Info Lumière attaches particular importance to the protection of personal data. This policy explains which data are processed in the Beosigner member area, why they are processed, on what legal bases, with which service providers, for how long and what your rights are.
1.Data controller
For subscriptions to the Beosigner CRM and the related digital services:
The controller of personal data is Laurent Vandebotermet (Info Lumière), Rue de la Maladrerie 90, 1370 Jodoigne, Belgium, email: info@infolumiere.be.
Business activity operated as a sole proprietorship.Enterprise number (Belgian CBE): 1006.929.977VAT number: BE 1006.929.977Data-rights email: info@infolumiere.be
Sales of Beosigner hardware are carried out separately by Vitarights Innovations GmbH, Bussardweg 3, 41468 Neuss, Germany, Amtsgericht Neuss HRB 21527, VAT DE315072869. Where Vitarights Innovations GmbH acts for its own purposes relating to sale, delivery, warranty or after-sales service, it acts as an independent data controller for the data relating to those operations, in accordance with its own privacy documentation.
2.Data we may process
2.1.Account and profile data
We may process, in particular: email address, name, language, title, profile information, preferences, account settings and data necessary for authentication.
2.2.Birth and astrological data
If you choose to use the personalised “daily oracle” features, we may process your date of birth and, if you provide them, your time and place of birth.
These data are used to calculate and personalise astrological wellbeing content. Providing them is optional. Without this information, some features may remain available in a non-personalised or simplified mode.
2.3.Activity, journey and loyalty data
We may process check-ins, sessions, feelings, “Moon Days” streaks, energy points, boxes, usage history and other information necessary for your journey within the CRM.
2.4.Wellbeing data and data that may concern health
Depending on the features you use, you may choose to provide information such as sleep, stress, certain physical or emotional feelings, habits or other wellbeing information.
Some of this information may constitute health data under the GDPR. Such data are processed only where you provide them voluntarily and after obtaining separate explicit consent where required.
These data are not intended to establish a medical diagnosis or to make a medical decision about you.
2.5.Photos, documents and uploaded files
Depending on the available features, you may upload photos, documents or other files. Such content may contain personal data and, in some cases, sensitive or health-related data.
You should upload only information that is necessary for the feature being used and avoid unnecessarily including data relating to third parties.
2.6.Payment and subscription data
Payments are processed by Mollie. Info Lumière does not store your full payment-card numbers. We may retain transaction references, payment status, information necessary for invoicing and the status of your subscription.
2.7.Technical and security data
To operate and secure the service, certain technical data may be processed, including IP address, connection logs, security events, browser or device type and technical information necessary to diagnose an incident.
2.8.Preferences and evidence of consent
We retain the choices you make regarding birth data, sensitive data, optional communications and any cookies or trackers subject to consent, together with the information necessary to demonstrate those choices.
We also retain the categories of information you allow “Lumière” to use under point 3.7. Those categories are operating preferences: the evidence of your consent to personalisation is retained separately, with its date and the version of the policy that was shown to you.
3.Purposes and legal bases
3.1.Account creation and management, Club access and provision of the subscription
Purposes: creating your account, authenticating you, providing the subscribed features, managing your journey, providing support and managing your subscription.
Legal basis: performance of the contract or steps taken at your request before entering into a contract.
3.2.Payment, invoicing and accounting obligations
Purposes: processing payments, managing invoicing, preventing payment errors and complying with accounting, tax and legal obligations.
Legal bases: performance of the contract and compliance with legal obligations.
3.3.Daily oracle and astrological personalisation
Purposes: calculating and generating personalised content using your date, time and place of birth and the astrological parameters used by the service.
Legal basis: your consent.
You may refuse or withdraw this consent without losing access to other features that do not require these data.
3.4.Health or sensitive wellbeing data
Purposes: enabling tracking or personalisation features that you choose to use.
