PRIVACY POLICY
Last updated: 23 April 2025
This Privacy Policy describes our policies and procedures regarding the collection, use and disclosure of your information when you use the Service. It informs you about your privacy rights and how the law protects you.
We process your personal data only on the basis of a valid legal ground as referred to in Article 6 of the General Data Protection Regulation (GDPR). By using the Service, your data are processed in accordance with this Privacy Policy.
1. Interpretation and Definitions
Interpretation
Words whose initial letter is capitalised have the meaning defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.
Definitions
For the purposes of this Privacy Policy, the following shall apply:
Account means a unique account created for you to access our Service or parts of it.
Affiliate means an entity that controls, is controlled by, or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for the election of directors or other managing authority.
Application refers to Lumee, the software programme offered by the Company.
Company (referred to in this agreement as “the Company”, “we”, “us” or “our”) refers to Lumée. For questions about your rights or this policy, you can contact us at: privacy@lumée.com
Country refers to: the European Union.
Cookies are small files placed on your computer, mobile device or other device by a website, containing, among other things, details of your browsing history on that website.
Device means any device that can access the Service, such as a computer, mobile phone or digital tablet.
Personal Data means any information that relates to an identified or identifiable natural person (data subject), as described in the GDPR.
Service refers to the Application, the Website or both.
Processor (Service Provider) means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals engaged by the Company to facilitate the Service, provide the Service on behalf of the Company, perform services related to the Service or assist the Company in analysing the use of the Service.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Lumee, accessible via www.lumée.com
You means the individual accessing or using the Service, or the company or other legal entity on behalf of which that individual is accessing or using the Service, as applicable.
2. Collection and Use of Personal Data
Types of Data Collected
Personal Data
During use of our Service, we may ask you to provide certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
Email address
First name and last name
Phone number
Usage Data
Usage Data is collected automatically when using the Service. Usage Data may include information such as your device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service via a mobile device, we may automatically collect certain information, including the type of mobile device you use, your mobile device's unique ID, your mobile device's IP address, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
3. Legal Basis for Processing (GDPR)
We process your personal data only when we have a valid legal basis under Article 6 of the General Data Protection Regulation (GDPR). The following legal bases apply:
Performance of a contract (Art. 6(1)(b) GDPR): when processing is necessary for the performance of a contract to which you are party, or for taking pre-contractual steps at your request.
Consent (Art. 6(1)(a) GDPR): when you have given us your explicit consent for one or more specific processing purposes. You have the right to withdraw your consent at any time.
Legal obligation (Art. 6(1)(c) GDPR): when processing is necessary for compliance with a legal obligation to which we are subject.
Legitimate interests (Art. 6(1)(f) GDPR): when processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, unless your interests or fundamental rights and freedoms override those interests.
4. Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track activity on our Service and store certain information. The tracking technologies used are beacons, tags and scripts to collect and track information and to improve and analyse our Service.
We only place non-essential cookies (such as analytics or marketing cookies) after your explicit consent via our cookie banner, in accordance with the requirements of the GDPR and the Telecommunications Act. You may withdraw your consent at any time.
The technologies we use include:
Types of Cookies
Necessary / Essential Cookies
Type: Session cookies — Managed by: Us
Purpose: These cookies are essential to provide you with the services available through the Website and to enable you to use certain features. They help authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services you have requested cannot be provided.
Cookie Policy Acceptance Cookies
Type: Persistent cookies — Managed by: Us
Purpose: These cookies record whether users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent cookies — Managed by: Us
Purpose: These cookies allow us to remember choices you make when using the Website, such as remembering your login details or language preference. The purpose of these cookies is to provide you with a more personalised experience and to avoid you having to re-enter your preferences every time.
5. Use of Your Personal Data
The Company may use personal data for the following purposes:
Provision and maintenance of our Service, including monitoring the use of our Service.
Management of your Account: managing your registration as a user of the Service.
Performance of a contract: developing, complying with and undertaking the purchase agreement for the products, items or services you have purchased or any other agreement with us through the Service.
Contacting you: contacting you by email, telephone calls, SMS or other equivalent forms of electronic communication, such as push notifications from a mobile application, about updates or informative notices related to the functionalities, products or contracted services, including security updates.
News and offers: providing you with news, special offers and general information about other goods, services and events we offer that are similar to those you have already purchased or enquired about, unless you have opted not to receive such information.
Managing your requests: attending to and managing your requests to us.
Business transfers: evaluating or using your information in connection with a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of our assets.
