Website Privacy Policy

Published: 2024-10-17

Luminatens takes the protection of website users' personal data very seriously and is committed to handling it with the utmost care and in compliance with applicable regulations, in particular the General Data Protection Regulation (GDPR). This Website Privacy Policy aims to clarify how we collect, use, and protect the personal data of users who visit our website.

Who is the Data Controller?

The Data Controller is Luminatens, the developer of the Luminatens app. For any information regarding this Website Privacy Policy, you can contact us via our official email address: [Luminatens@mail.com]. The Data Protection Officer (DPO) is the data controller and can be contacted at the same email address.

What Data is Collected and How?

We limit data collection to what is strictly necessary and collect the following personal data from website users:

Contact data: Name, surname, email, and any other information voluntarily provided through the contact form.
Navigation and performance data: IP address (anonymized by Vercel), approximate geolocation data (country derived from IP), information about the device used to access the website, browser type, operating system, pages visited, time of visit, and web performance metrics (like Core Web Vitals). This data is collected through Google Analytics, Microsoft Clarity, Vercel Analytics, and Vercel Speed Insights.
Behavioral data (collected only with explicit consent): Interactions with the website, such as clicks, time spent on pages, mouse movements, and other interactions. This data is collected through Microsoft Clarity.

This data is collected through:

Contact forms completed by users.
Analytics and performance monitoring tools (Google Analytics, Microsoft Clarity, Vercel Analytics, Vercel Speed Insights) to improve user experience and optimize our website (collected only with explicit consent for the 'Statistics' category via the cookie banner).
Cookies and similar tracking technologies (see our Cookie Policy for more details).

What is the Legal Basis for Collection?

The collection of personal data is based on the following legal bases:

User consent: Explicitly requested for certain processing activities, such as behavioral data analysis through Microsoft Clarity, statistical analysis via Google Analytics and Vercel Analytics/Speed Insights, and the use of non-technical cookies. Consent is obtained through the cookie banner upon first access to the website for the appropriate categories (e.g., 'Statistics').
Legitimate Interest of the Controller: To respond to inquiries submitted through the contact form and to ensure the security and integrity of our website. For aggregated and anonymous analysis of website performance and usage (via Vercel Analytics/Speed Insights and Google Analytics), where consent is not the primary basis, we rely on our legitimate interest to improve our web services. We have performed a balancing test and believe that this processing is proportionate, as the data is aggregated and/or anonymized to minimize the impact on privacy and helps us improve the website for all users. [Note: Verify this legal basis with a legal advisor.]

For What Specific Purposes is Data Collected?

The collected data is used for the following purposes:

To provide and manage the website and its content.
To improve the user experience on the website.
To analyze user behavior and website performance (via Google Analytics, Microsoft Clarity, Vercel Analytics, and Vercel Speed Insights) to optimize our services, understand how users interact with the website, and identify technical issues.
To respond to support requests, information inquiries, or other communications submitted through the contact form.
To monitor and ensure the security of our systems.
To collect aggregated and anonymous statistics on website usage and performance.

From Which Categories of Sources Do We Collect Personal Information?

Personal information is collected:

Directly from users through the website (e.g., contact forms).
Automatically through analytics and performance monitoring tools (Google Analytics, Microsoft Clarity, Vercel Analytics, Vercel Speed Insights) and tracking technologies (cookies).

Which Third Parties Will Have Access to the Information?

We share personal data (or anonymized/aggregated data) with the following third parties, only when necessary for the described purposes and based on the consent obtained:

Google (for Google Analytics): Used for website usage data analysis.
Microsoft Clarity: Used for behavioral analysis of users on the website.
Vercel Inc.: Provider of Vercel Analytics and Speed Insights for website traffic analysis and performance monitoring.

We ensure that all third-party data processors, including Google, Microsoft, and Vercel, are contractually bound by Data Processing Agreements (DPAs) compliant with GDPR or provide equivalent safeguards. These agreements ensure that data processing is carried out in accordance with GDPR requirements, providing adequate safeguards for your personal data.

Do We Transfer Data Abroad and, if so, What Measures Have Been Taken to Ensure Safe and Compliant Transfers?

Personal data collected through our website may be transferred to and stored on servers located outside the European Union, particularly in the United States, where Google, Microsoft Clarity, and Vercel Inc. servers are located. To ensure that such transfers comply with data protection regulations, we adopt the Standard Contractual Clauses (SCCs) approved by the European Commission, provided by Google, Microsoft, and Vercel, or rely on other valid legal bases for the transfer. In addition to SCCs, we assess and implement supplementary measures where necessary to further protect data during transfer and storage. For more details, you can consult the privacy policies of the respective providers: Google, Microsoft, Vercel.

What Are the Rights of Users?

Users have the right to:

Access their personal data.
Rectify or update their personal data.
Delete their personal data.
Limit the processing of their personal data.
Request data portability.
Object to processing for legitimate reasons.
Withdraw consent at any time (e.g., by changing preferences via the cookie banner or cookie icon). Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
Lodge a complaint with a supervisory authority.

To exercise these rights, users can contact us at the email address [Luminatens@mail.com]. We will respond to requests within one month, as required by the GDPR. Users also have the right to lodge a complaint with a supervisory authority.

How Will We Notify Users and Visitors of Changes or Updates to the Privacy Policy?

Any changes to this Website Privacy Policy will be published on this page with a revised update date. We recommend that you periodically review this page to stay updated on how we handle data.

What is the Effective Date of the Privacy Policy?

This Website Privacy Policy takes effect on 2024-10-17.