Legal & Compliance

Privacy Policy

Effective: September 20, 2026Version: 2.5Applies to: Global Users & EU/UK GDPR

The short version: You own your data. We collect only what is strictly necessary to run the service, we never sell your data or respondent submissions to data brokers, and you can export or purge workspace data from Settings. Traffic uses TLS. We do not promise a custom AES-256 vault on every D1 row.

This Privacy Policy describes how Lumina (“Lumina”, “we”, “us”, or “our”) collects, uses, and safeguards information when you interact with our website, interactive form builder, API, and associated services (the “Service”). This policy applies to workspace creators, collaborators, and the individuals who submit responses to forms created on Lumina (“respondents”).

1. Information We Collect

A. Account & Workspace Information

When you register for a Lumina workspace, we collect your name, business email address, workspace title, and a PBKDF2-SHA-256 password hash. We use this information solely to authenticate your access, deliver notifications, and administer your account.

B. Form Content & Respondent Submissions

Workspace owners create forms and define the fields requested from respondents. When a respondent completes a form, we store their inputs alongside a minimal set of attribution and operational metadata: campaign attribution parameters (utm_source, utm_medium,utm_campaign, utm_term, utm_content), paid-click identifiers (gclid, fbclid), the referring page and landing URL, the submission timestamp, completion duration, and anti-spam tokens. Ingest and API logs may include IP address and user-agent for abuse control. Lumina is a processor of respondent answers; the form owner is the controller.

C. Technical & Operational Telemetry

Platform administrators can view workspace-level statistics, account roles, package assignments, and active days. Administrative actions are recorded with actor identity, action, timestamp, and outcome. Audit records do not include account passwords, API-key secrets, or submitted answer bodies.

Forms also save progress as you answer: a first-party session identifier, start and last-active times, the current question, time spent, and unfinished answers. The form owner can review these to understand completion and follow up. Payment details, signatures, attachments, and hidden fields are excluded from partial-answer tracking. Completion is remembered in this browser to prevent another submission.

To maintain service reliability, protect against DDoS or brute-force attacks, and debug edge gateway issues, we log transient HTTP request headers, IP addresses, and user-agent strings. We do not deploy third-party advertising cookies, cross-site trackers, or behavioral profiling scripts.

Cookies and local storage. We use only first-party, strictly necessary storage: a secure session cookie that keeps you signed in; a per-form cookie that remembers you completed a form so you cannot submit it twice; preference values saved in your browser’s local storage; and in-progress form answers saved in your browser’s session storage. Cloudflare sets short-lived security cookies when it runs a Turnstile challenge. We set no advertising or cross-site tracking cookies. The full inventory is in our Cookie Notice.

2. How We Use Information

We process information strictly for the following legitimate purposes:

Delivering, operating, and refining the Lumina form builder and edge delivery pipeline.
Securing workspaces against fraudulent access, abuse, and automated spam submissions.
When email delivery is configured for the deployment, dispatching essential operational notifications such as password resets and new response alerts; deployments without a sending provider do not send outbound email.
Enforcing our Terms of Service and satisfying applicable legal and regulatory requirements.

Zero monetization of user data: We do not sell, rent, or monetize your personal information or respondent inputs, nor do we feed submitted data into public AI training datasets.

3. Legal Bases for Processing (GDPR)

For individuals situated in the European Economic Area (EEA), United Kingdom, or Switzerland, our processing is grounded in the following lawful bases under GDPR:

Contractual Necessity: Delivering core workspace features and processing form submissions pursuant to our agreement.
Legitimate Interests: Protecting the security, uptime, and fraud resistance of our infrastructure.
Consent: Where you have explicitly opted into specific communications or optional product experiments.
Legal Obligations: Compliance with applicable tax, accounting, or statutory reporting mandates.

Our hosted service uses Cloudflare Workers for application processing, D1 for database storage, and R2 for configured attachments. Where Turnstile security checks are enabled on account or submission flows, Cloudflare processes challenge tokens and browser and request information, including IP addresses, to help distinguish people from automated abuse. Transactional email and payment providers process the information needed to deliver those services; the current list is published on our Subprocessors page. Workspace-configured integrations receive the data their owners choose to send. We may disclose information when required by applicable law.

5. Security, Encryption & Retention

Traffic to the Service is encrypted in transit (TLS). Object storage, when configured, uses the provider's encryption at rest. We do not claim a custom AES-256 vault for every D1 row. You remain responsible for what you ask respondents to submit.

Retention periods: workspace content is kept until an owner deletes the relevant form, response, or workspace; deletion is immediate for active database records and extends to attachments stored in object storage. Partial (“in progress”) form answers in our analytics store are deleted on a rolling basis 30 days after their last activity — the cleanup runs on the form’s next activity, and answers for completed submissions are blanked at submission time. Security and administrative audit records are kept for investigating abuse, resolving disputes, and meeting legal obligations. Payment and finance records are kept as long as applicable tax and accounting law requires. Infrastructure backups may retain deleted content for the provider’s configured recovery window (approximately 30 days for the managed database) before it is unrecoverable.

6. Your Rights

Depending on your jurisdiction (such as under GDPR or CCPA/CPRA), you have the right to:

Access and obtain an export of your personal data in a structured, machine-readable format.
Correct inaccurate or incomplete profile records.
Request permanent erasure of your personal data (“Right to be Forgotten”).
Restrict or object to specific processing activities.

Workspace owners can initiate immediate data exports (CSV) and workspace purges within the Workspace Settings panel. Members who are not owners can exercise these rights for their own account data by contacting the workspace owner or emailing legal@luminaforms.app.

7. Respondent Privacy

Lumina is a technology provider to workspace owners. If you submitted responses to a form built on Lumina, the workspace owner is the data controller. Please direct requests regarding access, modification, or deletion of your specific responses to the form publisher directly. We will assist publishers in fulfilling valid requests.

8. Children’s Privacy

The Service is strictly targeted to professionals and businesses. We do not knowingly collect or solicit personal information from individuals under the age of 16. If you believe a child has provided us personal data without parental consent, please contact us for prompt removal.

9. International Transfers

Cloudflare may process requests across its global network. D1 storage location depends on the database configuration; a location hint is not a residency guarantee. Where a restricted international transfer applies, the relevant provider agreement and safeguards must cover that transfer. Cloudflare describes its safeguards in its Data Processing Addendum.

10. Changes to this Policy

We may periodically revise this Privacy Policy to reflect platform enhancements or statutory updates. For material changes affecting your rights, we will provide at least 14 days advance notice through your workspace dashboard — and by email where email delivery is configured — before changes take effect.

11. Privacy contact

For privacy questions or requests about your personal data, contact:

Lumina
Attn: Privacy & Data Protection
Email: legal@luminaforms.app

To report abuse, copyright (DMCA) concerns, or illegal content in a form or hosted page, use the same address and include the form or page URL: legal@luminaforms.app.