Legal
Privacy Policy
Last updated: October 2026
1. Who we are
Lumiera Strategy OÜ (“Lumiera”, “we”, “us”) is the controller of your personal data, which means we decide how and why it is used.
This policy applies to people who visit lumiera.ai, contact us, enquire about or apply for our programmes, or otherwise deal with us as business contacts. The terms of a signed client engagement govern personal data we process under that engagement.
For any privacy question or request, contact hello@lumiera.ai.
2. What personal data we collect
Source
Personal data
Information you give us through forms, bookings, applications, diagnostics and correspondence
Name, work email, company, role, and your answers and messages
Your use of our website
IP address, browser and device type, pages visited and referring page
Publicly available professional sources
Name, role, employer and professional profile
You are not obliged to provide personal data, but we need your name and email address to respond to you.
3. Why we use personal data
Purpose
Legal basis under GDPR Art. 6(1)
Responding to enquiries and arranging calls
Taking steps at your request before a contract (b), or our legitimate interest in answering business correspondence (f)
Assessing applications and diagnostics
Taking steps at your request before a contract (b)
Preparing for meetings and identifying relevant business contacts
Our legitimate interest in developing our business (f)
Sending you information about our services
Your consent (a), or our legitimate interest where electronic marketing rules allow it (f)
Operating and securing our website
Our legitimate interest in a secure, working website (f)
Keeping accounting and tax records
Our legal obligation (c)
Establishing, exercising or defending legal claims
Our legitimate interest in protecting our rights (f)
4. Cookies and similar technologies
We use only cookies and similar technologies that are strictly necessary to run and secure the website. We do not use analytics or advertising cookies.
Embedded forms and booking calendars may set cookies they need to work when you open them.
5. AI tools
We use AI tools to support our work, such as drafting and summarising correspondence. These providers act only on our instructions and must not use your personal data to train their models. We do not make decisions about you that have legal or similarly significant effects based solely on automated processing, including AI.
6. Who we share personal data with
We share personal data only where necessary, with:
service providers acting on our instructions, such as providers of website hosting, email, forms and scheduling, relationship management, AI tools and payments
professional advisers, such as accountants, lawyers and insurers, who are bound by confidentiality
a buyer or successor if we merge with another business, are acquired or sell our business
public authorities, where the law requires it
7. International transfers
Some of our service providers process personal data outside the European Economic Area (EEA). We protect each such transfer with one of these safeguards:
a European Commission decision that the destination offers adequate protection, including the EU-US Data Privacy Framework for certified recipients (Art. 45 GDPR)
the European Commission’s Standard Contractual Clauses (Art. 46 GDPR)
To request information about the safeguard that applies, contact hello@lumiera.ai.
8. How long we keep personal data
Personal data
How long we keep it
Enquiries, bookings and applications that do not lead to an engagement
24 months after last contact
Diagnostic answers
24 months after submission, then anonymised
Marketing contact details
Until you unsubscribe or object; we then keep only your email address, to avoid contacting you again
Invoices and accounting records
7 years from the end of the financial year, as the Estonian Accounting Act requires
Personal data needed for a legal claim
Until the claim is resolved and any limitation period has expired
9. Your rights
Under the GDPR, you have the right to:
access your personal data and receive a copy
have inaccurate or incomplete personal data corrected
have your personal data deleted
restrict how we use your personal data
receive personal data you gave us in a machine-readable format
object to our use of your personal data based on legitimate interest, and to direct marketing at any time
withdraw your consent at any time, without affecting our use of your personal data before you withdrew it
To exercise any of these rights, contact hello@lumiera.ai.
10. Security
We use appropriate technical and organisational measures to protect personal data against unauthorised access, loss and misuse, and we limit access to people who need it.
11. Changes to this policy
We may update this policy. The date below shows when we last updated it.
12. Complaints
If you have a concern, please contact us first at hello@lumiera.ai. You also have the right to complain to a data protection authority, in particular in the EEA country where you live or work, or where you believe the breach took place. In Estonia, this is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), aki.ee.