Privacy Policy

Last updated: September 26, 2025

This Privacy Policy explains how the Platform ensures the confidentiality and protection of Data of all Users, including Authors and Buyers, when they access and use the services of the Platform.

By setting out these provisions, we aim to make transparent the ways in which the Platform collects, processes, stores, and shares Data.

Throughout this Privacy Policy, references to “we”, “our” or “us” mean the Platform, while references to “you” or “your” mean the User — whether acting as a Author or a Buyer.

We respect your right to privacy and are committed to safeguarding your Data in compliance with applicable data protection laws, including the GDPR.

Words such as they and their derivatives are used for convenience and include all gender-neutral.

We are grateful to you for choosing to use the Platform.

1. DEFINITIONS

1.1. Personal Data means any information relating to an identified or identifiable natural person (User). An identifiable natural person is one who can be identified, directly or indirectly.

1.2. Statistical Data means information about the operation of the Platform and marketplace activity (including interactions of Authors and Buyers) that reflects aggregated measurements, trends, or performance indicators and is produced by the Platform in a manner (aggregation, anonymization or de-identification) that does not identify an individual User and cannot reasonably be used to do so.

1.3. Data means common name for Personal and Statistical Data.

1.4. Services means the set of functionalities and opportunities provided by the Platform to Users, including enabling Authors to offer their works, enabling Buyers to purchase such works, and ensuring the technical, informational, and organizational support necessary for the operation of the marketplace.

1.5. Author means a User who, through the Platform, offers works, goods, or services for sale to Buyers under the rules and functionality of the Platform.

1.6. Buyer means a User who, through the Platform, purchases works, goods, or services offered by Authors under the rules and functionality of the Platform.

1.7. User means a common name for Author and Buyer.

1.8. Platform’s website (hereinafter referred to as the “Site”) means a web page or a group of web pages on the Internet located at:https://lumini.net/

1.9. Platform “Lumini” (hereinafter – the “Platform” or “Lumini”) means an online marketplace owned and operated by a self-employed person registered in the Republic of Cyprus.

1.10. Terms of Use are a written document that regulates the conditions for using the Platforms. More detailed information is available at the following link:

1.11. Third Party means a natural or legal person, government agency, institution or body besides the Platform or the User, the Controller or the Processor.

1.12. Controller – means any natural or legal person, government agency, institution, or other body that independently determines the purposes and means of personal data processing.

1.13. Processor – is a natural or legal person, government agency, institution, or other body that processes Personal Data on behalf of and behalf of the Controller.

1.14. Cookies – are a piece of information in the form of text or binary data that is transmitted to the browser from the site.

1.15. User’s Consent (hereinafter “Consent”) – means a voluntary, specific, informed, and unequivocal expression of will, in which the User using a statement or explicit affirmative action agrees to the processing of his Personal Data and to comply with the terms of this Privacy Policy.

2. GENERAL PROVISIONS

2.1. The Platform provides Services to Users from different regions of the world. In its activities, the Platform complies with the applicable legislation of the Republic of Cyprus, including the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data Law 125(I)/2018, which implements the requirements of the General Data Protection Regulation (Regulation (EU) 2016/679, “GDPR”).

2.2. For Users located in the United States, the Platform takes into account the requirements of applicable federal and state privacy laws, including but not limited to the California Consumer Privacy Act (CCPA), as well as other relevant state-level regulations where applicable.

2.3. The Platform acts as a Controller with respect to the processing of Personal Data where it independently determines the purposes and means of such processing in the operation of the marketplace. The Platform may also act as a Processor where it processes Personal Data on behalf of a Author or Buyer, in cases where those parties determine the purposes and means of processing in the context of their activities on the Platform.

3. DATA PROCESSING

3.1. The Platform may receive the following Personal Data about the Users:
3.1.1. full name;
3.1.2. email;
3.1.3. telephone;
3.1.4. address;
3.1.5. country of residence;
3.1.6. data obtained from publicly available social media accounts;
3.1.7. login and password.

