This is a starting-point draft. Have it reviewed by qualified legal counsel before relying on it. It is not legal advice.

Privacy Policy

Last updated: August 9, 2026

1. Who we are

LumenGrow is operated by DevSimplex ("we", "us"). This policy explains what personal data we handle and how. Questions: hello@lumengrow.live.

2. Two roles

Account data (we are the controller): data about you and your team, such as name, email, workspace, and billing details.

Prospect data (we are a processor): data about the prospects and contacts you upload, enrich, score, or message. You are the controller of that data; we process it only on your instructions to provide the Service. You are responsible for having a lawful basis to process it.

3. What we collect

  • Account and profile information you provide.
  • Billing information, handled by our payment processor (we do not store full card numbers).
  • Content you create: campaigns, templates, connected-mailbox metadata, and prospect/contact records.
  • Usage and log data needed to run and secure the Service.

Credentials for connected mailboxes and accounts (SMTP passwords, OAuth tokens) are encrypted at rest and used only to send and sync on your behalf.

4. How we use data

To provide, secure, and improve the Service; to process payments; to communicate with you about your account; and to comply with law. We do not sell your data, and we do not sell or resell prospect data.

5. Sub-processors

We use trusted providers to run the Service, including:

  • Stripe — payments and subscription billing.
  • Email/SMTP and hosting providers — delivering the app and system email, and hosting infrastructure.
  • AI/LLM providers — generating research and personalized copy from the data you submit for that purpose.
  • Enrichment providers — where you enable enrichment.

Contact us for the current list.

6. Retention

We keep account data for as long as your account is active and as needed for legal and operational purposes. You can request deletion of your account data. Prospect data is retained and deleted per your instructions and your own retention policy.

7. Your rights

Depending on your location, you may have rights to access, correct, export, or delete your personal data, and to object to or restrict certain processing. To exercise them, contact us. For prospect data where we are a processor, please direct requests to the controller (the customer), and we will assist them as required.

If your business email appears in our contact database and you want it removed, use our self-service opt-out: app.lumengrow.live/api/data-opt-out. This permanently deletes the record and prevents it from being added again.

8. Security

We use technical and organizational measures to protect data, including encryption of sensitive credentials at rest. No method is perfectly secure, but we work to protect your information.

9. Changes

We may update this policy; material changes will be posted here with a new date. See also our Terms of Service.