Lumenarc Privacy Policy
Version 1.0 · Last updated 6 November 2026
This policy explains how Response IQ Ltd, trading as Lumenarc, uses personal data. We are a company registered in England and Wales (company number 09951115) at 124 City Road, London EC1V 2NX ("Lumenarc", "we", "us").
Lumenarc provides AI-led product demos: a voice agent shows a product to a prospective buyer, answers their questions, and records the conversation for the seller.
1. Our two roles
When we are the controller. We decide how personal data is used, and this policy applies, for:
- visitors to lumenarc.ai and our other websites;
- people who take a demo of Lumenarc itself;
- people who use Lumenarc's apps on behalf of our customers (customer users);
- our own sales, marketing, support and billing contacts.
When we are a processor. Our customers use Lumenarc to give demos to their own prospects. For those demos the customer is the controller and we act on its instructions, under our Data Processing Agreement. The one exception is that we use demo recordings, transcripts and content to train and improve our own models and services and to check quality; for that use we are a controller, and section 3 applies. The customer's own privacy policy explains how it uses your data, and it is linked where you start the demo. If you have taken a demo on another company's behalf and want to use your data rights, contact that company; if you contact us instead, we will pass your request to them.
2. Data we process
The data we process table lists each kind of personal data, where it comes from, what it is used for, our role and how long we keep it. In short:
- Details you give us, such as your name, work email, job title and company, and what you say on a demo call.
- Recordings and transcripts of demo calls, with summaries and call analytics produced from them. Calls may be recorded and used for training and quality purposes (section 4).
- How you use the demo or site, such as pages viewed, clicks and a replay of the demo screen.
- Technical data, such as IP address, browser, device and logs.
- Account and billing data for customer users.
Where the data comes from
We collect data from you, from your use of our services, from our customers (for example a prospect list they upload), and from public sources. To make a demo relevant, we look up public information about the person and their company: the company's website, public professional profiles, search engines and web archives. This covers business details such as the company's name, logo, what it does, its size and where it trades, and the person's published name and role. We do not look up or infer nationality or any other special category data.
3. Why we use it and our lawful bases
| Purpose | Lawful basis |
|---|---|
| Providing our services to customers and their users, including accounts, support and billing | Legitimate interests: providing the service our business customer has bought to its staff and contacts. Contract, where you are personally our customer |
| Running a demo of Lumenarc and personalising it with public information | Legitimate interests: showing our product to business buyers in a way that is relevant to them |
| Recording a demo call and sharing the recording in your sales room | Consent, which you give when you opt in to the demo, before the call starts |
| Training and improving our AI models and services, and quality checks, using recordings, transcripts and demo content | Legitimate interests: making our demos better |
| Keeping the service secure, preventing abuse, diagnosing faults (including reviewing calls and logs), and improving the service | Legitimate interests |
| Telling business contacts about Lumenarc | Legitimate interests; you can opt out at any time |
| Analytics on our website and demos (see section 7) | Legitimate interests: understanding how the site and demos are used, so we can improve them |
| Meeting legal, tax and accounting obligations | Legal obligation |
You need to give us your work email to take a demo or open an account, and we cannot provide them without it. Other details, such as your job title, are optional.
Where we rely on legitimate interests, we have weighed them against your rights. You can object at any time (section 9).
4. AI and recordings
- You are talking to an AI. Demos are given by an AI voice agent, not a person. People at the seller and at Lumenarc may review the call later.
- Calls are recorded and may be used for training and quality purposes. You agree to the recording when you opt in to the demo. The audio and transcript go to the seller's sales room. Lumenarc may also use recordings, transcripts and demo content to train and improve its AI models and services, and to check quality.
- No automated decisions about you. We use AI to run and summarise the conversation, not to make decisions that have legal or similarly significant effects on you.
5. Who we share data with
- Our sub-processors and service providers, such as hosting, AI model, transcription, email and analytics providers. They act on our instructions under written contracts. The current list is at /subprocessors.
- Providers' own improvement. Under their own terms, some of these providers may also keep data they process for us and use it to improve their own models, for example our call transcription provider. Where they do, they are responsible for that use under their own privacy policies, linked from /subprocessors.
- The customer who gave the demo, who receives the recording, transcript and analytics.
- Integrations a customer connects, such as its CRM, when it asks us to send data there.
- Professional advisers, authorities and courts, where the law requires it or to defend legal claims.
- A buyer or investor in a sale, merger or restructuring of our business, under confidentiality.
We do not sell personal data.
6. International transfers
Some providers process data outside the UK. When data leaves the UK or the EEA for a country without an adequacy decision, we use the UK International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses, and the EU Standard Contractual Clauses for EEA data, or another safeguard the law allows, such as the UK-US data bridge. The sub-processor list shows where each provider processes data. You can ask us for a copy of the safeguard.
7. Cookies and similar technologies
A cookie is a small text file placed on your device when you visit a website. We and our providers use cookies and similar technologies, such as local storage and tracking scripts, to:
- make the site and demos work, for example keeping you signed in and keeping them secure;
- measure how the site and demos are used, including which pages are viewed, what is clicked, and a replay of the demo screen, so we can improve them and fix faults;
- understand which of our marketing reaches people.
