LumelisDigital

Privacy Policy

Last updated: April 2026

1. Privacy at a Glance

General Information

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. For detailed information on the subject of data protection, please refer to our Privacy Policy listed below this text.

Data Collection on This Website

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. Their contact details can be found in the section “Notice on the Responsible Party” in this Privacy Policy.

How do we collect your data?

Your data is collected in part by you providing it to us — for example, data you enter into a contact form.

Other data is collected automatically or with your consent when you visit the website by our IT systems. This is primarily technical data (e.g. internet browser, operating system, or time of page access). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure the website is provided without errors. Other data may be used to analyse your user behaviour. Where contracts can be concluded or initiated via the website, the transmitted data is also processed for contract offers, orders or other enquiries.

What rights do you have regarding your data?

You have the right at any time to obtain free information about the origin, recipient and purpose of your stored personal data. You also have the right to request the correction or deletion of this data. If you have given consent to data processing, you may revoke that consent at any time for the future. You also have the right, under certain circumstances, to request restriction of the processing of your personal data. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

For this and any other questions on the subject of data protection, please feel free to contact us at any time.

Cookies and Local Storage

Certain interactive features and games on our website use local storage (localStorage) to save your progress, statistics, and preferences directly on your device. This data is not transmitted to our servers, does not contain personal identifiers, and is strictly necessary to provide the core functionality of these specific applications.

Additionally, our platform uses cookies through third-party services (such as Google AdSense) to display advertisements. The collection and processing of data via these non-essential cookies is strictly based on your explicit consent, which you can manage via the privacy banner provided when you first visit the site.

2. Hosting

We host the content of our website with the following provider:

External Hosting

This website is hosted externally. Personal data collected on this website is stored on the servers of the host(s). This may include, in particular, IP addresses, contact requests, meta and communication data, contract data, contact details, names, website accesses and other data generated via a website.

External hosting is carried out for the purpose of fulfilling contracts with our potential and existing customers (Art. 6(1)(b) GDPR) and in the interest of secure, fast and efficient provision of our online offering by a professional provider (Art. 6(1)(f) GDPR). Where appropriate consent has been requested, processing is carried out exclusively on the basis of Art. 6(1)(a) GDPR and § 25(1) TDDDG, insofar as the consent covers the storage of cookies or access to information on the user's device (e.g. device fingerprinting) within the meaning of the TDDDG. Consent may be revoked at any time.

Our host(s) will only process your data to the extent necessary to fulfil their service obligations and will follow our instructions with respect to that data.

We use the following host:

Cloudflare, Inc.
101 Townsend St.
San Francisco, CA 94107
USA

Data Processing Agreement

We have concluded a Data Processing Agreement (DPA) for the use of the above-mentioned service. This is a legally required contract under data protection law which ensures that the provider processes the personal data of our website visitors only in accordance with our instructions and in compliance with the GDPR.

Data Transfer to Third Countries (USA)

Our host is based in the USA. Data transfer to the USA is based on the Standard Contractual Clauses of the EU Commission and on the adequacy decision of the EU Commission for the EU-US Data Privacy Framework (DPF).

The company is certified under the “EU-US Data Privacy Framework” (DPF). The DPF is an agreement between the European Union and the USA that is intended to ensure compliance with European data protection standards for data processing in the USA. Every company certified under the DPF undertakes to comply with these data protection standards.

No Profiling

Cloudflare does not create profiles and does not use our website visitor data for purposes other than ensuring the security of our website and providing our services. No individual or user-related profiling takes place, and no data is passed on to third parties.

3. General Information and Mandatory Disclosures

Data Protection

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this Privacy Policy.

When you use this website, various personal data is collected. Personal data is data with which you can be personally identified. This Privacy Policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We point out that data transmission over the internet (e.g. when communicating by email) may have security vulnerabilities. Complete protection of data against access by third parties is not possible.

Notice on the Responsible Party

The party responsible for data processing on this website is:

Deepak Jeswani Dewan
trading as Lumelis Digital
Stresemannstr. 23
10963 Berlin
Germany

Phone: +49 1521 639 19 56
Email: info@lumelis.digital

The responsible party is the natural or legal person who, alone or jointly with others, decides on the purposes and means of processing personal data (e.g. names, email addresses, etc.).

Storage Duration

Unless a more specific storage period has been stated within this Privacy Policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you submit a legitimate request for deletion or revoke consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, deletion will take place after those reasons cease to apply.

