Privacy and cookies policy.

Data controller

The controller of personal data is LUMEDATA A&D SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, KRS 0001261244, NIP 7532486372, REGON 54551704300000.

Registered office address: Sławniowice 10, 48-355 Burgrabice, Poland.

Share capital: 5 000,00 zł.

Privacy contact: kontakt@lumedata-ad.com, IT telephone: +48 515 041 103, Cleaning telephone: +48 695 321 607.

Data we process and its source

We receive information directly from you when you contact us through the website form, Lumi assistant, telephone, WhatsApp or email. The form sends the enquiry to our mailbox and does not create a separate message database on the website.

• Form and professional details: selected service area, name and email address, plus company and telephone number where provided; an internet enquiry also includes the installation address and expected speed.
• Correspondence: information included in your enquiry, requested service scope and subsequent arrangements.
• Lumi conversation and appointment request: technical questions you enter and information you voluntarily place in the prepared email, such as preferred date, time and consultation topic.
• Technical data: IP address, request time, device or browser type and information stored in server security logs. Anti-spam controls and Lumi abuse protection use a pseudonymous hash of the IP address and counters within short rate-limit windows. Cloudflare Turnstile analyses technical browser and device signals to distinguish a visitor from an automated bot.
• Billing data: information required to enter into and perform a contract and issue accounting documents if you become a client.

Purposes and legal bases

Retention periods

• Enquiry correspondence is retained until the matter is closed and then for the period needed to protect against possible claims.
• The form does not store enquiry content in a website database; the message is retained in the email system in accordance with the rule above.
• Contract and accounting data is retained for the period required by law and until applicable limitation periods expire.
• Technical logs are retained for the time necessary to maintain security, diagnostics and website continuity.
• The analytics consent or refusal is stored in the browser for 180 days. You can change it earlier using Cookie settings or clear the website data.
• Lumi chat history is held in the memory of the current browser tab and disappears when the page is refreshed. LumeData does not save it in its own website database.
• Form-protection counters expire after 30 minutes and Lumi counters after one hour. They do not contain message or conversation content; expired data is removed during the next technical cleanup cycle.
• Once the full AI module is enabled, a short part of the conversation is sent to the OpenAI API with store=false. The provider may retain abuse-monitoring logs for up to 30 days unless a longer period is required by law or security needs.

Recipients and international transfers

Data may be entrusted to hosting, email and IT providers, including Cloudflare as the Turnstile provider, as well as accounting, legal or technical service providers, strictly to the extent required for their work. Data may also be disclosed to authorised public bodies where required by law.

Depending on provider infrastructure, technical data may be processed outside the European Economic Area. Such transfers use a mechanism permitted by the GDPR, in particular an adequacy decision or standard contractual clauses.

Lumi assistant, consultation requests and WhatsApp

Lumi helps visitors choose a service, perform safe first-line checks and prepare a consultation request. It does not make decisions with legal effects, access a visitor’s device or replace a specialist.

• Guided mode: predefined diagnostic rules run in the browser and do not send the conversation to the AI model provider.
• AI mode: once configured, the question and the necessary part of the current conversation are sent to OpenAI to generate an answer. According to the provider, API data is not used to train models by default unless the customer explicitly opts in to data sharing.
• Consultation request: Lumi prepares a message in your email application. It is sent only after you confirm it, and the time is valid only after LumeData replies.
• WhatsApp: the button opens the external WhatsApp service. The website itself does not pass the Lumi conversation to WhatsApp; information is provided only after you enter that service and is also subject to its terms.

Your rights

Depending on the legal basis and circumstances of processing, you may request:

• access to your data and a copy,
• rectification of inaccurate data,
• erasure of data,
• restriction of processing,
• data portability,
• an objection to processing based on legitimate interests,
• withdrawal of consent at any time without affecting prior lawful processing.

You may also lodge a complaint with the Polish President of the Personal Data Protection Office or another competent supervisory authority. We do not use automated decision-making or profiling.

Cookies and local storage

Essential technologies support website operation and security. Optionally, and only with consent, we use Google Analytics 4 to measure visits and clicks on contact links. Measurement includes a browser identifier, visited pages, technical browser and device information and contact events. We do not enable advertising features or Google Signals. Our measurement events do not contain information entered in forms or Lumi conversations.

The controller of data connected with website operation is LUMEDATA A&D SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, KRS 0001261244. The analytics choice is stored locally in the browser. Optional measurement is based on consent. Google receives analytics data as the Google Analytics provider. Processing may include transfers outside the EEA as described in the recipients section. More information: policies.google.com/privacy.

After consent, Google Analytics may set _ga and _ga_NHZZE9Y3CE cookies to recognise the browser and session. The code limits their lifetime to 180 days without renewal on each pageview. Retention of data held by Google depends on the Analytics property settings. Use Cookie settings to change or withdraw consent at any time. Withdrawal stops further measurement on this website and removes these cookies from the browser; it does not automatically delete previously sent data. Contact the controller about data deletion.

Contact and updates

For privacy matters, email kontakt@lumedata-ad.com. This policy may be updated when website functions, service providers or legal requirements change. The date of the current version appears at the beginning.