Legal bases: your consent for processing under Article 6(1)(a) GDPR and, where the data fall within Article 9 GDPR, your explicit consent under Article 9(2)(a) GDPR.
Refusing or withdrawing this consent does not prevent the use of other features that do not depend on it.
3.5.Communications
Emails necessary for operation of the service, security, payment confirmations, contractual changes or subscription management may be sent on the basis of performance of the contract or a legal obligation.
Optional communications, news, engagement reminders or marketing communications are sent only where you have agreed to receive them. You may withdraw that consent at any time.
3.6.Security, abuse prevention and service continuity
Purposes: protecting accounts and infrastructure, detecting abusive use, preventing incidents and ensuring service stability.
Legal basis: Info Lumière’s legitimate interest in securing its service and the data it contains, subject to your fundamental rights and freedoms.
3.7.“Lumière” personalisation
Purposes: to allow “Lumière” to use certain information already present in your member area in order to make its readings and answers more personal.
Legal basis: your consent within the meaning of Article 6(1)(a) GDPR. Where the information concerned falls under Article 9 GDPR, the explicit consent referred to in point 3.4 remains required in addition to this one and is not replaced by it.
This processing only takes place if you have enabled “Lumière” personalisation in the settings of your member area. No category is pre-ticked, and no activation is inferred from any other choice you may have made.
You choose which categories of information “Lumière” may use, among the following:
- My Life: the moments you chose to leave with “Lumière” as memory;
- sessions and BeoKeys: the useful information from your sessions and your BeoKeys;
- universes and feelings: your information linked to the wellbeing universes and to your feelings;
- Circle: the relational context you explicitly linked to your Circle;
- symbolic data: the symbolic information you chose to provide;
- assistant history: your exchanges with the assistant, where their retention is otherwise authorised.
These categories define what may be used. They do not mean that all the data in a category is transmitted: when this feature is used, only the authorised information relevant to the context concerned is intended to be selected.
An enabled category has no effect as long as the specific authorisation it presupposes is not active elsewhere. Enabling a category never grants another consent on your behalf.
Keeping a moment in My Life, allowing “Lumière” to remember it, and enabling “Lumière” personalisation are three separate decisions, which you take separately and may change separately.
The content you entrust may include information concerning third parties, in particular when you refer to those close to you. Info Lumière does not have the purpose of building structured profiles of those persons from that content. As at the date of this policy, information concerning minors is not used as structured context for personalisation.
You may disable “Lumière” personalisation at any time, as easily as you enabled it. Disabling it ends any new use for that purpose. It does not in itself entail the deletion of the data concerned, which may remain retained for other legitimate purposes described in this policy; a deletion request remains a separate right, described in point 9.
The categories you have authorised form part of the preferences retained in your member area and are included in the data you can obtain under your right to portability.
3.8.“My Life” — personal stories you entrust to us
Purposes: to let you record and keep, in your member space, the life moments you choose to write down and then, if you allow it separately, to let “Lumière” analyse them in order to offer you an understanding of them.
“My Life” is a space for telling your story freely. The content you write there may include information falling within the special categories referred to in Article 9 GDPR — in particular information about your health, your beliefs or your intimate life — without our asking for it and without our inferring it from your texts.
Two separate permissions, which you give independently
Keeping. Legal basis: your explicit consent within the meaning of Article 9(2)(a) GDPR, in addition to the consent referred to in Article 6(1)(a). Until this permission is given, no free text from “My Life” is stored: the check takes place on our servers, on every save, and a save attempted without it writes nothing.
Analysis. Legal basis: your explicit consent, distinct from the previous one. It allows “Lumière” to analyse the content of “My Life” and, when the analysis features are used, the transmission of the information concerned to our artificial intelligence provider referred to in point 5, solely in order to produce that content.
These two permissions are independent. Allowing us to keep your content does not allow analysis, and neither is inferred from any other choice you may have made, in particular from the “Lumière” personalisation described in point 3.7, from the wellbeing tracking permission or from the “My Life” memory. No box is ticked in advance.
