LUME PRIVACY POLICY

INTRODUCTION

This privacy policy (Policy) relates to your personal information in connection with your use of and access to the LUME website https://lumeapp.io and mobile applications (the LUME Platform) and together with our Client Terms and User Terms set out the terms which apply when using the LUME Platform. Details of our Cookie Policy are set out in this Privacy Policy.

The terms "LUME", "we", "us" and "our" refer to LUME Solutions Limited, a company registered in England and Wales with company number 12555031 with its registered address at 49 Nicander Road, Liverpool, England, L18 1HU.  LUME is the controller (also known as a data controller) and is responsible for your personal information.  The term "you" refers to you, as a user of the LUME Platform. 

We are committed to protecting your Information (as defined below) and your right to privacy.  Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where information about your identity has been removed (anonymous data). 


When you use the LUME Platform, you trust us with your Information (as defined below). We take your privacy very seriously. We seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this Policy that you do not agree with, please discontinue use of the LUME Platform.

CHANGES TO THIS POLICY OR YOUR PERSONAL INFORMATION

We review this Policy regularly and it is your responsibility to check regularly and determine whether this Policy has changed.  If you do not agree to any change to this Policy then you must immediately stop using the LUME Platform.  In the event we make any significant changes to this Policy we will use our best endeavours to inform you of such changes in advance in writing. 

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes for example you change your email address.

INFORMATION WE MAY COLLECT ABOUT YOU

Personal information you disclose to us

In Short: We collect personal information that you or your employer provide to us including information such as name, address and contact information 

We collect personal information that your employer provides or you voluntarily provide to us when registering and using the LUME Platform or otherwise contacting us. The personal information that we collect depends on the context of your interactions, the choices you make and features you use. When you use the LUME Platform and/or when you otherwise deal with us, we may collect the following information about you (the Information):

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to your Information.

Information automatically collected 

In Short: Some information – such as IP address and/or browser and device characteristics – is collected automatically when you use the LUME Platform.

We automatically collect certain information when you visit, use or navigate the LUME Platform. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use the LUME Platform and other technical information. This information is primarily needed to maintain the security and operation of the LUME Platform, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in the How We Use Cookies section of this Privacy Policy.

Personal information you disclose to us

In Short: We process your Information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.

We use your Information collected via the LUME Platform for a variety of business purposes described below. We process your Information for these purposes in reliance on our legitimate business interests (Business Purposes), in order to enter into or perform a contract with you (Contractual), with your consent (Consent), and/or for compliance with our legal obligations (Legal Reasons). We indicate the specific processing grounds we rely on next to each purpose listed below. 

We may process your Information for the following purposes:

We use information from surveys administered by LUME for multiple purposes, including to:

HOW WE USE COOKIES  

The LUME website https://lumeapp.io and mobile applications (the LUME Platform) use cookies to distinguish you from other users of the LUME Platform. This helps us to provide you with a good experience when you browse the LUME Platform and also allows us to improve the LUME Platform. By continuing to browse the LUME Platform, you are agreeing to our use of cookies. Please be aware that restricting cookies may impact on your user experience and may prevent you from using parts of the LUME Platform.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

You can find more information about the individual cookies we use and the purposes for which we use them in the below table:

 Cookie Type
 Cookie Name
Purpose
More information
Analytical/ performance cookies
 Google Analytics
This cookie enables us to:

(a) Estimate our audience size and usage pattern.

(b) Understand how visitors navigate to and through the LUME Platform. 

(c) Track the effectiveness of digital marketing campaigns. 

(d) Recognise you when you return to our site.
 Targeting Cookies
 Google Adwords Conversion Tracking
 This cookie enables us to help us deliver targeted online adverts based on past visits to the LUME Platform. 
 These cookies expire within 30 days and do not contain information that can identify you personally. Please refer to the Google Advertising Privacy Notice and Google Privacy Policy for more information.
 Targeting Cookies
 Google Adwords Remarketing
This cookie enables us to help us understand visitor information and source.
You can find out more about Google Tags manager
 Targeting Cookies
 Google Tag manager 
This cookie enables us to help us understand visitor information and source.
This cookie enables us to help us understand visitor information and source.
 Targeting Cookies 
 Facebook Advertising 
 This cookie enables us to help us deliver targeted online adverts based on visits to the LUME Platform.
Please refer to the Facebook cookie policy for more information
 Targeting Cookies 
 Instagram Advertising 
 This cookie enables us to help us deliver targeted online adverts based on visits to the LUME Platform.
 You can find out more here

MANAGING COOKIES

The most popular web browsers all allow you to manage cookies. You can choose to accept or reject all cookies, or just specific types of cookies.

How to manage cookies in different web browsers

Most browsers will allow you to turn off cookies. Please note that turning off cookies will restrict your use of the LUME Platform.

The following links provide information on how to modify the cookies settings on some popular browsers:

Please note that we do not currently respond to Do Not Track (DNT) signals. 

