Your data, protected and yours
Last updated 13 October 2026
01 Introduction
02 Who we are
03 Personal data we collect
- Account & identity data: your name, work email, phone number and password (stored only as a salted hash).
- Firm & business data: your firm's name, address, GSTIN, logo and team-member details.
- Assessment data you upload: building geometry, project, site and zone records, drawings, single-line diagrams, site photos and other documents you attach to an assessment.
- Billing data: plan, seats, invoices and payment metadata. Card and bank details are handled by our payment processor; we do not store full card numbers.
- Usage & technical data: log data, device and browser information, and actions recorded in our audit trail.
- Communications: messages you send to support and your contact preferences.
- Email engagement: whether our lifecycle and marketing emails reached you, whether you opened them and which links you clicked. We never record this for security emails such as sign in codes, password resets and email verification.
- Conversations with Lumi: the questions you ask the in-product assistant, its replies, the workspace records it looked up to answer, and any rating or note you leave on a reply.
- Website chats with Lumi: the questions you ask Lumi on this website and its replies. We link them only to a random id in a browser cookie, not to your name. If you ask us to follow up, we also keep the name, email and details you leave, as an enquiry.
Lumex™ Surveyor app data
04 How we use your data
We use your data for the purposes below, and each purpose has its own legal basis. Where we rely on consent, your consent is explicit, granular, purpose-bound and revocable, and you can withdraw it at any time without affecting processing already carried out.
| What we do | Why | Legal basis (GDPR / UK GDPR) |
|---|---|---|
| Create and run your workspace, compute assessments, generate reports | To deliver the service you signed up for | Performance of a contract |
| Manage your team, roles and access | So the right people can use your workspace | Performance of a contract |
| Take payment and issue invoices | To bill you and meet tax law | Performance of a contract; legal obligation |
| Provide support and answer your messages | To help you use the product | Performance of a contract |
| Answer website chat and follow up the enquiries you leave there | Legitimate interests; steps at your request before a contract | |
| Legitimate interests. You can object at any time with the unsubscribe link in every outreach email, or by writing to privacy@lumex.zone | ||
| Keep the platform secure, prevent fraud, maintain the audit trail | To protect your data and ours | Legitimate interests; legal obligation |
| Improve the product from usage patterns | To make the service better | Legitimate interests |
| Send service-related messages about your account | So you know about billing, security and changes | Performance of a contract |
| To fill in site coordinates and add photos to your records | Performance of a contract, through the permission you give on your phone | |
| So you know when a report needs you or work is handed to you | Consent, which you give through your phone's notification prompt and withdraw with the app's notification switch | |
| To find and fix faults in the app | Legitimate interests | |
| Analytics on how the website and the portal are used, including masked session replay on this website and in the portal | To understand what is useful and where people get stuck | Consent for Google Analytics, Microsoft Clarity and PostHog cookies in the European Economic Area, the United Kingdom and Switzerland, and wherever we cannot tell your country. Elsewhere, legitimate interests for all three, which you can switch off at any time from Cookie settings. A choice you save always wins over this default |
| Product analytics on this website and in the signed-in customer portal | To see which pages and features are used | Consent when you allow analytics, which in the portal links the data to your user account. Legitimate interests when you do not, for counts of page views and product events with no cookies, nothing stored in your browser and no user profile |
| To see which screens and inspection steps are used, and where syncing fails | Consent in the European Economic Area, the United Kingdom and Switzerland, and wherever we cannot tell your country: the app sends nothing until you allow it. Elsewhere, legitimate interests, which you can switch off at any time in the app's Settings. A choice you save always wins | |
| Measure the opens and clicks of our lifecycle and marketing emails, and tag the links in all our emails with the email's name | To see which emails help and to send fewer that do not | Legitimate interests, which you can stop with the unsubscribe link in any of these emails. Security emails are never measured |
| Keep records the law requires us to keep | Tax, accounting and statutory obligations | Legal obligation |
Where we rely on legitimate interests, we have weighed those interests against your rights and you can object at any time by writing to privacy@lumex.zone.
