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Privacy Policy

This policy explains what personal data Lume CRM collects, why, how it is protected, and what your rights are. It is designed to comply with Québec Law 25, PIPEDA, and the GDPR.

Version : privacy-policy-2026-10-28Last updated : 2026-10-28

1. Who we are

Lume CRM is operated by William Hébert (sole proprietor), based in Québec, Canada.

Lume plays two distinct roles. For accounts, meaning the owners and members of the businesses that use Lume, their subscription and billing, Lume is responsible for the personal information. For the information a business enters in Lume about its clients, leads and employees, Lume is its service provider: it processes that information on the business's behalf, following its instructions, under the written mandate of the Terms of Service, Law 25 section 18.3. For that information, contact the business first; it remains responsible for collecting it.

Our Data Protection Officer (DPO) can be reached at [email protected].

2. Data we collect

We collect and process the following categories of data:

  • Account data — name, email, password (hashed), role, avatar, phone number.
  • Customer data you enter — leads, clients, contacts (names, emails, phone numbers, addresses, optional date of birth, notes).
  • Business data — jobs, invoices, payments, schedules, tasks, messages.
  • Technical data — IP address, browser user-agent, session cookies, audit logs (who did what, when).
  • Employee location — an employee's GPS position, only during clocked-in hours, if the business turned tracking on and the employee accepted it.
  • Voice — the audio of a dictation to the Lumi assistant or of a team member’s voice note received by text message, transcribed to text; a client’s voice note is transcribed only if their business turned it on.
  • Photos and files — job site photos, photos attached to a request, file attachments.
  • Employee performance — sales, revenue, doors knocked, conversion rate, hours and days worked, per person.

Technologies that locate, measure or use artificial intelligence

  • Location — during clocked-in hours only, at most one position every 15 seconds. It is used for job dispatch, routes and proof of presence at a job site. Only managers with the permission see other people’s positions. The employee is informed and can refuse on a dedicated screen; tracking stops at clock-out.
  • Artificial intelligence — the Lumi assistant and the support assistant use Claude, by Anthropic. Voice transcription and recognition of already-asked questions use Gemini, by Google. To answer, Lumi, the support assistant and the automation AI steps, “Lumi handles it” and the AI step, send the model the request and the account information it concerns; emails, phone numbers, street addresses and postal codes written in these texts are replaced by codes before sending and do not leave Lume. Names and the rest of the information needed for the answer are sent. Also sent as they are: screenshots attached to a support request, and the description of an automation to build with Lumi, with the names of the business settings it mentions, such as stages, tags and team members. A client’s voice note is sent to Google for transcription only if the business turned it on in Settings, Messaging. No decision is made without a person: a Lumi action that writes waits for a confirmation.
  • Performance measurement — the leaderboard and performance profiles compare employees on the indicators above. The business chooses who appears on the leaderboard. These measurements trigger no automated decision.

3. Why we process your data

We only process your data when we have a legal basis to do so:

  • Contract — operating the CRM for your organization.
  • Legal obligation — tax, accounting, consumer protection laws.
  • Consent — cookies (analytics, marketing), email/SMS marketing communications.
  • Security and operation — service security, fraud prevention, crash diagnostics.

Account follow-up by our team, on the basis of legitimate interest: every day, aggregated indicators of how your account is used — last sign-in date, number of invoices sent over 7 and 14 days, number of active employees, use of Lumi — and the state of your Lume subscription — failed payment, renewal date, cancellation reason — are sent to GoHighLevel, our team’s tool, so we can help when usage drops. None of your clients’ data, no invoice and no text you typed is part of it.

4. Your rights

At any time, you may:

  • access your personal data (export as JSON);
  • correct inaccurate data;
  • request erasure ("right to be forgotten");
  • request data portability;
  • object to processing for marketing;
  • withdraw a previously given consent;
  • file a complaint first with our privacy officer, at the address below: we acknowledge it, examine it and answer in writing within 30 days. If the answer does not satisfy you, you can file a complaint with the Commission d'accès à l'information du Québec, the Office of the Privacy Commissioner of Canada, or your local supervisory authority.

