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Legal

Privacy Policy

Last updated: May 17, 2026

1. Data Controller

The data controller responsible for processing your personal data on this website is:

Lumina
Munich, Germany
Email: contact@lumina-tech.ai

2. Data We Collect

2.1 Website Usage (Analytics)

When you visit lumina-tech.ai, we collect anonymized usage data including pages visited, time on site, referral source, device type, and browser information. This data is collected via analytics tools and does not directly identify you.

2.2 Contact Form Submissions

If you submit a contact form or reach out via email, we collect your name, email address, company name, and any information you voluntarily provide in your message.

2.3 Platform Usage Data (Customers)

For customers using the Lumina platform, we process manufacturing data including PLC signals, production incident records, and plant memory data. This processing is governed by separate data processing agreements (DPA) executed with each customer.

3. Legal Basis for Processing

We process personal data on the following legal bases under Article 6(1) GDPR:

  • Legitimate interest (Art. 6(1)(f)): Website analytics to improve our services and user experience.
  • Consent (Art. 6(1)(a)): Use of non-essential cookies and analytics tracking, obtained via our cookie consent mechanism.
  • Contract performance (Art. 6(1)(b)): Processing platform usage data to deliver our services to customers.
  • Legal obligation (Art. 6(1)(c)): Retaining data where required by applicable law.

4. Cookies

Our website uses the following categories of cookies:

  • Essential cookies: Required for the website to function correctly (e.g., session management, cookie consent preferences). These do not require consent.
  • Analytics cookies: Used to understand how visitors interact with our website. These are only set after you provide consent via our cookie banner.

You can manage your cookie preferences at any time through our cookie consent tool or by adjusting your browser settings.

5. Third-Party Processors

We use the following sub-processors to deliver our services. All processors are located within the EU/EEA and operate under appropriate data processing agreements:

  • Amazon Web Services (AWS), Frankfurt (eu-central-1): Infrastructure hosting and data storage.
  • Google Cloud Platform, Frankfurt (europe-west3): Cloud computing and platform services.
  • Analytics tools: Website usage tracking (anonymized data only, EU-hosted).

6. International Data Transfers

Your personal data is processed and stored exclusively within the European Union and European Economic Area (EU/EEA). We do not transfer personal data to third countries outside the EU/EEA.

7. Data Retention

  • Website analytics data: Retained for 26 months, then automatically deleted.
  • Contact form submissions: Retained for the duration of our business relationship, plus 3 years for legitimate interest purposes.
  • Platform customer data: Retained for the term of the service agreement, plus any legally mandated retention period.
  • Cookie consent records: Retained for 12 months as proof of consent.

8. Your Rights

Under the GDPR, you have the following rights regarding your personal data:

  • Right of access (Art. 15): Obtain confirmation of whether your data is being processed and request a copy.
  • Right to rectification (Art. 16): Request correction of inaccurate personal data.
  • Right to erasure (Art. 17): Request deletion of your personal data where applicable.
  • Right to data portability (Art. 20): Receive your data in a structured, machine-readable format.
  • Right to restriction (Art. 18): Request limitation of processing under certain conditions.
  • Right to object (Art. 21): Object to processing based on legitimate interest at any time.

To exercise any of these rights, contact us at contact@lumina-tech.ai. We will respond within 30 days of receiving your request.

9. Right to Lodge a Complaint

If you believe that our processing of your personal data violates the GDPR, you have the right to lodge a complaint with a supervisory authority. Our competent authority is:

Bayerisches Landesamt für Datenschutzaufsicht (BayLDA)
Promenade 18, 91522 Ansbach, Germany
Website: www.lda.bayern.de

10. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. The updated version will be indicated by the “Last updated” date at the top of this page. We encourage you to review this policy periodically.