Other purposes: data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and evaluating and improving our Service, products, services, marketing and your experience.
Sharing of Your Personal Data
We may share your personal data in the following situations:
With Processors: we may share your personal data with processors to monitor and analyse the use of our Service, or to contact you. We enter into a data processing agreement with each processor as required by the GDPR.
For business transfers: we may share or transfer your personal data in connection with a merger, sale of assets, financing or acquisition of all or part of our business.
With Affiliates: we may share your information with our affiliates, in which case we require those affiliates to honour this Privacy Policy.
With business partners: we may share your information with our business partners to offer you certain products, services or promotions.
With your consent: we may disclose your personal data for any other purpose with your consent.
6. Retention of Your Personal Data
The Company will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes and enforce our legal agreements and policies.
Usage Data is generally retained for a shorter period, unless it is used to strengthen the security or functionality of our Service or we are legally obliged to retain it for longer.
7. Transfer of Your Personal Data
Your information, including personal data, is processed at the Company's operating offices and at any other places where the parties involved are located. This means that this information may be transferred to and stored on computers outside your province, country or other governmental jurisdiction.
When your data are transferred outside the European Economic Area (EEA), the Company ensures that appropriate safeguards are in place in accordance with Chapter V of the GDPR. This includes the use of:
An adequacy decision by the European Commission; or
Standard Contractual Clauses as approved by the European Commission.
8. Your Rights as a Data Subject
As a data subject within the meaning of the GDPR, you have the following rights in relation to your personal data:
Right of access (Art. 15 GDPR): you have the right to request copies of the personal data we hold about you.
Right to rectification (Art. 16 GDPR): you have the right to have inaccurate personal data corrected or incomplete data completed.
Right to erasure (‘right to be forgotten’, Art. 17 GDPR): you have the right to request that your personal data be erased, subject to legal obligations to retain the data.
Right to restriction of processing (Art. 18 GDPR): you have the right to request that processing of your personal data be restricted in certain circumstances.
Right to data portability (Art. 20 GDPR): you have the right to receive your personal data in a structured, commonly used and machine-readable format, or to have it transmitted directly to another controller.
Right to object (Art. 21 GDPR): you have the right to object to the processing of your personal data on the grounds of legitimate interests, including profiling.
Right to withdraw consent: where processing is based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing before withdrawal.
Right to lodge a complaint: you have the right to lodge a complaint with the competent supervisory authority. In the Netherlands, this is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, AP), available at www.autoriteitpersoonsgegevens.nl.
To exercise any of these rights, you can contact us at privacy@lumee.app. We will respond to your request within one month of receipt, in accordance with the requirements of the GDPR.
9. Erasure of Your Personal Data
You have the right to request that we erase the personal data we have collected about you. Our Service may give you the ability to delete certain information about yourself from within the Service itself.
You may update, amend or delete your information at any time by logging into your Account (if you have one) and visiting the settings that allow you to manage your personal data. You may also contact us to request access to, correction of or deletion of personal data that you have provided to us. Please note, however, that we may need to retain certain information where we have a legal obligation or lawful basis to do so.
10. Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, your personal data may be transferred. We will notify you before your personal data are transferred and become subject to a different privacy policy.
Law Enforcement and Public Authorities
Under certain circumstances, the Company may be required to disclose your personal data if required by law or in response to valid requests from public authorities (e.g. a court or government agency). This is done solely on the basis of a lawful ground.
Other Legal Requirements
The Company may disclose your personal data in the good-faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of users of the Service or the public
Protect against legal liability
11. Security of Your Personal Data
The security of your personal data is important to us. We implement appropriate technical and organisational measures to protect your personal data, as required by Article 32 GDPR. However, remember that no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.
12. Privacy of Minors
Our Service is not aimed at persons under the age of 16. In accordance with Article 8 of the GDPR, we do not knowingly process personal data of children under 16 without valid consent from a parent or legal guardian.
If you are a parent or guardian and become aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from persons under 16 without verification of parental consent, we take steps to remove that information from our servers.
13. Links to Other Websites
Our Service may contain links to other websites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
14. Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service before the change takes effect and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
15. Contact Details
If you have any questions about this Privacy Policy or wish to exercise your rights as a data subject, you can contact us:
By email: privacy@lumée.com
Via our website: www.lumée.com
We aim to respond to all requests and complaints within one month, in accordance with the requirements of the GDPR.
PRIVACY POLICY
Last updated: 23 April 2025
This Privacy Policy describes our policies and procedures regarding the collection, use and disclosure of your information when you use the Service. It informs you about your privacy rights and how the law protects you.
