Privacy Policy — Lummura

Effective date: June 20, 2026

This Privacy Policy explains how Lummura Systems LLC ("Lummura", "we", "us") collects, uses, discloses, and protects personal information when you visit lummura.com or use our products, including CityPMS and CityFlipper (collectively, the "Services").

If you are a tenant, homeowner, lead, or other individual whose information is uploaded to the Services by one of our customers (e.g., a property manager or HOA), that customer is the controller of your data and you should direct privacy requests to them. Lummura processes the information on their behalf.

1. Information we collect

You give us:

account and contact details (name, email, phone, company, role);
billing information (handled by our payment processor — we do not store full card numbers);
content you upload to the Services (listings, leases, residents, owners, vendors, leads, deals, notes, attachments);
communications you send us (support tickets, emails, survey responses).

Collected automatically:

usage and device data (IP address, browser, OS, pages viewed, timestamps, referrers);
log data and diagnostic information;
cookies and similar technologies — see the Cookie Policy.

From third parties:

single sign-on profile information (when you log in with Google or similar);
enrichment, public records, or MLS-style data feeds, where you have asked us to connect such sources;
service providers that help us run the business (analytics, email, hosting, anti-fraud).

We do not intentionally collect sensitive categories of personal information (such as government IDs, precise geolocation, biometric data, or health data) unless a Service feature requires it and you provide it.

2. How we use information

We use personal information to:

provide, operate, secure, and improve the Services;
create and manage your account, and authenticate users;
process payments, send invoices, and prevent fraud;
communicate with you about your account, updates, and support;
send marketing emails about Lummura products (you can unsubscribe at any time);
understand how the Services are used and build new features;
comply with legal obligations and enforce our Terms.

Legal bases (where GDPR/UK GDPR applies): performance of a contract, our legitimate interests (running and improving the Services, securing them, marketing our own products), compliance with legal obligations, and your consent where required.

3. How we share information

We do not sell personal information. We share it only as described below:

Service providers that process data on our behalf — hosting, database, email, analytics, error tracking, payment processing — under written agreements that restrict their use of the data.
Customer instructions. If you are an end user of a Lummura customer (e.g., a tenant on a CityPMS portal), we share data with that customer as the controller.
Integrations you enable (e.g., calendar, accounting, MLS, marketing tools). You control what is connected.
Legal and safety. We may disclose data when required by law, in response to lawful requests by public authorities, or to protect rights, property, or safety.
Business transfers. If Lummura is involved in a merger, acquisition, or sale of assets, information may be transferred subject to this Policy.

4. International transfers

Lummura is based in the United States. If you access the Services from outside the U.S., your information will be transferred to and processed in the U.S. and other countries that may have different data-protection laws. Where required, we use Standard Contractual Clauses or equivalent safeguards for cross-border transfers.

5. Retention

We retain personal information for as long as your account is active and as needed to provide the Services. After termination, we make Customer Data available for export for 30 days and then delete or de-identify it in the ordinary course, unless a longer retention period is required by law (e.g., tax records) or for legitimate business purposes (e.g., dispute resolution, fraud prevention).

6. Security

We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit (TLS), encryption at rest for primary data stores, access controls, audit logging, least-privilege role assignment, and regular backups. No system is perfectly secure; you are responsible for safeguarding your credentials and reporting suspected incidents to Info@Lummura.com.

7. Your privacy rights

Depending on where you live, you may have rights to:

access the personal information we hold about you;
correct inaccurate information;
delete your information ("right to be forgotten");
port your information to another service;
object to or restrict certain processing;
withdraw consent where processing is based on consent;
opt out of "sale" or "sharing" of personal information (we do not sell, and we do not engage in cross-context behavioral advertising);
lodge a complaint with your local data-protection authority.

To exercise these rights, email Info@Lummura.com from the address on file. We will respond within the time required by applicable law (typically 30–45 days). If your data was provided by a Lummura customer, we will route the request to them.

8. Children

The Services are not directed to children under 16, and we do not knowingly collect personal information from them. If you believe a child has provided us personal information, contact Info@Lummura.com and we will delete it.

9. Cookies and tracking

See the Cookie Policy for the categories of cookies we use and how to manage them. We honor Global Privacy Control signals where required by law.

10. Changes to this Policy

We will update this Policy from time to time. Material changes will be notified by email or in-product notice, and we will update the "Effective date" above. Continued use of the Services after the change takes effect constitutes acceptance.

11. Contact

Lummura Systems LLC 17350 State Hwy 249, Ste 220, Unit #32575 Houston, Texas 77064 Email: Info@Lummura.com