Our analytics and error-monitoring providers are listed at /subprocessors; some of them set their own cookies.
You can block or delete cookies in your browser settings. If you block them, some features of the site or demos may stop working. For more information about cookies and how to control them, see the Information Commissioner's guidance at ico.org.uk/for-the-public/online/cookies.
8. How long we keep data
We keep data only as long as we need it for the purposes above, then delete or anonymise it. The periods are in the data we process table. When a customer's subscription ends, we delete its data as set out in our Terms of Service.
9. Your rights
You can ask us to:
- give you a copy of your data;
- correct it;
- delete it;
- restrict or object to how we use it, including for direct marketing (always free and always honoured);
- send it to you or another organisation in a reusable format;
- withdraw consent, where we rely on consent. Withdrawing does not affect processing we carried out before you withdrew.
Email privacy@lumenarc.ai. We will reply within one month. If a request is complex we may extend this by up to two more months and will tell you why. We do not charge, unless a request is manifestly unfounded or excessive. We may ask for information to confirm your identity, such as replying from the email address we hold; we will not ask for copies of your passport or other ID documents unless there is no other reasonable way to confirm who you are.
If a customer is the controller for your data (section 1), we will pass your request to them and help them answer it. For our own use of that data for training and quality, we are the controller and will answer that part of your request ourselves.
You can also complain to the Information Commissioner's Office (ico.org.uk, 0303 123 1113). We would appreciate the chance to deal with your concern first.
10. Security
We protect personal data with technical and organisational measures that suit the risk, including encryption in transit and at rest, access controls, and logging. No system is completely secure; if a breach affects you and the law requires it, we will tell you.
11. Contact
Our data protection contact is Scott Lee. Email privacy@lumenarc.ai, or write to Response IQ Ltd (Lumenarc), 124 City Road, London EC1V 2NX.
12. Changes
We review this policy when our services change. The version and date at the top show the current version. If we make a material change, we will email our customers and show a notice on our site before it takes effect.
Data we process
Version 1.0 · Last updated 6 November 2026
This table is kept separate from the legal text so we can update it without rewriting the policies. The Privacy Policy and the Data Processing Agreement both refer to it.
"Our role" says who decides how the data is used. Controller: Lumenarc decides. Processor: our customer decides and Lumenarc acts on its instructions.
| Data | Whose | Where it comes from | What it is used for | Our role | Kept for |
|---|---|---|---|---|---|
| Contact details: name, work email, job title, company | Prospects taking a customer's demo | The prospect, or the customer (for example from its CRM or a campaign list) | Running and personalising the demo, and sending the demo link and summary | Processor | 24 months from last contact |
| Public information about the person and their company: company name, website, logo, what it does, size, where it trades; the person's published name and role | Prospects | Public sources: company websites, public professional profiles, search engines and web archives | Personalising the demo | Processor for customer demos; controller for Lumenarc's own demos | 24 months from last contact |
| Call audio | Prospects | The demo call | Running the conversation, the recording in the customer's sales room, transcription; training and improving Lumenarc's models and services, and quality checks | Processor for the customer's purposes; controller for training and quality, and for Lumenarc's own demos | 24 months, including for training |
| Transcripts, summaries, call notes and call analytics | Prospects | Generated from the call | The customer's sales room and reports; diagnosing faults; training and improving Lumenarc's models and services, and quality checks | Processor for the customer's purposes; controller for training and quality, and for Lumenarc's own demos | 24 months, including for training |
| Demo interaction data: pages viewed, clicks, session replay of the demo screen | Prospects and website visitors | The browser, through our own code and analytics tools | Showing the demo, reports for the customer, fixing faults | Processor for customer demos; controller on Lumenarc's own site and demos | 13 months |
| Technical data: IP address, browser, device, approximate region, logs | Everyone who uses the service or site | The browser and our servers | Security, routing calls to the nearest region, error monitoring | Controller | Logs 30 days; analytics 13 months |
| Customer account data: names, work emails, sign-in records, team, settings | Customer users | The customer user | Providing accounts, support and billing | Controller | For the life of the account, then 30 days |
| Content the customer uploads: website captures, scripts, documents, product media | Customers (may include personal data about the customer's staff) | The customer | Building and running the customer's demos; training and improving Lumenarc's models and services, and quality checks | Processor for the customer's purposes; controller for training and quality | Until the customer deletes it, or 60 days after the subscription ends; copies used for training kept up to 24 months |
| Billing details: billing contact, company, invoices | Customers | The customer | Billing and accounting | Controller | As UK tax law requires (currently 6 years) |
| Sales and marketing contacts | Lumenarc's own prospects and customers | Them, events, referrals and public sources | Selling Lumenarc and sending relevant B2B updates | Controller | 24 months from last contact |
We do not look up or infer nationality, ethnicity, health or any other special category data, and we ask customers not to put such data into the service.
Backups are kept for up to 30 days after data is deleted from live systems.