Privacy Policy

Protocol | Operational Architecture, LLC is a Florida-based operational consultancy. Lumina is our proprietary route optimization and proximity matching platform, developed in partnership with Hackerware, LLC, and designed for ABA (Applied Behavior Analysis) in-home service providers.

Lumina is a geocoding and routing tool. It processes anonymized location data — addresses and geographic codes — to calculate proximity and drive time. It does not receive, store, or process Protected Health Information (PHI) as defined under HIPAA. See our HIPAA Positioning Statement for full detail on how Lumina's data model relates to HIPAA.

Information you provide directly:

• Email address (collected via the pricing gate on our landing page)
• Name and practice name (if provided during account setup)
• Billing information (processed by our payment provider; we do not store raw card data)
• Anonymized location data — street addresses paired with internal reference codes — uploaded via your organization's in-house template. No client names, diagnoses, or identifying information is submitted to or stored by Lumina.

Information collected automatically:

• IP address and general location (country/region level)
• Browser type, device type, and operating system
• Pages visited and interaction data via analytics tools
• Referral source and UTM parameters

What we do not collect:

• Client names, diagnoses, treatment records, or insurance information
• Any data that could be used to identify an individual patient or staff member within your uploaded data — your internal coding system ensures this stays with you
• Social Security numbers or government-issued identifiers

We use the information we collect to:

• Provide, operate, and improve the Lumina platform
• Deliver the planning materials and product information you requested
• Send our email follow-up sequence, from which you may unsubscribe at any time
• Process payments and manage your subscription
• Respond to support inquiries
• Analyze usage patterns to improve platform performance
• Comply with applicable legal obligations

We do not use your information for automated decision-making that produces legal or significant effects without human review.

We do not sell your personal information. We may share information only in the following circumstances:

• Service providers: Trusted third parties (email delivery, analytics, payment processing, cloud hosting) who process data on our behalf under contractual data protection obligations
• Hackerware, LLC: Our development partner may access platform data as necessary to maintain and improve the software
• Legal compliance: We may disclose information if required by law, subpoena, or other legal process
• Business transfers: In the event of a merger or acquisition, your information may transfer as part of that transaction with notice provided

Lumina is designed so that no identifying information about clients or staff enters the platform. Your organization is responsible for ensuring that all data uploaded to Lumina has been properly de-identified using your in-house template before upload — replacing names and other identifiers with internal reference codes prior to submission.

We recommend maintaining your own internal records that map reference codes to individuals, kept securely within your organization and never shared with Lumina.

We implement appropriate technical and organizational measures to protect your information, including:

• AES-256 encryption for data at rest
• TLS 1.3 encryption for all data in transit
• Role-based access controls limiting internal data access
• Regular security reviews conducted by Hackerware, LLC

No system is completely secure. In the event of a data breach affecting your information, we will notify you as required by applicable law.

We retain your account information for as long as your subscription is active. Location data uploaded to Lumina is retained only for the duration of your active subscription and is permanently deleted within 30 days of account termination. Billing records may be retained longer as required by law.

You may at any time:

• Request access to the personal information we hold about you
• Request correction of inaccurate information
• Request deletion of your account and associated data
• Unsubscribe from marketing emails using the link in any email we send

To exercise any of these rights, contact us at the address below. We will respond within 30 days.

Our landing pages use cookies and similar technologies to understand how visitors interact with our site, including analytics cookies (traffic and performance) and attribution cookies (UTM parameters). You can control cookies through your browser settings.

We may update this Privacy Policy from time to time. When we make material changes, we will update the "Last Updated" date above and notify active subscribers by email. Continued use of Lumina after a policy update constitutes acceptance of the revised policy.