Privacy Policy

This Privacy Policy explains how BlackLens Studio (“LumaKol”, “we”) collects, uses and shares personal data when you visit our websites, create an account, or use the LumaKol web and mobile applications (the “Service”).

It covers two situations, and which one applies to you changes what we can do for you.

• Account holders and staff of our customers — owners, admins, team leads and agents. For your account, profile, device and billing data, BlackLens Studio is the data controller. This policy is our commitment to you directly.
• People whose details our customers store in LumaKol — leads, contacts and callers. For that data the customer is the controller and BlackLens Studio is a processor acting only on their documented instructions. We do not decide what a business stores about you or why.

If you are a lead or contact and want to know why a business holds your number, please ask that business first; they hold the answer. You can also write to us at [email protected] and we will pass your request on, tell you who the customer is where we are allowed to, and help them respond.

This policy does not cover the websites, dialers, messaging apps or storage services our customers use alongside LumaKol. Those have their own policies.

Account data you provide at signup or invitation: first and last name, email address, mobile number, country, date of birth when you sign up with an email address (used only to confirm you are 18 or older), time zone, language, password (stored only as a salted Argon2id hash), organisation name, industry and team size, and your consent records (terms version, time, IP address).

If you sign in with Google or Apple, we receive from them your email address, whether it is verified, a unique account identifier and, from Google, your first and last name. We keep the identifier and email to recognise you next time; we do not receive your password, contacts or profile photo, and we do not keep the provider’s access tokens.

Usage and device data collected automatically: sign-in events, IP address, browser or app version, device manufacturer and model, operating-system version, notification tokens, session identifiers, diagnostic logs, crash reports from the Android app, the result of the app-integrity check on the Android app, which link or campaign the Android app was installed from as Google Play reports it (for example our website or Play search), whether the app is still installed, which we learn from the push notification service, and the state of permissions and battery settings needed to capture calls reliably. While the web app or a mobile app is open in the foreground it sends a presence signal about once a minute; this feeds the live team board and the active-time figures in attendance reports.

Call and CRM data processed on behalf of the customer: phone numbers, call direction, start time and duration for calls with leads on the selected Work SIM; where the workspace turns it on, calls on the Work SIM from numbers that are not yet leads (see “Call log data”); call feedback and notes; lead and contact records; follow-ups, quotes, attendance check-ins, breaks and field visits; messages logged from connected channels; and, where enabled by the customer and permitted by law, call recordings and their metadata. The Android app reads only the Work SIM the user selects; calls on other SIMs are not read.

Location: a single position fix at the moment a user taps Check in or Check out — for attendance, where the workspace requires a location, or for a field visit at a lead. Location is never collected in the background.

Connected mailboxes: if a user connects their own email account under Settings → Email so that emails to leads go out from it, we store the mail server, username and password (the password encrypted) and send those emails through that mailbox. LumaKol never emails a customer’s leads from its own address.

Billing data: plan, seats, invoices, the tax details you enter and payment status. Card and bank details are entered directly with our payment provider and never touch our servers.

Enquiry data when you use a form on our website — the contact form, a demo request or an account-deletion request: your name, email address, the message you write, an optional phone number and company, and the time and IP address of the submission, which we keep to prevent abuse of the form.

Leads from connected lead sources: where a workspace connects IndiaMART, JustDial or Google Ads lead forms, those services send us the enquiries they collected — typically name, phone number, email, city and the enquiry text — and we add them to that customer’s workspace as leads, on the customer’s instructions.

Quotes: when a customer sends a quote link, we record when the recipient first opens it, so the customer can see that it was viewed.

Lead capture forms and website chat: where a customer publishes a LumaKol capture form or adds the LumaKol chat widget to its own website, we receive what the visitor types — such as name, mobile number, email, company, city and chat messages — together with the time and IP address, and we create or update a lead in that customer’s workspace. The chat widget keeps a conversation token in the visitor’s browser storage so the chat carries on across pages. The customer is the controller of that data; we process it on their instructions.

We do not collect SMS messages, your phone’s contact list, the content of any call, or your location in the background. See “Mobile app permissions” and “Call log data” for exactly what the apps read.