You can keep your stories without allowing analysis. This is an intended use, not a restriction: you keep your moments, and “Lumière” does not read them.
As at the date of this policy, “My Life” and its analysis feature are not open. When “My Life” is made available to you, you choose each of the two permissions described above separately. No “My Life” content is analysed or sent to our artificial intelligence provider until the analysis feature is open.
Withdrawal
You may withdraw the analysis permission at any time, as easily as you gave it. Withdrawal ends future analyses and does not delete any of your stories: your permission to keep them, if given, remains in place.
Withdrawing the permission to keep your content has a different effect, and you are told so before you confirm it: because it ends the legal basis allowing that content to be kept, it results in the deletion of the stories you have entrusted to “My Life”. Those stories are deleted from the active database and are no longer accessible in “My Life”; this action is irreversible from your member space. Technical backup copies follow the cycle described in point 8. The deletion concerns only that content: your other data, your other permissions and the people in your Circle are not deleted.
Scope of these permissions: you, not others
These two permissions cover the processing of data THAT RELATES TO YOU. They do not constitute consent given on behalf of another person, and cannot stand in for it.
A story may naturally mention the people around you. But if you write sensitive information about someone else — their health, their beliefs, their intimate life — your permission does not amount to that person's explicit consent within the meaning of Article 9(2)(a) GDPR. We therefore ask you not to enter such information in “My Life”, and the interface reminds you of this.
The regime applicable to information about third parties, including any information owed to them, is still under review and is not settled by this policy. In the meantime, “My Life” is not generally open.
Earlier content
Content written before these two permissions were introduced is not deemed to be covered by them. No consent is inferred from its existence, none is recorded retroactively, and any use of it by the analysis features would require a separate decision and prior information.
Your “My Life” stories, together with the history of these two permissions — grants, withdrawals, dates and the applicable version of the policy — are included in the data you can obtain under your right to portability.
3.9.“My Morning Light” — optional morning email
Purposes: to send you, at the time and frequency you choose, an email containing a positive thought written by Info Lumière and, if you wish, a selection of news from identified public sources, chosen according to the topics you have indicated.
This service is free and optional. It is never switched on by default: it only works if you activate it in your member area and tick the dedicated consent box. Legal basis: your consent within the meaning of Article 6(1)(a) GDPR. This consent is separate from all other consents described in this policy.
Data used: your verified email address, your first name for the greeting, the language you chose, and the preferences you provide — time, time zone, frequency, topics, custom subjects, intention of the day, format and, if you specify one, a geographical area (country or region, never an address). We also keep the technical history of deliveries (date, status, identifiers of the thought and news items sent) and the evidence of your consent. No health data, no “My Life” content, no sessions and no practitioner notes are used for this service, and none of this data is passed to an artificial intelligence provider.
The news items are headlines and excerpts published by their sources, together with the source name, the date and a link to the original article. Info Lumière does not write them and invents none; when no suitable news is available, the message contains only the thought of the day.
The emails are sent through Resend (point 5.3). Every message includes an unsubscribe link, and compatible email clients offer one-click unsubscribe. You can also switch the service off at any time from the “My Morning Light” page in your member area; switching it off withdraws your consent and ends the deliveries. If you have asked not to receive any optional email from us, no message from this service is sent to you.
Retention: your preferences are kept for as long as your account exists, so that you can switch the service back on without setting everything up again, and are deleted with the account; the technical history of deliveries is kept for no more than 13 months; the evidence of your consent and its withdrawal follows the rule applicable to evidence of consent (point 8).
4.Profiling and automation
The “daily oracle” may constitute a form of automated profiling or personalisation. Its operation is based, among other things, on the birth data you choose to provide, astrological parameters and content-generation rules.
The sole consequence of this personalisation is to adapt the wellbeing content shown to you. It is not used to make a decision that produces legal effects concerning you or similarly significantly affects you.