3.2. The Platform may receive the following Statistical Data about the Buyer:
3.2.1. data obtained from publicly available social media accounts;
3.2.2. information on activity within the Platform (frequency of visits, interactions with Authors’ works, search queries, browsing history);
3.2.3. aggregated data used to verify authenticity and compliance of works offered by Authors;
3.2.4. anonymized technical indicators related to the Buyer’s use of the Platform;
3.2.5. other statistical information that does not identify the Buyer as an individual but is necessary for analytics, verification, or marketplace integrity.

3.3. The Platform may receive the following Statistical Data about the Author:
3.3.1. data obtained from publicly available social media accounts;
3.3.2. information on the activity of the Author within the Platform (number of works uploaded, frequency of updates, interaction with Buyers);
3.3.3. aggregated data used for verification of the originality and compliance of the works offered;
3.3.4. anonymized indicators of sales performance, ratings, and feedback;
3.3.5. other statistical information that does not identify the Author as an individual but is necessary for analytics, verification, or marketplace integrity.

3.4. The Platform may receive the following Personal Data about the User’s personnel – legal entity:
3.4.1. full name;
3.4.2. email;
3.4.3. telephone.

3.5. The Platform may receive the following Statistical Data about the User – legal entity:
3.5.1. data from publicly available corporate or business social media accounts and websites;
3.5.2. information on the activity of the legal entity’s account within the Platform (number of listings, interactions with Buyers and Authors, frequency of updates);
3.5.3. company data: name, legal address, company number, email, phone;
3.5.4. aggregated data used to verify the legitimacy of the legal entity and the compliance of works or goods offered through the Platform;
3.5.5. anonymized indicators of transaction volume, ratings, and marketplace performance;
3.5.6. other statistical information that does not identify natural persons but reflects the business activity of the legal entity on the Platform

3.6. The Platform purposefully does not process the User’s banking data, and such data is processed exclusively by the payment system, which is used to receive payments. The Platform may process payment data solely to resolve disputes and/or to comply with the requirements of the legislature and/or the decision of the judicial/executive authority.

3.7. The Platform does not collect or process sensitive Personal Data of Users, such as race or ethnic origin, political views, religious or philosophical beliefs, union membership, genetic or biometric data, health information, sexual life or sexual orientation.

3.8. The Platform may, prior to granting a User the right to act as an Author, conduct a manual verification procedure. Such verification includes the review of the User’s professional background, including but not limited to publicly available information on professional networking platforms (such as LinkedIn), personal or corporate websites, and other sources reasonably necessary to assess the User’s expertise. The purpose of this verification is to ensure that the User’s qualifications and professional profile are consistent with the requirements and standards of the Platform before enabling the User to offer works, goods, or services through the Platform.

3.9. In order to receive payouts, each Author shall undergo a Know Your Customer (KYC) verification directly with the Platform’s authorised payment partners (Stripe, PayPal, Payoneer). The collection and verification of identification data and supporting documents are carried out exclusively by the respective payment partner as an independent Controller under applicable anti-money-laundering and counter-terrorist-financing legislation. The Platform does not access or store such documents and only receives confirmation of the verification status necessary to enable payouts.

3.10. Buyers are not subject to any separate verification procedure by the Platform. All identity and transaction checks are carried out exclusively by the authorised payment partners during their standard anti-fraud and payment security procedures. In the course of such checks, certain data related to the Buyer may be collected and processed directly by the payment partners and subsequently made available to the Platform only to the extent necessary to confirm the outcome of the payment transaction.

3.11. The Platform may collect and process User Data through its internal notification system, through transactional email messages (including purchase confirmations, payout notifications, and status updates), as well as through interactions via the official social media accounts of the Platform, solely for the purpose of providing the Services, maintaining communication with Users, and ensuring the proper functioning of the Platform.

3.12. The Platform may use certain User Data for marketing purposes, subject to applicable data protection laws. Marketing communications, including newsletters and promotional offers, are sent exclusively on the basis of the User’s explicit prior consent (opt-in). For promotional campaigns of the Platform, including campaigns on social media, the Platform may use the name of the Author and information about the Author’s works offered on the Platform, provided that such use serves the purpose of advertising both the Platform and the Author’s activity within it.

