Effective date: 23 February 2026
This Cookie Policy explains how cookies and similar technologies are used when you visit www.lumiors.com (the “Website”). The purpose of this policy is to provide clear information about what cookies are, why they are used, the legal grounds relied upon, and how you can exercise control over them.
This Policy forms part of our broader approach to privacy and data protection and complements our Privacy Policy. It has been prepared in accordance with the requirements of the General Data Protection Regulation (EU) 2016/679 (GDPR), the Dutch Telecommunications Act (Telecommunicatiewet), and the recommendations of the Autoriteit Persoonsgegevens and the European Data Protection Board.
Cookies are small data files that are downloaded to a user’s device, such as a computer, tablet, or smartphone, when they visit a website. These files contain information that can be read by the website on subsequent visits and may serve a variety of purposes, ranging from basic functionality to user tracking and advertising.
In addition to traditional cookies, lumiors may also use technologies that perform similar functions, including tracking pixels, web beacons, fingerprinting scripts, and device identifiers. These are collectively referred to as “cookies” for the purposes of this Policy.
Cookies may be placed directly by lumiors (first-party cookies) or by third parties that process data for their own or joint purposes (third-party cookies).
In accordance with the Dutch Telecommunications Act, cookies may only be placed or read on a user’s device if:
Exceptions to this rule apply to cookies that are strictly necessary to enable the provision of a service explicitly requested by the user. Where cookies process personal data, we process such data in line with the GDPR, relying on a legal basis as outlined below.
lumiors distinguishes between the following categories of cookies, each of which is deployed in accordance with applicable legal requirements.
lumiors uses strictly necessary cookies to ensure the technical operation and security of its Website. These cookies enable core functionalities such as secure log-in, session persistence, fraud prevention, and load balancing.
These cookies do not require user consent, as they fall under the exemption in Article 11.7a(3) of the Dutch Telecommunications Act. Processing of related data is based on our legitimate interest in delivering a secure and functional Website (Article 6(1)(f) GDPR).
lumiors uses functional cookies to remember user choices and preferences, such as language settings, region selection, or display options. These cookies enhance the usability and personalisation of the Website.
Placement of these cookies requires the user’s prior consent. The associated data is processed on the basis of Article 6(1)(a) GDPR (consent). Consent is obtained via a clear opt-in mechanism, and users can withdraw their consent at any time.
Analytical cookies help us understand how visitors interact with our Website by collecting statistical data such as page views, average session duration, click paths, and technical errors. These cookies allow us to improve the performance and relevance of our content and services.
We use Google Analytics (GA4) to collect statistical information about website usage. IP anonymisation functionality is enabled within Google Analytics. Data collected via Google Analytics may be transferred to the United States. Where such transfers occur, appropriate safeguards are implemented, including reliance on the EU–US Data Privacy Framework where applicable and/or Standard Contractual Clauses approved by the European Commission.
Marketing cookies are used to track individual browsing behaviour and enable the display of personalised advertisements across third-party websites and platforms. lumiors may use tools such as the Google Ads Remarketing Tag, Meta Pixel, and LinkedIn Insight Tag to reach audiences who have previously interacted with our Website.
Placement of marketing cookies always requires explicit, informed consent from the user. Data collected via these cookies is processed on the basis of Article 6(1)(a) GDPR (consent). Users can withdraw their consent at any time via the cookie preference centre.
lumiors does not engage in behavioural profiling without a lawful basis and does not share user-level cookie data with unauthorised third parties.
Where lumiors embeds external content, such as YouTube videos or social media sharing buttons, the platforms providing that content may set cookies on the user’s device. These cookies may be used to track user interactions across websites and build user profiles.
lumiors does not control the use of these cookies and is not responsible for the practices of third-party platforms. Users are encouraged to consult the privacy and cookie policies of these providers before interacting with embedded content.
Upon first visit to the Website, users are presented with a cookie banner that:
No analytical, marketing, retargeting or social media cookies are placed before the user provides explicit, granular, opt-in consent. Declining non-essential cookies will not restrict access to the Website.
Consent is recorded and stored in accordance with accountability obligations under Article 5(2) GDPR. Consent records are retained for as long as necessary to demonstrate compliance with legal obligations. Users may modify or withdraw their consent at any time by accessing the “Cookie Settings” link in the Website footer.
