Privacy Policy

Last Updated: May 30, 2025

1. Introduction

Lumora Dynamics ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our Lumora Apex platform, or engage with our services. Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access or use our services.

2. Information We Collect

2.1 Personal Information You Provide

We collect information you voluntarily provide to us, including:

• Account Information: Name, email address, phone number, username, and password
• Profile Information: Biography, profile picture, business information, and preferences
• Payment Information: Billing address, payment method details (processed securely through third-party processors)
• Communication Data: Messages, emails, support requests, and feedback
• Marketing Preferences: Newsletter subscriptions and communication preferences
• Survey and Quiz Responses: Answers to assessments, quizzes, and surveys

2.2 Information Automatically Collected

When you access our services, we automatically collect:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, time spent, click-through rates, referral sources
• Location Data: General geographic location based on IP address
• Performance Data: Error logs, loading times, and technical diagnostics

2.3 Information from Third Parties

We may receive information from:

• Payment Processors: Transaction data and payment verification
• Social Media Platforms: If you connect your social media accounts
• Analytics Providers: Website usage statistics and performance metrics
• Affiliate Partners: Referral information and commission tracking data

3. How We Use Your Information

3.1 Primary Uses

• Service Provision: Creating and managing your account, providing access to Lumora Apex benefits
• Communication: Sending important updates, newsletters, and promotional materials
• Payment Processing: Processing membership fees and affiliate commissions
• Customer Support: Responding to inquiries and providing technical assistance
• Platform Improvement: Analyzing usage patterns to enhance our services

3.2 Marketing and Promotional Uses

• Sending you information about new products, features, and opportunities
• Personalizing content and recommendations based on your interests
• Running promotional campaigns and special offers
• Tracking affiliate referrals and managing commission payments

3.3 Legal and Security Uses

• Complying with legal obligations and regulatory requirements
• Protecting against fraud, abuse, and security threats
• Enforcing our Terms of Service and other policies
• Resolving disputes and legal claims

4. Legal Basis for Processing (GDPR)

For users in the European Union, we process your personal data based on:

• Contract Performance: Processing necessary to fulfill our service obligations
• Legitimate Interests: Improving our services, security, and business operations
• Consent: Marketing communications and optional features you've agreed to
• Legal Obligation: Compliance with applicable laws and regulations

5. Information Sharing and Disclosure

5.1 We Do Not Sell Your Data

We do not sell, rent, or trade your personal information to third parties for monetary consideration.

5.2 Service Providers

We share information with trusted third-party service providers who assist us in:

• Payment Processing: Stripe, PayPal, and other secure payment gateways
• Email Services: Email marketing platforms and communication tools
• Analytics: Google Analytics and other performance monitoring tools
• Customer Support: Help desk and support ticket management systems
• Cloud Hosting: Secure server and database hosting providers

5.3 Legal Requirements

We may disclose your information when required by law, such as:

• Responding to legal process, court orders, or subpoenas
• Investigating suspected fraud or security breaches
• Protecting the rights and safety of our users and the public
• Complying with regulatory investigations or requirements

5.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to the same privacy protections.

6. Cookies and Tracking Technologies

6.1 Types of Cookies We Use

• Essential Cookies: Required for basic site functionality and security
• Performance Cookies: Help us understand how visitors use our site
• Functionality Cookies: Remember your preferences and settings
• Marketing Cookies: Track visitors across websites for advertising purposes

6.2 Managing Cookies

You can control cookies through your browser settings. However, disabling certain cookies may limit your ability to use some features of our services.

7. Data Security

7.1 Security Measures

We implement industry-standard security measures to protect your information:

• Encryption: SSL/TLS encryption for data transmission
• Access Controls: Limited access to personal data on a need-to-know basis
• Regular Audits: Periodic security assessments and vulnerability testing
• Secure Storage: Encrypted databases and secure server infrastructure
• Staff Training: Regular privacy and security training for all team members

7.2 Data Breach Response

In the unlikely event of a data breach, we will notify affected users and relevant authorities within 72 hours as required by applicable law.

8. Data Retention

8.1 Retention Periods

• Account Data: Retained while your account is active and for 3 years after closure
• Payment Records: Kept for 7 years for tax and legal compliance
• Marketing Data: Until you unsubscribe or request deletion
• Support Communications: Retained for 5 years for quality assurance
• Analytics Data: Aggregated data retained indefinitely, personal identifiers removed after 2 years

8.2 Data Deletion

We will delete your personal information when it's no longer necessary for the purposes for which it was collected, unless we're required to retain it by law.

9. Your Privacy Rights

9.1 General Rights

Depending on your location, you may have the following rights:

• Access: Request a copy of the personal information we hold about you
• Correction: Update or correct inaccurate personal information
• Deletion: Request deletion of your personal information (subject to legal requirements)
• Portability: Receive your data in a structured, machine-readable format
• Objection: Object to certain types of data processing
• Restriction: Request limitation of how we process your data

9.2 Marketing Communications

You can opt out of marketing communications by:

• Clicking "unsubscribe" links in our emails
• Updating your preferences in your account settings
• Contacting our support team directly

9.3 Exercising Your Rights

To exercise your privacy rights, contact us at privacy@lumoradynamics.com. We will respond to your request within 30 days.

10. International Data Transfers

10.1 Cross-Border Transfers

Your information may be transferred to and processed in countries other than your own. We ensure adequate protection through:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions for countries with equivalent privacy protections
• Other appropriate safeguards as required by applicable law

10.2 Data Processing Locations

Our primary data processing occurs in the United States, with additional processing potentially occurring in other countries where our service providers operate.

11. Children's Privacy

Our services are not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected information from a child under 18, we will take steps to delete such information promptly.

12. California Privacy Rights (CCPA)

12.1 California Consumer Rights

California residents have additional rights under the California Consumer Privacy Act (CCPA):

• Right to know what personal information is collected, used, shared, or sold
• Right to delete personal information held by us
• Right to opt-out of the sale of personal information (we do not sell personal information)
• Right to non-discrimination for exercising CCPA rights

12.2 Exercising CCPA Rights

California residents can exercise these rights by emailing privacy@lumoradynamics.com or calling our toll-free number. We may verify your identity before processing your request.

13. Third-Party Services

13.1 External Links

Our services may contain links to third-party websites or services. We are not responsible for the privacy practices of these external sites. We encourage you to review their privacy policies.

13.2 Integrated Services

We integrate with various third-party services (payment processors, analytics tools, etc.). These services have their own privacy policies, and we encourage you to review them.

14. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of material changes by email or through our platform. The "Last Updated" date at the top of this policy indicates when it was last revised.

15. Contact Information

If you have questions about this Privacy Policy or our privacy practices, please contact us:

• Email: privacy@lumoradynamics.com
• Support: support@lumoradynamics.com
• Website: Contact Form
• Mail: Lumora Dynamics, 726 Ruiz Street, San Antonio, TX 78207, USA

16. Data Protection Officer

For users in the European Union, our Data Protection Officer can be reached at dpo@lumoradynamics.com for any privacy-related concerns or questions.