PRIVACY POLICY

Last updated: July 30, 2026

Introduction

This Privacy Policy for LUMEN LIBRA SIA ("we," "us," or "our"), acting as the Data Controller in accordance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) and the applicable laws of the Republic of Latvia, describes how and why we process your personal data when you use our Services, including when you visit our website at https://lumenlibra.com/.

Questions? If you do not agree with this Privacy Policy, please do not use our Services. For any questions, contact us at info@lumenlibra.com or by post (see Section 11).
Summary of Key Points

  • What personal data do we process? We process only the personal data you provide directly or that is collected automatically (e.g., IP address).
  • Do we process sensitive personal data? No. We do not process racial/ethnic origin, political opinions, religious beliefs, or biometric data.
  • Do we collect personal data from third parties? No.
  • How do we process your personal data? We process data to provide, improve, and secure our Services, communicate with you, and comply with Latvian and EU law (e.g., tax obligations).
  • How do we keep your personal data safe? We implement organizational and technical measures as required by GDPR Article 32. However, 100% security cannot be guaranteed.
  • What are your rights? As a resident of Latvia/EEA, you have the rights to access, rectify, erase, restrict, port, and object.

1. WHAT PERSONAL DATA DO WE COLLECT?

Personal data you disclose to us
We collect personal data that you voluntarily provide when contacting us, expressing interest in our products, or using our Services.

Personal Data Provided: Names, phone numbers, email addresses, company name, and message content.

Sensitive Information: We do not process sensitive information. If such data is required, we will obtain your explicit written consent.

Information automatically collected
When you visit our Services, we automatically collect technical data necessary for security and analytics:
  • Log and Usage Data: IP address, browser type, device information, date/time stamps, pages viewed, error reports.
  • Device Data: Operating system, hardware model, language preferences.
  • Location Data: Imprecise location based on IP address (we do not collect precise GPS data without consent).
Cookies and Tracking Technologies: We use cookies and similar technologies. No non-essential cookies (e.g., analytics, marketing) are placed on your device until you provide your explicit consent via our cookie banner. For details, see our Cookie Policy at lumenlibra.com/en/cookie.

2. HOW DO WE PROCESS YOUR PERSONAL DATA?

We process your personal data only when we have a valid legal basis under GDPR Article 6:

Purpose

Legal Basis (Latvia/EU)

To provide and maintain our Services

Performance of a contract (or steps prior to a contract)

To respond to inquiries and communicate with you

Legitimate interest (to respond to your request)

To comply with tax and accounting laws

Legal obligation (Latvian Law on Accounting, tax laws)

For security and fraud prevention

Legitimate interest (to ensure network and data security)

For analytics and improving user experience

Consent (via cookie banner for non-essential cookies)


We do not process your data for automated decision-making or profiling.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We may share your personal data only in the following situations:
  • Service Providers (Processors): With third-party companies (e.g., hosting providers, Google Analytics) under written contracts that require them to protect your data and comply with GDPR.
  • Legal Authorities: If required by the laws of the Republic of Latvia or EU regulations (e.g., a lawful request from the Latvian State Police or tax authorities).
We do not sell your personal data to any third party.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

Yes, but only with your consent.
We use cookies and similar tracking technologies (web beacons, pixels) in accordance with the Electronic Communications Law of the Republic of Latvia.
  • Strictly Necessary Cookies: These are essential for the website to function and do not require your consent. They cannot be disabled.
  • Non-Essential Cookies (Analytics, Advertising): These are only activated after you click "Accept" or "Save Preferences" on our cookie banner.
Google Analytics: We use Google Analytics to analyze site usage. Google Analytics sets cookies only after you give consent. To opt out globally, visit https://tools.google.com/dlpage/gaoptout.

Detailed information about each cookie (name, purpose, retention period) is available in our separate Cookie Policy at: lumenlibra.com/en/cookie.

How to withdraw consent: You can change or withdraw your cookie consent at any time by clicking the "Cookie Settings" link in our website footer or by clearing cookies in your browser settings.

5. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We retain your personal data only as long as necessary for the purposes set out in this Privacy Policy, subject to legal retention requirements under Latvian law:
  • Contact/Inquiry data: Retained for 1 year after the last interaction.
  • Accounting data (invoices, contracts): Retained for 10 years after the end of the financial year (as required by the Latvian Law on Accounting).
  • Technical data (logs, IP addresses): Retained for 12 months for security purposes.
When the retention period expires, your data is securely deleted or anonymized.

6. HOW DO WE KEEP YOUR PERSONAL DATA SAFE?

We have implemented appropriate technical and organizational security measures (encryption, access controls, firewalls) as required by GDPR Article 32 to protect your personal data.
However, please note: No electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not defeat our security.
By using our Services, you acknowledge this inherent risk.

7. DO WE COLLECT PERSONAL DATA FROM MINORS?

We do not knowingly collect data from or market to children under 18 years of age.
If we learn that we have collected personal data from a minor under 18 without parental consent, we will delete that personal data immediately. If you believe we might have such data, please contact us.

8. WHAT ARE YOUR PRIVACY RIGHTS?

If you are a resident of Latvia or the European Economic Area (EEA), you have the following rights under the GDPR:

Right

What it means

Right to access

Request a copy of your personal data we hold.

Right to rectification

Correct inaccurate or incomplete data.

Right to erasure ("Right to be forgotten")

Request deletion of your data (subject to legal retention obligations).

Right to restriction

Limit how we process your data.

Right to data portability

Receive your data in a structured, machine-readable format.

Right to object

Object to processing based on legitimate interests.

Right to withdraw consent

Withdraw consent for cookie processing or marketing at any time.


To exercise any of these rights, email us at lyubov.kachanova@outlook.com. We will respond within 30 days (as required by Latvian law).
Right to lodge a complaint: If you believe we have violated your rights, you have the right to lodge a complaint with the Latvian Data State Inspectorate (Datu valsts inspekcija).
Website: www.dvi.gov.lv
Address: Blaumaņa iela 11/13-15, Rīga, LV-1011, Latvia.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers include a Do-Not-Track ("DNT") feature. As there is no uniform technology standard for DNT signals, we currently do not respond to DNT browser signals.

10. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

Yes. We will update this Privacy Policy as necessary to stay compliant with relevant laws. The "Last updated" date at the top indicates when changes were made. If we make material changes, we will notify you via email or a prominent notice on our website.

11. DATA PROTECTION OFFICER (DPO)

We have not appointed a Data Protection Officer (DPO). Under the GDPR, companies are required to appoint a DPO only if they are a public authority, perform large-scale monitoring, or process large-scale sensitive data. As we do not meet these criteria, we have not appointed a DPO. All privacy-related inquiries can be directed to:
LUMEN LIBRA SIA
Address: Drosmes 2-13, Jūrmala, LV-2015, Latvia
Email: lyubov.kachanova@outlook.com

12. HOW CAN YOU REVIEW, UPDATE, OR DELETE YOUR DATA?

To request access to, correction, or deletion of your personal data, please contact us at info@lumenlibra.com. We will verify your identity before processing your request.

LUMEN LIBRA SIA

Drosmes 2-13, Jūrmala LV-2015, Latvija

Reg Number 50203587611

License number AGL0003487
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