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Privacy Policy for Lumira Travel

Effective Date: [27.06.25]
Last Updated: [27.06.25]

This Privacy Policy (“Policy”) governs the manner in which Lumira Travel (“Company,” “we,” “us,” or “our”) collects, uses, stores, and discloses personal data from users (“you,” “your,” or “data subjects”) in connection with the use of the website located at [https://www.lumiratravel.com] (“Website”).

1. Who We Are

This Website is operated by Lumira Travel, a Cyprus-based travel advisory company.

2. What Personal Data We Collect and Why

We may collect and process the following categories of personal data:

  • Identity Data: Name, email, phone number — typically submitted via contact forms.
  • Technical Data: IP address, browser type, operating system, and device type — collected automatically for performance, analytics, and security.
  • Usage Data: Interaction data related to browsing and submitted requests.
  • Communication Data: Content of emails and form submissions.

Purposes for processing include, but are not limited to:

  • Responding to inquiries
  • Improving site experience
  • Legal compliance
  • Marketing (with consent)

Data is processed under GDPR-compliant legal bases including consent, legitimate interest, and contractual necessity.

3. Comments

If commenting is enabled, we collect the comment text, metadata, IP address, and browser agent for spam prevention.

4. Media

Users uploading media to the site confirm ownership and grant us non-exclusive rights to use it in relation to our services. Users must not upload images with embedded location data (EXIF GPS) if privacy is a concern.

5. User-Uploaded Content Disclaimer

Users are solely responsible for ensuring they possess full legal rights for any media uploaded to this Website. Lumira Travel assumes no liability for infringing, inappropriate, or unlawful content uploaded by users and will remove such content upon verified request.

6. Website Image Disclaimer

All images published on the Website are either original, licensed for commercial use, or, to the best of our knowledge, in the public domain or shared under permissible licenses (e.g., Creative Commons).

If you believe any image used violates your copyright, please contact us immediately at info@lumiratravel.com. We will promptly investigate and, if appropriate, remove the disputed content.

We expressly disclaim all liability for unintentional copyright infringement.

7. Cookies

Cookies are used to ensure functionality, monitor usage, and enhance the user experience. These may include session cookies, analytics cookies, and third-party cookies from services like Google Analytics. Users may control or delete cookies via browser settings.

8. Analytics

We use anonymized tracking tools (e.g., Google Analytics) to measure traffic and user behavior. No personally identifiable data is collected unless explicitly provided by you.

9. Data Sharing and Disclosure

We do not sell or rent your personal information. However, we may share limited data with:

  • Hosting and technical service providers
  • Analytics and traffic monitoring platforms
  • Legal authorities, if compelled

All third parties are required to uphold strict data protection standards.

10. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this Policy:

  • Contact form data: 6 months
  • Analytics data: 12 months
  • Customer transactions: Up to 10 years, as required by law
11. Your Rights Under GDPR

You may exercise the following rights:

  • Right to access your data
  • Right to correct inaccuracies
  • Right to erase data (“right to be forgotten”)
  • Right to restrict processing
  • Right to data portability
  • Right to object to processing

To exercise these rights, email us at info@lumiratravel.com. We may request proof of identity.

12. Data Transfers Outside the EU

If your data is processed outside the European Union, we ensure such transfers are protected under appropriate legal safeguards, such as Standard Contractual Clauses or equivalent frameworks.

13. How We Protect Your Data

We implement appropriate technical and organizational measures to safeguard your data, including:

  • SSL/HTTPS encryption
  • Access controls and password protection
  • Malware protection
  • Secure backups
14. Data Breach Procedures

Should a data breach occur, we will notify affected users and relevant supervisory authorities within the timeframes required by law and will take prompt corrective actions.

15. Third-Party Data Sources

We do not collect personal data from third-party sources unless users explicitly grant access or opt into such services (e.g., third-party tour providers).

16. Automated Decision-Making

We do not use automated decision-making or profiling that produces legal or significant effects without human involvement.

17. Prohibited Data Mining and Scraping

Any automated access, extraction, or data mining of this Website or its contents — including user data, tour information, pricing, and metadata — is strictly prohibited. Violation may result in IP blocking, legal action, or reporting to applicable authorities.

18. Industry-Specific Disclosures

If applicable, any additional disclosures required under Cyprus or EU travel industry regulations will be provided upon request or integrated in future updates.

19. Contact Information

For privacy-related concerns, data access requests, or copyright matters, contact us at:

Email: info@lumiratravel.com