Datenschutzerklärung

1. Controller (Verantwortlicher)

Email: legal.lumora@gmail.com

2. What we collect & why

Waitlist email

When you join the waitlist, we store the email address you submit, plus the time of submission. Purpose: to contact you about private-beta access. This is based on your consent, given when you submit the form (and, for EU visitors, Art. 6(1)(a) GDPR). You can withdraw it at any time (see section 7).

Invite code & access cookie

When you redeem an invite code, we set one essential cookie (lumora_access) so the gated terminal knows you are an approved beta user. It contains a signed expiry value only (no tracking, no personal data) and expires after 30 days. As a strictly necessary cookie it does not require prior consent. For EU visitors the legal basis is our legitimate interest in securing the private beta (Art. 6(1)(f) GDPR).

Analytics (Google Analytics 4) — only with your consent

We use Google Analytics 4 to understand how the site is used. Nothing loads and no Google cookie is set until you click “Akzeptieren” in the consent banner; declining is just as easy and is the default. Your choice is stored locally (lumora_consent_v1 in your browser). If you consent, Google sets analytics cookies and processes your usage data and IP address (IP handling is truncated/anonymised by Google). Basis: your consent (for EU visitors, Art. 6(1)(a) GDPR). Withdraw any time by clearing the stored choice or contacting us. Provider: Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (Google Analytics 4 — only after consent).

Server logs

Our hosting provider may process technical access data (IP address, timestamp, user agent) to deliver and secure the site. Basis: legitimate interest in a secure, functioning service (for EU visitors, Art. 6(1)(f) GDPR).

3. Processors & hosting

We use the following service providers, bound by data-processing agreements:

• Hosting: Vercel Inc., 340 S Lemon Ave #4133, Walnut, CA 91789, USA (hosting, server logs)
• Database: Supabase, Inc., 970 Toa Payoh North #07-04, Singapore 318992 (database, waitlist + invite codes)
• Analytics: Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland (Google Analytics 4 — only after consent)

4. Transfers abroad

Some providers process data outside Switzerland and the EU/EEA (e.g. in the USA). Such transfers are safeguarded by the EU Standard Contractual Clauses with the Swiss addendum, or by the provider’s certification under the EU–US / Swiss–US Data Privacy Framework, or an equivalent mechanism recognised under the revDSG and the GDPR.

5. Retention

We keep waitlist emails until the beta ends or you ask us to delete yours, whichever comes first. The access cookie expires automatically after 30 days. Analytics data is retained for the period configured in Google Analytics.

6. No automated decision-making & no profiling

The market “reads” shown in the product are not based on your personal data and do not profile you. We do not sell or share your data for marketing.

7. Your rights

Under the Swiss revDSG (and, for EU visitors, the GDPR) you have the right to:

• access the personal data we hold about you (Art. 25 revDSG / Art. 15 GDPR);
• rectification and erasure (Art. 32 revDSG / Art. 16–17 GDPR);
• restriction of processing and data portability (Art. 20 GDPR);
• object to processing based on legitimate interest (Art. 21 GDPR);
• withdraw consent at any time, without affecting prior processing;
• lodge a complaint with a supervisory authority: in Switzerland the Federal Data Protection and Information Commissioner (EDÖB), Feldeggweg 1, 3003 Bern; in the EU your local data protection authority.

To exercise any of these, email legal.lumora@gmail.com.

8. Changes

We may update this policy as the product evolves. The current version always lives at this URL; the date below reflects the last change.