Consent is valid for a period of no more than thirteen (13) months, after which it will be renewed.
Cookies are stored for defined periods depending on their purpose:
Retention periods for third-party cookies may vary depending on the provider’s policy. Lumiors takes reasonable steps to monitor and verify retention periods for cookies placed via its Website.
Users have the ability to delete existing cookies or block future cookies via their web browser settings. The procedure for doing so varies depending on the browser used. The following links provide detailed instructions:
Users may also manage advertising preferences across platforms via www.youronlinechoices.eu.
Please note that disabling or blocking certain cookies may impair the functionality and usability of the Website.
If you refuse or disable analytical, marketing or social media cookies, certain personalised features may not function. Core website access remains unaffected.
The Website currently does not respond to Do-Not-Track signals. Where support is added, this Policy will be updated accordingly.
In accordance with the GDPR, Website users have the right to:
Requests should be submitted to compliance@lumiors.com. lumiors reserves the right to verify the identity of the requester in accordance with applicable KYC or anti-fraud measures.
lumiors endeavours to ensure full transparency regarding the cookies used on its Website. However, due to the use of third-party services and embedded content, it is possible that third-party cookies are placed beyond our direct control.
In cases where third-party tracking technologies are used (e.g., Google, Meta, LinkedIn, YouTube), lumiors and the respective provider may operate as joint controllers under Article 26 GDPR. Users are encouraged to review third-party cookie policies for full details.
If you encounter cookies or trackers that are not documented in this Policy, we invite you to report them by contacting compliance@lumiors.com. We will investigate such instances and update our Policy or practices as required.
lumiors reserves the right to modify this Cookie Policy at any time, for example in response to new legal requirements, regulatory guidance, or operational changes. The most recent version of the Policy will always be available on the Website.
Users are advised to consult this Policy regularly to remain informed of any changes. Substantive changes will be communicated through the Website and, where required, via direct notification to users.
If you have any questions, concerns, or complaints regarding this Cookie Policy or the use of cookies on our Website, you may contact us at:
lumiors funds
Attn: Data Protection Officer
Email: compliance@lumiors.com
| Field | Meaning (for clarity) |
|---|---|
| Cookie Name | Identifier stored on user device |
| Provider / Domain | Who places or reads the cookie |
| Purpose | Why the cookie exists (functional, analytical, marketing) |
| Type | First-party or third-party |
| Retention / Expiry | How long it remains active |
| Legal Basis (GDPR) | Consent or legitimate interest |
| International Transfer | If data leaves EEA + safeguards |
| Cookie Name | Provider / Domain | Purpose | Category | Retention | Legal Basis | Third Country Transfer & Safeguards |
|---|---|---|---|---|---|---|
| _lumiors_session | lumiors.com | Maintains secure login and session continuity | Strictly necessary | Session only | Legitimate interest (Art. 6(1)(f)) | None — EEA hosted |
| cookie_preferences | lumiors.com | Saves visitor cookie selections & consent status | Functional | 12 months | Consent (Art. 6(1)(a)) | None |
| _ga / ga* | Google Analytics | Aggregated usage analytics, website improvement | Analytical / performance | 13 months | Consent (Art. 6(1)(a)) | US — EU–US Data Privacy Framework (DPF) + SCC fallback |
| _gid | Google Analytics | Visitor tracking across pages (short-term analytics) | Analytical | 24 hours | Consent (Art. 6(1)(a)) | US — DPF/SCC |
| _fbp | Meta (Facebook) | Interest-based retargeting ads & campaign performance | Marketing | 90 days | Consent (Art. 6(1)(a)) | US — DPF/SCC |
| li_fat_id / li_gc | LinkedIn Insight Tag | Ad analytics, conversion tracking, audience insights | Marketing + analytical | Up to 180 days | Consent (Art. 6(1)(a)) | US — SCC with contractual safeguards |
| yt_remote_* | YouTube Embedded Player | Tracks video interactions when content is viewed | Social/embedded content | Session or persistent (varies) | Consent (Art. 6(1)(a)) | US — DPF/SCC |
Note: This register is continuously monitored and updated. Any newly introduced cookie or tracking technology will be recorded here together with purpose, lifespan, legal basis and transfer safeguards.