Privacy Policy
This Privacy Policy describes how Lumina collects, uses and discloses information, and what choices you have with respect to the information. Updates in this version of the Privacy Policy reflect changes in data protection law. In addition, we have worked to make the Privacy Policy clearer and more understandable.
APPLICABILITY OF THIS PRIVACY POLICY
APPLICABILITY OF THIS PRIVACY POLICY
This Privacy Policy applies to Lumina’s online tools and platform, including the associated Lumina mobile and desktop applications (collectively, the "Services"), Lumina.co (the "Website")and other interactions (e.g.,customer service inquiries, etc.) you may have with Lumina. If you do not agree with the terms, do not access or use the Services, website or any other aspect of Lumina’s business.
This Privacy Policy does not apply to any third party applications or software that integrates with the Services through the Lumina platform ("Third Party Services"), or any other third party products, services or businesses. In addition, a separate agreement governs delivery, access and use of the Services(the "Customer Agreement"), including the processing of any messages, files or other content submitted through Services accounts (collectively,"Customer Data").
The organization (e.g.,your employer or another entity or person) that entered into the Customer Agreement ("Customer") controls their instance of the Services (their "Workspace") and any associated Customer Data. If you have any questions about specific Workspace settings and privacy practices, please contact the Customer whose Workspace you use. If you have an account, you can check with your workspace administrator(s) for contact information. If you have received an invitation to join a Workspace but have not yet created an account, you should request assistance from the Customer that sent the invitation.
INFORMATION WE COLLECT AND RECEIVE
INFORMATION WE COLLECT AND RECEIVE
Lumina may collect and receive Customer Data and other information and data ("Other Information") in a variety of ways:
- Customer Data. Customers or individuals granted access to a Workspace by a Customer ("Authorized Users") routinely submit Customer Data to Lumina when using the Services.
- Other Information. Lumina also collects, generates and/or receives Other Information:
Lumina will collect billing and payment information which may include your credit card number, billing address, and other payment related information ("Billing Information"). Billing Information is collected and processed by our third-party payment processor operating as our agent. Lumina does not directly obtain or process any Billing Information.
- Usage Information.
- Cookie Information. Lumina uses cookies and similar technologies in our Websites and Services that help us collect Other Information. The Websites and Services may also include cookies and similar tracking technologies of third parties, which may collect Other Information about you via the Website and Services and across other websites and online services. For more details about how we use these technologies, please see our Cookie Policy.
- Third Party Services. Customer can choose to permit or restrict Third Party Services for their Workspace. Typically, Third Party Services are software that integrate with our Services, and Customer can permit its Authorized Users to enable and disable these integrations for their Workspace. Once enabled, the provider of a Third Party Service may share certain information with Lumina. For example, if a cloud storage application is enabled to permit files to be imported to a Workspace, we may receive user name and email address of Authorized Users, along with additional information that the application has elected to make available to Lumina to facilitate the integration. Authorized Users should check the privacy settings and notices in these Third Party Services to understand what data may be disclosed to Lumina. When a Third Party Service is enabled, Lumina is authorized to connect and access Other Information made available to Lumina in accordance with our agreement with the Third Party Provider. For example, you may choose to sign-in using your Google, or your company identity provider account. By signing-in using your Third Party account, the Third Party will supply Lumina any and all information that you have authorized the Third Party to provide to us. Such information may include your first and last name, unique identifier, e-mail address and picture. If you would like to know more about 3rd parties or any other information about them, you can write an email to compliance@Lumina.co.
- Contact Information. In accordance with the consent process provided by your device, any contact information that an Authorized User chooses to import is collected when using the Services.
- Third Party Data. Lumina may receive data about organizations, industries, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Other Information we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
- Additional Information Provided to Lumina. We receive Other Information when submitted to our Websites or if you participate in an activity or event, apply for a job, request support, interact with our social media accounts or otherwise communicate with Lumina.
HOW WE USE INFORMATION
Customer Data will be used by Lumina in accordance with Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Lumina is a processor of Customer Data and Customer is the controller. Customer may, for example, use the Services to grant and remove access to a Workspace, assign roles and configure settings, access, modify, export, share and remove Customer Data and otherwise apply its policies to the Services.
Lumina uses Other Information in furtherance of our legitimate interests in operating our Services, Websites and business. More specifically, Lumina uses Other Information:
- To provide, update, maintain and protect our Services, Websites and business. This includes use of Other Information to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or at an Authorized User’s request.
- As required by applicable law, legal process or regulation.
- To communicate with you by responding to your requests, comments and questions. If you contact us, we may use your Other Information to respond.
