Privacy Policy

Last updated: January 2026

Data Controller Information

lumisfera Ltd is the data controller for the personal information we collect and process. We are registered in Cyprus with registration number HE917358. Our registered office is located at Ledra Street 48, Paralimni, 5288, Famagusta District, Cyprus.

Data Collection

The data we collect depends on how you interact with our website and services. We collect personal data that you provide directly to us, as well as information automatically collected through your use of our website.

Information You Provide

• Contact information (name, email address, phone number, company details)
• Communication content (messages sent through contact forms or email)
• Service enquiry details and business requirements
• Any other information you choose to provide when contacting us

Information Automatically Collected

• Website usage data (pages visited, time spent, navigation patterns)
• Technical information (IP address, browser type, device information)
• Cookie data and tracking technologies (as detailed in our Cookie Policy)
• Referral source and marketing campaign attribution

How We Use Your Information

We process your personal data for various purposes based on legitimate business interests, contractual necessity, and legal compliance. The specific ways we use of your data include:

• Responding to your enquiries and providing customer support
• Delivering our CRM implementation and consulting services
• Communicating about our services and business updates
• Improving our website functionality and user experience
• Analysing website performance and user behaviour
• Complying with legal obligations and protecting our business interests
• Marketing our services to potential clients (with appropriate consent)

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner.

For detailed information about the cookies we use and how to control them, please refer to our Cookie Policy.

Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

• Contractual necessity: To provide our services and fulfil our contractual obligations
• Legitimate interests: To operate our business, improve our services, and communicate with clients
• Consent: For marketing communications and certain cookie usage (where required)
• Legal compliance: To meet our legal and regulatory obligations

Data Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your data in the following limited circumstances:

• With trusted service providers who assist in operating our website and business
• When required by law or to protect our legal rights
• In connection with a business transfer, merger, or acquisition
• With your explicit consent for specific purposes

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Contact information and communication records are typically retained for up to seven years from the last interaction, whilst website analytics data is retained for up to 26 months.

International Data Transfers

As we operate within the European Union, your data is primarily processed within the EU/EEA. Any transfers to third countries are conducted in accordance with GDPR requirements, including appropriate safeguards such as adequacy decisions or standard contractual clauses.

Your Rights

Under GDPR and applicable data protection laws, you have the following rights regarding your personal data:

• Right of access: Request a copy of the personal data we hold about you
• Right to rectification: Request correction of inaccurate or incomplete data
• Right to erasure: Request deletion of your personal data in certain circumstances
• Right to restrict processing: Request limitation of how we process your data
• Right to data portability: Request transfer of your data to another organisation
• Right to object: Object to processing based on legitimate interests or for marketing
• Right to withdraw consent: Withdraw consent for processing where applicable

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, secure data transmission, access controls, and regular security assessments.

Contact Information

If you have any questions about this Privacy Policy, wish to exercise your rights, or need to contact us regarding data protection matters, please reach out using the following contact information:

Supervisory Authority

You have the right to lodge a complaint with the relevant data protection supervisory authority if you believe we have not complied with applicable data protection laws. In Cyprus, this is the Office of the Commissioner for Personal Data Protection.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated policy on our website and updating the "Last updated" date. We encourage you to review this policy periodically.