Effective Date: 1 April 2015
Who We Are
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
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.
• 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 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.
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.
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.
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 email@example.com.
Lumi Technologies Inc.
1501 Broadway, 12th Floor
United States of America