Privacy policy

Who are we?
Lumi Technologies Limited (trading as Lumi Mobile, 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 offices in New York, Hong Kong, Vaasa (Finland) and London.
Lumi uses a range of mobile technology products and services to collect and analyse personal information, in order 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
The purpose of this Privacy Policy is to give you the basic information about who we are, what information we might collect and what we do with it, and to explain what your rights are.

However, because our business involves collecting and analysing personal information at the request of our clients ("Clients"), we only collect and process your information in accordance with their instructions (i.e., as data processor). We are required to comply with our Clients' directions as to how they want us to use your information, subject always to applicable laws, and the terms of any assurances they have given you about privacy.

Those Clients therefore remain responsible (i.e., as data controller) for ensuring that your information is kept secure and handled in accordance with your legal rights and the terms of any consents given by you, even when it is in our possession. They will provide you with a copy of their Privacy Policy, which sets out further detail on those issues.

The purpose of this Privacy Policy is to inform you how we use, store, protect and disclose your personal information when it is in our hands.

Lumi Technologies Ltd. are fully compliant with the UK Data Protection act 1988.

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 Technologies Limited 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 countries around the world, including outside the European Economic area.

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

Where does Lumi get personal information from?
We collect personal information from a range of sources:

  • when you visit our website(s);
  • when you have downloaded and installed one of our mobile applications;
  • when responding to one of our online or email surveys or questionnaires; or
  • when using one of our products or services,

(together, our “Services”).

Because our business revolves around helping organisations (our “Clients”) to reach and better understand their customer base, we may also receive information about you from those Clients, so that we can help them get in touch with you or analyse the information they have about you.

What information do we collect?
Our apps and products collect and analyse a range of information. Depending on the particular app you are using, this may include:

  • Biographical information, such as your name, email address and date of birth
  • Location Information, meaning data which reveals the geographic location of you and your mobile device - provided that you have given your consent. Note that this may include information about locations you ‘check in’ to using apps on your device or social networking sites, but because our technology allows us to track your location on a semi-continuous basis, it will also include location information generally, whether you actively choose to disclose it or not. We will only collect your location information where you have agreed to us doing so by clicking 'OK' on your mobile device.
  • Mobile Usage Information, which refers to information about your use of your mobile device which we are able to collect once you have downloaded and installed our app on your device. The exact nature of the personal information that is collected about you may differ depend on the make of mobile device that you use, but can include the following:
    • Information about calls you make or receive on your mobile device (the time and duration of that call, and the number of the person you are calling. We do not collect or record the content of your calls.
    • Information about when you send or receive text messages, SMS or MMS and the number of the person you have sent them to or receive them from. We do not collect or record the content of your text messages or MMS.
    • Information about emails that you send on your mobile device – the time they are sent, how long you spend composing emails, and the email address they are sent to. We do not collect or record the content of your emails.
    • Information about your location (please see below).
    • Information about your internet browsing habits – how much time you spend browsing the internet on your mobile device, the websites you visit, and the terms of any search you carry out.
    • Whether people you call, email or send SMS or MMS to are already in your ‘Contacts’ in your mobile device.
    • Information about the type of mobile device you own, when and for how long you charge it, its battery status, whether it is switched on, off or in a stand-by or ‘Airplane’ mode.
    • Information about which mobile network you use, which wi-fi networks you connect to, and at what times.
    • Information about the volume of data downloaded to your phone, the times that you download that data and the method of connection you use (wi-fi or mobile network).
    • Information about your usage of other apps on your phone, including the identity of the apps, when you downloaded them, how often you use them and how long for
    • Information we can deduce from combining the above information – e.g., what apps you were using just before you searched for particular information using your mobile device’s internet browser, or how often you call, email or text a particular contact, or the geographic location in which you are most likely to charge your device, make a telephone call, or download an app.
  • App Metadata, which means information about the way in which our app is used and functions on your mobile device – e.g., how long it takes to transmit information to us, the volume of information etc. Metadata does not include any personal information about you.
  • Survey or other information, which means information contained in the responses given by you to survey questions in the app, or any other information you choose to provide using the app from time to time.

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 as otherwise described in this Privacy Policy.
We may share your personal information in the following circumstances:

  • Our Clients who have asked us to collect it on their behalf. You can find out more about those Clients by reading the section of this Privacy Policy which applies to the Lumi product or service you're using.
  • Our partners, who provide us with IT and support services to help us manage and store information. Again, you can find out more about these companies by reading the section of this Privacy Policy which applies to the Lumi product or service you're using.
  • We may share your personal information with our affiliated companies, including RealityMine Limited.
  • We may disclose your personal information if we believe that it is reasonably necessary to comply with a law, regulation or legal request.
  • We may sell, transfer or otherwise share some or all of our assets, including your personal information, in connection with a merger, acquisition, reorganisation or sale of assets or in the event of bankruptcy. We will endeavour to provide you with notice prior to the transfer of your personal information to the new entity.
  • RealityMine Limited: The information collected may be transmitted to RealityMine for processing and analysis. RealityMine is an affiliated company of Lumi Technologies Limited.

We take the privacy of your personal information very seriously, and use a number of methods to try to keep it secure from loss or unauthorized use or access when it is in our possession or control, including reasonable physical, technical and organizational measures which restrict who may access your personal information. For example, your personal information is encrypted when stored or transmitted by us using secure socket technology (SSL).

Where required by applicable laws, we will notify you of any loss of or unauthorized access to your personal information and comply with the appropriate regulatory authorities in investigating such incidents, in accordance with applicable laws.

International transfers of information
We are a global company with service providers and Clients operating in several countries around the world. In particular, 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 the European Economic Area. 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, as described in this Privacy Policy. 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, because we are subject to our Client’s instructions, they may ask us to retain it for longer or to delete it sooner, depending on their requirements.
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.

We automatically collect information on our website(s) using “cookies”, which are small data files stored on your computer. We use cookies to analyse how you use our website, in order to improve user experience, and to make it easier for you to use and navigate the 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 arrive at our website.

Technologies, privacy laws and our way of doing business change from time to time, and 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. We will always try to notify you when we make those changes, and will publish the updated versions on our website (

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 or write to us at:

Lumi Technologies Limited
Bohunt Manor
Portsmouth Road
Liphook, Hampshire, GU30 7DL
United Kingdom

Try our Lumi Say app

Lumi Say combines an online dashboard for building surveys, management of respondents and reporting, with a mobile application available across iPhone and Android. Try our Lumi Say app now. Download (see below options), open the app and click 'Try It Now' on the login page.

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