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PRIVACY POLICY

Effective Date: November 19, 2025

​Lumaro Innovation and Artificial Intelligence FZCO is committed to protecting the privacy and security of personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit our website, use our services, or otherwise interact with us.

 

1. Information We Collect

Information You Provide

  • Account Information: Name, email address, company name, job title, phone number, and billing information.

  • Service Data: Information you provide when using our services, including CRM data, contact information, communication preferences, and custom workflow configurations.

  • Communications: Information contained in emails, support tickets, and other communications with us.

  • Payment Information: Payment card details and billing addresses processed through our payment processor Stripe.

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Information Collected Automatically

  • Usage Data: Information about how you use our services, including access times, pages viewed, features used, and the actions you take.

  • Device Information: IP address, browser type, operating system, device identifiers, and similar technical information.

  • Cookies and Tracking: Information collected through cookies, web beacons, and similar technologies as described in our Cookie Policy.

  • AI Interaction Data: Records of interactions with AI agents, including conversation logs, appointment data, and automated communication records.

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Information from Third Parties

  • CRM and integration platforms when you connect them to our services;

  • Business partners and service providers who assist in delivering our services;

  • Publicly available sources to supplement the information you provide.

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AI Voice Data

If Client uses Lumaro’s AI Voice Services (Inbound or Outbound), we may collect and process the following:

  • Call Audio: Audio recordings from inbound or outbound calls.

  • Transcriptions: Automatically generated text transcriptions of call audio for service delivery, quality assurance, and troubleshooting.

  • Call Metadata: Timestamps, call duration, call outcome, and related technical details.

  • Phone Number Information: Caller ID, dialed numbers, and routing details.

  • Voice Interaction Records: AI voice agent responses, decision logs, and automation behavior linked to the call session.

  • Usage Monitoring: Call volumes and usage patterns processed in accordance with Lumaro’s Fair Use Policy and the AI Voice Service Usage Terms defined in Appendix A of the Master Service Agreement (MSA).

 

2. How We Use Your Information

We use the information we collect for the following purposes:

  • Service Delivery: To provide, maintain, and improve our AI-powered automation services;

  • Customization: To customize and optimize service performance based on your preferences and usage patterns;

  • AI Training: To train and improve our AI models and automation systems, using anonymized and aggregated data;

  • Account Management: To create and manage your account, process transactions, and provide customer support;

  • Communications: To send service-related notices, updates, security alerts, and administrative messages;• Marketing: To send promotional communications about new features, services, and offers (with your consent where required);

  • Analytics: To analyze usage patterns, measure service effectiveness, and conduct research;

  • Security: To detect, prevent, and address technical issues, fraud, and security threats;

  • Legal Compliance: To comply with applicable laws, regulations, and legal processes.

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3. Legal Bases for Processing (GDPR)

For individuals in the European Economic Area, we process personal data based on the following legal grounds:

  • Contract Performance: Processing necessary to provide services under our agreement with you;

  • Legitimate Interests: Processing necessary for our legitimate business interests, such as improving services, security, and fraud prevention;

  • Consent: Where you have provided explicit consent for specific processing activities;

  • Legal Obligation: Processing required to comply with applicable laws and regulations.

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4. Information Sharing and Disclosure

We may share your information with the following parties: Service Providers We engage third-party service providers to perform functions on our behalf, including:

  • Cloud hosting and infrastructure providers;

  • Payment processing (Stripe);

  • CRM and marketing automation platforms;

  • Analytics and monitoring services;

  • Customer support and communication tools.

Business Transfers in connection with any merger, acquisition, financing, sale of assets, or similar transaction, your information may be transferred to the successor entity. Legal Requirements We may disclose information when required by law or in response to legal process, to protect our rights and property, or to ensure the safety of our users and the public. With Your Consent We may share information with third parties when you specifically authorize such disclosure.

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5. International Data Transfers

Lumaro operates from the United Arab Emirates and may transfer, store, and process information in the UAE, the United States, and other countries. When transferring personal data from the European Economic Area, we implement appropriate safeguards such as Standard Contractual Clauses approved by the European Commission.By using our services, you consent to the transfer of your information to countries that may have different data protection standards than your country of residence.

 

6. Data Security

We implement industry-standard technical and organizational security measures to protect your information, including:

  • Encryption of data in transit and at rest;

  • Regular security assessments and penetration testing;

  • Access controls and authentication mechanisms;

  • Employee training on data protection and security practices;

  • Incident response and breach notification procedures.

While we strive to protect your information, no security system is impenetrable. We cannot guarantee absolute security of information transmitted through or stored in our systems.

 

7. Data Retention

We retain personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Account information is retained for the duration of your business relationship with us and for a reasonable period thereafter. Service data and usage logs may be retained for up to seven years for operational, analytical, and legal purposes. After the retention period, personal data will be securely deleted or anonymized.

 

8 Your Rights and Choices

Depending on your jurisdiction, you may have the following rights:

  • Access: Request access to the personal information we hold about you;

  • Correction: Request correction of inaccurate or incomplete personal information;

  • Deletion: Request deletion of your personal information, subject to legal retention requirements;

  • Portability: Request a copy of your personal information in a structured, machine readable format;

  • Restriction: Request restriction of processing in certain circumstances;

  • Objection: Object to processing based on legitimate interests or for direct marketing purposes;

  • Withdraw Consent: Withdraw consent for processing based on consent, without affecting the lawfulness of prior processing.

To exercise these rights, contact us at info@lumaro-innovation.com. We will respond to your request within thirty days.

 

9. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a child, please contact us immediately.

 

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on our website and updating the effective date. Your continued use of our services after changes become effective constitutes acceptance of the revised policy.

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11. Contact Information

For questions about this Privacy Policy or our data practices, contact us at: Lumaro Innovation and Artificial Intelligence FZCO IFZA Business Park, DDP PO Box 342001 Dubai, United Arab Emirates Email: info@lumaro-innovation.com Website: www.lumaro-innovation.com

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