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PRIVACY POLICY

Effective Date: January 4, 2026

Lumaro Innovation and Artificial Intelligence FZCO (“Lumaro,” “we,” “us,” or “our”) is committed to protecting the privacy and security of personal information. This Privacy Policy explains how we collect, use, disclose, and protect personal data when you visit our website, communicate with us or engage our services.

 

1. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to:

  • visitors of www.lumaro-innovation.com;

  • business contacts and prospective clients;

  • clients and authorized users engaging Lumaro’s services under a separate written agreement.

This Privacy Policy does not replace or override any Data Processing Agreement (“DPA”) or contractual privacy provisions agreed separately.

 

2. INFORMATION WE COLLECT

2.1 Information You Provide

  • Business Contact Information: name, business email, company name, job title, phone number.

  • Client Service Data: information provided in connection with CRM implementations, automation workflows, lead management, scheduling, and communications.

  • Communications: emails, messages, support requests, and related correspondence.

  • Billing Information: billing contact details and transaction references processed via third-party payment processors (e.g., Stripe). Lumaro does not store full payment card details.

 

2.2 Information Collected Automatically

  • Usage and Technical Data: IP address, browser type, device information, access timestamps and interaction data related to the Website.

  • Cookies and Similar Technologies: as described in our Cookie Policy.

 

2.3 AI and Voice Interaction Data (If Applicable)

Where clients use Lumaro’s AI Voice or automation services, Lumaro may process:

  • call audio recordings (inbound and outbound);

  • call transcriptions generated automatically;

  • call metadata (timestamps, duration, routing);

  • AI interaction logs and automation behavior;

  • usage metrics for monitoring and service optimization.

Processing of such data is governed primarily by the applicable client agreement and DPA.

 

2.4 Information from Third Parties

  • CRM platforms and integrations connected by the client;

  • service providers supporting hosting, analytics, communications or security;

  • publicly available business information.

 

3. HOW WE USE INFORMATION

We process personal information for the following purposes:

  • providing and operating contracted services;

  • configuring, maintaining, and improving automation workflows;

  • account administration and client support;

  • operational monitoring, security, and fraud prevention;

  • internal analytics and service improvement using aggregated or anonymized data;

  • compliance with legal and regulatory obligations.

Lumaro does not sell personal data.

 

4. LEGAL BASES FOR PROCESSING

Where required under applicable data protection laws, processing is based on one or more of the following:

  • performance of a contract or pre-contractual steps;

  • legitimate business interests (e.g., service delivery, security, improvement);

  • compliance with legal obligations;

  • consent, where explicitly obtained.

 

5. DISCLOSURE OF INFORMATION

Lumaro may disclose personal information to:

  • Service Providers: hosting, infrastructure, payment processing, analytics, communications and security vendors acting under contractual confidentiality obligations.

  • Business Transactions: in connection with a merger, acquisition, restructuring or sale of assets.

  • Legal Requirements: where disclosure is required by law, regulation or legal process.

  • With Consent: where you expressly authorize disclosure.

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6. INTERNATIONAL DATA TRANSFERS

Lumaro operates from the United Arab Emirates and may process data in the UAE, the United States or other jurisdictions. Where required, appropriate safeguards are implemented for cross-border transfers.

 

7. DATA SECURITY

Lumaro implements commercially reasonable technical and organizational measures to protect personal information, including encryption, access controls, and security monitoring. No system is completely secure. Lumaro cannot guarantee absolute security of data.

 

8. DATA RETENTION

Personal information is retained only as long as reasonably necessary for the purposes described, including legal, accounting and compliance requirements. Data may be anonymized or deleted once no longer required.

 

9. YOUR RIGHTS

Depending on applicable law, you may have rights to access, correct, delete or restrict processing of personal information or to object to certain processing activities. Requests may be submitted to info@lumaro-innovation.com. Responses will be provided within a reasonable timeframe.

 

10. CHILDREN’S PRIVACY

Lumaro’s services are intended for business use only and are not directed to individuals under 18 years of age.

 

11. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. Updates will be posted on the Website with a revised effective date.

 

12. CONTACT INFORMATION

For questions 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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