Privacy Policy

Effective Date: February 26, 2026

This privacy policy (the “Privacy Policy”) explains how Luminor Risk, LLC and its affiliates and subsidiaries (“Luminor”, “we”, “our”, or “us”) collect, use, share, or disclose personal information, as a data controller or business (as the terms are defined in applicable privacy laws), provided by or about you, either directly or indirectly, when you visit our website (the “Website”) or interact with us in connection with our insurance-related activities (collectively, the “Services”). 

For purposes of this privacy policy, “personal information” means any information which directly or indirectly identifies or otherwise relates to an individual, and has the same meaning as the equivalent term is defined under applicable laws. It does not include certain types of information, such as de-identified information. 

By accessing and using the Services, you understand and agree to this Privacy Policy. You understand that you may be subject to a separate privacy policy depending on your interaction with, or the products or services you obtain from, other insurers or reinsurers.  

What Personal Information Do We Collect? 

We, or third parties on our behalf, may collect the following categories of personal information from or about you in connection with the Services:

• Identifiers, such as your name, email address, Internet Protocol (“IP”) address, and telephone number;
• Categories of personal information listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), such as name, signature, Social Security number; 
• Protected classifications under state or federal law, such as your age, racial or ethnic origin, marital status, and gender;
• Commercial information, such as financial information;
• Internet or other electronic network activity information, such as your IP address, device information, and information regarding your interaction with our Website;
• Audio, electronic, visual, or similar information, such as audio or video recordings;
• Geolocation, such as your approximate location;

• Professional or employment-related information, such as current and past employment history;

• Education information, such as the schools you have attended;

• Biometric information, such as activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints and voiceprints;

• Inferences about you drawn from any of the categories of personal information; and 

• Sensitive personal information, such as Social Security number, state identification card or passport number, or other government ID information.

We may collect personal information directly from you.  We may also collect or receive such information from other sources, such as our subsidiaries and affiliates, business partners, governmental authorities, or other third parties. 

 

Purposes For Collection and Processing of Personal Information 

We, or others on our behalf, may collect and/or process personal information for the following purposes:

• To provide and operate the Services, such as to support underwriting, communicate with brokers, partners, and counterparties;
• To carry out our contractual obligations;  
• To communicate with you, such as to respond to your inquiries or to send communications, including news and/or marketing communications;
• To understand how you interact with our Services and personalize the product experience and content; 
• To conduct internal business purposes, including for audits and enhancing our Services;
• To maintain the safety, security, and integrity of our Services, or to improve the Services; 
• To offer certain features or functionalities through the Services, which may involve interacting with artificial intelligence technology or tools.
• To comply with legal and regulatory requirements;
• To establish or defend our legal rights and obligation; 
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding; and
• For any other purpose for which you provide consent, or as otherwise required or permitted by law.

 

We may aggregate, anonymize, and/or de-identify personal information that cannot be used to identify you and is not considered personal information under applicable laws, and use it for additional purposes, including to improve our Services.

 

How We Disclose Personal Information

We may disclose personal information collected from or about you to any of the following recipients for the purposes listed above:

• Insurers, reinsurers, and service providers supporting insurance operations; 
• Our subsidiaries and affiliates;
• Vendors, payment processors, contractors, business and service partners, or other third parties;
• Government authorities; 
• Successor(s) of our business, relating to all or part of the business, to evaluate a proposed transaction or conduct a sale, reorganization, merger, acquisition, or other change of control.

 

Security and Retention of Personal Information 

We use administrative, technical and physical security measures to protect personal information we collect and process from unauthorized access and use. However, no system of transmission or storage can be 100% secure. As such, we cannot guarantee the absolute security of the personal information we collect and process. 

We retain personal information as long as you use the Services, and no longer than is reasonably necessary to fulfill the purposes for which we collect personal information and to comply with our legal obligations.

Cookies and Similar Technology

We may use cookies, pixels, web beacons, and other similar online tracking technologies (collectively, “cookies”) on our Services, including to analyze your use of the Services or to provide advertising tailored to your interests.  We may engage vendors, partners, or third parties to place and use cookies on the Services, and third parties may collect and analyze information about your use of the Services.

Some browsers permit the user to send a “Do Not Track” (“DNT”) preference to websites that the user visits indicating that the user does not wish to be tracked over time and across websites. We do not currently respond to DNT signals. 

International Users 

We are located and operate in the United States.  You understand and agree that personal information that you provide to us, or which we collect about you, may be transferred to, or processed or stored in, the United States, which may not provide the same level of protection for such information as that of your country of residency.  

Your Privacy Rights

Depending on applicable law in the jurisdiction you reside in, you may have certain rights regarding personal information, which may include the following rights:

• Right to Know and Access Personal Information: You have the right to access personal information we have collected and maintain about you;  
• Right to Delete Personal Information: You have the right to delete personal information we have collected from or about you;
• Right to Correct Personal Information: You have the right to request the correction of inaccurate personal Information we have about you;
• Right to Data Portability: You have the right to obtain a copy of personal information in a portable and readily usable format, to the extent technically feasible;  
• Right to Opt-out of Selling and Sharing of Personal Information: You have a right to opt out of certain “selling” or “sharing” or personal information (as the terms are defined under applicable laws); 
• Right to Limit Use and Disclosure of Sensitive Personal Information: You have the right to request that we limit the use of sensitive personal information about you. 
• Right to Non-Discrimination: You have the right to be not discriminated against for exercising your consumer privacy rights.
• Right to Appeal: You have the right to appeal a decision regarding your consumer privacy request.

 

We do not “sell” or “share” your personal information. We only process and disclose sensitive personal information as permitted by the California Consumer Privacy Act (“CCPA”).

 

Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception applies under applicable laws, such as to complete the requested transaction or comply with a legal obligation.

 

To exercise your rights, please email info@luminorrisk.com .

 

Please note that to protect personal information we may need to verify your identity before processing your request. In some cases, we may need to collect additional information to verify your identity, such as your government-issued ID. We are also prohibited by applicable law from disclosing certain personal information we may have under any circumstances. Under applicable law, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf.

 

Links to Third-Party Websites

Our Website may link to a third-party website, and if you choose to click on or use such links, we do not control such third-party websites and are not responsible for the content of any third-party website, including your personal information collected or processed by such sites.  Please review the privacy policy of any such third-party website for its privacy practices and how it handles personal information.

Children’s Privacy

You must be 18 years or older to use our Services. Our Services are not targeted to children, and we do not knowingly collect personal information from children under 18 years of age.

Changes To This Privacy Policy

We may revise or update this Privacy Policy from time to time, including as required under applicable laws. Updates to this Privacy Policy will be reflected in the “Last Updated” date.  

How to Contact Us 

If you have any questions about this Privacy Policy or questions or concerns about handling of your personal information, please contact us by:  

Email: info@luminorrisk.com 

Mail: 3440 Preston Ridge Road, Suite 100, Alpharetta, GA 30005 ℅ John Lavin