Privacy Policy

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:

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:

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.

For B2B direct marketing and lead generation, we typically collect professional Identity Data (first name, last name, job title) and professional Contact Data (corporate email address, company phone number, company name, and company address).

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. Specifically, for B2B direct marketing purposes, we may collect professional contact information (such as name, job title, company name, and corporate email address) from publicly available sources including company websites, professional networking platforms (e.g., LinkedIn), and public business registers.

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:

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 conduct B2B direct marketing and lead generation activities (legitimate interests). This includes sending relevant email communications to potential business clients whose professional roles align with our services, based on our assessment that they would have a legitimate interest in receiving information about our digital marketing, web design, or AI solutions that can benefit their business.
• •
  To register you as a new customer (performance of a contract).
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  To process and deliver services (performance of a contract, legitimate interests).
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  To manage our relationship with you (performance of a contract, legal obligation, legitimate interests).
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  To enable you to participate in a survey or feedback (consent, legitimate interests).
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  To administer and protect our business and this website (legal obligation, legitimate interests).
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  To deliver relevant website content to you (legitimate interests).
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  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:

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, including with entities that may be based outside the European Economic Area (EEA). Whenever we transfer your personal data out of the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission or transfers to countries deemed adequate. Additionally, certain third-party services we use, such as Google Analytics, involve transfers to the United States under these Standard Contractual Clauses, as described in Section 7a.

• 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.