Privacy Policy

Privacy Policy

Last Updated: December 31, 2025

This Privacy Policy explains how Lumo Group LLC, doing business as Stronghold Ownership (“Stronghold Ownership,” “we,” “us,” “our”) collects, uses, discloses, and protects personal information when you visit https://strongholdownership.com/ (the “Site”) or otherwise interact with us.

Business name and address:

Lumo Group LLC DBA Stronghold Ownership

2307 SE 72nd Ave

Portland, OR 97215

Contact: hello@lumogroup.com

1) What personal information we collect

Information you provide directly

When you sign up for our email list or contact us, we collect:

  • Name

  • Email address

  • Zip code

  • Any information you choose to include in messages you send us

Information collected automatically

When you visit the Site, we (and our service providers) may automatically collect:

  • Internet or other electronic network activity information (pages viewed, time spent, referring/exit pages, clicks)

  • Device and browser information (browser type, operating system, device type)

  • Approximate location (generally derived from IP address at a city or regional level)

We use Google Analytics and related tools to understand Site traffic and usage.

We do not intentionally collect sensitive personal information (as defined by certain privacy laws), and we ask that you do not submit sensitive information through the Site.

2) How we use personal information

We use personal information to:

  • Operate and maintain the Site

  • Understand how the Site is used and improve it

  • Send emails and newsletters to people who opt in

  • Respond to inquiries and provide support

  • Maintain security, prevent fraud, and detect misuse

  • Comply with legal obligations and enforce our rights

3) Email list and communications (Mailchimp)

If you opt into our email list, we use Mailchimp to manage subscriptions and send emails. You can unsubscribe at any time using the unsubscribe link in our emails or by contacting us at hello@lumogroup.com.

4) Cookies and analytics

We and our service providers use cookies and similar technologies to:

  • Enable basic Site functionality

  • Measure traffic and usage patterns

  • Improve performance and content

Google Analytics. Google Analytics may set cookies and collect information about your use of the Site. You can control cookies through browser settings and can use Google’s opt-out tools where available (for example, the Google Analytics opt-out browser add-on).

If you disable cookies, parts of the Site may not function properly.

5) How we disclose personal information

We do not sell personal information. We do not show ads. We do not use remarketing services. We do not share personal information for cross-context behavioral advertising.

We may disclose personal information only in these circumstances:

  • Service providers: We use vendors to provide services on our behalf, including:

    • Squarespace (website hosting and site operations)

    • Mailchimp (email list management and email delivery)

    • Google Analytics (site analytics)

    These providers are permitted to process personal information only to perform services for us.

  • Legal and safety: We may disclose information if required by law, legal process, or if we believe it is necessary to protect rights, safety, or prevent fraud.

  • Business transfers: If we are involved in a merger, acquisition, financing, or sale of assets, personal information may be transferred as part of that transaction.

6) Data retention

We keep personal information only as long as reasonably necessary for the purposes described in this Policy:

  • Email list information is retained until you unsubscribe (or we delete it)

  • Website analytics data is retained according to our analytics settings and provider defaults

  • Inquiry communications may be retained for operational, recordkeeping, and legal reasons

7) Data security

We use reasonable safeguards designed to protect personal information. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

8) Children’s privacy

The Site is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has provided us personal information, contact hello@lumogroup.com and we will take appropriate steps to delete it.

9) Your choices

  • Email: Unsubscribe anytime via the link in our emails, or contact us.

  • Cookies: Control cookies via browser settings and related controls available through your device or browser.

10) California Privacy Notice (CCPA and CPRA)

This section applies to California consumers as defined by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”).

A) Categories of personal information collected (last 12 months)

We may collect:

  • Identifiers (name, email address)

  • General location data (zip code; approximate location derived from IP)

  • Internet or other electronic network activity information (usage data)

B) Sources of personal information

  • Directly from you (email sign-up, inquiries)

  • Automatically from your browser/device when you use the Site (cookies, logs, analytics)

C) Purposes for collection and use

  • Operating and improving the Site

  • Analytics and performance measurement

  • Sending email communications to subscribers who opt in

  • Security, fraud prevention, and legal compliance

D) Disclosures for a business purpose

In the last 12 months, we may have disclosed the categories above to service providers for business purposes such as hosting, analytics, and email delivery (for example, Squarespace, Google Analytics, and Mailchimp).

E) Sale and sharing

  • We do not “sell” personal information as defined by the CCPA/CPRA.

  • We do not “share” personal information for cross-context behavioral advertising as defined by the CCPA/CPRA.