The “Lumière” personalisation described in point 3.7 follows the same logic: based solely on the categories you have authorised, it adapts the wellbeing content shown to you, and is no more used to make such a decision.
5.Recipients and service providers
Access to data is limited to persons and service providers who need it for the purposes described above.
5.1.Neon, Inc.
Neon hosts the platform's database in a data centre located in the European Union. Neon acts as a processor for data hosted on behalf of Info Lumière.
5.2.Mollie
Mollie processes payments. For payment operations that it performs as a financial institution, Mollie acts as an independent data controller for its own purposes, including execution of transactions, fraud prevention and compliance with regulatory obligations.
5.3.Resend, Inc.
Resend is used to send transactional emails and, where you have consented, certain optional communications. Emails are sent by Resend, Inc. (United States), under appropriate safeguards (European Commission standard contractual clauses).
5.4.Anthropic
Anthropic is used to generate certain “daily oracle” content.
Where you have consented to this personalisation, the necessary information may include your first name, language, date of birth and, if provided, your time and place of birth, together with astrological data calculated or necessary to generate the content.
These data are transmitted solely to generate the requested content. Info Lumière does not intend to transmit your sensitive health or wellbeing data to Anthropic as part of oracle generation.
Anthropic is also used for the “AI assistant” in your member area. Two distinct processing operations take place, and they should not be confused.
A. Processing of your message by the provider. When you write to the assistant, the content of your message, your interface language and, where applicable, the earlier exchanges in the same conversation are transmitted to Anthropic for the sole purpose of producing a reply. This processing occurs with every message and is necessary for the feature to work. The content of your messages is free text: it may therefore contain whatever you choose to write, including matters relating to your wellbeing.
B. Retention of the history by Info Lumière. Your conversations are kept in your member area only if you have expressly consented to it, through a separate consent that you may withdraw at any time. Without that consent the assistant remains usable, but no conversation and no message is stored. Withdrawing consent stops any further retention; conversations already stored remain accessible and you may delete them at any time.
C. “Lumière” personalisation. Where you have enabled the personalisation described in point 3.7, information from the categories you have authorised may be transmitted to the provider, together with your request, for the sole purpose of producing the expected answer or reading. Only the authorised information relevant to the context concerned is intended to be selected; the categories you have not authorised are not used for that purpose. Without that activation, no information from those categories is transmitted for that purpose.
The conditions under which Anthropic processes, retains or reuses the data transmitted to it are governed by its own documentation and by the agreements concluded with Info Lumière. This policy makes no statement on that subject.
The AI assistant is intended for wellbeing and support. It makes no diagnosis and does not constitute medical advice.
5.5.GeoNames
GeoNames may be used as a source of geographical data or to help resolve a place name. Where this feature is used, only the information necessary for the geographical search is transmitted.
5.6.Vercel Inc.
Vercel hosts the application and stores the files uploaded by users, including the photos and documents referred to in point 2.5. Vercel acts as a processor on behalf of Info Lumière.
6.Equipment order requests (order forms)
When you submit an equipment order request through our site, we process the following data: identity (surname, first name), contact details (email address, telephone number), delivery address, language, content of the request (products, quantities, indicative prices) as well as the identification of the advisor to whom you are attached.
This data is used to: (i) send you the order form and its confirmation link; (ii) after your confirmation, forward the request to your advisor so that they register the order with Vitarights Innovations GmbH, seller of the equipment; (iii) ensure the follow-up of the request, including reminders and its expiry.
Legal basis: the performance of pre-contractual measures taken at your request (Article 6(1)(b) GDPR).
Recipients: your advisor and, upon registration of the order, Vitarights Innovations GmbH, which then processes your data on its own account as a separate data controller.
Retention: an unconfirmed request expires after 14 days; expired or cancelled requests are deleted at the latest 12 months after their creation; confirmed requests are kept for 3 years after the last interaction, unless a legal obligation imposes a longer period.
