Privacy Policy
How LumosTech B.V. collects, uses and protects personal data, in line with the EU General Data Protection Regulation (GDPR) and the Dutch implementation (UAVG / AVG).
In one paragraph: this website sets no cookies, runs no analytics, and loads nothing from third-party servers. If you send us a message we use it to reply to you and for nothing else, and we delete it within twelve months if it does not become an engagement.
1. Who we are (data controller)
LumosTech B.V. is a Netherlands-based technology company providing SaaS platforms, IT consulting and technical advisory, and marketing and advertising services. This policy covers www.lumostech.nl and www.lumostech.eu.
LumosTech is the controller for the personal data described here. Where we process personal data on a client’s behalf as part of our Services, we act as a processor under a separate Data Processing Agreement.
- General contact: info@lumostech.nl
- Privacy contact: privacy@lumostech.nl
Full company identification is at the foot of this page and on the About page.
2. What we collect
We may collect:
- Identity and contact data — name, email, telephone, company, job title;
- Engagement data — enquiries, project details, correspondence, contractual records;
- Technical data — the IP address, browser and device type recorded in server logs when a page is served;
- Professional data — interests and project information you choose to share.
We collect this when you submit the contact form, write or call us, or engage with us as a client or partner. We do not collect anything through cookies, analytics, tracking pixels or profiling, because this website uses none of those.
3. Why we process it, and on what basis
| Purpose | Legal basis (GDPR Art. 6) |
|---|---|
| Responding to enquiries and communicating with you | Steps taken at your request before entering a contract (6(1)(b)), or our legitimate interest in answering business enquiries (6(1)(f)) |
| Delivering Services and managing contracts | Performance of a contract (6(1)(b)) |
| Invoicing, accounting and tax records | Legal obligation (6(1)(c)) |
| Keeping the website available and secure | Legitimate interest (6(1)(f)) |
| Marketing communications, if you ever ask for them | Consent (6(1)(a)), withdrawable at any time |
We do not currently send marketing communications and do not operate a mailing list. Contacting us does not add you to one.
4. Retention
We keep personal data only as long as necessary for the purposes above, or as required by law — Dutch tax law, for example, requires financial records to be kept for seven (7) years. Specifically:
- Enquiries that do not lead to an engagement are deleted within twelve (12) months.
- Client correspondence is kept for the duration of the engagement and any statutory retention period that follows.
- Server logs are kept only as long as security requires.
When data is no longer needed it is securely deleted or anonymised.
5. Cookies, analytics and third-party content
This website sets no cookies. It does not use local storage, session storage or any similar technology, and it contains no analytics, advertising pixels, session recorders, embedded fonts, embedded maps, social widgets, chat tools or any other third-party component.
Article 5(3) of the ePrivacy Directive, as implemented in Dutch law, requires consent before information is stored on or read from your device. Because nothing is stored and nothing is read, no consent is required — which is why you were not asked for any, and why there is no cookie banner.
Every font, stylesheet and image is served from our own domain. Nothing you do on this site is visible to any other company. This replaces the previous cookie position published in June 2025 and June 2026; the separate Cookie Notice no longer applies to this website.
6. Server logs
Our hosting provider records standard technical information when a page is served, including a truncated or anonymised IP address, the time, the page requested and the browser identifier. This is used to keep the site available and secure, on the basis of our legitimate interest, and is retained only as long as necessary for that purpose.
7. Sharing and third parties
7.1 We do not sell or commercially exploit your personal data.
7.2 We may share data with trusted processors — cloud hosting, email delivery, accounting, legal advisors — bound by data processing agreements and acting only on our instructions.
7.3 Where required, we disclose data to comply with legal obligations or to establish or defend legal claims.
8. International transfers
Hosting and email delivery for this website are within the European Economic Area. Where personal data is transferred outside the EEA in the course of our Services, we rely on appropriate safeguards such as the European Commission’s Standard Contractual Clauses or an adequacy decision.
9. Your rights
Under the GDPR you have the right to:
- Access the personal data we hold about you;
- Rectify inaccurate or incomplete data;
- Erase your data (the “right to be forgotten”);
- Restrict or object to processing;
- Data portability — receive your data in a structured, machine-readable format;
- Withdraw consent at any time, without affecting prior lawful processing.
To exercise these rights, write to privacy@lumostech.nl. We respond within one month.
10. Complaints
If you believe we have not handled your data properly you may lodge a complaint with the Dutch supervisory authority, the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl). We would appreciate the chance to resolve it directly first.
11. Security
We apply appropriate technical and organisational measures — access controls, encryption in transit, and confidentiality obligations — to protect personal data against loss, misuse and unauthorised access. No method of transmission is fully secure, so we cannot guarantee absolute security.
12. Links to other sites
This site links to products we have built, including jeeboard.eu, totemian.com, epono.ca and smartrnt.com. Those are separate websites with their own privacy practices; this policy does not cover them.
13. Updates
We may update this policy to reflect legal, technical or business changes. Material changes are posted here with a revised date, and communicated directly to anyone already affected.
See also the Website Terms of Use and the Terms of Service.
Identification
| Statutory name | LumosTech B.V. |
|---|---|
| Legal form | Besloten vennootschap (hoofdvestiging) |
| Registered seat | Tilburg, the Netherlands |
| Address | Waardenburgstraat 92, 5036 BR Tilburg, the Netherlands |
| KvK number | 90475895 |
| Vestigingsnummer | 000056204418 |
| RSIN | 865329102 |
| BTW identification | NL865329102B01 |
| info@lumostech.nl | |
| Telephone | +31 6 498 198 77 |
Version 2.1 · September 2026 · replaces version 2.0 of June 2026.