General Information on the Legal Bases for Data Processing on This Website

Where you have given consent to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9(2)(a) GDPR where special categories of data are processed pursuant to Art. 9(1) GDPR. In the event of express consent to the transfer of personal data to third countries, processing is also based on Art. 49(1)(a) GDPR. Where you have given consent to the storage of cookies or access to information on your device (e.g. via device fingerprinting), processing is additionally based on § 25(1) TDDDG. Consent may be revoked at any time. Where your data is required for the performance of a contract or for pre-contractual measures, we process it on the basis of Art. 6(1)(b) GDPR. Furthermore, we process your data where required for compliance with a legal obligation pursuant to Art. 6(1)(c) GDPR. Data processing may also be carried out on the basis of our legitimate interest pursuant to Art. 6(1)(f) GDPR. The relevant legal bases applicable in each individual case are set out in the following sections of this Privacy Policy.

Recipients of Personal Data

In the course of our business activities, we work with various external parties. In some cases, this requires the transfer of personal data to those external parties. We only share personal data with external parties where this is necessary for the performance of a contract, where we are legally obliged to do so (e.g. sharing data with tax authorities), where we have a legitimate interest in doing so pursuant to Art. 6(1)(f) GDPR, or where another legal basis permits such sharing. Where we engage data processors, we only share personal data of our customers on the basis of a valid data processing agreement. In the case of joint processing, a joint processing agreement is concluded.

Withdrawal of Your Consent to Data Processing

Many data processing operations are only possible with your express consent. You may revoke consent you have already given at any time. The lawfulness of the data processing carried out prior to the revocation is not affected by the revocation.

Right to Object to Data Collection in Special Cases and to Direct Marketing (Art. 21 GDPR)

WHERE DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6(1)(E) OR (F) GDPR, YOU HAVE THE RIGHT AT ANY TIME TO OBJECT, ON GROUNDS RELATING TO YOUR PARTICULAR SITUATION, TO THE PROCESSING OF YOUR PERSONAL DATA; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING SERVES THE ESTABLISHMENT, EXERCISE OR DEFENCE OF LEGAL CLAIMS (OBJECTION PURSUANT TO ART. 21(1) GDPR).

WHERE YOUR PERSONAL DATA IS PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING TO THE EXTENT THAT IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21(2) GDPR).

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of breaches of the GDPR, data subjects have the right to lodge a complaint with a supervisory authority, in particular in the Member State of their habitual residence, place of work or place of the alleged infringement. The right to lodge a complaint is without prejudice to any other administrative or judicial remedy.

Right to Data Portability

You have the right to receive data that we process automatically on the basis of your consent or in performance of a contract, in a commonly used, machine-readable format, and to have it transmitted to yourself or to a third party. Where you request the direct transfer of data to another controller, this will only be done to the extent technically feasible.

Information, Correction and Deletion

Within the framework of applicable legal provisions, you have the right at any time to obtain free information about your stored personal data, its origin and recipients and the purpose of data processing and, if applicable, the right to correct or delete this data. For this and any other questions on the subject of personal data, please feel free to contact us at any time.

Right to Restriction of Processing

You have the right to request restriction of the processing of your personal data. You may contact us at any time for this purpose. The right to restriction of processing exists in the following cases:

  • If you dispute the accuracy of your personal data stored by us, we generally need time to verify this. For the duration of the review, you have the right to request restriction of the processing of your personal data.
  • If the processing of your personal data was/is unlawful, you may request restriction of data processing instead of deletion.
  • If we no longer need your personal data but you require it for the exercise, defence or assertion of legal claims, you have the right to request restriction of processing instead of deletion.
  • If you have lodged an objection pursuant to Art. 21(1) GDPR, a balance must be struck between your interests and ours. As long as it has not yet been established whose interests prevail, you have the right to request restriction of the processing of your personal data.

Where you have restricted the processing of your personal data, such data — apart from storage — may only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person, or for reasons of important public interest of the European Union or a Member State.

SSL/TLS Encryption

For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the website operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address bar of the browser changes from “http://” to “https://” and by the padlock symbol in your browser bar.

When SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Objection to Promotional Emails

The use of contact data published in the context of the duty to provide a legal notice for the purpose of sending unsolicited advertising and informational materials is hereby expressly prohibited. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam emails.

4. Data Collection on This Website

Server Log Files

The provider of the pages automatically collects and stores information in so-called server log files, which your browser transmits to us automatically. These are:

  • Browser type and browser version
  • Operating system used
  • Referrer URL
  • Hostname of the accessing device
  • Time of the server request
  • IP address

This data is not merged with other data sources.

This data is collected on the basis of Art. 6(1)(f) GDPR. The website operator has a legitimate interest in the technically error-free presentation and optimisation of its website — for this purpose, server log files must be recorded.

Web Analytics

We use two privacy-friendly tools to evaluate user behavior. Both services do not use cookies and therefore do not require a cookie opt-in (cookie banner).

