Privacy Policy

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Section 1 – Introduction

Lumos Technologies LLC ("we," "our," or "us"), a limited liability company registered in the State of Wyoming, United States, is committed to protecting the privacy and security of your personal information.

This Privacy Policy explains how we collect, use, store, disclose, and protect information when you visit our website at lumostechgroup.com (the "Website"). This policy also describes the rights available to you with respect to your personal data and how you can exercise them.

As a holding company, Lumos Technologies LLC is the parent entity of a portfolio of technology ventures, including Lumos One — a privacy and security ecosystem. Each venture may maintain its own privacy documentation for its specific products and services. This Privacy Policy applies specifically to the corporate website at lumostechgroup.com.

By accessing or using our Website, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

Section 2 – Data Controller

For the purposes of applicable data protection laws, including the General Data Protection Regulation (GDPR), the Data Controller is:

If you have any questions or concerns about how we process your personal data, please contact us using the details above.

Section 3 – Information We Collect

3.1 Information You Voluntarily Provide

We collect personal information that you choose to provide to us directly, which may include:

• Email address — when you subscribe to our updates or newsletter. Your email address is stored and processed by Brevo (Sendinblue SAS) for the purpose of sending you communications you have consented to receive.
• Name — if provided when filling out contact or inquiry forms
• Business information — such as company name, job title, or organization, when submitting partnership inquiries
• Message content — any information you include in emails or inquiry submissions

This Website does not operate an e-commerce storefront. All commercial products and services are offered through subsidiary ventures (e.g., Lumos One), which maintain their own privacy documentation. However, Lumos Technologies LLC may serve as the legal entity processing transactions on behalf of its ventures, as described in Section 6 below.

3.2 Information Collected Automatically

When you visit our Website, we or our service providers may automatically collect certain technical and usage information, including:

• IP address and approximate geographic location (country or city level)
• Browser type, version, and language preferences
• Operating system and device type
• Referring URLs and exit pages
• Pages viewed, time spent on pages, and navigation paths
• Date and time of your visit

This information is collected through standard server logs and analytics technologies, including Google Analytics 4 (provided by Google LLC). We use this data in aggregate and anonymized form to understand how visitors use our Website and to improve its performance and content.

3.3 Cookies and Similar Technologies

Our Website uses cookies and similar tracking technologies. Cookies are small text files stored on your device that help us recognize your browser and improve your experience. We use Google Analytics 4, which sets cookies to collect usage data. Google Analytics data is processed by Google LLC and subject to Google's Privacy Policy (policies.google.com/privacy). For full details on the cookies we use, please refer to our Cookie Policy available at lumostechgroup.com/cookie-policy.

You may control cookie preferences through your browser settings or via the cookie consent banner displayed on your first visit.

Section 4 – Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, we process your personal data on the following legal grounds under GDPR Article 6:

• Consent (Art. 6(1)(a)) — when you subscribe to our newsletter or updates, or accept non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Legitimate Interests (Art. 6(1)(f)) — for analyzing Website usage, improving our services, and ensuring Website security, where these interests are not overridden by your fundamental rights and freedoms.
• Compliance with Legal Obligations (Art. 6(1)(c)) — when we are required to process data to meet applicable legal requirements.

Where processing is based on consent, you have the right to withdraw it at any time by contacting us at legal@lumostechgroup.com.

Section 5 – How We Use Your Information

We use the information we collect for the following purposes:

• To send you company updates, news about our ventures, and product announcements — where you have subscribed and consented
• To respond to your inquiries, partnership requests, and communications
• To analyze and improve the performance and usability of our Website
• To maintain the security and integrity of our Website and infrastructure
• To comply with applicable legal obligations and enforce our legal rights
• To manage and facilitate business transactions, including those processed by Lumos Technologies LLC on behalf of its subsidiaries and ventures

Section 6 – Holding Company Structure & Payment Processing

Lumos Technologies LLC operates as the parent holding company for a portfolio of technology ventures. Commercial activities — including the sale of products and services — are conducted through subsidiary brands such as Lumos One.

Where Lumos Technologies LLC acts as the legal entity processing payments on behalf of its ventures (e.g., as the merchant of record), it may process payment-related information such as transaction amounts and payment confirmations. Detailed card and financial information is handled directly by our PCI-DSS compliant payment processors and is not stored by Lumos Technologies LLC.

Each venture under the Lumos Technologies LLC umbrella maintains its own dedicated privacy policy governing the collection and use of data within its specific products and services.

Section 7 – Information Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties for their own commercial purposes. We may share your information only in the following circumstances:

• Service Providers — We engage trusted third-party vendors to provide services on our behalf. These include cloud infrastructure providers (such as AWS or Google Cloud), email delivery services (Brevo, provided by Sendinblue SAS), web analytics providers (Google Analytics 4, provided by Google LLC), and security monitoring services. These vendors are contractually bound to process data only on our instructions and in accordance with applicable data protection laws.
• Legal Requirements — We may disclose your information when required by law, regulation, court order, or governmental request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.
• Business Transfers — In the event of a merger, acquisition, restructuring, or sale of assets involving Lumos Technologies LLC, your information may be transferred as part of that transaction. We will notify you of any such change and the choices available to you.
• Group Companies — We may share information within the Lumos Technologies LLC group of companies where necessary to operate our business, subject to equivalent data protection standards.
• With Your Consent — We may share information with third parties where you have given explicit consent for a specific purpose.