Where the GDPR or UK GDPR applies, we rely on the legal bases below. Each purpose has its own basis; we do not use consent as a catch-all for things you cannot realistically refuse.

• Contract (Article 6(1)(b)): creating and running your account, authenticating you, syncing calls and leads on your Work SIM, sending transactional messages such as verification codes, invitations, password resets and security notices, providing support, and billing you for the plan you chose.
• Legitimate interests (Article 6(1)(f)): keeping the Service secure and available — rate limiting, sign-in lockout, device attestation, crash reporting, audit logging, and fraud and abuse prevention — and improving the product using aggregated, de-identified usage data. We weigh these against your interests before relying on them, and you can object at [email protected].
• Consent (Article 6(1)(a)): the optional device permissions on the mobile apps — location for attendance and field-visit check-ins, microphone for dictation and voice notes, camera for visit photos on iPhone, file access to find recordings made by your dialer, and display over other apps for the post-call prompt — and product or marketing emails. You can withdraw consent at any time in device settings or through the unsubscribe link, and the core Service keeps working.
• Legal obligation (Article 6(1)(c)): keeping tax and accounting records, and responding to lawful requests from authorities.

For the leads and contacts our customers store, the customer chooses and is responsible for the legal basis. We process that data only on their instructions and never for our own purposes.

The Android app requests permissions only for the features described in the app and in Google Play’s Data Safety form: Phone / Call Log to capture calls on the Work SIM and show caller information; Notifications for follow-up reminders and feedback prompts; Display over other apps (optional) for the post-call feedback pop-up and caller ID; Audio files (optional) to find call recordings created by the phone’s own dialer; Microphone (optional) for dictation and voice notes; Location (optional) for attendance and field-visit check-ins. Scanning a business card uses the phone’s camera app; the text is read on the phone with on-device text recognition, the photo is deleted once it has been read and is never uploaded, and only the fields you choose to save become a lead.

Two limits are worth stating plainly. Location is requested in the foreground only and is read only at the moment you tap Check in or Check out — for attendance where your workspace requires a location, or for a field visit — and the app never tracks you in the background or between check-ins. And we never use accessibility services to record calls, never read SMS, never read your contact list and never record calls ourselves.

Permissions can be revoked at any time in device settings; the related features then stop working and the rest of the app carries on.

Apple does not allow any app to read the iPhone call log, so the LumaKol iOS app does not read it and cannot. It runs in assisted mode: calls you place from inside the app are logged, and you record the outcome yourself. Nothing is captured from calls you make elsewhere on the phone. The iPhone app asks for notifications, location at check-in, the microphone and speech recognition when you dictate or record a note, and the camera when you take a visit photo; caller ID uses Apple’s Call Directory, which keeps your leads’ names on the phone.

LumaKol does not record calls. Where an Android phone’s own dialer creates a recording and local law permits it, you can let the app attach that file to the matching lead call. If you enable this, recordings are uploaded over an encrypted connection (over Wi-Fi by default) and stored on LumaKol’s own servers, where only the roles your workspace allows can play them. If you do not enable it, we never look for recordings at all.

Recorded voice notes and field-visit photos are saved in the Google Drive of the team member who connects it, and LumaKol keeps only a link to the file. Google Drive connections are not available yet, so until they are, voice notes and visit photos cannot be added.

This section describes exactly how the LumaKol Android app uses the phone’s call log, because it is the most sensitive permission the app requests.

What we read: once you have finished setup and granted the Call Log permission, the app reads new entries in your phone’s call log for the one SIM you selected as your Work SIM. For each entry it checks whether the number belongs to a lead in your workspace. The app does not read SMS, contacts or the content of any call, and it does not record audio.

Entries that do not match a lead are discarded on the phone. They are never stored, never shown to anyone and never uploaded to us — unless your workspace has turned on missed-call leads (off by default). Then a missed call (or, if the workspace chooses, any call) on the Work SIM from a number that is not yet a lead is uploaded and becomes a new lead. Calls on your personal SIM are not read at all.

