Luminelle - Shopify Coding Agent

Effective Date: January 15, 2025

This Privacy Policy ("Policy") describes how Qatana Technologies GmbH, headquartered at Hofzeile 10–12/10/9, 1190 Vienna, Austria, operating under the name Luminelle ("Luminelle","Luminelle Ai", "we", "us", or "our"), collects, processes, stores, and protects personal data when you access our website luminelle.xyz and related services (collectively referred to as the "Services").

Please note that this Privacy Policy does not apply to personal data we process on behalf of our business customers (“Customers”) pursuant to a separate service agreement and data processing agreement. In such cases, Luminelle acts as a data processor (or service provider) and processes personal data solely in accordance with the Customer’s instructions. The relevant Customer remains the data controller as defined under applicable data protection laws. Our obligations in such scenarios are governed by the specific contractual terms agreed with each Customer and are not addressed in this Privacy Policy. If you are an end user of a Luminelle Customer and have questions regarding the processing of your personal data, please contact the respective Customer directly.

1. Controller Under GDPR

Qatana Technologies GmbH
Hofzeile 10–12/10/9
1190 Vienna, Austria

2. Collected Data

a) Data You Provide

We collect personal data when you:

Register or create an account
Complete forms on our website
Communicate with our support team
Actively use our Services

This may include:

First and last name
Email address
Company name
Payment information (processed via third-party providers such as Stripe)
Additional optional information (e.g., phone number, job title)

b) Data Collected Automatically

IP address, device information, browser type and version, operating system
Access times and visited pages
Interaction data within the CRM application
Cookies and tracking technologies (see Section 5)

c) Data from Third-Party Services

When you integrate Luminelle with third-party tools (e.g., Google Workspace), we may access certain data (e.g., email metadata, contacts) strictly in accordance with the respective API permissions and under Google's API Services User Data Policy (including Limited Use requirements).

d) Disclosure of Information to Outside Parties

We do not sell, trade, or otherwise disclose your personal data, except as outlined in this Privacy Policy. This excludes trusted third-party service providers who support the operation of our website, delivery of our Services, or other legitimate business functions, provided such parties are contractually bound to maintain the confidentiality and security of your information. We may also disclose your personal data where required by law, to enforce our legal agreements and policies, or to protect the rights, property, or safety of Luminelle, our users, or others.

3. Purposes of Processing

To provide and operate the CRM platform
To personalize your user experience
To offer customer service and support
To analyze product usage, detect bugs, and improve the Services
To comply with legal obligations and ensure security
For marketing purposes (only with your explicit consent)

Legal bases under GDPR include Art. 6(1)(a), (b), and (f) GDPR.

4. Data Sharing

We do not sell your personal data. We only share your data under the following circumstances:

With trusted service providers, such as:
- Payment processors (e.g., Stripe)
- Infrastructure providers (e.g., AWS, Shopify)
- Analytics services (e.g., Google Analytics, Matomo – if enabled)
When required by law or in response to legal obligations
To enforce legal rights or protect against fraud
In connection with corporate restructuring, such as mergers or acquisitions
With your explicit consent

5. Cookies and Tracking Technologies

Ensure the technical functionality of our website
Analyze user behavior
Serve personalized content and marketing (only with consent)

You can manage your cookie preferences at any time via our cookie banner. For further details, please refer to our Cookie Policy.

6. Data Retention

We retain your data only as long as necessary for the purposes outlined in this Policy, specifically:

For the duration of your active account or subscription
As required to fulfill legal retention obligations (e.g., accounting laws)
Until you withdraw your consent or object to processing

7. Your Rights Under the GDPR

Access the personal data we hold about you (Art. 15 GDPR)
Rectify inaccurate or incomplete data (Art. 16 GDPR)
Erase your personal data ("right to be forgotten", Art. 17 GDPR)
Restrict the processing of your data (Art. 18 GDPR)
Object to data processing (Art. 21 GDPR)
Receive your data in a structured, commonly used, and machine-readable format (Art. 20 GDPR)
Withdraw your consent at any time (Art. 7(3) GDPR)

8. Data Security

We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss, or manipulation, including:

SSL encryption
Access control and monitoring
Regular security audits and infrastructure reviews

Nevertheless, please note that no method of data transmission over the Internet is 100% secure.

9. International Data Transfers

We generally store and process your data within the European Economic Area (EEA). In cases where data is transferred outside the EEA, we ensure adequate protection through:

EU Standard Contractual Clauses
Equivalent safeguards in accordance with Articles 44 et seq. GDPR

10. Changes to This Policy

We may update this Privacy Policy from time to time. In case of significant changes, we will notify you via email or through notices on our website. The latest version will always be available at luminelle.xyz/privacy.

11. Google Integrations and Third-Party Data

Google Workspace Integration

Luminelle offers integration with Google Workspace (including Gmail, Google Calendar, and related services) to enable specific CRM functionality. In doing so, we may access certain information associated with your Google account, such as metadata, calendar events, or contact details—strictly limited to the scope of your authorization.

Our use and transfer of data obtained from Google APIs fully comply with the Google API Services User Data Policy, including the Limited Use requirements. We do not use this data to train, develop, or improve generalized AI or machine learning models. All data access is restricted to what is necessary to deliver the requested functionality within the Luminelle Services.

Other Third-Party Data Sources

We may also receive supplementary information, including statistical, technical, or demographic data, from reputable third-party sources such as analytics providers, marketing platforms, or business partners. This data may be associated with your user profile to help us better understand user behavior, personalize your experience, and improve our Services and communications.

12. Contact Information

If you have any questions about this Privacy Policy or your data, please contact us.