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Privacy Policy


1. General Information

This Privacy Policy explains how Lumias SIA, reg. no. 50203680421, legal address Stārķu iela 4-37, Rīga, LV-1084, (hereinafter ‒ the Company or we) processes personal data obtained through our website lumias.studio or during communication with us.

We process personal data in accordance with the European Union’s General Data Protection Regulation (GDPR) and the laws of the Republic of Latvia.

2. What Personal Data Is Processed

We process the following categories of personal data:

  • Data you provide via our Waitlist Registration Form:

    • Full name

    • Email address

    • Primary professional specialty

    • Workflow bottlenecks or challenges (optional free-text field)

  • Data you provide when contacting us directly via email or phone:

    • Name, email address, phone number, and any other information you voluntarily provide in your request.

  • Technical data about website visits (using Google Analytics):

    • Anonymized IP address, browser type and version, device information, and page visit data.

3. Purposes of Data Processing and Legal Basis

Your personal data is processed for the following specific purposes and legal bases:

  • Managing the Software Waitlist and Early Access: To register you for free early access to our software and manage your placement on the waitlist.

    • Legal basis: Performance of a contract or taking steps prior to entering into a contract at your request (GDPR Article 6(1)(b)).

  • Targeted Direct Communication: To contact you individually to discuss your professional needs, software status, or waitlist updates. We do not use your data for automated mass marketing blasts.

    • Legal basis: Our legitimate interest to engage with interested professionals and refine our software based on direct user feedback (GDPR Article 6(1)(f)).

  • User Profiling and Software Optimization: To analyze the specialties and workflow bottlenecks submitted through the form. This allows us to profile our audience demographics and adjust our software features to better match user needs.

    • Legal basis: Our legitimate interest to develop and optimize a relevant, market-fit product for our user base (GDPR Article 6(1)(f)).

  • General Communication: To respond to inquiries when you initiate contact outside the form.

    • Legal basis: Legitimate interest to respond to your request (GDPR Article 6(1)(f)).

  • Website Analytics: To analyze and improve website performance.

    • Legal basis: Your explicit consent via our cookie banner (GDPR Article 6(1)(a)).

4. Data Storage and Retention Periods

Your data is stored securely and retained only as long as necessary for the purposes outlined:

  • Waitlist and Profile Data: Form submissions are synchronized with our internal Odoo database where they are registered as an "Opportunity." This data is retained for the duration of the software development and early access phase, or until you request its removal.

  • General Communication Data: Retained for the duration of our professional relationship with you, or as long as necessary to evaluate potential future business opportunities and maintain historical context of our user interactions. If a communication does not lead to an active business relationship, the identifiable data will be reviewed periodically and removed when it is determined that the interaction is no longer relevant for our ongoing operational context.
  • Statistical and Historical Data: We may permanently anonymize communication data (removing all direct personal identifiers such as names and email addresses) to retain it indefinitely for internal historical analysis, research, and product development statistics.
  • Google Analytics Data: Retained according to Google’s standard retention settings (up to 14 months).

5. Recipients of Data and Transfers to Third Countries

We do not sell, rent, or disclose your personal data to third parties, except to essential service providers who support our operations:

  • Odoo S.A. / Odoo Partners: We use Odoo as our internal Customer Relationship Management (CRM) platform to manage our waitlist, track business opportunities, and securely organize the professional information you submit.

  • IT Infrastructure Providers: Website hosting and maintenance service providers.

  • Google LLC: For Google Analytics services. Google may process data outside the European Union. Appropriate safeguards, such as Standard Contractual Clauses (SCCs), are applied to ensure data security.

6. Your Rights

In accordance with the GDPR, you have the right to:

  • Access your personal data and request a copy.

  • Request the correction of inaccurate data or completion of incomplete data.

  • Request the deletion of your personal data ("right to be forgotten"), especially if you wish to leave the software waitlist.

  • Restrict the processing of your data under certain conditions.

  • Object to processing based on our legitimate interests (such as audience profiling or direct outreach).

  • Withdraw your consent at any time (for cookies/analytics).

  • Lodge a complaint with the Latvian Data State Inspectorate (Datu valsts inspekcijawww.dvi.gov.lv).

7. Contact Information

For any questions regarding this Privacy Policy, your data, or to exercise your rights, please contact us at: support@lumias.studio

Last updated: June 26, 2026