What we store: for lead calls — the lead’s number, direction (outgoing, incoming or missed), start time, duration, the SIM used and the outcome you log afterwards — and, when missed-call leads are on, the number and time of the call that created the new lead. This is stored in your organisation’s workspace, visible to you and to managers in your organisation according to their role.

Why: so that calls to and from your leads appear on the lead’s timeline without manual entry, you are prompted for an outcome when a lead call ends, and your team’s reports and follow-ups stay accurate. This is the app’s core function.

Retention: call records are kept while your organisation’s workspace is active. They are deleted when the organisation’s data is deleted (see “Retention”), or earlier when the customer asks us to erase them.

Sharing: call log data is never sold, never used for advertising, never shared with data brokers and never transferred to third parties except the service providers that host the Service on our behalf under contract.

Your control: you can revoke the Call Log permission at any time in Android settings. The app then stops reading the call log and keeps working for calls you start from the app. On iOS the permission does not exist, because the platform does not expose the call log to apps.

Use of this data complies with Google Play’s Permissions policy and Prominent Disclosure requirement: the app explains this use on a dedicated screen before requesting the permission, and you can decline.

• To provide the Service: authenticate you, sync calls and leads, send transactional emails (verification, password reset, invitations, security notices), and show dashboards to your organisation according to roles.
• Security and integrity: rate limiting, fraud and abuse detection, device attestation, audit logs of administrative actions.
• Billing: subscriptions, invoices, tax compliance.
• Support and communication: responding to requests and service announcements; product updates only with your opt-in, which you can turn off at any time from the unsubscribe link in every such email or under Settings → Notifications.
• Improvement: understanding how the Service is used and where it fails — for example which features are used, sign-in problems and crash reports — from our own records. Anything we publish or share about usage is aggregated so that no person or customer can be identified, and we do not use third-party analytics or advertising tools. We do not use customer CRM data, call records or recordings to train models, for ourselves or for third parties.
• Legal obligations: responding to lawful requests and enforcing our terms.

We do not use any of this data for advertising, and we do not combine it with data bought from third parties. The legal basis we rely on for each purpose is set out in “Legal bases for using your data”.

We share personal data only with the following categories of recipient, each bound by contract and processing data only for the purposes above: infrastructure and database hosting; transactional email delivery; network security and content delivery; app attestation, crash reporting and push-notification services of the mobile platforms; payment processing; and the integrations a customer chooses to connect. We also share data with the customer organisation you belong to, and with authorities where the law requires it or in connection with a corporate transaction, in which case this policy continues to apply to the data transferred.

Where a customer connects LumaKol to their own systems, data also leaves the Service at their instruction — see “Data a customer sends out of LumaKol”.

We do not sell personal data. We do not share it with advertisers or data brokers, and we do not use call, lead or recording data to target advertising — ours or anyone else’s.

The providers we rely on are named in “Service providers we use”.

A workspace can connect LumaKol to the customer’s own systems. Where it does, personal data leaves our Service under the customer’s instructions and their responsibility. The controls below are the ones we provide; what happens to the data once it arrives is governed by the receiving system’s own policies.

• API keys: an owner or admin can issue keys that let their own software read and write leads, calls and users through our public API. A key carries only the permissions ticked for it, is stored by us only as a one-way hash, can be restricted to named IP addresses and given an expiry date, and can be revoked at any moment. Anyone holding a key can act with its permissions, so it must be treated as a credential.
• Webhooks: an owner or admin can register a URL we send JSON to when a lead is created, updated, moves stage or is reassigned, a call is logged, or a follow-up falls due. The message carries the lead and call fields for that event. Every delivery is signed so the receiving system can verify it came from us. Deliveries that fail are retried for about half a day and then dropped.
• Calendar feeds: a member can create a private subscription link that publishes their own follow-ups — including the lead’s name, number, stage and last outcome — to Google Calendar, Outlook or Apple Calendar. Anyone holding that link can read the feed, so it should be treated as a credential; it can be regenerated or switched off at any time in Settings.
• Lead capture forms and website chat: a customer can publish a hosted form, embed one on their own site or add the chat widget. Submissions and chat messages come to us and become leads in that workspace; the customer decides what is asked and what notice the visitor is given.
• Emails to leads, including drip-sequence emails, are sent through the mailbox a user connects under Settings → Email and are governed by that email provider’s terms. Messages an agent sends from a lead through WhatsApp or SMS leave through the app on the agent’s own phone.