3.13. When visiting the Site or receiving Services, Platform may collect the following Personal Data automatically:
3.13.1. IP address;
3.13.2. time zone and language settings;
3.13.3. browser type and version;
3.13.4. operating system, device type, and screen extension;
3.13.5. the country in which you are located;
3.13.6. data about your visit to the Site, including full URL information, routes to and from the Site (including date and time), page response time, data loading errors, length of stay on certain pages, page activity (such information such as scrolling and mouse movements, clicks), methods used to exit the page and telephone numbers to contact the User’ support.

3.14. The Platform has the right to collect and use Personal Data as follows:

4. TRANSFER OF DATA

4.1. The Platform may transfer Data to entities with which the Platform cooperates in the implementation and provision of Services:

4.1.1. Payment service providers. For the purpose of processing payments and enabling payouts, Data may be transferred directly and automatically to authorised payment partners (including Stripe, PayPal, Payoneer), each acting as an independent Controller under applicable legislation. The Platform does not store or process payment card or banking details.
4.1.2. Key technological partners. Data may be transferred solely to essential service providers without which the operation of the Platform would not be possible, including hosting providers and email distribution services.
4.1.3. Contractors and consultants. Where necessary for the proper operation of the Platform, Data may be shared with carefully selected contractors such as legal, tax, accounting, marketing, and IT service providers, bound by confidentiality and data protection obligations.
4.1.4. Counterparties in corporate transactions. Data may be disclosed in the context of an acquisition, merger, financing, corporate reorganisation, joint venture, or sale of assets, subject to compliance with applicable data protection requirements.
4.1.5. Courts, law enforcement and state bodies. Data may be transferred where required by applicable law, including Law 125(I)/2018 of the Republic of Cyprus, the GDPR, or upon a binding order of a competent court or regulatory authority.

5. DATA TRANSFER OUTSIDE THE EUROPEAN UNION

5.1. The Platform may transfer certain User Data outside the European Union in limited cases, where this is strictly necessary for the functioning of the Platform and the provision of Services. Such transfers may occur, in particular, in relation to Authors, due to the use of global service providers that support the Platform’s operations. For example, authorised payment partners such as Stripe, Inc. (United States) may process and store Data in jurisdictions outside the EU.

5.2. All such transfers are carried out in compliance with the requirements of the General Data Protection Regulation (GDPR) and the Law 125(I)/2018 of the Republic of Cyprus, including the application of appropriate safeguards such as Standard Contractual Clauses (SCCs) or equivalent legal mechanisms ensuring adequate protection of User Data.

6. USER CONSENT

6.1. The processing of Data by the Platform is based on clear and explicit consent from the User, except where another lawful ground under applicable legislation applies (such as the necessity to perform a contract or to comply with a legal obligation). Consent is deemed valid only if it is freely given, specific, informed, and unambiguous.

6.2. The following actions of the Buyer shall be deemed as granting consent to this Privacy Policy:

6.2.1. registration of an account on the Platform;
6.2.2. browsing and purchasing works, goods, or services through the Platform;
6.2.3. explicit acceptance of this Privacy Policy during the checkout process or using Site.

6.3. By performing any of the above actions, the Buyer provides explicit Consent to the processing of his or her Data for the following purposes:
6.3.1. processing of the Buyer’s Data by the Platform for the purposes of providing and supporting the Services offered through the Platform, including account maintenance, facilitation of purchases, and communication related to the Buyer’s activity on the Platform;
6.3.2. administration and maintenance of the Buyer’s account, including enabling purchases, order formation and execution, delivery coordination, and access to Platform functionality;
6.3.3. receiving transactional communications related to purchases, delivery updates, account notifications, and dispute-resolution correspondence;
6.3.4. processing of technical and statistical Data related to the Buyer’s activity on the Platform for security, fraud-prevention, service stability, performance monitoring, and user-experience improvement;
6.3.5. limited sharing of strictly necessary Data with the Platform’s key technological partners essential for operation (including hosting providers and email distribution services), subject to appropriate contractual and technical safeguards;
6.3.6. processing carried out by authorised payment partners during their standard anti-fraud and payment-security procedures, with certain transaction-related Data (e.g., payment outcome/identifier and verification status) being made available to the Platform solely to confirm the result of the payment;
6.3.7. receiving marketing communications (newsletters, promotions) exclusively where the Buyer has provided prior explicit Consent (opt-in).

