Privacy Policy

PHV Solutions d.o.o. ("Lumina", "we", "us", or "our") provides Services through lumina-events.net web pages and Lumina Apps subject to this Privacy Policy, our Terms of Use, and other policies. We may change this Privacy Policy at any time. By continuing to access or use Lumina Services, you accept any changes or revisions to this Privacy Policy.

This Privacy Policy forms part of our Terms of Use. Any use of our services is subject to and governed by the Terms of Use.

1. Information Available in Lumina Services

Lumina aggregates information provided by event organizers, attendees, and publicly available sources. This may include information from company web pages, social network profiles, and other public sources ("Public Information"). We do not verify and cannot guarantee the accuracy of this Public Information. It is a user's responsibility to validate and revise their own profile information in Lumina Apps (including Lumina Android App, Lumina iOS App, and Lumina Web App).

2. Opt-in/Opt-out Policy for Attendee Lists

Lumina supports different policies on whether an attendee is listed in the event attendee list. Event organizers can decide which policy to apply to their events, and it is the event organizers' responsibility to inform their attendees about the applicable policy.

Important: Regardless of opt-in/opt-out policy, attendees' contact information (e.g., emails, phone numbers) is not disclosed to other attendees unless users explicitly exchange their contact information via Lumina Apps.

• Opt-out Policy (default): Attendees are listed in the attendee list to foster networking. Users can opt out by changing their visibility setting to "invisible" in the Settings menu.
• Opt-in once signed in: Once an attendee signs in, their name will be listed. They can still become invisible via Settings. If an attendee never signs in, their name is not listed.
• Explicit Opt-in: Upon signing in, attendees are explicitly asked whether they want to be listed. Their visibility status is set based on their answer and can be changed anytime in Settings.

3. Remove Your Information from Lumina Services

As a Lumina user, you have the right to remove your information from Lumina services by contacting us at info@lumina-events.net. After verification (we will need you to verify that you are removing your own information), we will remove your information from Lumina Services.

For a dedicated data deletion request page, visit Data Deletion Request.

Note that having information removed from Lumina Service does not mean that it is removed from its original data sources. Attendees need to contact organizers to ensure removals from all original data sources. In the Lumina app, users can also validate and revise their own profile.

4. Personal Data Lumina Collects

a) Platform Usage Data

Lumina Services collects information about platform usage. This may include:

• IP address used to access Lumina Services
• User activities on Lumina Platforms
• Device and browser details (device type/model, operating system and version, browser and version, language/locale, time zone, screen resolution)
• App/website interaction data (pages/screens viewed, clicks, session duration, referring/exit pages, date/time)
• Diagnostics/security signals (error and performance logs)

We may use cookies, SDKs, pixels, and similar technologies to collect this information. We use this data to operate, secure, and improve the Lumina Platform and Services.

b) Account Information

Lumina collects information that a user provides when creating an account. This may include your name, email address, and social network sign-in information. We do not provide your information to any third party except as described in Section 5.

c) User Activity Data

Lumina allows users to retain and access history, bookmarks, saved sessions, and connections. Users may delete this data at any time when Lumina Services are available. We do not share user browsing history and bookmarks with any third party except as described in Section 5.

d) Third-Party Integrations

Certain functionalities may require users to enter data to access their accounts with third-party websites. Your third-party login credentials are hashed and stored with strict security standards. We do not use this information for any other purpose.

5. Use and Sharing of Personal Data

a) Direct Use

Lumina may use Personal Data you provide to create and maintain your account, personalize your experience, and send email communications relating to Lumina Services. Lumina does not sell, exchange, transfer, or give this type of Personal Data to any other company without your consent.

b) Service Improvement and Third-Party Services

Lumina may use Personal Data about your use of Lumina Services to improve our services. We may also use personal data with third-party services and technologies:

• Analytics: Google Analytics to assist in improving our quality of service
• Cloud Infrastructure: Amazon Web Services (AWS) and Hetzner for hosting and data storage
• Security & Performance: Cloudflare for CDN, DDoS protection, and performance optimization
• Error Monitoring: Sentry for application error tracking and performance monitoring
• Push Notifications: Firebase Cloud Messaging for mobile push notifications
• Email Communications: Brevo (formerly Sendinblue) for transactional and marketing emails
• Payment Processing: Stripe for secure payment processing
• Cookies, Pixel Tags, Local Shared Objects, Web Storage and similar technologies

As a result, information about how you use Lumina Services may be available to these companies to the extent their technology collects such information. Lumina actively protects your usage anonymity and does not distribute personally identifiable information about your use of Lumina Services to any third parties other than those explicitly listed above.

c) Legal Requirements

Lumina reserves the right to disclose Personal Data to third parties if required to do so by law, or if Lumina has a good faith belief that disclosure is necessary to:

• Comply with legal process served on us
• Protect and defend our rights or property
• Act in an emergency to protect someone's safety

d) Business Transfers

Lumina reserves the right to transfer Personal Data to any successor in interest to Lumina's business.