Each of these is off until someone in the workspace turns it on, and an owner or admin can switch any of them off again. Actions that create or revoke these connections are written to the workspace’s audit log.

We rely on a small number of service providers (subprocessors) to run the Service. Each one is bound by a written contract, may process personal data only on our instructions, and is subject to confidentiality and security obligations.

The kinds of provider we use today are:

• database hosting, in Japan;
• application servers, and storage of call recordings and import files, in Singapore;
• DNS, content delivery and network security, from a global network;
• delivery of LumaKol’s own transactional email (verification codes, invitations, password resets, invoices and service notices), in the United States;
• payment processing for subscriptions and invoices, in India — card details are entered directly with the payment provider and never reach our servers;
• the mobile platforms’ own services for push notifications, crash reports from the Android app, and checking that a request comes from a genuine install of the app.

We do not use advertising networks, data brokers or cross-site analytics vendors, and none of these providers is permitted to use your data for their own purposes. Customers can ask for the current list of providers by name at [email protected]; the Data Processing Addendum explains how customers are told about changes.

Systems a customer connects themselves are not our subprocessors — those are the customer’s own choices, described in “Data a customer sends out of LumaKol”.

LumaKol is operated from India. Our database is hosted in Japan; the application servers, call recordings and import files are in Singapore; and a global content-delivery network sits in front of the site and the apps. Our staff and the providers described in “Service providers we use” may access data from other countries for support and operations. Where data leaves the EEA, the UK or another jurisdiction with transfer restrictions, we rely on adequacy decisions, Standard Contractual Clauses or the UK International Data Transfer Addendum, and equivalent safeguards under other laws.

We apply the same security controls wherever data is held, and our contracts with providers carry the same obligations across borders. We do not promise that your data will stay inside any one country or region, and these locations can change; if that is a requirement for you, ask us at [email protected] before you sign up so we can tell you honestly whether we can meet it. You can request a copy of the transfer safeguards we rely on at the same address.

Account data is kept for the life of the account. Call and CRM data is kept while the workspace is active and can be deleted earlier by the customer; plans do not shorten how long it is kept.

When a workspace is paused for non-payment, or a cancelled subscription reaches the end of its paid period, the workspace’s CRM data — leads, calls, notes, recordings, attendance and team data — is deleted 90 days later. An owner who deletes their account as the last active member closes the workspace and its data is erased at once. Administrator accounts, invoices and billing records, and security and audit logs are kept after a workspace closes: invoices for as long as tax law requires, and logs so that sign-ins, exports and support access remain traceable.

Backups: data you delete can remain in our backups for up to about four weeks before it rolls off. Backups are used only to recover from a failure, never to bring back data a customer deleted on purpose.

We do not keep a copy of a closed workspace to use later. Where we are required to retain a record, such as an invoice, we keep only that record and not the surrounding CRM data.

We use TLS for all connections, encryption at rest for the database, a second layer of AES-256 encryption for secrets such as tokens and connected-mailbox passwords, Argon2id password hashing with checks against known breached passwords, organisation-scoped queries that keep each workspace’s data apart, hashed session tokens, rate limiting and lockout on sign-in, append-only audit logs, and mandatory multi-factor authentication for our own staff.

Access to production data by our staff is limited to the people who need it to operate the Service and support customers, and is logged.

No system is perfectly secure. If we become aware of a breach affecting your data, we will notify you and the relevant authorities as the law requires, and tell you what happened and what to do about it. You can help by keeping the mobile app updated and revoking API keys and calendar links you no longer use.

Depending on where you live you may have the right to access, correct, delete, restrict or port your personal data, to object to certain processing, and to withdraw consent. Account holders can update most details in Settings, export their leads and read their data through the API, delete their own account from the mobile app, and request deletion of anything else by contacting us at [email protected].

