Introduction At Owlira Ltd (trading as Lumora AI), we respect your privacy and are committed to protecting your personal data. This privacy policy explains how we collect, use, and safeguard your information when you use our website lumora-ai.com. This policy complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. By using this website, you agree to the collection, processing, and storage of your data as described in this policy. If you do not agree, please discontinue use of this website.

Data Controller Owlira Ltd, trading as Lumora AI, is the Data Controller for this website (). For any data protection enquiries, please contact: Data Protection Officer (DPO): Michelle Hazelton Owlira Ltd 15 Old Park Road, Sheffield, S8 7DS Email: team@lumora-ai.com

What Data We Collect and Why 3.1 Personal Data You Provide We may collect personal data when you: Make an enquiry via our website Enter a competition, promotion, or survey Subscribe to marketing communications Report a problem with our website Contact us via email or other means The personal data we collect may include: Name Address Company name Email address Telephone number We collect this data to respond to your enquiries, provide services, and communicate effectively. 3.2 Automatically Collected Data When you visit our website, we may collect: IP address Browser type and version Operating system Pages viewed and time spent on our website Traffic and location data This data is used for website functionality, analytics, and security monitoring. It does not directly identify individuals.

How We Use Your Data We process your data for the following purposes: To respond to your enquiries and requests To improve website functionality and user experience To notify you of changes to our services To conduct internal research and customer profiling To send marketing communications (with your consent) 4.1 Legal Basis for Processing We process your personal data under the following legal bases as required by UK GDPR: Contractual obligation: When you request services from us Legitimate interest: For improving services and analytics Consent: For marketing communications (you can withdraw this at any time) Legal compliance: If required to fulfil a legal obligation

Marketing Communications If you have made an enquiry, we may contact you with information about similar services unless you opt out. If you actively opt in, we may send you updates, offers, and promotions via email. You can unsubscribe at any time by contacting us at team@lumora-ai.com.

Your Rights Under UK GDPR Under UK GDPR, you have the right to: Access your personal data (Subject Access Request) Request correction of inaccurate data Request deletion of your data (“right to be forgotten”) Restrict processing of your data Object to processing based on legitimate interests or marketing Request data portability (receive your data in a commonly used format) To exercise any of these rights, please contact our Data Protection Officer (DPO) at team@lumora-ai.com.

Data Security We take appropriate technical and organisational measures to protect your data from unauthorised access, loss, or misuse. However, while we take security seriously, no internet transmission is completely secure, and we cannot guarantee the security of your data while it is being transmitted to our website. All stored data is kept on secure servers, and access is restricted to authorised personnel only.

Data Retention We only retain your personal data for as long as necessary to: Fulfil the purposes outlined in this policy Comply with legal or regulatory requirements Resolve disputes and enforce agreements We will securely delete data that is no longer required.

Data Transfers Outside the UK If we transfer personal data outside the United Kingdom (UK), we ensure adequate safeguards, such as: UK-approved Standard Contractual Clauses (SCCs) Data transfers to countries with an adequacy decision from the UK Government

Third-Party Disclosures We do not sell or rent your personal data. We will only share your data if: We have your explicit consent It is required for legal or regulatory reasons We engage trusted third-party service providers to support our business operations (e.g., IT support, marketing) All third parties handling personal data are required to comply with UK GDPR.

Cookies & Tracking Technologies This website uses cookies and similar tracking technologies to improve user experience, analyse website traffic, and enable targeted advertising. 11.1 What Are Cookies? Cookies are small text files stored on your device when you visit a website. They help improve site functionality, analyse user behaviour, and personalise content. 11.2 Types of Cookies We Use We use the following types of cookies: Essential Cookies (Strictly Necessary) These cookies are required for the website to function properly. They enable core functionality such as security, network management, and accessibility. These cookies do not require user consent and cannot be disabled. Performance & Analytics Cookies These cookies help us understand how visitors use our website, allowing us to improve functionality and optimise user experience. We use tools like Google Analytics to collect anonymised data, such as page visits and session duration. These cookies require user opt-in consent before being stored. Marketing & Advertising Cookies These cookies track user activity to deliver personalised advertisements and measure the effectiveness of marketing campaigns. They may be set by third-party providers (e.g., Google Ads, Facebook Pixel). These cookies require explicit opt-in consent. 11.3 Managing & Disabling Cookies You can accept or reject cookies at any time by: Adjusting your browser settings to block or delete cookies. Using our cookie banner to manage consent preferences. Opting out of Google Analytics tracking via Google Analytics Opt-Out. Please note that disabling some cookies may impact website functionality and user experience. For further details on our use of cookies and tracking technologies, please contact us at team@lumora-ai.com.

External Links Our website may contain links to third-party sites. We are not responsible for their privacy practices. Please review their policies separately.