Privacy & Legal

At Lumos, privacy and data protection are important to us. This Privacy Notice (“Privacy Notice”) describes how Lumos and its affiliates collect and use your information. This Privacy Notice applies to all who use our websites, platforms and electronic systems - including mobile applications, touch technologies, social networking sites, interactive features, online services or any of our described online activities we own or control (collectively, the “Service”). For more information regarding the Service, please review our Terms and Conditions (the “Terms”). By using the Service, you acknowledge you have read the terms of the Privacy Notice. If you do not want your information handled as described in this Privacy Notice, please do not provide us with your information or interact with the Service.

In this Privacy Notice, “Lumos,” “we,” “our,” and “us” each mean Lumos App, Inc and the applicable affiliates involved in the Service.

Change

We regularly update our Privacy Notice to clarify our practices and to reflect new or different privacy practices, legal requirements or technologies, such as when we add new services, functionality, or features. We encourage you to revisit our Privacy Notice to view the current version and stay informed on our practices as they relate to your information. Please note should we amend our Privacy Notice we will update the “effective date” at the top of this notice.

Table of Contents

1. COLLECTION AND USE OF YOUR INFORMATION
2. TRANSFER AND DISCLOSURE OF YOUR INFORMATION
3. YOUR RIGHTS AND HOW TO EXERCISE THEM
4. HOW WE LOOK AFTER YOUR INFORMATION
5. INTERNATIONAL TRANSFERS OF PERSONAL DATA
6. OUR POLICY TOWARDS MINORS

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1. COLLECTION AND USE OF YOUR INFORMATION

We may collect your information in the following ways:

• Information you provide to us. We collect information that you provide to us, such as when you access our website, establish a user account with us, or otherwise give us your name, email address, etc. You may also choose to submit your information to us via other methods. For example, in response to marketing or other communications; through social media or online forums; through participation in an offer, program or promotion; or in connection with an actual or potential business relationship with us. When you contact Lumos, we may also keep a record of your communication to better support you in the future. From time-to-time, we may offer referral programs to refer prospective customers to us. Please refer a prospective customer and provide their information to us only if you have their permission. If you later find out you did not have such consent, please inform us as soon as possible.
• Information we collect automatically. When you use the Service, we may automatically collect information about the devices you use to access the Service, including hardware model, device Internet Protocol (IP) address, operating system and version, software, and other unique device identifiers. We may also collect information about how you use our Service, including event information (e.g., access times, browser type, what you’ve clicked on, and language) and data collected through cookies and/or other similar technologies.This information enables us to learn more about how individuals use the Service to both analyze and improve it. For more information on how we use cookies and similar tracking technologies, please review our section on Cookies.
• Information we collect from other sources. As mentioned above, we may receive your personal data via a referral. In addition, we may obtain information about you or your use of the Service from other third party sources. For instance, if you use the Service through one of our partners and you registered with such a partner, we may also receive your information from them. When you access the Service through other third party platforms, you are authorizing Lumos to collect, store, and use such information and content in accordance with this Privacy Notice. The information we receive from other third parties may depend on your account/privacy settings with those parties and keep in mind that any information provided by such parties may also be subject to that third party’s privacy policy.

Types of data we collect. The information you provide to us will include (depending on the circumstances):

• Identifiers: such as title, company name, names, addresses, signature, email addresses, phone number, social networking website user account names, online identifier, government-issues identifiers, account name, user preferences, or other similar identifiers.
• Internet and network activity information: such as information about your browsing behavior, IP address, search history, operating system, Internet Service Provider, the web page that directed you to our services, the date and time of your visit, information about how you engage with us (e.g., the links or buttons you click and pages you view of our website or applications), the fact of whether an email was opened, and other standard server log information, and interactions with websites and advertisements, including data from cookies, pixel tags and beacons.
• Third-party account information you grant us access to view: such as email or IT ticket content and metadata and related account information.
• Any other information that you choose to share with us: for example, any information that you provide via correspondence, when you fill out our survey(s), that you share via our website or social media accounts linked to our website, or any information that you choose to provide in person at events, meetings, or over the phone.
• Financial information: such as information collected to process any payment to Lumos for any products or services, such as your payment card number, expiration date, and card verification number.

How we use the information we collect. How we use the information we collect depends in part on how you choose to communicate with us, how you use our websites and interact with us, and any preferences you have communicated to us. In general, we use your information as is necessary to run our business and carry out our day-to-day activities. In addition to the uses identified elsewhere in this Privacy Notice, we may use your information in the following circumstances:

• Where necessary for us to administer our relationship with you. For example:

• creating and administering orders for you (including, if necessary, processing payments)
• registering, maintaining and managing your account (e.g., email preferences) or for interacting with our business (e.g., via our website, telephone, video conferencing and/or email)
• providing you with support and responding to your queries, feedback, claims and/or disputes
• when visiting our offices or attending events

• Where necessary for our legitimate business interests. For example:

• developing product or service features or functionality, including when you give us feature feedback and suggestions
• managing and improving our websites, systems and infrastructure
• identifying, developing, and marketing products and services that we believe will interest you
• communicating with you regarding our business, products and services, including promotional offers and suggested products, services, or new features which may be of interest to you
• protecting the security of our premises, assets, systems, customers, customer end users, and intellectual property and enforcing company policies
• undertaking mergers, acquisitions, reorganizations, or disposals, as permitted/required in accordance with local law
• protecting our legitimate business interests and legal rights, including use in connection with legal claims, compliance, regulatory, auditing, investigative and disciplinary purposes (including disclosure of such information in connection with legal process or litigation) and other ethics and compliance reporting requirements

• Where necessary to comply with a legal obligation. For example:

• tax law and similar obligations (e.g., tax and national insurance reporting, filing and withholding)
• responding to court orders, subpoenas or other legal processes with which Lumos is required to comply
• complying with legal, regulatory and other requirements

We may provide you with more specific notices for some of the processing described above and, if we require your consent, will ask for this at the time we collect your information.

