1. Introduction
Lumin Incorporated (“Lumin”, “we”, “us”, “our”) is committed to protecting the privacy of every visitor who accesses lumin.co.za (“the Site”) and any person who subscribes to our newsletter. This Policy explains how we collect, use, disclose, secure and retain your personal information in accordance with South Africa’s Protection of Personal Information Act 4 of 2013 (“POPIA”).
2. Scope
This Policy applies to all processing of personal information obtained through the Site or any associated sign‑up form where you voluntarily provide your details to receive our newsletter or other marketing communications.
3. What Personal Information We Collect
| Category | Typical items | Source |
|---|---|---|
| Contact details | Name, surname, e‑mail address | Directly from you via the newsletter form |
| Interaction data | Date/time of subscription, confirmation of opt‑in, e‑mail engagement metrics (opens, clicks) | Automatically generated by our e‑mail platform |
| Technical data (cookies) | IP address, browser type/version, pages visited | Collected through cookies if you consent |
We do not knowingly collect special‑category information (e.g. health or biometric data) or children’s information through this service.
4. Why We Collect and Use Your Information
| Purpose | POPIA basis |
|---|---|
| To send you our electronic newsletter and related updates | Consent (sections 11 & 69) |
| To manage your subscription, including confirmations, preference changes and unsubscribes | Consent |
| To improve content through aggregated analytics | Legitimate interest in optimising our communications, while respecting your privacy |
5. How We Share Information
Your data is kept confidential. We only share it with:
Service providers that help us distribute e‑mails or host the Site. They act on our instructions and must implement POPIA‑level safeguards.
Authorities or regulators if required by law or to protect our rights.
We never sell your data, and any cross‑border transfer will occur only where the recipient country affords a level of protection equal to or better than POPIA (section 72).
6. Security Safeguards
We apply appropriate technical and organisational measures—such as SSL encryption in transit, access controls and regular security testing—to protect the integrity and confidentiality of your information web-hosting-rsa.co.za.
7. Retention
We keep your contact details only for as long as you remain subscribed plus a further 12 months to evidence compliance with POPIA’s auditing obligations, after which they are securely deleted or anonymised.
8. Your POPIA Rights
As a data subject you may:
Request access to the personal information we hold;
Ask for correction or deletion of inaccurate, irrelevant or excessive data (section 24) popia.co.za;
Object to or restrict processing in certain circumstances;
Withdraw consent to direct marketing at any time (every newsletter contains an unsubscribe link);
Lodge a complaint with the Information Regulator (see §9).
We will respond within a reasonable time and, where required, within the timelines prescribed by POPIA.
9. Queries & Complaints
Information Officer
Lumin Incorporated
[Add physical address]
E‑mail: privacy@lumin.co.za
Tel: +27 (0) [add number]
Information Regulator – South Africa
JD House, 27 Stiemens St, Braamfontein, Johannesburg, 2001
Tel: +27 10 023 5200
E‑mail: enquiries@inforegulator.org.za inforegulator.org.za
10. Cookies
We use minimal, non‑intrusive cookies to understand site traffic and improve performance. You can refuse cookies in your browser settings; doing so will not affect your access to the newsletter sign‑up form.
11. Direct Marketing & Opt‑Out
By ticking the consent box and confirming your subscription, you choose to receive marketing e‑mails from Lumin. You can opt out at any time by:
Clicking “Unsubscribe” in any newsletter; or
Contacting us at privacy@lumin.co.za.
We will honour your opt‑out promptly and cease marketing within a reasonable period, as required by POPIA sections 11(3) & 69 popia.co.za.
12. Changes to This Policy
We may update this Policy from time to time. The latest version will always be posted on the Site with the “Last updated” date. Material changes will be communicated via e‑mail where feasible.
13. Acceptance
By supplying your personal information and clicking “Subscribe”, you confirm that:
You have read and understood this Policy;
You are 18 years or older (or have appropriate parental consent);
You consent to the processing of your personal information as set out above.
If you disagree, please do not subscribe.