We process your personal data only on the basis of a valid legal ground as referred to in Article 6 of the General Data Protection Regulation (GDPR). By using the Service, your data are processed in accordance with this Privacy Policy.
1. Interpretation and Definitions
Interpretation
Words whose initial letter is capitalised have the meaning defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or plural.
Definitions
For the purposes of this Privacy Policy, the following shall apply:
Account means a unique account created for you to access our Service or parts of it.
Affiliate means an entity that controls, is controlled by, or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for the election of directors or other managing authority.
Application refers to Lumee, the software programme offered by the Company.
Company (referred to in this agreement as “the Company”, “we”, “us” or “our”) refers to Lumée. For questions about your rights or this policy, you can contact us at: privacy@lumée.com
Country refers to: the European Union.
Cookies are small files placed on your computer, mobile device or other device by a website, containing, among other things, details of your browsing history on that website.
Device means any device that can access the Service, such as a computer, mobile phone or digital tablet.
Personal Data means any information that relates to an identified or identifiable natural person (data subject), as described in the GDPR.
Service refers to the Application, the Website or both.
Processor (Service Provider) means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals engaged by the Company to facilitate the Service, provide the Service on behalf of the Company, perform services related to the Service or assist the Company in analysing the use of the Service.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Lumee, accessible via www.lumée.com
You means the individual accessing or using the Service, or the company or other legal entity on behalf of which that individual is accessing or using the Service, as applicable.
2. Collection and Use of Personal Data
Types of Data Collected
Personal Data
During use of our Service, we may ask you to provide certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to:
Email address
First name and last name
Phone number
Usage Data
Usage Data is collected automatically when using the Service. Usage Data may include information such as your device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service via a mobile device, we may automatically collect certain information, including the type of mobile device you use, your mobile device's unique ID, your mobile device's IP address, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
3. Legal Basis for Processing (GDPR)
We process your personal data only when we have a valid legal basis under Article 6 of the General Data Protection Regulation (GDPR). The following legal bases apply:
Performance of a contract (Art. 6(1)(b) GDPR): when processing is necessary for the performance of a contract to which you are party, or for taking pre-contractual steps at your request.
Consent (Art. 6(1)(a) GDPR): when you have given us your explicit consent for one or more specific processing purposes. You have the right to withdraw your consent at any time.
Legal obligation (Art. 6(1)(c) GDPR): when processing is necessary for compliance with a legal obligation to which we are subject.
Legitimate interests (Art. 6(1)(f) GDPR): when processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, unless your interests or fundamental rights and freedoms override those interests.
4. Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track activity on our Service and store certain information. The tracking technologies used are beacons, tags and scripts to collect and track information and to improve and analyse our Service.
We only place non-essential cookies (such as analytics or marketing cookies) after your explicit consent via our cookie banner, in accordance with the requirements of the GDPR and the Telecommunications Act. You may withdraw your consent at any time.
The technologies we use include:
Types of Cookies
Necessary / Essential Cookies
Type: Session cookies — Managed by: Us
Purpose: These cookies are essential to provide you with the services available through the Website and to enable you to use certain features. They help authenticate users and prevent fraudulent use of user accounts. Without these cookies, the services you have requested cannot be provided.
Cookie Policy Acceptance Cookies
Type: Persistent cookies — Managed by: Us
Purpose: These cookies record whether users have accepted the use of cookies on the Website.
Functionality Cookies
Type: Persistent cookies — Managed by: Us
Purpose: These cookies allow us to remember choices you make when using the Website, such as remembering your login details or language preference. The purpose of these cookies is to provide you with a more personalised experience and to avoid you having to re-enter your preferences every time.
5. Use of Your Personal Data
The Company may use personal data for the following purposes:
Provision and maintenance of our Service, including monitoring the use of our Service.
Management of your Account: managing your registration as a user of the Service.
Performance of a contract: developing, complying with and undertaking the purchase agreement for the products, items or services you have purchased or any other agreement with us through the Service.
Contacting you: contacting you by email, telephone calls, SMS or other equivalent forms of electronic communication, such as push notifications from a mobile application, about updates or informative notices related to the functionalities, products or contracted services, including security updates.
News and offers: providing you with news, special offers and general information about other goods, services and events we offer that are similar to those you have already purchased or enquired about, unless you have opted not to receive such information.
Managing your requests: attending to and managing your requests to us.
Business transfers: evaluating or using your information in connection with a merger, divestiture, restructuring, reorganisation, dissolution or other sale or transfer of some or all of our assets.