You can exercise these rights from the Privacy Center in your account, or by email at [email protected]. We respond within 30 days.

5. Data retention

We only keep your data for as long as necessary:

Active account dataKept for the duration of the service.
Inactive leadsAnonymized after 24 months of inactivity.
Invoices & paymentsKept 10 years, tax obligation.
Audit logsKept 3 years, then purged automatically.
Marketing communicationsKept while consent is active; deleted on withdrawal.
Employee GPS positionsRoute points: 180 days. Live position: 7 days. Proof of presence at a job site: 3 years.
Conversations with LumiDeleted after 12 months without activity.
Voice recordingsNot kept by Lume: the audio is transcribed and discarded; only the text remains, with the conversation.
Photos and attachmentsKept as long as the record exists; deleted with the client upon an erasure request.

6. Subprocessors

We share data with the subprocessors below, each bound by a Data Processing Agreement, except the two public services built on OpenStreetMap, OpenStreetMap Foundation and FOSSGIS:

SubprocessorPurposeLocation
Supabase Inc.Database, authentication, storageCanada, AWS ca-central-1, Montréal
Railway Corp.Application hostingUnited States
Cloudflare, Inc.Delivery network in front of all traffic, attack protection, CAPTCHAGlobal, US company
Stripe Inc.Payment processingUnited States and international
PayPal HoldingsAlternative paymentsUnited States and international
Twilio Inc.Sending and receiving text messagesUnited States
Amazon Web Services, Amazon SESTransactional emailCanada, AWS ca-central-1
Anthropic, PBCAI: Lumi, support, website assistant, import assistantUnited States
Google LLCMaps, geocoding, voice transcription with GeminiUnited States and international
Mapbox, Inc.Maps, fallback geocoding, directionsUnited States
OpenStreetMap FoundationLast-resort geocodingEurope
FOSSGIS e.V.Route travel timesGermany
Functional Software, Inc., SentryCrash reporting, performance measurementUnited States
Slack Technologies, LLCRouting support requestsUnited States
HighLevel, Inc., GoHighLevelFollowing up demo requests, account usage as aggregated indicators and, with your consent, website visitsUnited States
UpstashRate-limiting cache, when enabledUnited States and international

Full, up-to-date list: /subprocessors. We notify you 30 days in advance before adding a new subprocessor that receives personal data.

Integrations you turn on. If your business owner or an admin connects Zapier or Make to Lume, those services receive what your scenarios ask for: your clients’ and leads’ contact details, and the status, amounts and dates of your quotes, invoices and jobs, never your internal notes, custom fields or payment data. They are then your providers, chosen by you, not Lume subprocessors. You can remove this access at any time in Settings › API & MCP.

7. International transfers

Our primary database is hosted in Canada, in the AWS ca-central-1 region in Montréal. Our application server and several of our subprocessors process data in the United States. For data subjects in Québec, these transfers are subject to a Privacy Impact Assessment as required by Law 25, art. 17, which we keep on file and make available upon request.

8. Security

Data is encrypted at rest (AWS KMS / AES-256) and in transit (TLS 1.3). Access is gated by Row-Level Security, role-based access control (RBAC), and optional two-factor authentication. Security incidents are handled per our Breach Response Plan.

9. Cookies & trackers

In the app, Lume sets no advertising cookies and uses no third-party trackers: no Google Analytics, no Meta pixel, nothing equivalent. What is strictly necessary is kept in your browser’s local storage — your authentication session and your display settings (language, theme, open panels) — and never leaves your device.

Performance measurement (page-load timings, in-app navigation) is sent to Sentry, our diagnostics processor, only if you accepted it in the banner. You can withdraw that consent at any time from the Privacy Center: measurement stops immediately, with no page reload.

On our public website — home, features, pricing, contact — and only if you accept the “Marketing” category in the banner, the GoHighLevel tracking script, our sales team’s tool, records the pages you visit and what you type into our forms. It is never loaded in the app. When you request a demo, your contact details and message are sent to GoHighLevel so our team can get back to you, along with the campaign that brought you: its UTM parameters are kept for 30 days in a website cookie.