Section 8 – Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, accounting, or regulatory obligations.

• Newsletter and subscription data — retained until you unsubscribe or request deletion
• Inquiry and contact data — typically retained for up to 24 months from the date of last contact
• Technical and usage logs — typically retained for up to 12 months

When personal data is no longer required, we securely delete or anonymize it in accordance with our data management procedures.

Section 9 – Data Security

We implement appropriate technical and organizational security measures to protect your personal information from unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL
• Access controls limiting data access to authorized personnel only
• Regular security assessments and vulnerability management
• Secure server infrastructure managed by enterprise-grade hosting providers

Despite our best efforts, no method of transmission over the Internet or electronic storage system is completely secure. We cannot guarantee the absolute security of your personal data, but we are committed to maintaining and improving our security practices.

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and relevant supervisory authorities in accordance with applicable law.

Section 10 – International Data Transfers

Lumos Technologies LLC is based in the United States. If you are located in the EEA, UK, or other jurisdictions with data transfer restrictions, please be aware that your information may be transferred to and processed in the United States or other countries where our service providers operate.

Where we transfer personal data from the EEA or UK to countries that have not received an adequacy decision from the European Commission, we rely on appropriate safeguards such as the Standard Contractual Clauses (SCCs) approved by the European Commission, or other lawful transfer mechanisms.

By using our Website, you acknowledge that your data may be transferred internationally subject to these safeguards.

Section 11 – Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right of Access (Art. 15 GDPR) — Request a copy of the personal data we hold about you.
• Right to Rectification (Art. 16 GDPR) — Request correction of inaccurate or incomplete data.
• Right to Erasure (Art. 17 GDPR) — Request deletion of your personal data, subject to certain legal exceptions.
• Right to Data Portability (Art. 20 GDPR) — Request your data in a structured, machine-readable format.
• Right to Object (Art. 21 GDPR) — Object to processing based on legitimate interests, including profiling.
• Right to Restrict Processing (Art. 18 GDPR) — Request that we restrict the processing of your data under certain circumstances.
• Right to Withdraw Consent — Withdraw consent at any time where processing is consent-based, without affecting prior lawful processing.

To exercise any of these rights, please contact us at legal@lumostechgroup.com. We will respond to your request within 30 days (or within any shorter timeframe required by applicable law). We may need to verify your identity before processing your request.

Section 12 – Additional Information for California Residents (CCPA/CPRA)

If you are a resident of the State of California, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) may grant you additional rights regarding your personal information.

12.1 Categories of Personal Information Collected

In the preceding 12 months, we may have collected the following categories of personal information from Website visitors: identifiers (such as email address and IP address), internet or network activity information (such as browsing behavior on our Website), and commercial information in connection with our venture operations.

12.2 Do We Sell or Share Personal Information?

Lumos Technologies LLC does not sell your personal information to third parties for monetary consideration, nor do we share your personal information with third parties for cross-context behavioral advertising purposes, as those terms are defined under the CCPA/CPRA.

12.3 Your California Privacy Rights

California residents may have the following additional rights:

• Right to Know — Request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the third parties with whom we have shared it.
• Right to Delete — Request deletion of personal information we have collected, subject to certain exceptions.
• Right to Correct — Request correction of inaccurate personal information.
• Right to Opt-Out of Sale/Sharing — As noted above, we do not sell or share personal information in the CCPA sense. No opt-out is required.
• Right to Non-Discrimination — We will not discriminate against you for exercising your CCPA rights.

To submit a request under CCPA/CPRA, please contact us at legal@lumostechgroup.com. We will verify your identity before processing your request and respond within 45 days as required by law.

Section 13 – Right to Lodge a Complaint

If you are located in the EEA or UK and believe that we have not handled your personal data in accordance with applicable data protection law, you have the right to lodge a complaint with the relevant supervisory authority in your country of residence.

For EU residents, the relevant authority is the Data Protection Authority (DPA) in your EU member state. For UK residents, this is the Information Commissioner's Office (ICO) at ico.org.uk.

We would, however, appreciate the opportunity to address your concerns before you approach a regulator, and encourage you to contact us first at legal@lumostechgroup.com.

Section 14 – Children's Privacy

Our Website is not directed to individuals under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that we have inadvertently collected personal data from a child under 16 without verifiable parental consent, we will take prompt steps to delete such information.

If you believe we may have collected data from a child, please contact us at legal@lumostechgroup.com.

Section 15 – Third-Party Links

Our Website may contain links to third-party websites, platforms, or services that are not operated by Lumos Technologies LLC. We have no control over and accept no responsibility for the content, privacy practices, or policies of third-party sites.

We encourage you to review the privacy policy of any third-party website you visit. The inclusion of a link does not constitute our endorsement of that site or its practices.

Section 16 – Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will update the "Last updated" date at the top of this document and post the revised policy on our Website.

If we make material changes that significantly affect how we process your personal data, we will provide more prominent notice, which may include sending an email notification to subscribers or displaying a notice on our Website.

Your continued use of our Website after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

Section 17 – Contact Us

For any questions, concerns, or requests related to this Privacy Policy or the way we process your personal data, please contact us:

We are committed to addressing your concerns promptly and transparently.