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Privacy Policy

Effective date: February 23, 2026

This Privacy Policy ("Policy") governs how Lumiotech Private Limited ("Lumiotech," "we," "us," or "our") collects, uses, discloses, and safeguards personal information within our intelligent corporate agent platform, lumioWhisper (also known as "Whisper"). Whisper helps enterprises manage a variety of needs, including hiring, training, compliance, record management, and much more.

This Policy is designed to comply with applicable data protection laws, including the Digital Personal Data Protection (DPDP) Act, 2023of India.

1. Introduction

By accessing or using lumioWhisper (the "Platform"), you acknowledge that you have read, understood, and agree to be bound by this Policy. If you do not agree with the data practices described in this Policy, you should not use the Platform.

2. Data Fiduciary and Consent Manager

For the purposes of the DPDP Act, Lumiotech acts as a "Data Fiduciary" for its direct customers, and may act as a "Data Processor" when providing B2B SaaS services to enterprises. Our designated Consent Manager and Data Protection Officer oversee data collection and user rights.

3. Information We Collect

We may collect and process various types of information from users (Data Principals), strictly limited to what is necessary for our stated purposes:

  • Personal Information: Full name, email address, phone number, job title, and similar identifiable information.
  • Business Information: Company name, business address, corporate structure, and other enterprise-related details.
  • Credentials: Passwords, authentication data, and other security-related information.
  • Device and Interaction Data: IP address, browser type, operating system, device identifiers, features used, and time spent.

4. How We Use Your Information

We use the collected information for the following specific purposes:

  • Platform Operations: To provide and maintain lumioWhisper functionality.
  • Improvement & Development: To conduct analysis and improve our software.
  • Customer Support: To respond to inquiries and provide assistance.
  • Compliance & Legal Obligations: To meet legal requirements, including mandatory logs retention.
  • Security & Fraud Prevention: To ensure platform integrity and investigate suspicious activity.

5. Consent and Withdrawal

We process personal data based on your free, specific, informed, and unambiguous consent. You have the right to withdraw your consent at any time. The process to withdraw consent is as simple as providing it. To withdraw, please contact our Consent Manager at[email protected] or utilize the in-app settings (when available). Upon withdrawal, we will cease processing your personal data within a reasonable timeframe, unless we are legally obligated to retain it.

6. Security Safeguards and Breach Notification

We implement rigorous administrative, technical, and physical safeguards—including data encryption, role-based access controls, and masking—to protect personal data against unauthorized access, loss, or alteration. In the event of a personal data breach, we will promptly notify the Data Protection Board of India and affected users as mandated by law.

7. Data Retention

We retain personal data only as long as necessary for its specified purpose or as required by law. Once the purpose is fulfilled and retention is no longer necessary for legal or business purposes, we will securely delete, erase, or anonymize your data.

8. Data Sharing and Disclosure

We may share information with trusted third-party service providers (Data Processors) who are contractually obligated to uphold robust data protection standards. We may also disclose data to comply with legal processes or during a business transfer.

9. Your Rights as a Data Principal

Under the DPDP Act and other applicable laws, you hold the following rights:

  • Right to Access: You may request a summary of personal data processed by us and the identities of Data Processors with whom it was shared.
  • Right to Correction and Erasure: You may request the correction of inaccurate data, completion of incomplete data, or erasure of your personal data.
  • Right of Grievance Redressal: You have the right to readily available means to register complaints.
  • Right to Nominate: You may nominate another individual to exercise your rights in the event of incapacity or death.

To exercise any of these rights, please use our Grievance Redressal mechanism.

10. Grievance Redressal Mechanism

If you have any questions, concerns, or complaints regarding how your personal data is handled, please contact our Data Protection Officer / Consent Manager at:

Lumiotech Private Limited
New Delhi, India
[email protected]

We are committed to resolving your grievance promptly. If you remain dissatisfied with our response, you have the right to escalate the matter to the Data Protection Board of India.

11. Updates to This Policy

We may update this Policy from time to time to reflect changes in our practices or legal requirements. When we do, we will revise the "Effective Date" at the top of this Policy.

By continuing to use lumioWhisper, you acknowledge that you have read and understand this Privacy Policy and agree to be bound by its terms.