Privacy Policy
Last updated 3 September 2026 ยท Effective 9 September 2026
LUMINA respects your privacy and handles personal data with care. This Privacy Policy explains what information we collect, why we use it, who may receive it, how long we keep it and which rights you have under the General Data Protection Regulation (GDPR) and other applicable privacy laws.
1. Who is responsible for your personal data?
The data controller is DD Agency, operating the LUMINA brand ("LUMINA", "we", "us" or "our").
Business address:
Dorpsstraat 36
1396 KK Baambrugge
The Netherlands
Dutch Chamber of Commerce (KvK): 27373641
VAT identification number: NL001856489B19
Privacy and general enquiries: [email protected]
Customer support and returns enquiries: [email protected]
2. To whom does this Policy apply?
This Policy applies when you visit our website, join a waiting list, subscribe to our emails, contact us, purchase or participate in a LUMINA offering, use our Kajabi course and community environment, attend a Live Online Circle, or upload photographs, artwork, reflections or other content.
LUMINA offerings are intended for adults aged 18 and over. We do not knowingly collect personal data from children.
3. Personal data we collect
3.1 Information you provide
Identity and contact data, such as your name, email address, telephone number if provided, billing address and shipping address.
Purchase and account data, such as the offer purchased, payment status, invoices, login details, access dates and customer-service history.
Course and participation data, such as course progress, community activity, answers to reflection questions and communications with LUMINA.
Creative uploads, such as photographs of your Body & Mind Map, artwork, written reflections and other files you choose to submit.
Live Online Circle data, including your display name, image, voice, spoken contributions, chat messages and attendance where a session is recorded.
Waiting-list and marketing preferences, including the choices you make about receiving LUMINA news and offers.
3.2 Information collected automatically
When you use our website or course platform, we and our service providers may receive technical and usage data, such as IP address, device and browser information, approximate location, login activity, pages viewed, course progress, cookie identifiers and diagnostic information.
3.3 Payment information
Payments are processed through Kajabi Payments and its relevant payment-service providers. LUMINA does not normally receive or store your full payment-card number. We receive transaction information needed to confirm and administer your purchase.
3.4 Sensitive information
Some voluntary reflections, artworks or spoken contributions may reveal information about health, sexuality, emotional wellbeing, spiritual beliefs or other sensitive aspects of your life. Please share only what you genuinely choose to share.
Where applicable, LUMINA processes special-category personal data on the basis of your explicit consent. You may withdraw that consent and request deletion by contacting us. Withdrawal does not affect processing that was lawful before withdrawal.
4. Why we use your personal data
We process personal data only when we have a lawful basis. Depending on the situation, we use it:
To perform our contract with you: processing orders and payments, creating your account, providing course and community access, shipping the Collection Box, supporting participation and responding to service requests.
To comply with legal obligations: maintaining tax and accounting records, handling statutory consumer rights, responding to lawful requests and meeting safety or regulatory duties.
For our legitimate interests: securing and improving our services, preventing misuse, keeping appropriate records, managing customer relationships and understanding general service performance, provided those interests do not override your rights.
With your consent: sending optional marketing, using non-essential cookies, processing sensitive information where required, or using a testimonial, image or recording for a purpose not necessary to deliver your purchase.
We do not use participant images, recordings, artwork or reflections for public marketing without separate, specific permission.
If you separately agree to provide a review or testimonial, LUMINA will use or publish only the name, words, image, social-media handle, artwork or Body & Mind Map material covered by that specific permission.
You may withdraw permission for future use at any time by contacting [email protected]. Withdrawal does not affect use that was lawful before withdrawal. LUMINA will remove the material from channels under its control within a reasonable period after withdrawal, unless another lawful basis applies.
5. Uploads, reflections and the Sister Space
Your private uploads are visible only to you and authorised members of the LUMINA team who need access to deliver or support the programme. They are not visible to facilitators or other participants unless you deliberately post something in a community area identified as shared.
Authorised team access may change as LUMINA grows, but access is limited to people working for or on behalf of LUMINA who need the information and are subject to confidentiality and data-protection obligations.
