30) days, with residual backup copies overwritten on a rolling ninety (90) day cycle. Minimal transaction records are retained where tax or other statutes require. Unsubscribe records for email are retained as suppression entries — deleting them is what would cause someone to be emailed again.

10. Security and breach response

We protect personal information with safeguards appropriate to its sensitivity — encrypted transport, hashed credentials, tenant isolation, role-based access, and security logging. If a breach of security safeguards creates a real risk of significant harm to an individual, we will notify the Office of the Information and Privacy Commissioner of Alberta and affected individuals without delay, in accordance with PIPA.

11. Email and anti-spam (CASL)

Operational messages (sign-in codes, password resets, billing and security notices) are non-marketing. Marketing email — including our newsletter — is sent only with your express opt-in consent, records of which we keep, and every marketing message carries a working one-click unsubscribe that we honour immediately. Business-outreach email to organizations is sent under CASL's consent rules with sender identification, our mailing address, and a working unsubscribe in every message.

12. Cookies and local storage

We use strictly necessary cookies for sign-in sessions and security (including CSRF protection), and browser local storage for on-device study conveniences. We set no third-party advertising or cross-site tracking cookies.

13. Health Information Act (HIA) non-applicability

Lumina AI is an educational simulation platform. Every patient in the Services is fictional; we do not collect real patient health records, and NGN Simulation Labs Ltd. is not a custodian or information manager under Alberta's Health Information Act. Entering identifiable real patient information into the Services is prohibited by our Terms of Service.

14. Your rights and how to reach us

Subject to legal exceptions, you may access, correct, or request deletion of your personal information, and withdraw consents, by contacting the Privacy Officer. We respond within the 45-day period prescribed by PIPA.

NGN Simulation Labs Ltd. (Lumina AI) — Attention: Privacy Officer (Jay Kambo)
11 South Shore Rd, Chestermere, AB T1X 2Y4, Canada · hello@albertalpnprep.com
Product support: hello@albertalpnprep.com

If you are unsatisfied with our response, you may contact the Office of the Information and Privacy Commissioner of Alberta (oipc.ab.ca).