--- title: Privacy Policy | LUMAN description: How LUMAN collects, uses and protects personal data on luman.io, including the Coherence Check. --- [![LUMAN](https://luman.io/hs-fs/hubfs/Luman_Logo_1.png?width=110&height=30&name=Luman_Logo_1.png)](https://luman.io?hsLang=en) Legal # Privacy Policy Last updated: 12 October 2026 This policy explains what personal data LUMAN collects when you visit luman.io, take the Coherence Check, or get in touch with us, what we do with it, and the rights you have. We keep it short and plain on purpose. ## 1. Who is responsible The controller for personal data processed on this website is: LUMAN Group Inc. 449 Frederick Street San Francisco, CA, USA Email: [contact@luman.io](mailto:contact@luman.io) For any privacy question or request, write to the email address above. ## 2. What we collect and why **Visiting the website.** When you load a page, our hosting provider processes technical data such as your IP address, browser type, the page requested and the time of the request. This is needed to deliver the page securely. Legal basis: Art. 6(1)(f) GDPR (our legitimate interest in operating a secure website). **Analytics and tracking cookies.** With your consent, we use HubSpot cookies to understand how visitors use the site and which content is useful. You can give or withdraw consent at any time through the cookie banner. Legal basis: Art. 6(1)(a) GDPR and, where applicable, § 25(1) TDDDG. **The Coherence Check.** Your answers are scored in your browser. They are not sent to us unless you ask for your results by email. If you do, we receive your email address, your first name (if you provide it), your three field scores, your result and the practice recommended to you. We use this to send you your results. Legal basis: Art. 6(1)(a) GDPR (your consent, given by ticking the box). **Occasional notes from philip horváth.** Only if you tick the separate box, we will also send you occasional emails on leadership and coherence. Every email contains an unsubscribe link. Legal basis: Art. 6(1)(a) GDPR. **Contacting us.** If you email us or use a contact form, we process what you send us to respond and, where relevant, to prepare or carry out a working relationship. Legal basis: Art. 6(1)(b) GDPR (pre-contractual and contractual steps) or Art. 6(1)(f) GDPR (our legitimate interest in answering inquiries). We do not sell personal data, and we do not use it for automated decision-making or profiling with legal or similarly significant effects. The Coherence Check result is a reflection prompt, not an assessment of you. ## 3. Who processes data on our behalf We use HubSpot, Inc. (Cambridge, MA, USA) to host this website and to run our CRM, forms, emails and analytics. HubSpot processes data on our behalf under a data processing agreement. More information: [HubSpot privacy policy](https://legal.hubspot.com/privacy-policy). Fonts and images on this website are served from our own HubSpot-hosted domain. We do not load fonts from Google or other third-party font services. ## 4. Transfers outside the EU HubSpot may process data in the United States. These transfers rely on the EU-US Data Privacy Framework, where the recipient is certified, and on the European Commission's Standard Contractual Clauses. ## 5. How long we keep data - **Coherence Check results:** until you ask us to delete them, or at the latest 24 months after your last interaction with us. - **Email consent:** until you unsubscribe or withdraw consent, plus the record of consent we are required to keep. - **Inquiries:** as long as needed to handle them, and longer only where tax or commercial law requires it. - **Server logs:** for a short period as set by our hosting provider for security purposes. ## 6. Your rights You have the right to: - access the personal data we hold about you (Art. 15 GDPR) - have it corrected (Art. 16) or deleted (Art. 17) - restrict its processing (Art. 18) - receive it in a portable format (Art. 20) - object to processing based on our legitimate interests (Art. 21) - withdraw any consent at any time, with effect for the future (Art. 7(3)) - lodge a complaint with a data protection supervisory authority, for example the one in your country of residence To exercise any of these rights, email [contact@luman.io](mailto:contact@luman.io). To stop receiving emails, use the unsubscribe link in any email. ## 7. Changes We update this policy when our practices or the law change. The date at the top shows the latest version. © LUMAN