Privacy Policy

Draft: to be reviewed by legal counsel before publication.

This Privacy Policy explains how personal data is processed when you visit the Lumen Edge website (the "Website") or contact us through it. It does not cover data processed within the Lumen Edge platform on behalf of our customers; that processing is governed by the relevant customer agreement and data processing agreement.

1. Controller

The controller within the meaning of the General Data Protection Regulation (GDPR) is:

[Company legal name] [Registered address] Email: privacy@lumenedge.co Phone: [Phone number]

2. Data we process

2.1 Visiting the Website

When you access the Website, our web server automatically processes technical information transmitted by your browser ("server log data"):

• IP address
• date and time of the request
• requested page or file and the referring URL
• HTTP status code and amount of data transferred
• browser type, version and operating system

This data is required to deliver the Website, to ensure its stability and security, and to detect and defend against misuse.

2.2 Contact and demo request forms

When you submit a contact, demo or partner form, we process the information you provide, typically:

• name, business email address and company
• job title, country and phone number (where provided)
• the content of your message and the topic of your request
• the date and time of submission

We use this data only to respond to your request, to arrange and conduct a demonstration, and to carry out pre-contractual discussions.

2.3 Email communication

If you email us directly, we process your email address, the content of your message and any further information you choose to share, in order to handle your inquiry.

2.4 Local storage and cookies

The Website stores a small number of settings in your browser's local storage, such as your theme preference and your cookie-consent choice. Details are set out in our Cookie Policy.

2.5 Visit analytics (only with your consent)

If you allow analytics in the cookie banner, we set a first-party cookie (le_vid) containing a random identifier, so we can recognize your browser when you return. For each page you view we then record:

• the identifier from that cookie, and whether this is your first visit
• the page you viewed and the page or website you came from (referrer)
• your IP address, browser type and preferred language
• the date and time

We use this data to understand which content is useful and how visitors find us. It is stored on our own servers, is not combined with data from third parties and is not used for advertising. If you withdraw your consent, the cookie is deleted and no further page views are recorded.

3. Legal bases

We process personal data on the following legal bases:

Purpose	Legal basis
Delivering the Website, server logs, security	Art. 6(1)(f) GDPR: legitimate interest in a secure, functioning website
Responding to contact and demo requests	Art. 6(1)(b) GDPR: pre-contractual measures; otherwise Art. 6(1)(f) GDPR: legitimate interest in responding to business inquiries
Strictly necessary local storage	Art. 6(1)(f) GDPR, and the applicable national rules implementing Art. 5(3) ePrivacy Directive
Visit analytics (le_vid cookie and page-view log)	Art. 6(1)(a) GDPR and the national rules implementing Art. 5(3) ePrivacy Directive: consent, which you may withdraw at any time
Compliance with legal obligations	Art. 6(1)(c) GDPR

4. Retention

• Server log data is deleted after no more than [30] days unless it is needed to investigate a specific security incident.
• Form submissions and correspondence are kept for as long as necessary to handle your request and any resulting business relationship, and then deleted after [24] months of inactivity, unless statutory retention obligations (for example commercial or tax law) require longer storage.
• Visit analytics records are deleted after no more than [12] months. The le_vid cookie expires one year after your last visit, or as soon as you withdraw consent.
• Local storage settings remain in your browser until you clear them.

5. Recipients and processors

We share personal data only where necessary for the purposes described above. We use service providers who process data on our behalf under a data processing agreement pursuant to Art. 28 GDPR, for example:

• [Hosting provider: name, location]
• [Email provider: name, location]
• [CRM / form-handling provider: name, location]

We do not sell personal data.

6. International transfers

We aim to process personal data within the European Union / European Economic Area. Where a service provider processes data outside the EU/EEA, we ensure an adequate level of protection, for example through an adequacy decision of the European Commission or standard contractual clauses pursuant to Art. 46(2)(c) GDPR, together with any supplementary measures required.

7. Your rights

Under the GDPR you have the right to:

• access the personal data we hold about you (Art. 15)
• rectification of inaccurate data (Art. 16)
• erasure (Art. 17)
• restriction of processing (Art. 18)
• data portability (Art. 20)
• object to processing based on legitimate interests (Art. 21)
• withdraw consent at any time, without affecting the lawfulness of processing before withdrawal (Art. 7(3))

To exercise these rights, contact privacy@lumenedge.co.

8. Right to lodge a complaint

You have the right to lodge a complaint with a data protection supervisory authority, in particular in the member state of your habitual residence, place of work or the place of the alleged infringement. The authority competent for us is: [Name and address of competent supervisory authority].

9. Automated decision-making

We do not use automated decision-making, including profiling, within the meaning of Art. 22 GDPR.

10. Security

We use appropriate technical and organizational measures to protect personal data, including encrypted transmission (TLS) for all connections to the Website.

11. Changes

We may update this Privacy Policy when our processing or legal requirements change. The current version is always available on this page, with the date of the last update shown above.