1. Data Controller
For data collected directly by this Site (purchase records, learning progress, support e-mails), the controller is:
- Jing Lu, OSVČ, trading as Lume Studio
- IČO: 29611911
- Address: Italská 2304, 272 01 Kladno - Kročehlavy
- Contact: [email protected]
Where Managed Payments applies to your transaction, the seller of record is Sold through Link, LLC. Your payment and transaction data are processed by Stripe and its affiliated entities as independent controllers, for their own payment, tax, fraud-prevention and compliance purposes; we do not direct or control that processing. The transaction is carried out through Link, Stripe's payment service. Your receipt email contains a link that lets you associate the transaction with a Link account; creating or using a Link account is optional and is not required in order to buy from us. We do not receive or store your full payment card details.
2. What We Collect
We do not operate a self-service account/password system. After Stripe confirms your payment, we send you access to your Course by e-mail (e.g., an access link). We collect:
- E-mail address: provided at checkout via Stripe, used to deliver and re-send your Course access.
- Purchase data: which Courses you bought and your access status. (Card/payment details are collected and stored by Stripe, not by us.)
- Learning data (if applicable): progress, exercise responses, and usage within Courses, used to show your learning progress and improve content.
- Technical data: anonymized, host-level traffic statistics only — see §6. We do not collect analytics data tied to you individually.
- Communications: messages you send us for support, and, if you opt in, marketing e-mails (e.g., waitlist sign-up).
3. Why We Process Your Data (Legal Basis)
- Contract performance (Art. 6(1)(b) GDPR): delivering your purchased Course access by e-mail, providing customer support.
- Legal obligation (Art. 6(1)(c)): bookkeeping/tax records as required of Lume Studio as OSVČ.
- Consent (Art. 6(1)(a)): marketing e-mails (e.g., waitlist sign-up) — you can withdraw consent at any time.
- Legitimate interest (Art. 6(1)(f)): keeping the Site secure, improving Course content based on aggregated, anonymized usage.
4. How Long We Keep Data
We retain your purchase and learning data for as long as needed to provide you Course access and support, plus a reasonable period afterward for legal/accounting purposes. Bookkeeping records are kept for the period required by Czech law. You may request earlier deletion — see §7.
5. Who We Share Data With (Processors / Recipients)
| Purpose | Party | Notes |
|---|---|---|
| Payments, billing, invoicing, indirect tax | Stripe and its affiliated entities | Independent controllers for payment and transaction data. Where Managed Payments applies, the seller of record is Sold through Link, LLC and the transaction is carried out through Link; associating the transaction with a Link account is optional |
| Hosting / CDN | Cloudflare, Inc. | Hosts the Site and app assets; provides anonymized, host-level traffic statistics (see §6) |
| E-mail / marketing | MailerLite | Waitlist and course-related e-mails, if you opt in |
| Analytics | — | We do not use any third-party analytics tool or non-essential cookies. Site-wide traffic is only measured through Cloudflare's anonymized, host-level statistics. |
We do not sell your personal data. We only share data with the parties above (and legal authorities where required by law).
6. Cookies
We only use strictly necessary cookies — those required for the Site to function, such as maintaining your session and handing off to Stripe's checkout. We do not use any non-essential cookies, and we do not use cookies for analytics or advertising. Cloudflare Web Analytics, used for our own aggregate traffic statistics, is cookie-free by design and does not set any cookies in your browser. Because we use only strictly necessary cookies, no cookie-consent banner is required under applicable law; this section serves as our required disclosure.
7. Your Rights (GDPR)
As an EU/Czech data subject, you have the right to: access your data; request correction; request erasure; restrict or object to processing; data portability; and withdraw consent at any time without affecting prior lawful processing. You may also lodge a complaint with the Czech Office for Personal Data Protection (Úřad pro ochranu osobních údajů, uoou.cz).
To exercise these rights, contact: [email protected]
8. International Transfers
Some of our processors (e.g., hosting/e-mail providers) may process data outside the EU/EEA. Where this occurs, we rely on appropriate safeguards such as Standard Contractual Clauses or an adequacy decision.
9. Children
Courses are not directed at children under 16 without parental consent. If you believe a child has provided us data without appropriate consent, contact us to have it removed.
10. Changes
We may update this Privacy Policy; material changes will be reflected by an updated "Last updated" date.