1. Who We Are
LumarPay ("Company", "we", "us", "our") operates this website (the "Site") to present our payment sales and consultancy services. Our primary contact email is hello@lumarpay.com.
2. Scope and Acceptance
This Privacy Policy describes how we collect, use, disclose, and protect personal data submitted to or collected through the Site. By accessing or using the Site, you acknowledge that you have read, understood, and agree to the practices described herein. If you do not agree, please discontinue use of the Site immediately.
You are solely responsible for the accuracy, completeness, and lawfulness of any information you provide to us. We process personal data in good faith based on information you supply. We accept no liability for inaccurate, misleading, or unlawfully submitted data.
3. Data We Collect
We collect information that you provide directly to us, as well as data generated through your use of the Site and our services.
Website and enquiry data:
- Contact data: name, company name, email address, and message content when you complete our contact form or email us directly.
- Usage data: IP address, browser type, operating system, referring URLs, pages visited, and timestamps - collected automatically through server logs and analytics tools.
- Cookie data: identifiers stored in cookies as described in our Cookie Policy.
- Communications data: records of correspondence between you and LumarPay.
Service provision data (collected where you engage LumarPay for payment onboarding or consultancy services):
- Account information: name, email address, phone number, business name, and business address.
- Financial information: bank account details for payouts and tax identification numbers.
- Transaction data: payment amounts, dates, customer information, and transaction history.
- Identity verification: government-issued ID, proof of address, and other documents required for regulatory compliance.
4. Legal Basis for Processing
- Contractual necessity - to respond to your enquiry and provide services you request.
- Legitimate interests - to operate and improve the Site, prevent fraud, and conduct our business. We have carried out a balancing test and determined that our legitimate interests are not overridden by your rights and freedoms. Details of this assessment are available on request.
- Consent - for non-essential cookies where required by applicable law.
- Legal obligation - where processing is required by applicable law or regulation.
5. How We Use Your Data
- To respond to your enquiry or job application.
- To match you with appropriate payment partners and facilitate introductions.
- To improve and maintain the Site.
- To comply with legal and regulatory obligations.
- To detect and prevent fraud, abuse, or security incidents.
6. Disclosure of Data
We do not sell personal data. We may share your data with:
- Payment institutions and partners - solely where you have requested an introduction or onboarding and with your knowledge.
- Infrastructure providers - including cloud hosting (e.g. AWS, Google Cloud, Cloudflare) and analytics providers, operating under appropriate data processing agreements.
- Professional advisers - lawyers, accountants, and auditors under confidentiality obligations.
- Authorities - where required by law, court order, or regulatory request.
7. International Transfers
LumarPay operates globally. Your data may be processed in countries outside your jurisdiction. Where data is transferred outside the European Economic Area, we apply appropriate safeguards (Standard Contractual Clauses or equivalent) as required by applicable law.
The Site uses Google Fonts, a font delivery service operated by Google LLC. When the Site loads, your browser makes a request to Google's servers to retrieve font files. This request includes your IP address and is transmitted to Google servers, which may be located in the United States. This transfer is governed by Google's Standard Contractual Clauses. If you prefer no IP transfer to occur, you may disable web fonts in your browser settings.
8. Data Retention
We retain personal data for as long as necessary to fulfil the purposes for which it was collected, to comply with legal obligations, and to resolve disputes. Contact enquiries are typically retained for up to 3 years. You may request deletion at any time (subject to legal retention obligations).
9. Your Rights
Depending on your jurisdiction, you may have rights to: access, rectify, erase, restrict, or port your personal data; withdraw consent; and lodge a complaint with a supervisory authority. To exercise any right, email hello@lumarpay.com. We will respond within 30 days. Where your request is complex or numerous, we may extend this period by a further two months and will notify you accordingly.
10. Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. No transmission over the internet is completely secure; you provide data at your own risk.
11. Third-Party Links
The Site may contain links to third-party websites. We are not responsible for the privacy practices of those sites. Review their privacy policies independently.
12. Children
The Site is not directed at children under 16. We do not knowingly collect personal data from children. If you believe a child has submitted data to us, please contact us and we will delete it promptly.
13. Automated Decision-Making
We do not engage in profiling or automated decision-making that produces legal or similarly significant effects in relation to your personal data.
14. Changes to This Policy
We may update this Privacy Policy from time to time. The "Last updated" date at the top will reflect any changes. Where changes are material, we will notify you via the Site or by email where we hold your contact details. Where consent is the legal basis for processing affected by the change, we will seek fresh consent before the change takes effect.
15. Contact
For any privacy-related enquiry: hello@lumarpay.com
Note: LumarPay is currently in the process of establishing its legal entity. Full controller details including registered name and address will be added to this Policy upon incorporation and will be reflected in the "Last updated" date.