6.4. The following actions of the Author shall be deemed as granting consent to this Privacy Policy:
6.4.1. registration of an Author’s account on the Platform;
6.4.2. uploading and offering works or goods through the Platform;
6.4.3. explicit acceptance of this Privacy Policy during the onboarding or verification process.

6.5. By performing any of the above actions, the Author provides explicit Consent to the processing of his or her Data for the following purposes:
6.5.1. processing of the Author’s Personal Data by the Platform in accordance with this Privacy Policy, including collection, recording, storage, use, disclosure and transfer of such Data for the purposes of operating and maintaining the Author’s account; enabling creation, publication, display and management of listings and portfolios; managing orders and communications with Buyers; Service providing; performing non-financial verification of compliance with the Platform’s standards; ensuring security, fraud- and abuse-prevention and marketplace integrity; resolving disputes and enforcing the Platform’s rules (including takedowns and IP protection) and providing Author performance analytics within the Platform;
6.5.2. processing and transfer of Data to authorised payment partners (including Stripe, PayPal, Payoneer) for the purpose of completing financial verification (KYC/AML), enabling payouts, and complying with anti-fraud and payment-security procedures;
6.5.3. limited sharing of Data with the Platform’s key technological partners essential for the operation of the Platform (hosting providers, email distribution services), subject to contractual and technical safeguards;
6.5.4. use of the Author’s name and information about works, goods, or services offered on the Platform in marketing campaigns and promotional materials of the Platform, including on official social media accounts, provided that such use is limited to promoting both the Platform and the Author’s activity within it.

6.6. Consent may be obtained by the Platform in the form of an explicit affirmative action of the User, including by ticking a checkbox or marking a selection field during registration, account setup, checkout, or use of the Platform.

7. PERSONAL DATA STORAGE AND PROTECTION

7.1. The Platform protects and stores Data from:

7.1.1. losses;

7.1.2. unlawful use, transfer, disclosure, modification, deletion, and/or destruction.

7.2. Data is stored on servers provided by Hosting Ukraine LLC (operating under the ADM.TOOLS brand), with physical servers located in the USA. Only minimal Data required for the operation of the Platform is stored directly by the Platform, including email addresses, full name, phone numbers, and contact details provided by the User. All payment-related Data is stored exclusively by authorised payment service providers (such as Stripe, PayPal, Payoneer) or by other essential service providers used for the operation of the Platform.

7.3. The following technical measures are applied:

7.3.1. User account passwords are stored in hashed form (bcrypt / PHP password hashing framework);

7.3.2. SSL/HTTPS encryption is enabled to secure Data during transmission between the User’s browser and the Platform’s servers;

7.3.3. Personal data is stored on secure servers with limited access;

7.3.4. no payment card or banking Data is stored on the Platform’s servers.

7.4. We may use the following methods to protect Data in accordance with the article “Security of processing” 32 GDPR:

7.4.1. pseudonymization and encryption of Data;
7.4.2. ability to ensure constant confidentiality, integrity, availability and fault tolerance of Data processing systems;
7.4.3. regular testing, evaluation and measurement of the effectiveness of technical and organizational measures to ensure the security of processing Personal Data.

7.5. The Platform does not store the User’s Data in the event of a request to delete such Data in accordance with the right to erasure, as provided in Article 17 GDPR.

7.6. The Platform has the right to retain certain User Data for a period of up to three (3) years following the termination of the relationship with the User, but only to the extent strictly necessary for the following purposes:
7.6.1. Statistical and analytical purposes – storage of depersonalised or aggregated Data required to generate reports and maintain records on the usage of the Platform, provided that such Data does not identify the User directly;
7.6.2. Compliance with legal obligations – retention of Data where such storage is required under applicable laws and regulations, including tax, accounting, anti-money laundering (AML), and consumer protection requirements;
7.6.3. Protection of legal rights and dispute resolution – retention of Data that may be necessary to initiate, substantiate, or defend against potential legal claims, investigations, audits, or regulatory proceedings related to the User’s use of the Platform;
7.6.4. Business continuity – retention of limited Data necessary to preserve records of transactions, ensure the integrity of business operations, and maintain historical evidence of activities carried out on the Platform.