7.International transfers
Some data may be processed outside the European Economic Area.
The database is hosted in a data centre located in the European Union.
Some service providers, including Vercel, Resend and Anthropic, may involve processing in the United States. Where processing is not covered by an applicable adequacy decision, Info Lumière relies on safeguards provided for by the GDPR, including the European Commission’s Standard Contractual Clauses where incorporated into the relevant data-processing agreements.
Mollie may also involve service providers outside the EEA in connection with its own activities. Mollie states that it implements the transfer mechanisms required by the GDPR where necessary.
8.Retention periods
Unless a legal obligation requires otherwise:
- account, profile, birth, activity, wellbeing, health and uploaded-file data: for the duration of the account, followed by deletion or anonymisation within a target period of 30 days after account closure;
- AI assistant conversation history: kept only where you have consented, until you delete the conversation or your account is closed; deleting a conversation is permanent and also erases the messages and feedback attached to it;
- “My Morning Light”: preferences for the duration of the account, technical history of deliveries for no more than 13 months (point 3.9);
- technical backup copies: may remain for up to 90 days before rotation or permanent deletion;
- transaction references, invoices and accounting records: for up to 10 years where required by Belgian accounting or tax law;
- evidence of consent: for the duration of the relevant processing and for as long as necessary to demonstrate compliance or defend legal rights;
- technical and security data: only for as long as necessary for security, diagnosis or incident management, subject to longer retention where an incident or legal obligation justifies it.
When you remove your birth data from your profile, the relevant birth data and stored natal chart are deleted or made unavailable for future processing. Previous oracle content may be retained for as long as necessary for operation of your account, provided it no longer contains the deleted birth data or is no longer directly linked to them.
9.Your rights
Subject to the conditions laid down by the GDPR, you may request:
- access to your data;
- rectification;
- erasure;
- restriction of processing;
- portability of certain data;
- objection to certain processing based on legitimate interests;
- withdrawal of consent at any time for processing based on consent.
Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.
To exercise your rights, contact: info@infolumiere.be.
Info Lumière may request reasonable additional information where necessary to verify the identity of the requester. Requests are handled within the time limits laid down by the GDPR.
You may also lodge a complaint with:
Belgian Data Protection AuthorityRue de la Presse 351000 BrusselsBelgium
10.Consent management
Consents relating to:
- birth data and astrological personalisation;
- health data or other sensitive data;
- optional communications;
- “Lumière” personalisation (point 3.7);
- the “My Morning Light” service (point 3.9);
- any non-essential cookies or trackers;
are requested separately where required. They must not be pre-ticked and may be withdrawn as easily as they were given.
Consent to “Lumière” personalisation is separate from consent relating to health or wellbeing data, from consent to the retention of the assistant history, and from the My Life memory settings. None of these consents activates another, and withdrawing one does not withdraw the others.
11.Cookies, local storage and trackers
The platform uses cookies strictly necessary for authentication, security and session maintenance, together with the beo_ref cookie described below. Such mechanisms do not require consent where they are strictly necessary for the service requested.
Where an advisor link is used, a cookie named beo_ref is set. It retains the link to your advisor for 90 days, for the purposes of attributing the commercial relationship and calculating commissions.
As of the date of this policy, Info Lumière does not use third-party advertising or non-essential audience-measurement trackers in the CRM. If such tools are added later, they will, where required by law, only be activated after the user’s consent has been obtained and this policy will be updated.
12.Security
Info Lumière implements technical and organisational measures proportionate to the nature of the data processed, including access controls, authentication, encryption of communications via HTTPS/TLS, backups, security updates and limiting access to persons or service providers who need it.
Because no system can guarantee absolute security, Info Lumière adapts these measures according to the risks and the evolution of the state of the art.
13.Updates to this policy
This policy may be amended to reflect changes to the service, service providers, processing activities or legal framework. Where a change is material, appropriate information will be provided to users.
See also the Beosigner CRM Legal Notice.