Privacy Policy
Last updated: September 10, 2026
1. About This Policy
Lumen Global Investments (“Lumen,” “we,” or “us”) operates Lumen R4A. This policy explains how we collect, use, share, and protect information from users of the R4A Free, Pro, and Enterprise services.
2. Information We Collect
We may collect your name, email address, telephone number, company, job title, login details, and subscription information. We also keep messages and support requests you send to us.
3. Investment Information
We collect information you enter into R4A. This may include investment goals, risk preferences, portfolio holdings, allocations, investment choices, constraints, and model portfolios.
4. Information Collected Automatically
When you use R4A, we may collect your IP address, browser and device details, login activity, features used, and technical error reports. This helps us operate, secure, and improve R4A.
5. Free, Pro, and Enterprise Users
Free users may enter their own investment information. Pro users may create portfolios for themselves or their clients. Enterprise customers may enter information about their staff, clients, portfolios, and investment models.
6. Client Information
Pro and Enterprise users must have permission to enter their clients’ information into R4A. Lumen uses this information only to provide, support, secure, and improve R4A.
7. How We Use Information
We use information to manage accounts, provide R4A’s tools, save portfolios and preferences, answer questions, improve the platform, protect against misuse, and meet legal requirements.
8. Email Communications
We may use your email address to send product information, service updates, account notices, and answers to technical or account questions. To stop receiving these communications or ask about your account, email support@lumenadvisors.com.
9. Sharing Information
We may share information with trusted companies that help us provide hosting, security, payments, email, data storage, and technical support. We may also disclose information when required by law or needed to protect Lumen and its users.
10. No Sale or Advertising
Lumen does not sell your personal information. We do not use or share your personal, client, or portfolio information for third-party advertising.
11. Cookies
Our website and platform may use cookies to keep you signed in, remember your preferences, improve security, and understand how R4A is used. You can manage cookies through your browser settings.
12. Security and Data Retention
We use reasonable measures to protect your information from loss, misuse, or unauthorized access. We keep information only as long as needed to provide R4A, maintain required records, resolve issues, and meet legal obligations.
13. Your Choices and Rights
You may ask to review, correct, or delete your personal information, subject to legal and business recordkeeping requirements. If your account is managed by an adviser, employer, or Enterprise customer, you may need to contact that organization first.
14. International Users and Children
Lumen is based in the United States, and information may be processed in the United States or other countries where our service providers operate. R4A is intended for adults and is not directed to children under 13.
15. Changes and Contact Information
We may update this policy when R4A, our practices, or the law changes. For privacy requests, communication preferences, technical help, or account questions, contact support@lumenadvisors.com, call +1 (415) 425-0697, or write to Lumen Global Investments, 580 California Street, Suite 1200, San Francisco, California 94104, USA.