7.7. Upon expiry of the three-year retention period, or once the above purposes are fully satisfied, whichever occurs earlier, the Data shall be securely deleted or anonymised.

8. GROUNDS FOR PERSONAL DATA PROCESSING

8.1. The Platform processes Personal Data based on the following legal grounds:

8.1.1. Consent of the User – where the User has provided explicit Consent (e.g., for receiving marketing communications, or for specific uses of Data not directly necessary for the provision of Services). The User may withdraw Consent at any time without affecting the lawfulness of processing based on Consent prior to its withdrawal.
8.1.2. Performance of a contract – where the processing of Data is necessary for the conclusion and execution of agreements with the User, including the provision of Services through the Platform (such as registration, account management, purchases, payouts, and related communication).
8.1.3. Compliance with legal obligations – where processing is necessary to comply with applicable legislation (such as tax, accounting, anti-money laundering (AML), and consumer protection laws).
8.1.4. Legitimate interests of the Platform – where processing is necessary to ensure the proper level of business operations, including the maintenance of the security and integrity of the Platform, prevention of fraud, support of corporate transactions (such as mergers or acquisitions), and protection of legal rights in disputes.

8.2. In cases where the basis for the processing of Personal Data is Your Consent, You have the right to withdraw it at any time. To withdraw your Consent, You may emai: info@lumini.net . If Your Consent is withdrawn, the Platform has the right to terminate the provision of the Services and terminate all relations with You. If Consent is withdrawn, your Personal Data will be permanently deleted.

8.3. The Platform undertakes to stop processing Personal Data within 15 (fifteen) business days from the date of receipt of the withdrawal of Consent.

9. USER RIGHTS (EEA JURISDICTION)

9.1. This section of the Privacy Policy governs the processing of Data belonging to Users who are residents of the member states of the European Economic Area (EEA), in accordance with the provisions of the General Data Protection Regulation (Regulation (EU) 2016/679, GDPR).

The processing of such Users’ Data is carried out on lawful grounds and in compliance with the principles of lawfulness, transparency, proportionality, purpose limitation, and data minimization as set forth by the GDPR.

9.2. When processing personal and statistical data, the Service grants the User the following rights:

9.2.1. Right of access (Article 15 GDPR). The User may contact us directly to access the Data we hold about them, as well as any additional information provided for in Article 15 of the General Data Protection Regulation (GDPR).

9.2.2. Right to erasure (Article 17 GDPR). The User has the right to request the deletion of their Data. In such a case, the Data will be permanently deleted in accordance with Article 17 GDPR, unless legal exceptions apply.

9.2.3. Right to data portability (Article 20 GDPR). The User has the right to receive their Data in a structured, commonly used, and machine-readable format and to transmit it to another controller or request its direct transmission to a third party, where technically feasible, pursuant to Article 20 GDPR.

9.2.4. Right to rectification (Article 16 GDPR). The User has the right at any time to request the update, correction, or completion of inaccurate or incomplete Data in accordance with Article 16 GDPR.

9.2.5. Right to object (Article 21 GDPR). The User has the right to object at any time to the processing of their Data on grounds relating to their particular situation, pursuant to Article 21 GDPR.

9.2.6. Automated individual decision-making, including profiling (Article 22 GDPR). The User has the right not to be subject to a decision based solely on automated processing, including profiling, if such a decision produces legal effects concerning them or similarly significantly affects them, as set forth in Article 22 GDPR.

9.3. Right to lodge a complaint with the supervisory authority. In accordance with Law 125(I)/2018 of the Republic of Cyprus, the User has the right to submit a complaint regarding the processing of their Data to the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus, without prejudice to their right to seek remedies before the competent courts. Contact details of the Commissioner are available at: https://www.dataprotection.gov.cy

10. USER RIGHTS (USA)

10.1. This section of the Privacy Policy regulates the procedure for processing personal data of Users who are residents of the United States of America, taking into account the requirements of the legislation of individual U.S. states on the protection of personal information, in particular the California Consumer Privacy Act (CCPA/CPRA).

