Privacy Policy
Last updated: May 4, 2025
1. Introduction
Welcome to LuminaX Digital ('we,' 'our,' or 'us'). We respect your privacy and are committed to protecting your personal data. This privacy policy informs you about how we handle your personal data when you visit our website and tells you about your privacy rights according to the EU General Data Protection Regulation (GDPR) and German data protection laws, particularly the Federal Data Protection Act (Bundesdatenschutzgesetz, BDSG).
2. Controller Information
The controller responsible for the processing of your personal data under applicable data protection laws is:
LuminaX Digital
Represented by: Fabian Faraz Farid and Irma Mesic
[Company Address]
[Postal Code and City]
Germany
Email: [Email Address]
Phone: [Phone Number]
3. Data Protection Officer
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our DPO at:
[DPO Name]
Email: [DPO Email Address]
Address: [DPO Address]
4. Personal Data We Collect
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped as follows:
- Identity Data includes first name, last name, username or similar identifier.
- Contact Data includes email address, telephone numbers, and postal address.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products, and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
5. How We Collect Your Personal Data
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email, or otherwise.
- Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources.
6. Legal Basis for Processing Personal Data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform a contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Where you have given consent to the processing of your personal data for one or more specific purposes.
7. Purposes for Which We Use Your Personal Data
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so:
- •To register you as a new customer (performance of a contract).
- •To process and deliver services (performance of a contract, legitimate interests).
- •To manage our relationship with you (performance of a contract, legal obligation, legitimate interests).
- •To enable you to participate in a survey or feedback (consent, legitimate interests).
- •To administer and protect our business and this website (legal obligation, legitimate interests).
- •To deliver relevant website content to you (legitimate interests).
- •To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences (legitimate interests).
8. Data Retention
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
9. Your Rights Under Data Protection Laws
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
Right to access
You have the right to request access to your personal data.
Right to rectification
You have the right to request correction of your personal data.
Right to erasure
You have the right to request erasure of your personal data.
Right to restrict processing
You have the right to request restriction of processing of your personal data.
Right to data portability
You have the right to request the transfer of your personal data.
Right to object
You have the right to object to processing of your personal data.
Right to withdraw consent
You have the right to withdraw consent where we are relying on consent to process your personal data.
If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
10. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.
11. International Transfers
We share your personal data within our group. This will involve transferring your data outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
12. Changes to the 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 website, prior to the change becoming effective and update the 'last updated' date at the top of this privacy policy.
13. Contact
Questions, comments, and requests regarding this privacy policy are welcomed and should be addressed to our Data Protection Officer or to us using the contact details provided above.
14. Complaints
You have the right to make a complaint at any time to the Federal Commissioner for Data Protection and Freedom of Information (BfDI) or to the respective state data protection authority in Germany, the supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.