LUMEN PRIVACY POLICY

Effective Date: January 1, 2026
Last Updated: January 1, 2026

If you are experiencing a medical or mental health emergency, call 911 or seek immediate medical assistance.

Thank you for choosing to be part of the Lumen community (“Lumen,” “we,” “us,” or “our”). We are committed to protecting your personal information and your right to privacy.

When you visit our website (the “Site”) or use our related services, programs, applications, events, or communications (collectively, the “Services”), you trust us with your personal information. This Privacy Policy explains what information we collect, how we use it, and your rights regarding your information.

If you do not agree with this Privacy Policy, please discontinue use of our Site and Services.

TABLE OF CONTENTS

  1. What Information Do We Collect?

  2. How Do We Use Your Information?

  3. Will Your Information Be Shared With Anyone?

  4. Privacy Protections Related to Therapy and Clinical Services

  5. Cookies and Tracking Technologies

  6. International Data Transfers

  7. Data Retention

  8. Data Security

  9. Information From Minors

  10. Your Privacy Rights

  11. Do-Not-Track Signals

  12. California Privacy Rights

  13. Updates to This Policy

  14. Contact Information

1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Voluntarily Provide

We collect personal information that you voluntarily provide when you:

  • Submit a contact form

  • Complete an application

  • Request referral information

  • Subscribe to communications

  • Register for events

  • Communicate with us

Depending on your interaction, we may collect:

  • Name

  • Email address

  • Phone number

  • Mailing address

  • Educational background

  • Professional background

  • Application responses

  • General personal history information

  • Any other information you choose to provide

All information you provide must be accurate and complete.

Automatically Collected Information

When you visit our Site, we may automatically collect:

  • IP address

  • Browser type

  • Device information

  • Operating system

  • Referring URLs

  • Usage data

  • Date and time of access

This information does not directly identify you and is used for analytics, security, and site performance.

Information From Other Sources

We may receive information from:

  • Marketing partners

  • Public databases

  • Social media platforms

  • Analytics providers

2. HOW DO WE USE YOUR INFORMATION?

We process personal information based on:

  • Legitimate business interests

  • Your consent

  • Legal obligations

  • Contractual necessity where applicable

We use your information to:

  • Respond to inquiries

  • Review and process applications

  • Coordinate referrals to independent providers

  • Communicate program information

  • Send newsletters and marketing communications (with opt-out options)

  • Improve our Services

  • Maintain security and prevent fraud

  • Comply with legal obligations

Submission of information does not guarantee placement, acceptance, or services.

3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We do not sell personal information.

We may share information:

With Service Providers

We may share information with trusted third-party vendors that perform services on our behalf, including:

  • Website hosting providers

  • Email marketing platforms

  • CRM systems

  • Analytics providers

  • IT support services

These providers are contractually obligated to safeguard your information.

For Legal Compliance

We may disclose information if required by:

  • Law

  • Court order

  • Subpoena

  • Government request

  • To protect rights, safety, or property

For Safety and Protection

We may disclose information when necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, or threats to safety.

For Referral Coordination

If you request connection with a licensed therapist or clinician, we may share limited necessary contact or application information for coordination purposes.

4. PRIVACY PROTECTIONS RELATED TO THERAPY AND CLINICAL SERVICES

Lumen may facilitate connections between individuals and licensed therapists, clinicians, or other independent providers (“Providers”). These Providers may operate independently or under contractual arrangements and are responsible for delivering their own professional services.

Independent Clinical Responsibility

Providers are independently licensed professionals and are solely responsible for:

  • The clinical services they provide

  • Their professional judgment and treatment decisions

  • Maintaining their own records

  • Complying with applicable federal and state laws

  • Safeguarding any protected health information in accordance with healthcare privacy regulations

Lumen does not control, supervise, or direct the clinical judgment, recordkeeping practices, or treatment decisions of Providers.

Submission of information through the Site does not create a therapist-client or healthcare provider-patient relationship with Lumen.

Collection of Sensitive Information

Individuals may voluntarily provide information relating to health history, treatment preferences, wellness goals, or other sensitive matters through applications or inquiries.

Such information is used solely for legitimate administrative and business purposes, including:

  • Reviewing applications

  • Determining program fit

  • Coordinating referrals

  • Facilitating communication

  • Internal recordkeeping

Lumen does not create or maintain clinical treatment records.

We implement reasonable administrative, technical, and physical safeguards designed to protect sensitive personal information. However, no electronic transmission or storage system is completely secure.

HIPAA and Healthcare Privacy Laws

Certain Providers may be subject to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and other healthcare privacy laws.

Lumen itself is not a healthcare provider and does not provide medical or mental health treatment services directly. To the extent Lumen receives or processes information that may be considered health-related, Lumen will handle such information in accordance with applicable legal requirements and commercially reasonable privacy safeguards.

Individuals receiving clinical services directly from a Provider should review that Provider’s own Notice of Privacy Practices for information regarding how their health information is handled.

5. COOKIES AND TRACKING TECHNOLOGIES

We may use cookies, pixels, and similar technologies to:

  • Improve user experience

  • Analyze website traffic

  • Measure marketing effectiveness

  • Deliver relevant advertising

You may adjust cookie settings in your browser. Disabling cookies may impact site functionality.

6. INTERNATIONAL DATA TRANSFERS

Our servers are located in the United States. If you access our Site from outside the U.S., your information may be transferred to and processed in the United States.

By using our Services, you consent to this transfer.

7. DATA RETENTION

We retain personal information only as long as necessary for:

  • Business operations

  • Legal compliance

  • Dispute resolution

  • Enforcement of agreements

When no longer required, information is securely deleted or anonymized.

8. DATA SECURITY

We implement reasonable administrative, technical, and physical safeguards designed to protect personal information.

However, no method of transmission over the Internet is 100% secure.

If required by law, we will notify affected individuals in the event of a data breach.

9. INFORMATION FROM MINORS

Our Services are not directed to children under 18 without appropriate parental involvement.

We do not knowingly collect personal information from minors without required consent. If you believe we have collected such information, please contact us.

10. YOUR PRIVACY RIGHTS

Depending on your state of residence, you may have rights to:

  • Access your personal information

  • Request correction

  • Request deletion

  • Withdraw consent

  • Opt out of marketing communications

To exercise your rights, contact privacy@[yourdomain].com.

11. DO-NOT-TRACK SIGNALS

Some browsers offer Do-Not-Track features. We do not currently respond to DNT signals due to lack of standardized regulation.

12. CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you may have rights under the California Consumer Privacy Act (CCPA/CPRA), including:

  • Right to know what personal information is collected

  • Right to request deletion

  • Right to correct inaccurate information

  • Right to opt out of sale or sharing

Lumen does not sell personal information.

California privacy requests may be submitted to privacy@[yourdomain].com.

13. UPDATES TO THIS POLICY

We may update this Privacy Policy periodically. Updates will be reflected by a revised “Last Updated” date.

Continued use of the Site after updates constitutes acceptance of the revised policy.

14. CONTACT INFORMATION

Lumen
JillC@launchwithlumen.com