  • Cloudflare Web Analytics: A service provided by our host Cloudflare Inc. It does not store IP addresses permanently and does not create user-related profiles (profiling).
  • Umami: Privacy-friendly open-source analytics software that we host ourselves on our own servers (VPS). No data is transferred to third parties. Umami does not collect any personal data, completely anonymizes all IP addresses, and only measures basic metrics (such as page views, source of origin, and device type).

The data collection is based on our legitimate interest in statistical evaluation for the optimization of our website in accordance with Art. 6(1)(f) GDPR.

Google AdSense

This website uses Google AdSense, an advertising service provided by Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google AdSense enables the display of advertisements on this website. Google uses technologies such as cookies, local storage, and similar tracking technologies to collect and store information about user interactions. This may include data such as IP address, browser type, device information, and user behavior on this website.

Personal data may be used by Google to provide personalized ads, measure ad performance, and prevent fraud. Users may be shown personalized or non-personalized ads depending on their consent preferences. Consent signals are transmitted to Google to ensure compliance with user choices.

The use of Google AdSense and the storage of or access to information on the user's device takes place exclusively on the basis of your consent in accordance with Art. 6(1)(a) GDPR and § 25(1) TDDDG. Consent is obtained via our Consent Management Platform (cookie banner) when you first visit this website and can be revoked or modified at any time.

Google may process data in countries outside the European Union. Data transfers to the United States are based on the EU-US Data Privacy Framework (DPF), to which Google is certified. Where applicable, Standard Contractual Clauses (SCC) of the European Commission are also used.

For more information on how Google processes personal data and uses data from partner sites, please visit:
https://policies.google.com/privacy
https://policies.google.com/technologies/partner-sites

Security and Bot Protection (Cloudflare)

To protect our website from harmful bots, spam, and automated attacks, we use the security features (e.g., Bot Management / Turnstile) of our host Cloudflare. In the process, technical data (such as temporary, anonymized IP addresses and browser information) is analyzed to distinguish between human users and bots. This processing is based on our legitimate interest in the security and availability of our website (Art. 6 Abs. 1 lit. f GDPR). The data is processed exclusively for threat prevention and is not used for other purposes.

Enquiries by Email, Phone or Fax

If you contact us by email, phone or fax, your enquiry including all resulting personal data (name, enquiry) will be stored and processed by us for the purpose of handling your request. We do not pass this data on without your consent.

This data is processed on the basis of Art. 6(1)(b) GDPR where your enquiry is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, processing is based on our legitimate interest in the effective handling of enquiries directed to us (Art. 6(1)(f) GDPR) or on your consent (Art. 6(1)(a) GDPR) where this has been requested; consent may be revoked at any time.

The data you send to us via contact enquiries remains with us until you request deletion, revoke your consent to storage, or the purpose for data storage ceases to apply (e.g. after completion of handling your request). Mandatory statutory provisions — in particular statutory retention periods — remain unaffected.

Our Social Media Presence

Data Processing by Social Networks

We maintain publicly accessible profiles on social networks and other online platforms (including YouTube, TikTok, Instagram, Facebook, Pinterest, Threads, X, as well as Linktree, Buy Me a Coffee and Ko-fi). Social networks and platform operators can generally analyse your user behaviour comprehensively when you visit their website. Visiting our online presences triggers numerous data-protection-relevant processing operations.

If you are logged into your social media account and visit our profile, the operator of the portal can attribute this visit to your user account. Your personal data may also be collected even if you are not logged in. This data collection occurs, for example, via cookies stored on your device or by recording your IP address.

Using the data collected in this way, the operators of the portals can create user profiles containing your preferences and interests. In this way, interest-based advertising can be displayed to you inside and outside the respective social media presence. Please note that we cannot trace all processing operations on the social media portals. For details, please refer to the terms of use and privacy policies of the respective portals.

Legal Basis

Our social media presences are intended to ensure the broadest possible presence on the internet. This constitutes a legitimate interest within the meaning of Art. 6(1)(f) GDPR. The analysis processes initiated by the social networks may be based on different legal bases, which are to be stated by the operators of the social networks (e.g. consent within the meaning of Art. 6(1)(a) GDPR).

Controller and Assertion of Rights

When you visit one of our social media presences, we are jointly responsible with the operator of the social media platform for the data processing operations triggered by that visit (Art. 26 GDPR). You can assert your rights (access, rectification, deletion, restriction of processing, data portability and complaint) in principle both against us and against the operator of the respective portal (e.g. against Google or Meta).

For our presences on Facebook and Instagram (Meta), we have concluded a joint processing agreement (Controller Addendum) with the provider. This governs who fulfils which GDPR obligations. The text can be found here: https://www.facebook.com/legal/terms/page_controller_addendum.

Further information on data processing and your rights can be found in the privacy policies of the respective providers:

Source: https://www.e-recht24.de