6. Live Online Circle recordings
Live Online Circle sessions are recorded. Participants may be visible and audible, and their name, image, voice, chat messages and contributions may appear in the replay. Camera-on participation is part of the Live Online format and is disclosed before purchase.
Recordings are made available only to authorised LUMINA team members and participants in the same Live Online Circle. They remain available for the applicable 12-month access period and must not be copied, downloaded, recorded, shared or published.
Recordings are not reused for a later circle or for marketing without a separate lawful basis and, where required, separate permission.
7. Who receives personal data?
We do not sell your personal data. We may share or make it available only where necessary to:
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Authorised LUMINA team members who administer the programme, provide customer support or fulfil Collection Box orders.
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Kajabi, which provides our website, course, community, account, email and platform-analytics services.
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Kajabi Payments and relevant banks or payment-service providers, which process transactions and help prevent fraud.
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DHL, which receives the information required to deliver or return a Collection Box.
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One.com, which hosts our business email service.
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Professional advisers, such as our accountant, lawyer or IT/security adviser, where reasonably necessary.
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Public authorities or courts where disclosure is legally required.
Service providers may use personal data only for the agreed services and in accordance with applicable data-protection requirements.
8. International transfers
Some providers, including Kajabi and payment or technology providers, may process data outside the European Economic Area. Where this occurs, we rely on an applicable adequacy decision, approved Standard Contractual Clauses or another lawful transfer safeguard.
You may contact us for further information about the safeguards relevant to your data.
9. How long we keep personal data
Purchase, invoice and accounting records: generally seven years, where required by Dutch tax and accounting law.
Course account, private creative uploads and reflections: for the 12-month access period and deleted or anonymised no later than three months after that period ends, unless an earlier deletion request applies or a legal obligation requires longer retention.
Live Online Circle recordings: available for the 12-month access period and then deleted or irreversibly anonymised, subject to reasonable technical backup cycles.
Waiting-list and marketing data: until you unsubscribe, withdraw consent, object to marketing or the relevant list is no longer used, after which minimal suppression data may be kept to honour your choice.
Customer-support correspondence: only as long as reasonably needed to resolve the request and protect legitimate legal interests.
10. Cookies and analytics
Our website and Kajabi environment use cookies and similar technologies required for security, login, checkout and platform operation.
Analytics or other non-essential cookies are used only where permitted and, where required, after you have made a cookie choice.
We do not currently intentionally use a Meta/Facebook advertising pixel.
You can review or change available cookie choices through the cookie settings on our website.
11. Marketing communications
We send marketing emails only where permitted, including where you have subscribed or otherwise requested updates.
You may unsubscribe at any time using the link in an email or by contacting us.
Service messages about an existing purchase, shipment, account or Live Circle are not marketing and may still be sent where necessary to perform our contract.
12. Security
We use reasonable technical and organisational measures designed to protect personal data against loss, misuse, unauthorised access, alteration or disclosure.
Access is limited according to role and need.
No internet service is completely risk-free, and we cannot guarantee absolute security.
13. Your privacy rights
Subject to the conditions and exceptions in applicable law, you may request:
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access to your personal data;
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correction of inaccurate or incomplete data;
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deletion of personal data;
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restriction of processing;
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data portability;
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objection to processing based on legitimate interests and an absolute objection to direct marketing;
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withdrawal of consent at any time; and
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information about relevant international-transfer safeguards.
Send requests to [email protected].
We may ask for information needed to verify your identity. We normally respond within one month, subject to any lawful extension.
You may also lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at www.autoriteitpersoonsgegevens.nl, or with the competent supervisory authority in your country of residence.
14. Automated decisions
LUMINA does not currently make decisions producing legal or similarly significant effects about you solely through automated processing.
15. Changes to this Privacy Policy
We may update this Policy when our services, providers or legal obligations change.
The current version and effective date will be published on our website.
Material changes will be communicated where required.
16. Contact
For privacy questions or requests, contact [email protected].
For customer-support or return questions, contact [email protected].