05 How we share your data
We share data only as needed to run the service: within your workspace, according to the role each team member holds; with the sub-processors listed below, who act on our instructions under written confidentiality and data-processing agreements; and where required by law or to protect our rights. If Webority is involved in a merger or acquisition, data may transfer under the same protections.
| Sub-processor | What it does | Where |
|---|---|---|
| Microsoft Azure | Cloud hosting, database and file storage | India |
| Microsoft Azure AI | United States | |
| Razorpay | Payment processing | India |
| Zoho Books (Zoho) | Accounting: receives a copy of each invoice we issue, with the billing details on it | India |
| Invoice Registration Portal (IRP) | Registers the GST e-invoices we issue to customers in India, as Indian tax law requires | India |
| SendGrid (Twilio) | Email delivery. For our lifecycle and marketing emails, it also records when you open one, through a tracking pixel, and which links you click, through its own link addresses. It does neither for security emails such as sign in codes, password resets and email verification | United States |
| Google Firebase (Crashlytics, Cloud Messaging) | United States | |
| Apple Push Notification service | United States | |
| Cloudflare | Content delivery and security filtering in front of the website and the portal. Every request passes through it. It also reads the country of your connection to set the wui_region cookie, which holds no identifier | Worldwide edge network |
| Google reCAPTCHA | Checks that a website form or chat message comes from a person, not an automated script. Receives your IP address and browser details when you send one | United States |
| Microsoft 365 Bookings | Books the product demo you request: receives your name, email, phone number, company, time zone and any message you add | India |
| Google (Analytics 4, Tag Manager) | Website analytics, under your cookie choice | United States |
| Microsoft Clarity | Website analytics. It stays off until you opt in in the European Economic Area, the United Kingdom and Switzerland, and is on by default elsewhere until you turn it off. | United States |
| PostHog | United States | |
| Ahrefs | Cookieless website analytics. Sets no cookies and stores no identifiers on your device | Singapore |
| Apollo.io | United States |
We update this list, and the date at the top of this policy, before a new sub-processor starts handling your data. To object to a new sub-processor, write to privacy@lumex.zone. Analytics sub-processors receive usage data only. PostHog session replays are masked in your browser before they are sent, so no assessment or client data is readable in them.
We do not sell, rent or lease your personal data to anyone, and we do not use advertising cookies or cross-site tracking.
06 Where your data is stored
If you are in the European Economic Area or the United Kingdom, your data may be transferred to and processed in India, and Lumi's processing in the United States. Where a destination is not covered by an EU or UK adequacy decision, we rely on the European Commission's Standard Contractual Clauses (and, for UK data, the UK International Data Transfer Addendum), together with the technical and organisational safeguards described in section 08, as the legal basis for that transfer. A copy of the relevant clauses is available on request.
07 How long we keep your data
We keep each kind of data for a set period, then delete or anonymise it. Where the law requires us to keep something longer, the legal period wins.
| Data | How long we keep it |
|---|---|
| Projects, sites, assessments, inspections, reports, photos, documents and clients | For the life of the workspace, then deleted 90 days after the workspace is closed |
| Conversations with Lumi | For the life of the workspace, then deleted 90 days after the workspace is closed. |
| Website chats with Lumi | 180 days after your last message, then deleted |
| Your user profile and sign-in history | While you belong to a workspace. When your last workspace is deleted, sign-in is turned off and the profile is kept so an invitation can bring you back. You can ask us to erase it at any time. |
| Invoices, tax records and the billing details on them | 8 years, as required by Section 36 of the CGST Act, even after the workspace is deleted |
| Your phone's push registration (push token and installation id) | Until you turn off notifications in the app or sign out, or until the push service tells us the token no longer works. It is deleted with your workspace's data at the latest. |
| Audit trail and security logs | 12 months. We keep records of billing actions, such as refunds and invoice corrections, for 8 years with the invoices they explain. |
| Support tickets and correspondence | 24 months |
| Backups | 35 days on a rolling cycle, after which they are overwritten |
The 90-day window after closure lets us restore a workspace closed by mistake. Contact support before the deletion date and we will bring it back. We email the workspace's admins when deletion is scheduled, again seven days before, and once it is done. A workspace left on the read-only plan for 12 months after its subscription ends is closed in the same way, after a warning email 30 days before. Deletion requested through Data Deletion is actioned sooner, subject only to the statutory records above.
08 Security
We protect your data with TLS 1.2 or later in transit, AES-256 at rest, role-based access controls, workspace isolation and an append-only audit log of sensitive actions. No system can be guaranteed perfectly secure, but we work continuously to protect your information.
If a personal data breach occurs, we will tell you without undue delay once we become aware of it, with what we know about the nature of the breach, the categories and approximate number of records affected, the likely consequences, and the steps we are taking. Where you are the controller and we are your processor, that notice is what lets you meet your own reporting deadline. We notify supervisory authorities where the law requires it.
09 Your rights & how to use them
Subject to applicable law, you can access your data, correct it, request its erasure, withdraw consent, nominate a representative, and raise a grievance. To exercise any right, email privacy@lumex.zone; we aim to respond within 7 days. To request erasure, see Data Deletion.