 We strongly recommend that you leave Cookies active, because they enable you to take advantage the most attractive features of the LUME Platform, but this remains your personal choice.

You can also visit the About Cookies, for more information about cookies and how to manage them.

THIRD PARTY COOKIES

Please note that third parties (including, for example, content providers, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. 

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.

If you would like more information about these third-party cookies, it is available from  youronlinechoices.com/UK/.

Note that when third parties are collecting information about you, these third parties are acting as controllers in their own right (ie. they are not acting on our behalf).

EMBEDDED CONTENT

Sometimes, we embed images or videos from sites such as YouTube.  As a result, when you visit a page featuring such content, you may be presented with cookies from these websites. We do not control these cookies and cannot prevent these sites or domains from collecting information on your use of this content. 

You should check the relevant third-party website for more information about them and how to opt out.  They may still gather usage information about you (e.g. number of views, plays, loads etc.) and may also be able to work out who you are even if you are not logged in to their services.  Read more about YouTube's privacy policy for embedded content

WILL YOUR INFORMATION BE SHARED WITH ANYONE

In Short: We only share information to comply with Contractual obligations, fulfil our Business Purposes, or with your Consent

We only share and disclose your Information in the following situations:

We may disclose aggregated, anonymous information (i.e. information from which you cannot be personally identified), or insights based on such anonymous information, to selected third parties, including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the LUME Platform. In such circumstances we do not disclose any information which can identify you personally.

MARKETING AND OPT OUT

If you have given Consent to marketing we may contact you about our products, services, promotions and special offers.  If you no longer wish to receive such information you can withdraw your Consent at any time by sending an email to hello@lumeapp.io or unsubscribe from the communications.

IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY

In Short: We may transfer, store, and process your Information in countries other than your own to ensure optimal performance of the LUME Platform, but will take all reasonable steps to ensure it is protected.

Whenever we transfer your Information outside of the UK, we will take all reasonable measures that we can to protect your Information in accordance with this Policy and applicable law.  To the extent that any transfer requires approved safeguards are in place (for example if transferring outside of the European Economic Area that the EU model contract clauses) we will ensure these measures are in place. 

Your Consent to processing

You will be required to give Consent to certain processing activities before we can process your Information. Where applicable, we will seek Consent from you when you first submit Information to or through the LUME Platform.

If you have previously given your Consent you may freely withdraw such Consent at any time. You can do this by emailing hello@lumeapp.io.

If you withdraw your Consent, and if we do not have another legal basis for processing your Information, then we will stop processing your Information. If we do have another legal basis for processing your Information, then we may continue to do so subject to your legal rights.

Please note that if we need to process your Information in order for you to use the LUME Platform and you object or do not provide Consent to us processing your Information, the LUME Platform will not be available to you.

HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your Information for as long as necessary to fulfil the purposes outlined in this Policy unless otherwise required by law.

We will only keep your Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). 

When we have no ongoing Business Purpose to process your Information, we will either delete or anonymize it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your Information and isolate it from any further processing until deletion is possible.

HOW DO WE KEEP YOUR INFORMATION SAFE

In Short: We aim to protect your Information through a system of organisational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any Information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your Information, transmission of personal information to and from the LUME Platform is at your own risk. You should only access our services within a secure environment.

THIRD-PARTY WEBSITES

In Short: We are not responsible for the safety of any information that you share with third-party providers who feature or advertise, but are not affiliated with, the LUME Platform.

The LUME Platform may feature links to third-party websites or contain advertisements from third parties that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the LUME Platform. You should review the policies of such third parties and contact them directly to respond to your questions.

Your sole and exclusive right and remedy in case of dissatisfaction with the LUME Platform, related services, or any other grievance shall be your termination and discontinuation of access to, or use of the LUME Platform.

WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You have certain rights in respect of your Information.

You have certain rights in relation to the Information that we hold about you.  Details of these rights and how to exercise them are set out below.  Please note we will require evidence of your identity before we are able to respond to your request. This is a security measure to ensure that your Information is not disclosed to a person who does not have the right to receive it.  We may also contact you to ask you for further information in relation to your request to speed up your response.   To exercise or discuss any of your rights please contact us at hello@lumeapp.io.

 You may also have the right to restrict our use of your Information, such as in circumstances where you have challenged the accuracy of the Information and during the period where we are verifying its accuracy.

In such circumstances, you can ask us to transmit your Information to you or directly to a third party organisation.

If we are relying on Consent to process your Information, you have the right to withdraw your Consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

Please note that we have the right to reject deletion requests that are unduly burdensome or repetitive or that cannot be honoured in light of legal obligations or ongoing disputes, or where retention is necessary to enforce our agreements or protect our or another party's rights, property, safety, or security. For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the LUME Platform or to comply with legal obligations. 

CONTACT INFORMATION

LUME has a Data Protection Officer who is responsible for matters relating to privacy and data protection. If you have any questions regarding our privacy practices or information about you, please contact our Data Protection Officer at hello@lumapp.io.

You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns/). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Last updated 7th October 2020