Privacy Policy

We are (hereinafter, “the Company”, “We”, “Us”) firmly committed to regulatory compliance and the privacy and protection of personal data. Accordingly, in the present Privacy Policy, we provide the relevant information on how we process the personal data collected from our Users and/or Customers through the present Website, in compliance with the data protection laws and regulations that apply to us (e.g: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”), Spanish Organic Law 3/2018, of December 5, Protection of Personal Data and guarantee of digital rights (the “LOPDGDD”)).

This Privacy Policy may be updated from time to time according to new laws, regulations, jurisprudential requirements and/or business needs and industry standards, among others. Any update or modification of the present Privacy Policy will be considered applicable from the moment of its publication on the Website. Therefore, we advise the User and/or Customers to review this Privacy Policy regularly to access its most current version.

Without affecting the Customer’s rights under current applicable laws and regulations, the present Privacy Policy is not contractual or part of the service contract between Customers and Us.

For the purposes of this Privacy Policy, "personal data" means all data that identifies a person or that could be used to identify a person, such as the identification data the User provides when registering on this Website, log data (IP address), economic and financial data (bank details), etc.

LUMMER AI SYSTEM LLC a limited liability company registered in 400 N ASHLEY DR SUITE 1900 TAMPA, FL 33602 and provided with Tax number 42-2228006 (the “Company” or the “Data Controller”) will be the data controller of your personal data collected, when you browse our Website, you purchase a subscription plan to the Services offered herein, you use our Services and/or you contact us for any reason.

We may collect and process personal data in the following circumstances:

Direct interactions: We may process User and/or Customer personal data when a direct action with this Website is taken (e.g: create a Personal Account, purchase a subscription plan to our Services, use our Services, sending an email).

Automated technologies and usage information: We may automatically collect information related to how the User and/or Customer use this Website and the Services (e.g: the time of use of the Website, loggins to the Personal account, most used functionalities and/or tools) by using cookies, whether our own or from third parties. You can consult our Cookie Policy to obtain more information about the cookies of our Website, their purposes and any other information of interest.

Payment data: We together with our payment services providers may process the User and/or Customer payment data when hiring a subscription plan to our Services. This data is securely sent to the information systems of our certified payment service providers. In no case do We visualize or access the complete data of a credit/debit card. It is the Customer's responsibility not to enter, provide or send their card information through channels not authorized by the Company.

Please be informed that the User and/or Customer are only required to provide the personal data and information strictly necessary for the fulfillment of the purposes detailed below (What do We use your personal data for?). Therefore, not providing this information could result in the inability to have full access to the Services or inability to address your requests, etc. Taking this into consideration, kindly be aware that by providing us with additional personal information beyond what is strictly and expressly required, the User and/or Customer consent to the processing of it for the informed purpose/s for which it is being sent. We recommend that you do not include sensitive personal data, legally privileged information, or confidential data belonging to third parties in the content you submit for AI processing. You are solely responsible for ensuring you have the right to share any content you provide to AI features.

The User and/or Customer must provide accurate, updated and complete personal data and/or private information in order to fulfill the purposes detailed below. We will not assume any liability for circumstances beyond our reasonable control, such as receiving erroneous, incomplete and/or fraudulent information from the User and/or Customer.

Remarks

The services offered in this Website are not directed to minors and we do not knowingly collect personal information from minors. If you are under age according to your local law, it is forbidden to use this Website without the prior consent of your parents or legal guardians to include your personal data on this Website. If you learn that your children have provided us with personal information without your consent, you may contact us as set forth below. The Company will not accept any liability for failure to comply with these requirements. As soon as We learn that We have collected personal information from people under age in breach of the applicable law we will take immediate steps to delete such information and terminate the account.

