Privacy Policy

This Privacy Policy explains how Lumen (“Lumen”, “we”, “us”) collects and uses personal data when you visit lumengroup.cc (the “Website”) or contact us through it.

1. Data we collect

Information you provide. When you submit an inquiry we collect the details you enter, such as your name, email address, organization, website or social profiles, Telegram username, and the description of your project, interests or request.

Technical information. When you submit a form we record the date and time, the page it was sent from, campaign parameters (such as UTM tags), your IP address and the approximate location derived from it (city, region and country). This is used to prevent spam and abuse and to understand where inquiries come from.

Analytics. If enabled, we use privacy-friendly analytics to understand how the Website is used. Analytics tools that set cookies (such as Google Analytics or Yandex Metrika) are only loaded after you give consent, and you can change your choice at any time via “Cookie settings” in the footer.

2. How we use your data

• to review your inquiry, assess whether there is a relevant fit and respond to you;
• to make introductions you have agreed to;
• to protect the Website and our forms against spam and abuse;
• to understand and improve how the Website performs.

The legal bases for this processing are taking steps at your request before entering into a possible collaboration, our legitimate interest in running and protecting the Website, and - for analytics cookies - your consent.

3. Sharing

We do not sell personal data. We share the details of your inquiry with another party only when you have agreed to an introduction. We use service providers to operate the Website, including our hosting provider, Telegram (to deliver inquiries to our team), Cloudflare (network protection, spam prevention and approximate location), an IP geolocation service and, if enabled, analytics providers. These providers process data on our behalf or under their own privacy terms.

4. International transfers

Some of our service providers may process data outside your country. Where this happens, we rely on appropriate safeguards provided by those providers.

5. Retention

We keep inquiry data for as long as needed to evaluate and follow up on it, and for a reasonable period afterwards for our records, unless you ask us to delete it sooner. Technical spam-prevention records are kept for a short period only.

6. Your rights

Depending on where you live, you may have the right to access, correct or delete your personal data, to object to or restrict its processing, to withdraw consent, and to lodge a complaint with a data protection authority. To exercise these rights, contact us through the Connect page (choose “Other”).

7. Security

We use reasonable technical and organisational measures to protect personal data, including encrypted connections (HTTPS) and restricted access to submitted inquiries.

8. Changes

We may update this policy from time to time. The “Last updated” date at the top shows when it was last changed.