We respond within the period the applicable law requires — for example 30 days under the GDPR and 45 days under the CCPA — and we will tell you if we need longer and why. Exercising a right is free and we will not treat you differently for it. We may need to verify who you are first; we ask for the minimum needed and use it only to check the request.

If your data was stored in LumaKol by one of our customers, they are the controller. We will forward your request to them and assist them in responding, and we will not delete or change their records on our own initiative.

You can opt out of product emails at any time using the link in the email or in Settings; transactional security emails, such as verification and sign-in alerts, cannot be turned off while your account is open. The interface is available in 33 languages, and you can make a request to us in any of them.

We do not carry out automated decision-making that produces legal effects or similarly significant effects on you. We do not profile individuals for advertising, score people for creditworthiness or employability, and we do not build or sell profiles of anyone.

The Service does order work for agents, and we want to be precise about what that is. The calling queue sorts a customer's own leads using rules that customer configures — chiefly which follow-ups are overdue, how many attempts have already been made, when the lead was last contacted and which stage it sits in. That is a sorted list of who to ring next: a workflow aid, not a judgement about a person. It decides nothing about anyone's rights, eligibility or treatment, and a person in the team always chooses whether to call and what to say.

We do not use call records, recordings or CRM content to train models, for ourselves or for third parties.

If one of our customers uses data from LumaKol as an input to a decision of their own, that decision is theirs and they are responsible for explaining it. If you believe a decision has been made about you automatically, write to [email protected] and we will tell you what we hold and pass the question to the relevant customer.

European Economic Area and United Kingdom (GDPR / UK GDPR): the legal bases set out in “Legal bases for using your data” apply; you may contact our privacy contact at [email protected] and lodge a complaint with the supervisory authority of your country of residence. Automated decision-making with legal or similarly significant effects is not used — see “Automated decisions and profiling”.

California and other US states (CCPA/CPRA and similar laws): in the preceding 12 months we collected the categories of personal information described in “Data we collect” for the purposes described in “How and why we use data”. We do not sell or share personal information for cross-context behavioral advertising, and we do not use or disclose sensitive personal information for purposes other than providing the Service. You have the right to know, delete, correct and limit, and not to be discriminated against for exercising these rights; authorised agents may submit requests on your behalf.

India (Digital Personal Data Protection Act, 2023 and the rules made under it): for account data, BlackLens Studio is the Data Fiduciary; for the leads and contacts a customer stores, that customer is the Data Fiduciary and BlackLens Studio is its Data Processor. You may ask what personal data we hold about you and how we use it, withdraw consent as easily as you gave it, request correction, completion, updating or erasure, and nominate another person to exercise your rights if you die or become unable to. Grievances may be addressed to our Grievance Officer at [email protected]; we aim to resolve them within 30 days and in any case within the period the rules allow. If you are not satisfied, you may approach the Data Protection Board of India. If a personal data breach affects you, we will tell you and the Board as the Act requires.

Brazil (LGPD): you may exercise your rights by writing to our privacy contact at [email protected], who handles requests under the LGPD; you may also contact the ANPD.

Canada (PIPEDA and provincial laws): you may request access to and correction of your personal information and complain to the Office of the Privacy Commissioner of Canada.

Australia (Privacy Act 1988 and the Australian Privacy Principles): you may complain to us first and then to the Office of the Australian Information Commissioner; data may be disclosed to overseas recipients as described in “International transfers”.

Singapore (PDPA), United Arab Emirates (PDPL), Saudi Arabia (PDPL) and Nigeria (NDPA): you have rights of access, correction and withdrawal of consent under those laws; requests go to [email protected].

The LumaKol website and web application use strictly necessary cookies only. There is no advertising cookie, no cross-site tracking pixel and no third-party analytics cookie, which is why you are not asked to click through a consent banner.