Crash reporting stays on even without that consent: it rests on our legitimate interest in keeping the service running and secure. It sends your account’s technical identifier and your company name — never your name, never your email address, and no session recording.

10. Google integration

Lume connects to Google in two ways, both optional: to sign you in to Lume with your Google account, and to connect Google Sheets, Google Drive and Google Calendar to your automations. Lume only requests permissions limited to your identity, to the files you choose or that Lume creates, and to the calendar Lume creates. Lume requests no access to Gmail: we cannot read, send, or modify your email.

Google permissions requested

  • email — signing in to Lume and connecting an app: identify the Google account used and show its address in the app.
  • profile — signing in to Lume only: Google sends your name and profile picture, which Lume uses only for your Lume account.
  • openid — connecting an app only: confirm to Lume which Google account was just connected.
  • https://www.googleapis.com/auth/drive.file — read and write only the files you choose yourself in the Google window, and those Lume creates in your Drive at your request; Google Sheets goes through this permission, Lume requests no access to all your spreadsheets. Lume sees no other file in your Drive.
  • https://www.googleapis.com/auth/calendar.app.created — when you connect Google Calendar, Lume creates a calendar named “Lume” in your account, then creates, updates and deletes your visits in it. Lume neither reads nor changes your other calendars.

Lume requests no other permission from Google. Connecting a Google account is entirely optional, and we only access the data required by the features you enable. The access tokens Google gives Lume for a connected app are stored encrypted and are used only for these operations.

Limited Use (Google API Services User Data Policy). Lume's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements. Lume uses this information only to provide the features you see: signing you in, reading and writing the files you chose or that Lume created, and keeping the “Lume” calendar up to date. Lume does not transfer it to anyone except to provide these features, for security, when required by law, or with your consent. Lume never uses it for advertising, does not sell it, and does not use it to develop, improve or train artificial intelligence models. No one at Lume reads it, except with your agreement, for security, or when required by law.

Revoking access. You can revoke Lume's access at any time from your Google account, at myaccount.google.com/permissions. The tokens Lume holds then stop working right away, and we delete them on request.

11. QuickBooks integration

Connecting QuickBooks Online, by Intuit, is optional. Only the owner and admins of a business can connect it, from the Apps page. Lume requests a single permission from Intuit, com.intuit.quickbooks.accounting, which gives access to the accounting of the QuickBooks company you choose when you connect.

What Lume sends to QuickBooks: your invoices (lines, quantities, prices, taxes, number, date, due date and subject), payments received, applied to their invoice with their payment method, and your clients (name, company, email, phone and billing address). An invoice voided in Lume is voided in QuickBooks.

What Lume reads in QuickBooks: only what is needed to avoid duplicates and to offer you the settings, that is, the clients and invoices already there, and your lists of products and services, tax codes, income accounts and payment methods. Lume does not read your other transactions, your reports or your bank accounts.

Retention: the access tokens Intuit gives Lume are stored encrypted and are used only for this sync. Lume also keeps the QuickBooks identifier of the records it created or matched, to update them later, and the status of each send. On disconnect from Lume, Lume revokes access at Intuit and deletes the tokens; after a disconnect from QuickBooks, Lume deletes the tokens as soon as Intuit refuses them. Nothing more is sent. Nothing is deleted in QuickBooks. QuickBooks data is never sold, never used for advertising, and never used to train AI models.

12. Protection of minors

Lume CRM is a professional tool for businesses. The service is not intended for individuals under 16, and we do not knowingly collect personal data about them. If you believe a minor has provided us with data, contact us so we can delete it.

13. Changes to this policy

Any material change is announced in-product at least 30 days before it takes effect. The version identifier shown at the top of this page lets you track which version you accepted.

14. Contact us

William Hébert

Data Protection Officer

Québec, Canada

Version : privacy-policy-2026-10-28 — Last updated : 2026-10-28.