Privacy Policy

1. Introduction

This Privacy Policy explains how Lumina Spark ("we," "us," "our"), a sole proprietorship based in Osaka, Japan, collects, uses, discloses, and protects your personal information in connection with our website (luminasparkdesign.com), digital products, and related services (collectively, the "Services").

We are committed to complying with applicable data protection laws, including the EU General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA/CPRA), and Japan's Act on the Protection of Personal Information (APPI).

If you have questions, contact us at: contact@luminasparkdesign.com

2. Definitions

"Personal Information" refers to any information that identifies or can identify an individual, including:

• Identity data: name, company name, job title
• Contact data: email address, phone number, postal address
• Technical data: IP address, browser type, device identifiers, operating system
• Usage data: pages visited, session duration, interaction logs
• Transaction data: order IDs, license keys (payment card details are processed by our Merchant of Record and not stored by us)

3. Data We Collect and Lawful Basis

Data Category	Purpose	Lawful Basis (GDPR)
Contact form submissions	Respond to inquiries	Legitimate interest / Contract
Purchase & license data	Order fulfillment, licensing	Contract performance
Analytics data	Improve our Services	Legitimate interest / Consent
Cookies (non-essential)	Personalization, advertising	Consent
Early access email signups	Product launch notifications	Consent

4. Payment Processing — Merchant of Record

Lemon Squeezy, LLC (a Stripe company) acts as our Merchant of Record for all digital product transactions. This means:

• Lemon Squeezy handles payment processing, invoicing, tax collection, and remittance on our behalf.
• Your payment card details are collected and stored by Lemon Squeezy — not by Lumina Spark.
• Lemon Squeezy issues your receipt, manages chargebacks, and processes refund requests.

For Lemon Squeezy's privacy practices, see: lemonsqueezy.com/privacy

5. Cookies and Tracking Technologies

We use the following types of cookies and similar technologies:

• Essential cookies: Required for site functionality (e.g., session management). Cannot be disabled.
• Analytics cookies: Google Analytics 4 (GA4) with anonymized IP addresses, to understand traffic patterns.
• Advertising cookies: Remarketing (Google Ads, Meta Ads) for targeted advertising. Only set with your consent.

You can manage or refuse non-essential cookies through your browser settings. Disabling analytics cookies will not affect your ability to use our Services.

6. Third-Party Service Providers

We share limited personal information with the following trusted third parties, each bound by their own privacy policies:

• Lemon Squeezy, LLC — Payment processing (Merchant of Record)
• Google LLC — Analytics (GA4), advertising (Google Ads), Chrome Web Store distribution
• Meta Platforms, Inc. — Advertising (Meta Ads) — only if you consent to advertising cookies
• Cloud hosting providers — Website and email infrastructure

We do not sell your personal information to any third party.

7. International Data Transfers

Our Services are operated from Japan. If you access our Services from outside Japan, your information may be transferred to, stored, and processed in Japan or other countries where our service providers operate. For transfers from the EU/EEA, we rely on appropriate safeguards, including Standard Contractual Clauses (SCCs) approved by the European Commission.

8. Your Rights

Under GDPR (EU / EEA / UK residents)

• Right of access: request a copy of your personal data
• Right of rectification: correct inaccurate or incomplete data
• Right of erasure ("right to be forgotten")
• Right to restrict processing
• Right to data portability
• Right to object to processing (including direct marketing)
• Right to withdraw consent at any time without affecting lawfulness of prior processing
• Right to lodge a complaint with your local supervisory authority

Under CCPA / CPRA (California residents)

• Right to know what personal information is collected about you
• Right to delete personal information
• Right to opt-out of the sale or sharing of personal information (we do not sell your personal information)
• Right to correct inaccurate personal information
• Right to non-discrimination for exercising these rights

Under APPI (Japan)

• Right to disclose, correct, or delete your personal data
• Right to stop use or stop provision of your personal data

To exercise any of these rights, email us at: contact@luminasparkdesign.com. We will respond within 30 days (GDPR) or 45 days (CCPA).

9. Data Retention

We retain personal information only as long as necessary for the stated purposes or as required by law:

• Contact inquiries: 2 years from last contact
• Purchase and license records: 7 years (tax and legal compliance)
• Analytics data: 26 months (Google Analytics default)
• Early access signups: until product launch + 12 months, or until you unsubscribe

10. Security

We implement industry-standard technical and organizational measures to protect your personal information, including HTTPS/TLS encryption, access controls, and regular security reviews. However, no system is entirely secure. In the event of a data breach affecting your rights and freedoms, we will notify you as required by applicable law.

11. Children's Privacy

Our Services are not directed to children under the age of 16 (or 13 in the US). We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us immediately and we will delete it.

12. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or applicable law. Material changes will be communicated via a notice on our website. The "Last Updated" date at the top of this page indicates the current version. Continued use of our Services after any changes constitutes acceptance of the updated policy.

13. Contact

For privacy-related questions, requests, or complaints:
Business Name: Lumina Spark
Operator: Lumina Spark (sole proprietor)
Location: Osaka, Japan
Email: contact@luminasparkdesign.com