To the extent that we process any special categories of personal data relating to you, we will do so because: (i) the data has been manifestly made public; (ii) the processing is necessary for the establishment, exercise or defense of a legal claim; (iii) the processing is necessary for reasons of substantial public interest; or (iv) you have given your explicit consent to us to process that information (where legally permissible).

2. TRANSFER AND DISCLOSURE OF YOUR INFORMATION

There are certain circumstances in which we may share your personal information, as follows:

• Where you have provided your consent.
• With other website users and clients who use our Service to communicate or otherwise interact with you.
• With sponsors, partners and collaborators, including sponsors of our events and products or services.
• With our vendors who assist us with our administrative or business functions, or in the provision of any of our products/services to you. We may share your information with such vendors subject to confidentiality obligations consistent with this Privacy Notice and that on the condition your information is only used on our behalf and pursuant to our instructions.
• With marketing and advertising parties which are any selected third party that you consent to us sharing your information with for marketing and/or advertising purposes.

• With any subsequent owner, co-owner, or operator of the Service.

• With any prospective buyer of our business or assets, in connection with a corporate merger, consolidation, or restructuring, the sale of our assets, or other corporate change, including, without limitation, during the course of due diligence.
• To comply with legal orders and government requests, or as needed to support auditing, compliance, and corporate governance functions.
• In response to a subpoena, or similar legal process, including to regulators, courts, and law enforcement agencies.
• Other third parties including legal, professional or other advisors, regulatory authorities, courts, law enforcement agencies and government agencies where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our users or where such disclosure may be permitted or required by law.
• To enforce or apply our Terms and/or any other agreement that governs the sale, use or purchases of our products and/or services.

• To protect the rights, property or security of Lumos, our users, our users and/or others.

3. YOUR RIGHTS AND HOW TO EXERCISE THEM

Under your local data privacy laws, you may be able to:

• request access to any applicable information we hold about you;
• request that your information be updated, rectified, or blocked;
• request that we delete information we hold about you;
• request a restriction on the processing of your information;
• request that we provide you or a third party with a copy of certain information about you;
• object to any of our uses of your information described in this notice; and
• withdraw your consent, to the extent consent was required and provided by you.

To exercise any of the rights above, you may send an email to privacy@lumosidentity.com. If you are not satisfied with how we process your personal data, please let us know and we will investigate your concern.

If you are in the European Economic Area (EEA) and are not satisfied with our response, you have the right to make a complaint to the data protection authority in your country of residence. The contact details of each Data Protection Authority can be found at the following website: https://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

If you are personnel of a customer that uses our Service or otherwise have had your information collected via our products by or on behalf of our customers, please note this Privacy Notice does not apply to such information. Please therefore refer to such applicable party who has acquired Lumos products if you need any correction, amendment, or deletion of such personal data.

4. HOW WE LOOK AFTER YOUR INFORMATION

Security. We use administrative and technical safeguards to protect the security, confidentiality, and integrity of personal information against loss, misuse and unauthorized access, disclosure, alteration, and destruction. Such safeguards have been implemented taking into account the state of the art of the technology, their cost of implementation, the risks presented by the processing and the nature of the personal data. However, please note that there is no method of transmission over the Internet, or method of electronic storage, that is 100% secure. Therefore, although Lumos complies with its legal obligations with respect to the security of your information, we cannot guarantee its absolute security.

Retention. We will keep your information for as long as is necessary to provide you with the services that you have requested from us or for as long as necessary to comply with our legal obligations, resolve disputes, for safety, security, and fraud prevention purposes, and to enforce our agreements.

5. INTERNATIONAL TRANSFERS OF PERSONAL DATA

To facilitate our global operations, and in accordance with applicable laws, we may transfer your personal data to, and access your personal data from, our offices, subsidiaries, and affiliates in countries located outside the EEA that may not be considered providing the same level of protection for certain information under European law. In such instances, we put in place appropriate safeguards, including contractual commitments approved by the European Commission, on recipients of the data, to ensure there is adequate protection for your information. For more information about the safeguards in place and to view a copy of such safeguards, please contact us using the details in Section 8 below.

6. OUR POLICY TOWARDS MINORS

Our website and services are not intended for children. We do not knowingly collect or maintain the personal information of children under the age of 13, and in some jurisdictions under the age of 16. By using the Service, you represent that you are at least eighteen years old and understand that you must be at least eighteen years old in order to use our Service.

1. COOKIES

Cookies are unique identifiers that are placed on your device and used to better understand how applications and websites work and to optimize online and mobile experiences. Cookies placed on your device by Lumos are “first party” cookies while those placed on your device by a party other than Lumos are “third party” cookies. There are two types of cookies used by the Service:

• Essential: These are cookies that are essential to the Service and our site working properly. They include, for example, cookies that make it possible for you to browse and use the Service, such as cookies that you remember you have logged into your account.
• Functional: These cookies gather information about how visitors use the Service, monitor performance, and are used to recognize and remember your preferences. If you agree to receive emails from us, we also use them to track responses to emails we send you, and to track whether you opened or deleted an email. These cookies can also be used to identify and remedy operational problems with our Service.

You may be able to opt out of the placement of certain cookies by configuring your browser settings or opting out directly with the third party that operates and controls the cookie, where applicable.

1. HOW TO CONTACT US

If you have any questions regarding our privacy practices or would like to exercise any of the rights described above, you may email us at privacy@lumosidentity.com. You can also contact us by writing to us at the following address:

Lumos App Inc. -- Privacy,

2632 Laguna Street

San Francisco, CA 94123