• Session cookie (lumakol_session): an encrypted, HTTP-only cookie that keeps you signed in and ties your browser to a session we can revoke. Without it you cannot stay signed in.
• Language cookie (NEXT_LOCALE): remembers which of the 33 interface languages you chose, so pages load in it next time.
• Currency cookie (lumakol_currency): remembers whether prices are shown in rupees or US dollars, set from the country your connection comes from or from the switch on the pricing page. It lasts a year.
• Form token (lumakol_ft): a short-lived, HTTP-only cookie set on the sign-in, sign-up, password, invitation, contact, demo and account-deletion pages, so we can check a submission came from a real browser session and block automated spam. It lasts until you close the browser, and the token inside it is valid for two hours.
• Social sign-up cookie (lumakol_social): a short-lived, HTTP-only cookie that holds a Google or Apple sign-in while you finish creating an account.
• Sidebar cookie (lk_nav): remembers whether you collapsed the web app’s sidebar.

Your light or dark theme choice is kept in your browser’s local storage, not in a cookie. You can block or clear cookies in your browser settings. Doing so signs you out, resets your language and currency choices and may prevent public forms from submitting, because these cookies are what make those features work.

Embedded videos: the guide and tutorial pages show a still image of our YouTube tutorials with a play button. Nothing loads from YouTube and no cookie of theirs is set unless you press play; if you do, the player is served from youtube-nocookie.com and Google’s own privacy policy applies to what happens inside it.

LumaKol is a business product sold to organisations, and it is not directed at children. You must be 18 or older to hold an account. We ask for your date of birth at signup for that single purpose and use it for nothing else; anyone inviting a colleague into a workspace is responsible for the same limit.

We do not knowingly collect personal data from anyone under 18, we do not market to children, and we do not build profiles of anyone for advertising. If we learn that an account belongs to someone under 18, we close it and delete the account data.

Separately, our customers decide whose details they store as leads. If you believe a business has stored a child's details in LumaKol, write to us at [email protected]. That customer is the controller of the record, so we will contact them and support them in removing it, and we will tell you what happened.

If you are unhappy with how we have handled your personal data, tell us first. Write to [email protected] with enough detail to identify the issue and, where you can, the email address or mobile number on the account. We will investigate and reply within the period the applicable law requires, and we will say plainly what we found and what we are doing about it.

If our answer does not satisfy you, you have further options:

• EEA and United Kingdom: you may lodge a complaint with the supervisory authority in the country where you live or work, or where you believe the problem occurred. You do not have to come to us first, though it usually resolves things faster.
• India: you may raise a grievance with our Grievance Officer, who is reachable at [email protected]. If it is not resolved to your satisfaction, you may approach the Data Protection Board of India.
• Other regions: the authorities named in “Additional information for specific regions” accept complaints directly.

If your data is held in LumaKol by one of our customers, the complaint may properly be one for that business as the controller. We will say so, identify them where we are allowed to, and pass your complaint on rather than leave you to chase it.

We update this policy as the product and the law change. The current version always lives on this page, and the date shown at the top tells you when it last changed.

For minor edits — wording, clarifications, an extra example — we simply post the revised text. For material changes, such as a new purpose for using data, a new category of recipient or a change to how long we keep things, we notify account holders by email or in the product before the change takes effect. Where the law requires your consent for a change, we will ask for it rather than assume it.

We will not start applying a materially different use to data we already hold without telling you first. If you do not agree with a change, you can export your data and close your account; “Retention” explains what happens to it afterwards. Customers with a signed agreement should also check that agreement, which may set its own notice terms.

Write to us — a person reads everything sent to these addresses.

• Privacy requests and questions about this policy, including access, correction, deletion and complaints: [email protected]. For users in India, the same address reaches our Grievance Officer.
• Everything else, including help with your account, billing and the mobile apps: [email protected].

BlackLens Studio, 33/19B/8G, Lohiya Nagar, Balkeshwar, Agra, Uttar Pradesh 282005, India.

We have not appointed a statutory Data Protection Officer; the privacy contact above is responsible for these requests and routes them to the right people internally. To help us answer quickly, tell us which email address or mobile number your account uses — or, if you are a lead rather than an account holder, which business stored your details. We may need to verify who you are before acting on a request about personal data; we will ask for the minimum needed and will not use what you send for anything else.