10.2. This section applies to Users who are residents of the United States of America. Within the framework of applicable legislation, including the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), Users have the right to exercise the following rights with respect to their Personal Data:

10.2.1. Right of access. The User has the right to request which Personal Data about them is stored by the Service, as well as to learn about the purpose of its processing, its source, and the categories of third parties to whom it may have been disclosed.

10.2.2. Right to deletion. The User has the right to request full deletion of their Personal Data, except in cases where its retention is necessary under applicable law.

10.2.3. Right to rectification. The User has the right to update, change, or supplement inaccurate or incomplete Personal Data stored by the Service.

10.2.4. Right to data portability. The User has the right to receive a copy of their Personal Data in a commonly used machine-readable format and to transfer this data to another service provider upon request.

10.2.5. Right to object. The User may object at any time to the processing of their Personal Data, including for marketing or analytical purposes.

10.2.6. Right to withdraw Сonsent. The User has the right to withdraw previously given Сonsent to the processing of Personal Data. In such a case, the Service reserves the right to discontinue the provision of Services.

10.3. The Service does not support the “Do Not Track” (DNT) signal, in accordance with the California Online Privacy Protection Act (CalOPPA). DNT is a browser setting that allows Users to notify websites that they do not wish to be tracked. The User can enable or disable the DNT feature in their web browser settings.

11. OTHER JURISDICTIONS

11.1. The Platform processes Personal Data in jurisdictions outside the EEA and the United States in accordance with applicable local laws and recognized international standards for data protection, applying privacy-by-design principles and proportionate safeguards.

11.2. This Privacy Policy sets out the Platform’s general approach to processing and the core legislative frameworks primarily applicable to the Services. Where the laws of a particular jurisdiction grant additional rights or impose additional obligations, the Platform will comply with those requirements. Nothing in this Privacy Policy limits mandatory provisions of applicable local law.

11.3. Due to the global nature of the Services, it is not feasible to list every data-protection law in every jurisdiction. Jurisdiction-specific notices or addenda may be provided where required and shall supplement this Privacy Policy.

11.4. The basic rights described in this Privacy Policy apply to the extent required by the law of the User’s place of residence. The scope, conditions, and exceptions to such rights may vary by jurisdiction. The Platform will handle requests in accordance with applicable law, may request information necessary to verify the requester’s identity, and will inform the User where an exemption or lawful refusal applies.

12. SUBMISSION OF REQUEST

12.1. A User in any jurisdiction has the right to submit a request to the Platform if he believes that his rights have been violated by writing a request in writing to the support of the Platform at the address: info@lumini.net

12.2. The User’s request must contain accurate information about the requirements for the Platform. If the exact requirements are not specified in the request, the Platform has the right to refuse to fulfill the request.

12.3. We will not be able to respond to your request or provide you with Data unless we can verify your identity and confirm that the Data belongs to you. In case of receiving a request with inaccurate information and/or in case of inability to confirm the User’s identity, the Platform has the right not to process the received request and contact the User for clarification. In case of receiving a response to a request for clarifications, the User must provide a new corrected request or submit a new request.

12.4. The Platform must respond to the request or fulfill the conditions set forth in the request within 21 (twenty one) business days from the moment of its receipt.

13. RESPONSIBILITY

13.1. The Platform informs the User that certain categories of Data must be processed in order to enable the operation of the Platform and the provision of Services. If the User does not agree to the processing of such Data in accordance with this Privacy Policy, the Platform will not be able to provide Services to that User.

13.2. The Platform shall not be held responsible for:
13.2.1. any damage, loss, or unauthorised disclosure of Data that occurs as a result of the User’s own actions or omissions, including the use of weak credentials, disclosure of login details to third parties, or use of non-secure devices or networks;
13.2.2. any access to or use of Data by Third Parties (such as payment service providers, hosting companies, or communication platforms) acting as independent controllers, which process Data in accordance with their own privacy policies;
13.2.3. the content, data collection practices, or privacy standards of external websites, platforms, or services to which the Platform may provide links, since such practices are governed exclusively by the privacy policies of those Third Parties;
13.2.4. any consequences of the User providing explicit Consent to the processing of Data, where such Consent was freely and knowingly given by the User.