- To develop and provide search, learning and productivity tools and additional features. Lumina tries to make the Services as useful as possible for specific Workspaces and Authorized Users. For example, we may improve search functionality by using Other Information to help determine and rank the relevance of content, channels or expertise to an Authorized User, make Services suggestions based on historical use and predictive models, identify organizational trends and insights, to customize a Services experience or create new productivity features and products.
- To send emails and other communications. We may send you service, technical and other administrative emails, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them. In addition, we sometimes send emails about new product features, promotional communications or other news about Lumina. These are marketing messages so you can control whether you receive them.
- For billing, account management and other administrative matters. Lumina may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
- To investigate and help prevent security issues and abuse.
DATA RETENTION
Lumina will retain Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and as required by applicable law. Customer may also apply different settings to messages, files or other types of Customer Data. The deletion of Customer Data and other use of the Services by Customer may result in the deletion and/or de-identification of certain associated Other Information. For more detail, please contact Customer. Lumina may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Other Information after you have deactivated your account for the period of time needed for Lumina to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.
HOW WE SHARE AND DISCLOSE INFORMATION
HOW WE SHARE AND DISCLOSE INFORMATION
This section describes how Lumina may share and disclose Information. Customers determine their own policies and practices for the sharing and disclosure of Information, and Lumina does not control how they or any other third parties choose to share or disclose Information.
SECURITY
- Customer’s Instructions. Lumina will solely share and disclose Customer Data in accordance with a Customer’s instructions, including any applicable terms in the Customer Agreement and Customer’s use of Services functionality, and in compliance with applicable law and legal process.
- Displaying the Services. When an Authorized User submits Other Information, it may be displayed to other Authorized Users in the same or connected Workspaces. For example, an Authorized User’s email address may be displayed with their Workspace profile. Please consult support@Lumina.co for more information on Services functionality.
- Collaborating with Others. The Services provide different ways for Authorized Users working in independent Workspaces to collaborate. Other Information, such as an Authorized User’s profile Information, may be shared, subject to the policies and practices of the other Workspace(s).
- Third Party Service Providers and Partners. We may engage third party companies or individuals as service providers or business partners to process Other Information and support our business. These third parties may, for example, provide virtual computing and storage services.
- Third Party Services. Customer may enable or permit Authorized Users to enable Third Party Services. When enabled, Lumina may share Other Information with Third Party Services. Third Party Services are not owned or controlled by Lumina and third parties that have been granted access to Other Information may have their own policies and practices for its collection and use. Please check the privacy settings and notices in these Third Party Services or contact the provider for any questions at compliance@Lumina.co.
- Corporate Affiliates. Lumina may share Other Information with its corporate affiliates, parents and/or subsidiaries.
- During a Change to Lumina’s Business. If Lumina engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Lumina's assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Other Information may be shared or transferred, subject to standard confidentiality arrangements.
- Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Other Information for any purpose. For example, we may share aggregated or de-identified Other Information with prospects or partners for business or research purposes, such as telling a prospective Lumina customer the average amount of time spent within a typical Workspace.
- To Comply with Laws. If we receive a request for information, we may disclose Other Information if we reasonably believe disclosure is in accordance with or required by any applicable law, regulation or legal process. Except as expressly permitted by the Contract or in cases of emergency to avoid death or physical harm to individuals, Lumina will only disclose Customer Data in response to valid and binding compulsory legal process. Lumina requires a search warrant issued by a court of competent jurisdiction (a federal court or a court of general criminal jurisdiction of a State authorized by the law of that State to issue search warrants) to disclose Customer Data. All requests by courts, government agencies, or parties involved in litigation for Customer Data disclosures should be sent to compliance@Lumina.co. Requests should be prepared and served in accordance with applicable law. All requests should be narrow and focused on the specific Customer Data sought. All requests will be construed narrowly by Lumina, so please do not submit unnecessarily broad requests. Lumina will notify Customer before disclosing any of Customer’s Customer Data so that the Customer may seek protection from such disclosure, unless Lumina is prohibited from doing so or there is a clear indication of illegal conduct or risk of harm to people or property associated with the use of such Customer Data. If Lumina is legally prohibited from notifying Customer prior to disclosure, Lumina will take reasonable steps to notify Customer of the demand after the nondisclosure requirement expires. In case of international requests, Lumina requires that any individual issuing legal process or legal information requests (e.g., discovery requests, warrants, or subpoenas) to Lumina properly domesticate the process or request and serve Lumina in a jurisdiction where it is resident or has a registered agent to accept service on its behalf. Lumina does not accept legal process or requests directly from law enforcement entities outside the U.S. Foreign law enforcement agencies should proceed through a Mutual Legal Assistance Treaty or other diplomatic or legal means to obtain data through a court where Lumina is located.
- To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of Lumina or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
- With Consent. Lumina may share Other Information with third parties when we have consent to do so.