Other purposes: data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and evaluating and improving our Service, products, services, marketing and your experience.
Sharing of Your Personal Data
We may share your personal data in the following situations:
With Processors: we may share your personal data with processors to monitor and analyse the use of our Service, or to contact you. We enter into a data processing agreement with each processor as required by the GDPR.
For business transfers: we may share or transfer your personal data in connection with a merger, sale of assets, financing or acquisition of all or part of our business.
With Affiliates: we may share your information with our affiliates, in which case we require those affiliates to honour this Privacy Policy.
With business partners: we may share your information with our business partners to offer you certain products, services or promotions.
With your consent: we may disclose your personal data for any other purpose with your consent.
6. Retention of Your Personal Data
The Company will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations, resolve disputes and enforce our legal agreements and policies.
Usage Data is generally retained for a shorter period, unless it is used to strengthen the security or functionality of our Service or we are legally obliged to retain it for longer.
7. Transfer of Your Personal Data
Your information, including personal data, is processed at the Company's operating offices and at any other places where the parties involved are located. This means that this information may be transferred to and stored on computers outside your province, country or other governmental jurisdiction.
When your data are transferred outside the European Economic Area (EEA), the Company ensures that appropriate safeguards are in place in accordance with Chapter V of the GDPR. This includes the use of:
An adequacy decision by the European Commission; or
Standard Contractual Clauses as approved by the European Commission.
8. Your Rights as a Data Subject
As a data subject within the meaning of the GDPR, you have the following rights in relation to your personal data:
Right of access (Art. 15 GDPR): you have the right to request copies of the personal data we hold about you.
Right to rectification (Art. 16 GDPR): you have the right to have inaccurate personal data corrected or incomplete data completed.
Right to erasure (‘right to be forgotten’, Art. 17 GDPR): you have the right to request that your personal data be erased, subject to legal obligations to retain the data.
Right to restriction of processing (Art. 18 GDPR): you have the right to request that processing of your personal data be restricted in certain circumstances.
Right to data portability (Art. 20 GDPR): you have the right to receive your personal data in a structured, commonly used and machine-readable format, or to have it transmitted directly to another controller.
Right to object (Art. 21 GDPR): you have the right to object to the processing of your personal data on the grounds of legitimate interests, including profiling.
Right to withdraw consent: where processing is based on your consent, you have the right to withdraw that consent at any time, without affecting the lawfulness of processing before withdrawal.
Right to lodge a complaint: you have the right to lodge a complaint with the competent supervisory authority. In the Netherlands, this is the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, AP), available at www.autoriteitpersoonsgegevens.nl.
To exercise any of these rights, you can contact us at privacy@lumee.app. We will respond to your request within one month of receipt, in accordance with the requirements of the GDPR.
9. Erasure of Your Personal Data
You have the right to request that we erase the personal data we have collected about you. Our Service may give you the ability to delete certain information about yourself from within the Service itself.
You may update, amend or delete your information at any time by logging into your Account (if you have one) and visiting the settings that allow you to manage your personal data. You may also contact us to request access to, correction of or deletion of personal data that you have provided to us. Please note, however, that we may need to retain certain information where we have a legal obligation or lawful basis to do so.
10. Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, your personal data may be transferred. We will notify you before your personal data are transferred and become subject to a different privacy policy.
Law Enforcement and Public Authorities
Under certain circumstances, the Company may be required to disclose your personal data if required by law or in response to valid requests from public authorities (e.g. a court or government agency). This is done solely on the basis of a lawful ground.
Other Legal Requirements
The Company may disclose your personal data in the good-faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of users of the Service or the public
Protect against legal liability
11. Security of Your Personal Data
The security of your personal data is important to us. We implement appropriate technical and organisational measures to protect your personal data, as required by Article 32 GDPR. However, remember that no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.
12. Privacy of Minors
Our Service is not aimed at persons under the age of 16. In accordance with Article 8 of the GDPR, we do not knowingly process personal data of children under 16 without valid consent from a parent or legal guardian.
If you are a parent or guardian and become aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from persons under 16 without verification of parental consent, we take steps to remove that information from our servers.
13. Links to Other Websites
Our Service may contain links to other websites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
14. Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Service before the change takes effect and update the “Last updated” date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
15. Contact Details
If you have any questions about this Privacy Policy or wish to exercise your rights as a data subject, you can contact us:
By email: privacy@lumée.com
Via our website: www.lumée.com
We aim to respond to all requests and complaints within one month, in accordance with the requirements of the GDPR.