13.3. While the Platform applies technical and organisational measures, including the use of SSL/HTTPS encryption and secure password hashing, to protect the confidentiality and integrity of Data, the transmission of information over the Internet cannot be guaranteed to be completely secure. Accordingly, the Platform cannot be held liable for any Data breaches, interception, or unauthorised access occurring during transmission of Data between the User’s device and the Platform’s servers.

13.4. The User remains solely responsible for ensuring the security of their own devices, maintaining the confidentiality of their login credentials, and exercising caution when transmitting Data over open or unsecured networks.

14. COOKIES

14.1. The Platform uses Cookies and similar technologies (such as web beacons, pixels, and tracking scripts) to ensure the secure and efficient operation of the Platform, to improve the User experience, and to support marketing and analytical activities.

14.2. Cookies do not transmit viruses or malware to your device. They function as logs that record User activity, remember state information, and are updated each time you visit the Platform.

14.3. The Platform uses Cookies for the following purposes:
14.3.1. Authentication and identification – to recognise Users and manage account sessions;
14.3.2. Storage of personal preferences and settings – to save language preferences and interface settings;
14.3.3. Session tracking – to maintain secure access sessions and prevent unauthorised use;
14.3.4. Statistical and analytical purposes – to analyse traffic and User behaviour on the Platform;
14.3.5. Marketing and advertising purposes – to measure and improve the effectiveness of marketing campaigns.

14.4. The Platform uses the following advertising and marketing tools:
14.4.1. Organic promotion and content marketing through TikTok, YouTube Shorts, LinkedIn, Instagram, and Facebook;
14.4.2. SEO and blog content published on the Platform and external resources for search traffic optimisation;
14.4.3. Influencer and affiliate marketing, including User-Generated Content created and distributed by influencers;
14.4.4. Paid advertising through Meta Ads (Facebook, Instagram) and Google Ads;
14.4.5. Email marketing, limited to Users who have provided explicit Consent (opt-in).

14.5. The Platform uses the following analytics tools:
14.5.1. Google Analytics and Microsoft Clarity for traffic and behaviour analysis;
14.5.2. Built-in analytics of social platforms, including Meta Business Suite, TikTok Analytics, and LinkedIn Analytics.

14.6. When visiting the Platform for the first time, the User will be presented with a cookie consent banner (pop-up). The banner provides clear options to either “Accept” or “Reject” the use of Cookies. Only strictly necessary Cookies will operate by default; all other categories (including marketing and analytics) will be enabled only upon the User’s explicit Consent. The User may also change or withdraw Consent at any time via the cookie settings on the Platform.

15. CONFIRM POLICY

15.1. The Services of the Platform are intended exclusively for persons who have reached the age of eighteen (18) years. The Platform does not knowingly collect or process the Data of minors under the age of eighteen (18).

15.2. The Platform reserves the right to delete any Data belonging to a person who has not reached the age of eighteen (18) without prior notice and without any liability for the Platform, as well as to immediately terminate the provision of Services to such a person.

15.3. If you have information that a person under the age of eighteen (18) has registered an account or received Services through the Platform, please notify the Platform’s support service by email: info@lumini.net.

16. PRIVACY POLICY CHANGE

16.1. We have the right to periodically make changes to the Privacy Policy, the security of Personal Data, and compliance with the requirements of the laws of the jurisdiction in which we operate.

16.2. The User is obliged to familiarize himself with the new terms of the Privacy Policy and the Platform is not responsible if the User has not familiarized himself with the new terms of the Privacy Policy.

16.3. The Platform updates the date of changes to the current version of the Privacy Policy in the “Updated” line at the top of the document.

16.4. Our digital or otherwise stored copies of the Privacy Policy are considered true, complete, valid, and enforceable and in effect, at the time you visit the Site.

17. CONTACTS

17.1. The User has the right to contact the Platform support service at: info@lumini.net to ensure his rights, in accordance with the terms of this Privacy Policy, or in case of violation of his rights, or to leave feedback or ask a question.