Privacy Policy

Lumina Mind Lab
Johan Huizingalaan 763A,
1066 VH Amsterdam,
The Netherlands

hester@luminamindlab.nl
www.luminamindlab.com

Last updated: 1st of march 2026

1. Introduction
Lumina Mind Lab ("we", "us", or "our") is committed to protecting your personal data. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have in relation to it.
We operate in accordance with the General Data Protection Regulation (GDPR) and applicable Dutch privacy law. Lumina Mind Lab is the data controller for the personal data described in this policy.

2. What Personal Data We Collect
Depending on how you interact with us, we may collect the following categories of personal data:

Through the contact form on our website:
First name and last name
Email address
Company name
The content of your message
Through direct communication (email, LinkedIn):
Name and contact details you provide
The content of your correspondence with us
Through our Services (client engagements):

Professional information such as your role, goals, and working style
Business-related information and documents you choose to share with us
Notes and outputs from our consultancy and AI tool development work

Automatically when you visit our website:

Technical data such as browser type, device type, and pages visited (collected via Wix platform functionality and standard web server logs)
Cookie data (see Section 7)

3. Why We Collect Your Data and Our Legal Basis
We only process your personal data when we have a lawful basis to do so under GDPR. The table below outlines our purposes and the corresponding legal basis:
PurposeLegal BasisResponding to your enquiry via the contact form or emailLegitimate interests (Art. 6(1)(f)) / Pre-contractual steps (Art. 6(1)(b))Delivering our Services under a contractPerformance of a contract (Art. 6(1)(b))Sending project-related communicationsPerformance of a contract (Art. 6(1)(b))Maintaining records of client workLegitimate interests (Art. 6(1)(f))Improving our website and servicesLegitimate interests (Art. 6(1)(f))Complying with legal obligationsLegal obligation (Art. 6(1)(c))
We do not use your data for automated decision-making or profiling.

4. How We Use Your Data
We use your personal data only for the purposes described in Section 3. Specifically:

To respond to your enquiries and follow up on potential collaborations.
To design, build, and deliver personalised AI tools and thought-partner systems as part of our Services.
To communicate with you throughout our engagement, including sending proposals, updates, and invoices.
To maintain internal records required for legal or business purposes.
To improve our website and understand how visitors interact with it.

We will never sell your personal data to third parties.

5. Who We Share Your Data With
We may share your personal data with the following categories of third parties where necessary:

Wix.com — our website hosting and form-processing platform. Wix stores contact form submissions on our behalf. You can review Wix's privacy practices at wix.com/about/privacy.
AI platforms and tools — where we use third-party AI services (such as OpenAI, Anthropic, or others) to develop and deliver your personalised AI tools, we take care to minimise the personal data processed. We will inform you of any specific AI tools used as part of your engagement.
Professional advisors — such as lawyers or accountants, where necessary, under obligations of confidentiality.
Authorities — where we are required by law to disclose information.

We do not share your data with third parties for marketing purposes.

6. International Data Transfers
Some third-party platforms we use (such as Wix or AI providers) may process data outside the European Economic Area (EEA). Where this is the case, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission, in accordance with GDPR requirements.

7. Cookies
Our website is built on the Wix platform, which may use cookies and similar technologies to ensure the website functions correctly and to analyse usage. These may include:

Essential cookies — required for the website to operate.
Analytics cookies — used to understand how visitors use the site (if enabled via Wix settings).

When you visit our website, you may be asked to consent to non-essential cookies. You can manage your cookie preferences at any time through your browser settings. For more information on how Wix uses cookies, please visit support.wix.com.

8. How long we keep your data
We retain your personal data only for as long as necessary for the purposes described in this policy:

Enquiries that do not lead to an engagement: up to 12 months after our last communication.
Client data: for the duration of our engagement and up to 7 years afterwards, in line with Dutch legal and tax record-keeping requirements.
Website usage data: in accordance with Wix's standard data retention practices.

When your data is no longer needed, we securely delete or anonymise it.

9. Your Rights Under GDPR
As a data subject, you have the following rights regarding your personal data:

Right of access — you can request a copy of the personal data we hold about you.
Right to rectification — you can ask us to correct inaccurate or incomplete data.
Right to erasure — you can ask us to delete your data in certain circumstances.
Right to restriction — you can ask us to restrict how we process your data.
Right to data portability — you can request your data in a structured, machine-readable format.
Right to object — you can object to processing based on legitimate interests.
Right to withdraw consent — where processing is based on consent, you can withdraw it at any time.

To exercise any of these rights, please contact us at hester@luminamindlab.nl. We will respond within one month of receiving your request.
You also have the right to lodge a complaint with the Dutch data protection authority:
Autoriteit Persoonsgegevens
www.autoriteitpersoonsgegevens.nl
Telephone: +31 88 180 52 50

10. Data Security
We take appropriate technical and organisational measures to protect your personal data from unauthorised access, loss, or misuse. These include using secure communication channels and limiting access to personal data to those who need it.
However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

11. Third-Party Links
Our website may contain links to third-party websites, including LinkedIn. This Privacy Policy applies only to our website and Services. We encourage you to read the privacy policies of any third-party sites you visit.

12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The most current version will always be available on this page, with the date of last update shown at the top. We encourage you to review this policy periodically.

13. Contact
If you have any questions about this Privacy Policy or how we handle your personal data, please contact:

Hester Ezra, Lumina Mind Lab
Johan Huizingalaan 763A, 1066 VH Amsterdam
hester@luminamindlab.nl