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Privacy Policy

Last updated: template — pending legal sign-off.

Legal review pending

This is a working template. The final wording is awaiting sign-off from legal counsel and the Data Protection Officer before launch. It does not yet constitute the binding agreement.

1. Data controller

NUWA LIMITED, Ground Floor, 71 Lower Baggot Street, Dublin 2, Ireland (VAT IE3666666EH) is the data controller for personal data processed through www.lumynio.dev. We are committed to processing personal data in line with the EU General Data Protection Regulation (GDPR).

2. Data Protection Officer

You can contact our Data Protection Officer at dpo@lumynio.dev for any question about this policy or your personal data.

3. What we collect on this website

This website is intentionally minimal. It does not use analytics, advertising or tracking cookies, and it sets no non-essential cookies. We do not operate a contact form; if you email us, we process the contact details and message content you choose to send.

4. Why we process it, and our legal basis

  • To respond to enquiries you send us by email — legal basis: our legitimate interest in answering you, or steps taken at your request prior to entering a contract.
  • To provide and administer our Services to business customers — legal basis: performance of a contract.
  • To meet legal, accounting and tax obligations — legal basis: legal obligation.

5. Sharing and international transfers

We host this website and our platform on EU-sovereign infrastructure within the European Union. We do not sell personal data. We share data only with processors who help us run the Services under appropriate safeguards, and we avoid transfers outside the EU/EEA; where a transfer is unavoidable it is protected by an approved transfer mechanism.

6. Retention

We keep personal data only as long as necessary for the purpose it was collected, or as required by law, and then delete or anonymise it.

7. Your rights

Under the GDPR you have the right to access, rectify, erase, restrict and port your personal data, and to object to certain processing. You also have the right to lodge a complaint with a supervisory authority — in Ireland, the Data Protection Commission. To exercise any right, contact our DPO at dpo@lumynio.dev.

8. Changes to this policy

We may update this policy from time to time. The current version will always be available on this page.