1. Who we are
LumaKode ("LumaKode", "we", "us") is a trading name of Right Web Solution, a business based in India. For the personal data described in this policy, Right Web Solution is the data controller (or "data fiduciary" under Indian law).
For any privacy question or request, email us at hello@lumakode.com.
2. Who this policy covers
This policy applies to visitors to lumakode.com, people who enquire about our services, and the individual contacts at our clients and agency partners.
When we build or maintain a website or app for a client, we may also handle personal data belonging to that client's customers or users. In that situation we act as a data processor on the client's instructions, under our agreement with them. That processing is covered by the client's own privacy notice, not this one.
3. Information we collect
Information you give us
- Booking and contact form: your name, email address, the service you're interested in, your message about your business goals, your preferred call time and your time zone.
- Emails and calls: anything you choose to share when you email us or speak with us on a Google Meet call. We don't record calls without asking you first.
- Client and partner information: billing contact details, invoices and the project communications needed to deliver our services.
Information collected automatically
- Security data: when you submit the form, we record your IP address and the time of submission to protect the site from spam and abuse.
- Server logs: our hosting provider keeps standard access logs (such as IP address, browser type, pages requested and time) for security and troubleshooting.
- Analytics: only if you accept analytics cookies — see Cookies and analytics.
We don't ask for sensitive information (such as health, financial account or government ID details). Please don't include it in messages to us.
4. How we use your information
We only use personal data where we have a lawful basis to do so. Under the UK and EU GDPR, those bases are:
| Purpose | Lawful basis |
|---|---|
| Reply to your enquiry, schedule your call and prepare a proposal | Steps taken at your request before entering a contract; our legitimate interest in responding to business enquiries |
| Send an automatic confirmation that we received your request | Legitimate interest in confirming receipt and setting expectations |
| Deliver services, invoice and provide support | Performance of a contract |
| Keep accounting and tax records | Legal obligation |
| Protect the site from spam, fraud and abuse | Legitimate interest in keeping our systems secure |
| Understand how visitors use the site (analytics) | Your consent, which you can withdraw at any time |
We don't send marketing newsletters unless you ask to receive them, and we never use your data for automated decision-making that has legal or similarly significant effects on you.
5. The booking form and spam protection
When you submit the booking form, your details are emailed to our team inbox and we send you a confirmation email. Our confirmation never repeats the message you wrote.
To stop automated spam, the form uses a hidden field, a time check and rate limits. For rate limiting, we keep a one-way-encrypted (hashed) record of your IP address and email address, together with submission times, for up to 24 hours. It can't be turned back into your details and is deleted automatically.
8. International transfers
Right Web Solution is based in India, and our service providers may process data in other countries. When personal data protected by the UK or EU GDPR is transferred outside the UK or European Economic Area, we rely on appropriate safeguards, such as the UK International Data Transfer Addendum or the European Commission's Standard Contractual Clauses, or on an adequacy decision where one exists.
9. How long we keep data
- Enquiries that don't become projects: up to 24 months after our last contact, then deleted.
- Client and partner records: for the length of our relationship, then as long as tax and accounting laws require.
- Spam-protection records: up to 24 hours.
- Analytics data: up to 14 months, if analytics is enabled.
10. How we protect your data
We use HTTPS encryption across the site, restrict access to personal data to the people who need it, keep our systems updated and use reputable providers. No method of transmission or storage is completely secure, but we work to protect your data and will notify you and the relevant authorities of a breach where the law requires.
11. Your rights
UK and EU (GDPR)
You can ask to access, correct or delete your personal data, restrict or object to how we use it, receive a portable copy, and withdraw consent at any time. If you're unhappy with how we handle your data, you can complain to the UK Information Commissioner's Office (ico.org.uk) or your local EU data protection authority. We'd appreciate the chance to put things right first.
United States (including California)
Depending on your state, you may have the right to know what personal information we collect and how we use it, and to access, correct or delete it. You can also opt out of the sale or sharing of personal information (we don't do either), and we won't discriminate against you for using these rights. We honour Global Privacy Control signals.
India (Digital Personal Data Protection Act, 2023)
You can request a summary of the personal data we process, ask us to correct, complete, update or erase it, withdraw consent, nominate someone to exercise your rights, and raise a grievance with us.
How to make a request
Email hello@lumakode.com. We may need to verify your identity before acting on a request. We respond within one month (UK/EU), 45 days (US) or the time required by the law that applies to you.
12. Children
Our services are for businesses. The site isn't directed at children under 16, and we don't knowingly collect their personal data. If you think a child has sent us personal data, contact us and we'll delete it.
13. Changes to this policy
We'll update this policy when our practices change, and revise the "Last updated" date at the top. If a change materially affects how we use personal data you've already given us, we'll tell you directly.
14. Contact us
For any question about this policy or your personal data, email hello@lumakode.com. You can also review our Terms of Service.