The Customer is responsible for the files uploaded to this Website, especially, if it contains personal data of third parties:

If the Customer provides us with personal data of third parties, whether they are minors or adults, the Customer warrants that he/she has informed them of the purposes for which their personal data will be processed by the Company and that they have obtained, where appropriate, their prior express consent to communicate their personal data to Us. Likewise, if you provide us with the personal data of a minor, you warrant that you are their parent, legal guardian or that you have obtained the authorization of their parents or legal guardians to communicate the minor's personal data to Us. The Company will not accept any liability for failure to comply with this requirement.

Likewise, if applicable, the Customer shall be in possession of the corresponding authorization and/or license to reproduce, copy, distribute, public communicate, transform the file (and its content). The Company disclaims any responsibility in this regard.

We process personal data for the following purposes:

• To provide the Services available on this Website and/or to send operational communications related to the subscription plan purchased by the Customer;
• To perform operations related to subscription plans: charges, cancellations, refunds, fraud control, billing tasks etc.
• To verify the identity of our Customers;
• To send information about the latest updates to our Website;
• To improve the User experience on our Website and support by analyzing your and other customers usage of our Website and/or your communications with Us;
• To comply with our legal obligations and/or to respond to judicial, administrative or police requirements;
• To properly address informational request, claims or queries, through the Services;
• To carry out periodic checks against fraudulent, unauthorized or illegal activity on/or through our Website.
• To provide AI-assisted interaction with documents, including the generation of automated summaries and translations, ensuring the processing of the information contained within the PDFs is performed solely to fulfill the User's specific requests.

Note

AI features on this Website are powered by third parties’ LLM. Requests are processed through an AI Gateway, which acts as a technical intermediary. The AI Gateway does not use your data to train its models by default.

We only process your personal data when there is a legal basis for doing so. The legal basis will depend on the reason We collect and process your personal data.

Express consent: When processing your Personal Data, we usually rely on your unambiguous and express consent with regards to (i) the performance of the contract with you or in which you are a party, means, keeping the services offered on this Website available to you at all times, as well as to attend your refund requests and cancellation (unsubscribe) requests, and if applicable, for our payment service to carry out the latter above mentioned; (ii) The consent that you provided Us with for the processing of your personal data in connection to the purposes informed at the time of collection of your data, such as to receive the requested information, to attend to your queries or direct interaction via live chat or; (iii) for marketing and commercial communications purposes, including serving you personalized, interest-based ads.

Note

If you have provided Us with your consent to process your personal data for specific purposes, note that you can withdraw said consent at any time by sending Us an email to info@lumr.com, by clicking the unsubscribe link provided in our emails or via our Contact Form. In case of unsubscribing, We will try to process your request immediately, but please bear in mind that sometimes this process may take a number of days to become effective and during this period you may still receive our communications.

Legitimate interest when (i) administrative purposes along with responding to your requests and keeping records of them (ii) fraud control of credit cards and other methods of payments, (iii) to address possible claims regarding the services offered through this Website, (iv) enhancing User experience when you use this Website and to operate it efficiently, (v) monitoring fraudulent activity in order to preserve the security and integrity of our Website (vi) the compliance with our legal obligations and/or to attend to judicial, administrative or police requirements regarding the services offered to the Customer;

Personal data will be kept for the necessary time to fulfill the purposes for which they were collected. After that, the personal data file will only be retained, duly securely blocked in our information systems, for the necessary period that We need to keep it in case of claims, fraud investigation, or other legitimate purpose. After the necessary periods have elapsed, personal data will be securely deleted from our information systems.

Content submitted through AI features is transmitted to our AI model providers for processing. The AI Gateway deletes this data immediately upon completion of each request. AI model providers may retain request data for a limited period for operational purposes only, after which it is permanently deleted.

