Privacy Policy

Who we are

Lumera Path LLC (“Lumera Path”, “we”, “us”) provides coaching, advisory, consulting and educational services. This policy explains how we handle personal information through our website, inquiries, registrations, services and Allye.AI, the AI assistant on our website. Lumera Path is responsible for the processing described here, except where another provider independently determines its own processing.

Contact: allye@coachallye.com. Website: www.lumerapath.com.

Information we collect

We collect information you provide when contacting us, registering, purchasing or participating, including your name, email, contact details, booking information, billing information, communications and information you choose to share about your goals and circumstances.

Program records may include attendance, correspondence, agreed action items and facilitator notes. With your permission, individual sessions may be transcribed. Free masterclasses are recorded, and the replay is shared with people who registered, as explained in our Confidentiality and Recording Policy.

When you use Allye.AI, we save your messages and its replies, the date and time, and, if you followed a link that identifies it, the channel that brought you (for example LinkedIn). Before you chat, Allye.AI asks for your name and email, an optional note and whether you’d like to receive our emails, and saves them with your conversation. Allye and authorized members of her team can read saved conversations and the details saved with them. Do not provide payment-card details, passwords, medical records or confidential information about other people through the chat.

Our hosting and service providers may process technical information such as IP address, device and browser information, and security logs. Our website host, Vercel, also gives us statistics about page visits (Vercel Web Analytics), which do not use cookies. We do not use Google Analytics or Meta advertising pixels. See “Cookies and similar technologies” below.

Why we use information

We use information to respond to inquiries; arrange and deliver requested services; manage registrations and payments; communicate about bookings and programs; support agreed coaching work; operate Allye.AI; maintain security; handle cancellations and privacy requests; and meet legal and accounting obligations. If you register for a masterclass, free training or waitlist, we email you reminders and follow-ups about it. We send coaching updates, educational materials and promotional emails only if you tick the box asking for them on our forms. If you subscribe to our Substack, Substack sends it under its own terms.

Where a legal basis is required, we rely on contract performance for requested services and pre-contract steps; legal obligations for required records; consent for optional activities where required; and legitimate interests for proportionate administration, security and dispute handling where permitted and balanced against your rights. We do not rely on ordinary legitimate interests alone for sensitive information requiring additional protection.

You do not need to share medical or mental-health details to use our general educational resources. Before intentionally collecting sensitive information for a specific purpose, we explain that purpose and obtain the additional permission or establish the other legal condition required by applicable law.

Providers and disclosures

We use these providers:

• Vercel, to host our website and provide page-visit statistics
• Bluehost, for our domain name
• Google Workspace, for our email
• Formspree, to receive the forms you submit on our website
• Zoom, for scheduling and online sessions, and, only with your consent, session transcripts and meeting summaries (Zoom AI Companion)
• Substack, for our newsletter, which you join on Substack under its own terms
• Cloudflare, to host Allye.AI, store its conversations and the details given before chatting, and check that visitors are human
• OpenAI, to generate Allye.AI’s answers

Providers receive information relevant to their functions. Some process information on our behalf; others process certain information for their own purposes under their privacy notices.

Authorized facilitators receive the information needed for the engagement under confidentiality obligations. Other group participants can see and hear information you choose to share during group activities. We may disclose information when legally required or where necessary and lawful to protect rights or address a serious safety risk. Any corporate sponsor reporting must be agreed with the participant in advance.

We don’t sell personal information or share it for targeted advertising.

Allye.AI information

Allye.AI is an automated assistant, not a private session with Allye, and Allye is not in the conversation as it happens.

Allye and authorized members of her team review saved conversations to understand visitors’ questions, follow up on contact requests, and improve Allye.AI’s answers and the information on our website.

Allye.AI runs on Cloudflare, which hosts the chat and stores its conversations and the details you give before chatting. To answer you, the chat sends your recent messages, together with relevant passages from our own materials, to OpenAI. Under OpenAI’s terms for business use of its API, this information is not used to train OpenAI’s models, and OpenAI may keep it for up to 30 days to monitor for abuse before deleting it.

To protect Allye.AI from automated abuse, Cloudflare’s bot check (Turnstile) confirms that you’re a person when you start chatting, using technical information such as your IP address and browser details. It does not use cookies.

Allye.AI does not make decisions about you that have legal or similarly significant effects, and conversations are not used to build profiles of individual visitors.

We keep Allye.AI conversations for 30 days, then delete them. We keep the details you give before chatting for 12 months so we can follow up. To ask us to delete a conversation or your details, email allye@coachallye.com from the address you gave, or tell us that address, so we can find them.

Retention and security

We limit retention to what is needed for the stated purposes, applicable recordkeeping obligations and legitimate dispute handling. We restrict access to authorized people and apply reasonable safeguards appropriate to the information. No online system can guarantee complete security.

We keep information for these periods, then delete it:

• Allye.AI conversations: 30 days.
• Contact details from our website forms and the details given before chatting with Allye.AI, and email inquiries that don’t lead to working together: 12 months. If you asked to receive our emails, we keep your contact details until you unsubscribe; after that, we keep only a record of your opt-out so we don’t email you again.
• Client notes: 3 years after the last session.
• Session transcripts and meeting summaries: within 30 days of the session.
• Recordings: for as long as the replay is offered, as stated at registration or in the program agreement.
• Consent records: as long as the consent applies, plus 3 years.
• Financial records: as long as tax law requires, generally 7 years.
• Backups: providers delete backup copies on their normal schedules.

We may keep information longer where the law requires it or where it is needed for a legal claim.

Cookies and similar technologies

Our website and Allye.AI do not use cookies for analytics or advertising. Our website stores one temporary setting in your browser so the opening animation plays only once per visit; it is removed when you close the tab. Vercel Web Analytics counts page visits without cookies, and Cloudflare’s bot check on Allye.AI doesn’t use them either. Services we link to, such as Zoom, Substack, LinkedIn and Instagram, may use their own cookies when you visit them, under their own policies. We do not currently use Google Analytics or Meta advertising pixels. If we add technologies that require your consent, we will update this section and ask for your consent first.

International processing

Our services are operated from the United States and are available globally. By accessing or using our services, you acknowledge that your personal data and communications will be processed in and transferred to the United States, subject to US laws.

Your choices and rights

Depending on the law that applies, you may request confirmation of processing, access, correction, deletion, anonymization, restriction or portability; object to certain processing; withdraw consent; request information about recipients; and exercise applicable rights relating to automated decisions. You may also have rights to opt out of sale, targeted advertising or certain profiling, and to appeal a refused request where those laws apply.

Email allye@coachallye.com to make a request or ask about a decision. We may verify your identity using proportionate measures. We respond within applicable legal deadlines and explain lawful exceptions or reasons for denial. You may also contact your state attorney general. Applicable rights are not waived by using our services.

You can unsubscribe from our emails at any time using the link in any of them, through our Unsubscribe page, or by emailing allye@coachallye.com. You can unsubscribe from our Substack using the link in any of its emails. Necessary service communications may continue while we provide your purchase. Withdrawing consent does not invalidate processing lawfully carried out before withdrawal.

Children and policy updates

Our services are intended for adults aged 18 or older. We do not knowingly solicit children’s personal information. Contact us if you believe a child has provided information so we can assess and address it.

We update this policy when practices change, show the effective date and provide additional notice or obtain consent when required. Contact allye@coachallye.com with privacy questions.