Last Updated 22-Dec-2019
IN ADDITION TO THIS POLICY, PLEASE REVIEW OUR END USER LICENSE AGREEMENT
, WHICH IS INCORPORATED HEREIN BY REFERENCE, TOGETHER WITH SUCH OTHER POLICIES OF WHICH YOU MAY BE NOTIFIED OF BY US FROM TIME TO TIME.
What types of information do we collect?
We collect the following types of data from you when you use the Services:
- Non-Personal Information: This information cannot be used to identify the user from which that data was collected. Such Non-Personal Information include aggregated usage information and technical information transmitted by your device, such as your approximate geo-location, hardware specifications, OS and SDK version, browser type and version, the date of the Software installation, your URL requests, and respective time stamps.
- Personal Information: Personal Information is information that identifies or may identify you. The only Personal Information we may collect and retain is your IP address, which is necessary in order to provide our Service. Any Non-Personal Information that is specifically connected or linked to any Personal Information, is treated by us as Personal Information as long as such connection or linkage exists.
Legal basis for processing
Processing of Personal Information is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and to comply with our legal obligations.
How we use the information we collect
We may use the information for the following:
- To provide our Services, including audits and calculations of fees;
- To perform analysis and research to improve the Service;
We may transfer or disclose Personal Information to our subsidiaries, affiliated companies, subcontractors, or such other trusted third party service providers or partners, who are located in different jurisdictions across the world, for the purpose of: (a) storing or processing such information on our behalf (e.g. on cloud computing services) or to assist us with our business operations, to authenticate your access and to provide and improve our Service; (b) performing research, technical diagnostics, analytics or statistical purposes.
The above shall be deemed as the categories of Personal Information we have disclosed for a business purpose in the preceding 12 months for the purpose of the California Consumer Privacy Act, Cal. Civ. Code §§ 1798.100 et seq. ("CCPA").
We have not sold (as this term is defined under the CCPA) Your Personal Information in the preceding 12 months.
Security and Confidentiality
We use industry-standard security tools and measures, as well as internal procedures and strict guidelines to prevent information misuse and data leakage. Our employees and contractors access the information on a need-to-know basis and subject to confidentiality obligations.
We use measures and procedures that substantially reduce the risks of data misuse, but we cannot guarantee that our systems will be absolutely safe. If you become aware of any potential data breach or security vulnerability, you are requested to contact us immediately. We will use all measures to investigate the incident, including preventive measures, as required.
Since we operate globally, it may be required to transfer your Personal Information to other countries worldwide. In these instances, we will take steps to ensure that a similar level of protection is given to your Personal Information through adequate legal mechanisms, in accordance with the GDPR.
Your Choices and Retention
We value your privacy and your control of personal information. You may therefore notify us that you wish to review your Personal Information or delete it. You can notify us by sending an email to firstname.lastname@example.org. You may choose at any time not to allow us or any third party to collect data about you. You may request to view or edit Personal Information that is stored about you.For EU residents
: Please note that the following rights specifically apply regarding your Personal Information: (1) Receive confirmation as to whether or not Personal Information concerning you is being processed, and access your stored Personal Information, together with supplementary information; (2) Receive a copy of Personal Information you directly volunteer to us in a structured, commonly used and machine-readable format; (3) Request rectification of your Personal Information that is in our control; (4) Request erasure of your Personal Information; (5) Object to the processing of Personal Information by us; (6) Request to restrict processing of your Personal Information by us; (7) Lodge a complaint with a supervisory authority.
Please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements.
As of January 1st 2020, California residents are granted with the right not to be discriminated against for having exercised their rights under the CCPA. Unless permitted by the CCPA, we will not:
- Deny you goods or services;
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
- Provide you a different level or quality of goods or services;
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
If you are a resident of California, United States, you have the right to send us a written request regarding a list of Personal Information categories that we may have disclosed to third parties or to which we may have given to third parties, and the details of such third parties. To exercise such right, you may contact us at: email@example.com.
We will retain your Personal Information for the duration required to provide our App, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing Personal Information, account opening documents, communications and anything else as required by applicable laws and regulations.
We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
Change of Ownership
In the event of a change of ownership or control of all or a part of Luminati, including without limitation through acquisition, merger, or sale, we reserve the right to transfer all or part of the Personal Information we store in our systems.
Copyright (c) 2020 Luminati. All Rights Reserved.