SECURITY
Lumina implements reasonable and appropriate security measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in processing and the nature of such data, and comply with applicable laws and regulations. Lumina is SOC 2 Type II compliant and will continue to be SOC 2 Type II compliant. Lumina conducts penetration tests and audits of its servers and networks every quarter.
Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Service may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail. Any unauthorized access to or use of this Service or information collected and maintained by this Service should be immediately brought to our attention by sending us an email at compliance@Lumina.co.
To learn more about current practices and policies regarding security and confidentiality of Customer Data and other information, please see our Security Page; we keep that document updated as these practices evolve over time.
CHANGES TO THIS PRIVACY POLICY
CHANGES TO THIS PRIVACY POLICY
Lumina may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, Lumina will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.
INTERNATIONAL DATA TRANSFERS PRIVACY SHIELD AND CONTRACTUAL TERMS
INTERNATIONAL DATA TRANSFERS PRIVACY SHIELD AND CONTRACTUAL TERMS
Lumina may transfer your Personal Data to countries other than the one in which you live. Our servers are located in the US. If you are located outside of the US, please be aware that any information provided to us, including personal information, will be transferred from your country of origin to the US. We deploy the following safeguards if Lumina transfers Personal Data originating from the European Union or Switzerland to other countries not deemed adequate under applicable data protection law:
- E.U.-U.S. Privacy Shield and Swiss-U.S. Privacy Shield.To comply with European Union and Swiss data protection laws, Lumina has certified to the Department of Commerce that it adheres to the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, Recourse, Enforcement and Liability, and the Supplemental Principles (the "Privacy Shield Principles"). If there is a conflict between this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. We are committed to applying the Privacy Shield Principles to all personal information received from the EU, Iceland, Liechtenstein, Norway (referred to herein as the "EU") and Switzerland in reliance upon the Privacy Shield. With regard to the Principle of Accountability for Onward Transfer, for example, we remain liable if our agent processes such personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage. To learn more about the Privacy Shield program, and to view our certification page, please visit: https://www.privacyshield.gov/
- Lumina is subject to the investigatory and enforcement powers of the Federal Trade Commission. We are committed to resolving complaints from EU and Swiss data subjects pursuant to the Recourse, Enforcement and Liability Principle.
- In compliance with the EU-US Privacy Shield Principles and Swiss-US Privacy Shield Principles, Lumina commits to resolve complaints about your privacy and our collection or use of your personal information. European Union or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact Lumina at compliance@Lumina.co.
- European Union Model Clauses. Lumina offers European Union Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our Customers that operate in the European Union, and other international transfers of Customer Data. A copy of our standard data processing addendum, incorporating Model Clauses, is available by request at compliance@Lumina.co.
Lumina has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.
YOUR DATA, YOUR RIGHTS
You have a right to be informed of Personal Data processed by Lumina, a right to rectification/correction, erasure and restriction of processing. You also have the right to receive from Lumina a structured, common and machine-readable format of Personal Data you provided to us.
We can only identify you via your email address and we can only adhere to your request and provide information if we have Personal Data about you through you having made contact with us directly and/or you using our site and/or service. We cannot provide, rectify or delete any data that we store on behalf of our Authorized Users or Customers.
To exercise any of the rights mentioned in this Privacy Policy and/or in the event of questions or comments relating to the use of Personal Data you may contact Lumina's compliance team: compliance@Lumina.co
Where you have provided consent, you may withdraw it at any time, without affecting the lawfulness of the processing that was carried out prior to withdrawing it. Whenever you withdraw consent, you acknowledge and accept that this may have a negative influence on the quality of Lumina Website or Services or even impede the provision of the Services . You further agree that Lumina shall not be held liable with respect to any loss and/or damage to your Personal Data if you choose to withdraw consent.Where Personal Data is processed for the above purposes on the basis of Lumina's legitimate interests, under the GDPR, you may object to such processing at any time. To do so please contact: compliance@Lumina.co
In addition, you have the right to lodge a complaint with the data protection authority in your jurisdiction. Pursuant to Article 27 of Europe’s General Data Protection Regulation (GDPR), Tactivos Inc., DBA Lumina has appointed European Data Protection Office (EDPO) as its GDPR representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR by sending an email to privacy@edpo.brussels, using EDPO’s online request form, or writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium.
YOUR CALIFORNIA PRIVACY RIGHTS
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.
This section describes your CCPA (California Consumer Privacy Act) rights and explains how to exercise those rights.
You have the right to request that Lumina disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
You have the right to request that Lumina delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing: sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
You have the right to request that Lumina delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email to compliance@Lumina.co.
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email to compliance@Lumina.co.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.