We will not share your personal information with third parties without your consent. Nonetheless, in order to provide the Service and comply with a legal obligation, protect our legal rights, or respond to a valid legal request, we may communicate your personal data to the following third parties, including but not limited to:

• The staff of our Company;
• payment service providers, such as Stripe;
• technology service providers which host our information systems and/or that offer Us tools or technological support, such as Firebase, Google Chrome, Mozilla Firefox, Microsoft Internet Explorer, Apple Safari, Chrome for Android, and Opera, among others;
• Public entities to comply with our legal obligations;
• Administrative, judicial and/or police authorities in response to requirements, as long as they are required in accordance with the applicable law and regulations;
• Our legal advisors, when a claim is presented related to the services offered through this website and when it is necessary to protect and/or defend our legitimate interests.
• Third-party Artificial Intelligence service providers (such as API-based language model providers) for the sole purpose of processing, summarizing, and translating the documents at the User's request. These providers act as data processors. We use an AI Gateway as a technical intermediary to connect our application with third-party AI model providers. When you use AI-powered features, the content you submit is processed by these providers. The AI Gateway does not retain request data after completion. All providers acting as processors are bound by appropriate data processing agreements.

The third parties mentioned above may have their headquarters outside the European Economic Area (EEA), therefore the communication of personal data to them may involve an international transfer of personal data. In this regard, We inform you that We will only transfer personal data to recipients located in countries that offer a level of personal data protection comparable to the laws and regulations of data protection of European countries or, failing that, We will apply the appropriate safeguards required by the current applicable law and regulations on the protection of personal data, in order to ensure the privacy and security of your personal data and that your individual rights and freedoms are guaranteed.

Your personal data is securely stored in our information systems and We have established the technical and organizational measures necessary to ensure the confidentiality and integrity of your personal data and to protect it against unauthorized or unlawful processing and/or accidental loss, destruction, or damage.

Furthermore, We have taken reasonable measures to guarantee that all our staff, as well as the suppliers or collaborators with access to your personal data, have received adequate training regarding the processing of the personal data collected.

Although We will do our best to guarantee the protection of your personal data transmitted through our Website and/or that you may provide Us by other means such as email or phone, please bear in mind that you should also take precautions to keep safe your personal data e.g you must not share the details of your “User account” of this Website with other individuals, must take precautions against online fraud and phishing, and must not enter or confirm your bank details by means of fake messages.

You may, with any cost, exercise your rights of: information, access, rectification, restriction of processing, erasure, to object, as well as the right to the portability of your personal data and to withdraw your consent at any time.

If you want to exercise your abovementioned rights, you can address your request by sending Us an email to info@lumr.com or via our Contact Form and we will actively cooperate with you and provide assistance to you. All requests relating to your personal data must be directed to us through the indicated channels. AI model providers do not hold your personal identity data and cannot process data rights requests from end users directly.

If you request deletion of your personal data, we will delete your information from our own systems without undue delay. With respect to content transmitted to AI model providers, such data is automatically deleted by the provider within their applicable retention period. Immediate deletion prior to this period may not be technically feasible in all cases. We will coordinate with providers to the extent technically possible.

Your data protection rights request will be responded to within one (1) month; but occasionally, this period may be extended by two (2) further months where necessary, taking into account the complexity and/or number of requests you may have made. In this case, We will notify you of such an extension together with the reasons for the delay.

When you consider it appropriate, you have the right to lodge a complaint before the corresponding Supervisory Authority, (in Spain, Agencia Española de Protección de Datos or “AEPD”) for example, when you consider that your data protection rights have not been adequately addressed.

Notes

If you reside in California (United States of America) be informed that you are entitled to the rights set forth in this Privacy Policy.

Please be informed that, for security reasons, We may ask to provide personal data and/or information to verify the identity of our Customers, before proceeding to address your request. The requested data shall include: (i) registration email used in our website; (ii) User ID (which is provided in the payment confirmation email); (iii) last 4 digits of the credit/debit card used to purchase our services.

You may modify the “privacy settings” of your Website browser to set up tracking cookies at any time. Also, you can install programs or add-ons to your browser, known as "Do Not Track" tools, which will allow you to choose the Cookies you want to permit. For further information, check our Cookies Policy.

We remain at your disposal for any doubts or questions you may have about the present Privacy Policy or about the processing of your personal data, so please don’t hesitate to contact Us writing an e-mail to info@lumr.com or via our Contact Form.