10 Cookies
We use strictly-necessary cookies to keep you signed in and the site working, and preference cookies to remember your choices. We also use analytics cookies to measure how the site is used, through Google Analytics 4, Google Tag Manager, Microsoft Clarity and PostHog, governed by Google Consent Mode and our cookie banner. In the European Economic Area, the United Kingdom and Switzerland, Google Analytics, Microsoft Clarity and PostHog cookies stay off until you opt in, and the same applies if we cannot tell your country. Without that consent, PostHog still counts page views, clicks and scrolling for heatmaps, and page errors, but sets no cookie and records no replay. Elsewhere, all three are on by default, and you can turn them off at any time. Marketing stays off until you choose it. A choice you save always wins over the regional default. We set an essential cookie, wui_region, for one day to record which of these two groups your connection falls in. It holds no identifier. Wherever you are, you can change your choice at any time from the Cookie settings link in the footer. Google's advertising signals (ad storage, ad user data and ad personalisation) are always denied on this website and in the customer portal, whatever you choose. We additionally use Ahrefs, a cookieless analytics tool that sets no cookies. The Contact page can show a Google Maps view of our office. The map loads only when you choose Show the map, and then Google receives your IP address and may set its own cookies. When you send a form or a chat message, Google reCAPTCHA checks that it comes from a person. We do not use advertising cookies to build profiles or to track you across unrelated websites. Our lifecycle and marketing emails use a tracking pixel and tracked links, and our security emails use neither. Full detail, including how we measure emails, is in our Cookie Policy.
11 The Lumex™ Surveyor app
- Location: the app reads your phone's precise location once, when you tap to fill in a site's coordinates or when you start an inspection visit. It never reads your location in the background. The coordinates are saved with the assessment or the inspection, in your workspace.
- Camera and photos: the app opens your camera or your photo library only when you add a photo. It uploads only the photos you choose. The app takes photos only and never records sound.
- Records kept on your phone: the app keeps your inspection visits and assessment drafts on your phone until it can send them to us.
- Push notifications: after you sign in, the app asks to send you notifications. If you allow them, your phone gives the app a push token. The app sends us that token and a random id for this installation, and we store them against your account. We use them only to tell you when a report needs you or work is handed to you. On Android, Google Firebase Cloud Messaging delivers each notification. On iPhone and iPad, Apple delivers it.
- Crash reports: when the app crashes or meets an error, it sends a report to Google Firebase Crashlytics. The report holds the error, the steps the app recorded before it, your device model and its operating system version. The app does not add your name, email or account to the report.
- Product analytics: if you allow analytics, the app sends PostHog the screens you open and the inspection steps you complete, such as starting an inspection, saving a reading, adding a photo or a defect, handing over and syncing. It also sends when a sync fails. Events carry counts and types only, never your readings, comments, photos or anything you type, and they are linked to your user account and workspace by random ids. In the European Economic Area, the United Kingdom and Switzerland, and wherever we cannot tell your country, the app asks first and sends nothing until you allow it. Elsewhere it is on until you turn it off. You can change your choice at any time with the Analytics switch in the app's Settings.
The app contains no advertising tools, and it does not track you across other apps or websites.
No marketing by push. The app's notifications are about your work only. We do not send marketing or promotional messages by push notification.
How to withdraw permission. You can turn off location, camera or photo access at any time in your phone's settings. To stop notifications, turn off Push notifications in the app's Settings. We then delete your phone's push registration. We also delete it when you sign out. Turning off a permission does not delete records you have already saved to your workspace.
12 Children
13 Users in the EEA & UK (GDPR)
If you are in the European Economic Area or the United Kingdom, you have the rights granted under the GDPR / UK GDPR: access, rectification, erasure, restriction of processing, data portability, objection, and the right not to be subject to a decision based solely on automated processing that produces legal or similarly significant effects. The legal bases in section 04 describe how and why we process your data, and section 06 describes how we safeguard international transfers. You can withdraw consent at any time without affecting processing already carried out.
You also have the right to lodge a complaint with your supervisory authority. If you are in the EEA you can find yours via the European Data Protection Board; in the UK, the Information Commissioner's Office (ICO).
14 California residents (CCPA)
If you are a California resident, you have the right to know what personal information we collect, to request its deletion, and to opt out of any "sale" of personal information. We do not sell your personal information. We will not discriminate against you for exercising these rights.
15 Changes to this policy
We may update this Privacy Policy from time to time. We give at least 15 days' notice before any material change takes effect, and the "Last updated" date above always reflects the current version.
16 Grievance Officer & contact
In line with the Information Technology Act, 2000 and the DPDP Act, 2023, our Grievance Officer is Mr. Navneet Singh. Write to him at grievanceofficer@lumex.zone or privacy@lumex.zone, at Webority Technologies Private Limited (CIN: U72900HR2019PTC079747), 629-634, Vipul Trade Centre, Sohna Road, Sector 48, Gurugram, Haryana 122018, India.