Privacy Policy

This policy covers the personal data Lumia Labs BV handles through this website and through the contact that follows from it. It does not cover the Export Control Proxy software itself, which customers run on their own infrastructure; that is covered separately below.

Who is responsible

Lumia Labs BV, a besloten vennootschap established in the Netherlands, KvK 80468039, is the controller for the data described here. For anything in this policy, including access, correction, or deletion requests, write to info@lumialabs.com.

We have appointed a Data Protection Officer. You can reach them at info@lumialabs.com or through the contact form, marked for the attention of the Data Protection Officer.

What we collect

We collect personal data in two situations. The first is when you contact us. If you send the form on the contact page, write to info@lumialabs.com, or call the number in the legal notice, we have whatever you chose to put in that message: typically a name, a company, an email address, and the substance of the question. The form asks for those and nothing more, and there is nothing on this site that collects data in the background.

The second is when your organization becomes a customer. For the people we work with there, we keep the contact and administrative details needed to run the relationship: names, work email addresses, phone numbers, and the correspondence and records that go with a contract.

Why, and on what basis

Inquiries are handled because we have a legitimate interest in answering people who approach us, and because answering is usually a step towards a contract you asked about. Customer data is handled to perform the contract with your organization and to meet the record-keeping obligations that come with it.

We do not use personal data for advertising, we do not profile anyone, and we do not sell or rent data to anyone.

How long we keep it

A person reads your message and answers it. It is not filed as a record afterwards. A form submission is delivered straight to that mailbox: the endpoint behind the form keeps no copy of it.

Customer data is kept for as long as your organization is a customer, and after that for as long as we are required to keep our business administration.

Cookies and tracking

This site sets no cookies. It runs no analytics, no tracking pixels, no advertising tags, and no third-party embeds, so nothing on the page reports your visit to anyone else. There is no cookie banner.

Who else is involved

We use service providers to host this website and to run our email. They handle data on our instructions, for the purpose of providing that service, and for nothing else. We share personal data outside that in only two cases: when you ask us to, and when the law requires it.

What the product does with your data

Export Control Proxy is self-hosted. Customers run it inside their own infrastructure, and the session data, location records, and audit logs it produces stay there. It makes no outbound calls carrying that data, so we do not receive it and cannot access it. When a customer runs the product, the customer is the controller for what it processes; Lumia Labs BV is not.

Your rights

Under the GDPR you can ask us for a copy of the personal data we hold about you, ask us to correct it or delete it, ask us to restrict what we do with it, object to our handling of it, or ask for it in a portable form. Write to info@lumialabs.com and we will answer.

If you think we have handled your data badly, tell us first so we can fix it. You can also complain to the Dutch data protection authority, the Autoriteit Persoonsgegevens.

Changes

If this policy changes, the updated version appears on this page with a new date at the top.