Privacy Policy

Last updated: November 18, 2025

1. Introduction

Lumina Advisory Limited (“we”, “our”, or “us”) is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.luminaadvisory.im and use our services.

2. Information We Collect

2.1 Information You Provide

We collect information that you voluntarily provide to us when you:

• Fill out our contact form
• Subscribe to our newsletter
• Request information about our services
• Communicate with us via email or phone

This information may include:

• Name
• Organization name
• Email address
• Phone number
• Job title and role
• Service interests
• Message content

2.2 Automatically Collected Information

When you visit our website, we automatically collect certain information about your device, including:

• IP address
• Browser type and version
• Operating system
• Referring website
• Pages visited and time spent on pages
• Device type and screen resolution

3. How We Use Your Information

We use the information we collect for the following purposes:

• To respond to inquiries: Process and respond to your contact form submissions and service requests
• To provide newsletters: Send you updates, insights, and relevant information (with your consent)
• To improve our website: Analyze usage patterns to enhance user experience
• To comply with legal obligations: Meet regulatory and legal requirements
• To protect our interests: Prevent fraud and protect our legal rights

4. Legal Basis for Processing (GDPR)

We process your personal data under the following lawful bases:

• Consent: When you provide explicit consent (e.g., newsletter signup)
• Legitimate interests: When necessary for our legitimate business interests (e.g., responding to inquiries)
• Legal obligation: When required by law

5. Data Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may share your information with:

• Service providers: Third-party services that help us operate our website (e.g., SendGrid for email, Google Analytics)
• Legal authorities: When required by law or to protect our rights
• Business transfers: In the event of a merger, acquisition, or sale of assets

Our service providers are contractually obligated to protect your data and use it only for the purposes we specify.

6. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to:

• Remember your preferences
• Analyze website traffic and usage patterns
• Improve website performance

You can control cookies through your browser settings. Note that disabling cookies may affect website functionality.

6.1 Google Analytics

We use Google Analytics to understand how visitors interact with our website. Google Analytics collects information anonymously and reports website trends without identifying individual visitors. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this policy:

• Contact form submissions: 3 years from last contact
• Newsletter subscriptions: Until you unsubscribe
• Analytics data: 26 months (Google Analytics default)

8. Your Rights Under GDPR

If you are in the European Economic Area (EEA), you have the following rights:

• Right to access: Request a copy of your personal data
• Right to rectification: Request correction of inaccurate data
• Right to erasure: Request deletion of your personal data
• Right to restrict processing: Request limitation on how we use your data
• Right to data portability: Receive your data in a structured, machine-readable format
• Right to object: Object to processing based on legitimate interests
• Right to withdraw consent: Withdraw consent at any time (where processing is based on consent)

To exercise any of these rights, please contact us at privacy@luminaadvisory.im.

9. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• SSL/TLS encryption for data transmission
• Secure hosting infrastructure
• Access controls and authentication
• Regular security assessments
• Staff training on data protection

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

10. International Data Transfers

Your information may be transferred to and processed in countries outside your country of residence, including countries that may not have the same data protection laws. We ensure appropriate safeguards are in place for such transfers, including Standard Contractual Clauses approved by the European Commission.

11. Children's Privacy

Our website and services are not directed to individuals under the age of 16. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the new policy on this page and updating the “Last updated” date.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

• Email: privacy@luminaadvisory.im
• General inquiries: info@luminaadvisory.im
• Website: www.luminaadvisory.im

14. Data Protection Officer

For data protection matters specific to GDPR compliance, you may contact our Data Protection Officer at dpo@luminaadvisory.im.

15. Supervisory Authority

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with your local data protection supervisory authority.