6. Cookies and Similar Technologies

We use cookies and similar tracking technologies to track activity on our Services and store certain information. For more information about our use of cookies, please see our Cookie Policy.

7. Children's Privacy

a) Lumina Services is directed to people who are at least 18 years old, and Lumina does not knowingly collect Personal Data from anyone under the age of 18. If you are aware that Lumina has collected Personal Data from someone under the age of 18, please alert us at info@lumina-events.netand the information will be removed from our system as soon as reasonably possible.

b) This Privacy Policy does not apply to the practices of our Customers (event organizers) and other event participants with whom you may interact. You should review the applicable terms and policies from event organizers and their partners.

8. Security

We implement appropriate technical and organizational security measures to protect your Personal Data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

9. International Data Transfers and User Rights

9.1 Location of Data

Lumina is based in Croatia, European Union. We provide services globally using computer systems, servers, and databases located in the EU and other jurisdictions. When you use our services, your information may be transferred to and processed in these locations.

9.2 EU General Data Protection Regulation (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have certain rights under the GDPR:

Legal Grounds for Processing

We process your Personal Data based on the following legal grounds:

• You provided your consent
• It is necessary for our contractual relationship
• The processing is necessary for us to comply with our legal or regulatory obligations
• The processing is in our legitimate interest to fulfill our service as an event management platform

Lumina as a Data Processor

Where Lumina processes attendees' Personal Data on behalf of an Organizer as part of the Services, Lumina is a Data Processor and the Organizer is the Data Controller. Any questions relating to your Personal Data and your rights should be directed to the event organizer as the data controller.

Lumina as a Data Controller

In some cases, Lumina acts as a Data Controller, for example, where users directly provide Personal Data during account creation, or where data is processed to improve our products and features.

Your Rights Under GDPR

You have the following rights regarding your Personal Data:

• Right of Access: Request a copy of your Personal Data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your Personal Data
• Right to Restriction: Request restriction of processing
• 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 at any time where processing is based on consent

To exercise these rights, please contact us at info@lumina-events.net. You may also edit your profile or delete your data directly in the Lumina app.

Personal Data Retention

We retain your Personal Data only for as long as necessary to fulfill the purposes for which it was collected and processed. The retention period varies depending on the type of data, or until you request its deletion as outlined in this Privacy Policy.

We will also retain and use Personal Data for a period required to comply with our legal, tax, audit, or regulatory obligations, to manage potential liability, to resolve disputes, and to enforce our agreements.

Transfers of Personal Data

We may need to transfer your Personal Data outside of the EEA, Switzerland, or the UK. When we do so, we take legally required steps to ensure appropriate safeguards are in place, including EU Standard Contractual Clauses.

Data Incident Notifications

In cases where we are a data controller over data accessed in an unauthorized manner, we will notify the affected users directly. When we are solely a processor of data, we will notify event organizers who can then contact affected individuals.

Supervisory Authority

If you are located in the EU/EEA, you have the right to lodge a complaint with a supervisory authority. In Croatia, this is the Croatian Personal Data Protection Agency (Agencija za zastitu osobnih podataka - AZOP).

10. Event-Specific Privacy Policies

In addition to this general Privacy Policy, individual events hosted on the Lumina platform may have their own specific privacy policies and terms established by the event organizers. These event-specific policies may include additional terms regarding:

• How the event organizer collects and uses your personal data
• Sharing of attendee information with sponsors, exhibitors, or partners
• Photography and video recording policies at the event
• Communication preferences and marketing from the organizer
• Data retention specific to the event

Refunds, replacements, and complaints related to event registration, tickets, or event services are handled exclusively under the event organizer's terms. Those terms can be obtained by visiting the organizer's website or contacting the organizer directly.

Important: When you register for an event through Lumina, you should carefully review any event-specific privacy policy or terms provided by the event organizer. The event organizer acts as the Data Controller for personal data they collect through their event, and their policies supplement (but do not replace) this Lumina Privacy Policy.

Event-specific privacy policies can typically be found on the event's registration page or in the event details within the Lumina app. If you have questions about how a specific event handles your data, please contact the event organizer directly.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date. You are advised to review this Privacy Policy periodically for any changes.

12. Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact us at:

13. Data Subprocessors

The following is a list of our current data subprocessors:

This list may be updated from time to time. Please check back periodically for updates.