Who are we?
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
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.
- 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 may share your personal information in the following circumstances:
- 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.
Retention of your information
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.
Lumi Technologies Limited
124 Finchley Road
London NW3 5JS