PRIVACY POLICY

Effective Date: 1 April 2015

Who We Are

Lumi Technologies Inc. (trading as Lumi, and referred to in this Privacy Policy as “Lumi” or “we”). Lumi is a market leading provider of real-time audience engagement and consumer insight technology for research companies, media companies and brands. Our company is headquartered in London, UK, but our operations are global, run out of a number of offices in the USA, Europe, Asia, South Africa and Australia.

Lumi uses a range of mobile technology products and services to collect and analyze personal information to help its clients better understand their customers. That information is as important to us as it is to you, and we take very seriously our responsibility to safeguard it and use it fairly and responsibly.

Our Approach to Privacy

This Privacy Policy (together with our terms of use available at: http://lumiinsight.com/apps-terms-and-conditions-privacy-policy/ and any other documents referred to in it) sets out who we are, what information we might collect, and what we do with that information. It also explains what your rights are. This Privacy Policy informs you how we use, store, protect and disclose your personal information when it is in our hands.

Because our business involves collecting and analyzing personal information at the request of our clients (“Clients”), we only collect and process your information in accordance with their instructions. We are required to comply with our Clients’ directions as to how they want us to use your information and the terms of any assurances they have given you about privacy, subject always to applicable laws.

We may share your personal information with our Clients who have asked us to collect and process it. They have their own Privacy Polices that apply to your information once it is passed to them and will provide you with a copy of their Privacy Policy.

Your Consent

When you download one of our applications, use one of our services, or provide us with personal information in a survey or questionnaire, you will be asked to indicate that you have read and agreed to this Privacy Policy. Your use of our website(s) is also subject to this Privacy Policy. In giving your consent, you agree to:

• The collection and use of your personal information by Lumi and the third parties described in this Privacy Policy;

• The disclosure of your personal information to the third parties described in this Privacy Policy; and

• The transfer of your personal information to within the U.S. and to other countries.

If you do not want your personal information to be used in this way, then please do not use our products, services, or websites.

Where Lumi Gets Your Personal Information

We collect your personal information from a range of sources:

• When you visit our website(s);

• When you download and install one of our mobile applications;

• When you respond to one of our online or email surveys or questionnaires; or

• When you use one of our products or services.

Because our business revolves around helping our Clients to reach and better understand their customer base, we may also receive information about you from those Clients to help them get in touch with you or analyze the information they already have about you.

What Information Lumi Collects

Our apps and products collect and analyze a range of information. Depending on the particular app you are using, this may include:

• Biographical information that you have supplied to us or to our Clients.

• Location information, meaning data which reveals the geographic location of you and your mobile device. We will only collect your location information where you have agreed to us doing so by clicking ‘OK’ on your mobile device.

• Information about the type of mobile device you own.

• App Metadata, which means information about the way in which our app is used and how it functions on your mobile device (for example, which app screens you use most, how long it takes to transmit information to us, the volume of information, etc.). Metadata does not include any personal information about you. We collect metadata via Google Analytics in order to improve the usability and performance of our app.

• Survey or other information, which means information contained in the responses you give to survey or polling questions, or other information you provide or enter in the app, dashboard or website.

• Information received from other sources including other websites we operate or the other services we provide.

Sharing Information with Third Parties

We do not disclose any personal information about you to any third party for marketing, advertising or promotional purposes, unless you have given us express consent to do so or unless otherwise described in this Privacy Policy.

We may share your personal information with:

• Our Clients who have asked us to collect it on their behalf.

• Our partners, who provide us with IT and support services to help us manage and store information, and who may require such information for the performance of any contract we enter into with them.

• Our group companies, who may provide related or ancillary services.

We may also share your personal information in the following circumstances:

• If we believe that it is reasonably necessary to comply with a law, regulation or legal request.

• If we sell, transfer or otherwise share some or all of our assets in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy. We will endeavor to provide you with notice prior to the transfer of your personal information to a successor entity.

Security

The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, for example by providing data encryption, we cannot guarantee the security of your data transmitted to our website or app. Any transmission is at your own risk. However, we take the privacy of your personal information very seriously and use a number of methods to try to keep your personal information secure from loss or unauthorized use or access when it is in our possession or control. These methods include reasonable physical, technical and organizational measures to restrict access to your personal information. For example, your personal information is encrypted when stored or transmitted by us using secure socket technology (SSL).

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website and/or apps, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Where required by applicable law, we will notify you of any loss of or unauthorized access to your personal information, and we will cooperate with the appropriate authorities to investigate such incidents.

International Transfers of Information

We are a global company with service providers and Clients operating in several countries around the world. We use “cloud-based” storage solutions, meaning that your personal information may be transferred and stored in locations outside of your state, province or country, where the privacy laws may not be as protective as those in your jurisdiction. This includes countries outside United States. Our Clients may also operate in such locations and may require that we transfer your personal information to them in those locations.

We take steps to try to ensure that your personal information is kept secure regardless of its location, in compliance with applicable laws. Your consent to this Privacy Policy followed by your submission of personal information represents your agreement to that transfer.

Retention of your Information

We retain your personal information for as long as is necessary to fulfil the purposes for which it was collected. In most cases, this will be the duration of the particular research project or campaign for which our Client has asked us to collect and process information about you. However, we are subject to our Clients’ instructions and they may ask us to retain it for longer or to delete it sooner. We regularly audit the information we hold to ensure that it remains relevant to our current requirements and those of our Clients.

We maintain a permanent record of anonymized location, demographic and survey data. This data is used to produce aggregated consumer insights, and cannot be used to identify individuals.

Your Rights

You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by not using our apps, checking certain boxes on the forms we use to collect your data, where appropriate, or by contacting us at privacy@lumiinsight.com.

Cookies

We automatically collect information on our website(s) using “cookies,” which are small text files stored on your computer, smartphone or any other device used to visit our website. We use cookies to gather information about your actions, such as which pages you visited. This helps us improve your user experience and make it easier for you to use and navigate our website. You can set your browser to reject cookies by following the browser help file directions.

You will be asked to agree to the use of cookies when you first visit our website.

Updates

Technologies, privacy laws and our way of doing business change—so do your rights and expectations. To make sure we are up to speed, we make updates to this Privacy Policy from time to time. When we make those changes we will always publish the updated versions on our website (http://lumiinsight.com/apps-terms-and-conditions-privacy-policy/). This Privacy Policy is effective as of 31 March 2015.

Contact Us

If you have any questions, comments or concerns about this Privacy Policy, or our approach to privacy generally, you can email us at privacy@lumiinsight.com or write to us at:

Lumi Technologies Inc.
1501 Broadway, 12th Floor
New York
NY 100036-5505
United States of America