Lumeo, Inc. (“Lumeo,” “we,” “our,” and/or “us”) values the privacy of individuals who use our applications, website, www.lumeo.com, or any services that link to this Privacy Policy (collectively, our “Services”).  This privacy policy (“Privacy Policy”) explains how we collect, use, and share Personal Information from or about Lumeo users or their devices.  As used in this Privacy Policy, “Personal Information” means any information relating to an identified or identifiable individual.  By using our Services, you agree to the collection, use, disclosure, sharing, and procedures this Privacy Policy describes.  Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.

INFORMATION WE COLLECT

We may collect a variety of Personal Information from or about you or your devices from various sources, as described below.

A. Information You Provide to Us

Registration and Account Information.  When you sign up for an account or register to use our Services, we will ask you for your Personal Information to create your account, including your email address, password, and organization name

Video Content.  We will collect the Personal Information that is included in any video content you provide or otherwise make available to us in connection with your use of our Services.

Communications.  If you contact us directly, we may receive other Personal Information about you.  For example, when you contact us to learn more about Lumeo via our website, we will receive your name, email address, job title, and any Personal Information you include in the contents of your message.  If you subscribe to our newsletter, we will collect your email address.  When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and to improve our Services.

Careers.  If you decide to apply for a job with us, you may submit your contact information and your resume online.  We will collect the information you choose to provide on your resume or application, such as your education and employment experience.  You may also apply through a third-party service such as LinkedIn.  If you do so, we will collect any information you make available to us via such third-party platform.

B. Information We Collect When You Use Our Services

Location Information.  When you use our Services, we may receive your location information (for example, your IP address may indicate your general geographic region).

Device Information.  We may receive information about the device and software you use to access our Services, such as internet protocol (IP) address, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.

Usage Information.  To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view and the dates and times of your visits.

Information from Cookies and Similar Technologies.  We and our third-party partners may collect Personal Information using cookies, which are small files of letters and numbers that we store on your browser or the hard drive of your computer.  They contain information that is transferred to your computer’s hard drive.  We and our third-party partners may also use pixel tags and web beacons on our Services.  These are tiny graphic images placed on web pages or in our emails that allow us to determine whether you have performed a specific action.  We use cookies, beacons, invisible tags, and similar technologies (collectively “Cookies”) to collect information about your browsing activities and to distinguish you from other users of our Services.  This aids your experience when you use our Services and allows us to improve the functionality of our Services.  Cookies can be used for performance management (i.e., collecting information on how our Services are being used for analytics purposes).  They can also be used for functionality management, enabling us to make your visit more efficient by, for example, remembering language preferences, passwords, and log-in details.  Below is an overview of the types of Cookies we and third parties may use to collect Personal Information.

• • Strictly Necessary Cookies.  Some Cookies are strictly necessary to make our Services available to you.  We cannot provide you with our Services without this type of Cookies.  We use the following necessary Cookies:

• • Functional Cookies.  Functional Cookies are used to recognize you when you return to our Services.  This enables us to adapt our content for you and remember your preferences.  For example, we use functional Cookies to remember your choice of language or region.  We use the following functional Cookies:

• • Analytical or Performance Cookies.  We also use Cookies for website analytics purposes in order to operate, maintain and improve our Services.  We may use our own analytics Cookies or use third-party analytics providers such as Google Analytics.  Google uses the data collected to track and monitor the use of our Service. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.  We also encourage you to review Google’s policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.  These providers may also collect information about your use of other websites, apps, and online resources.  We also use the following analytical or performance Cookies:

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings.  Please note that if you delete or choose not to accept cookies from our Services, you may not be able to utilize the features of our Services to its fullest potential.  You can find more information about your rights and choices, and how to block the use of certain Cookies in the section Your Rights and Choices below.

C. Information We Receive from Third Parties

Third Parties.  We may receive additional Personal Information about you from third parties such as data or marketing partners and combine it with other information we have about you.  If you choose to submit information to social media websites operated by us, such as Facebook or Twitter, we may receive Personal Information about you, including your profile information and your use of the third-party account.  If you wish to limit the Personal Information available to us from third-party services, you should visit the privacy settings of your third-party accounts to learn about your options.

HOW WE USE THE INFORMATION WE COLLECT

We use the Personal Information we collect:

• To track user engagement with our Services;
• To provide, maintain, improve, debug, support, and enhance our Services;
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
• For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you;
• To generate de-identified and aggregated data and use it for any lawful purpose;
• To find and prevent fraud, and respond to trust and safety issues that may arise;
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• For other purposes for which we provide specific notice at the time the information is collected.

LEGAL BASES FOR PROCESSING EUROPEAN INFORMATION 

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), we only process your Personal Information when we have a valid “legal basis,” including as set forth below.

• • Consent.  We may process your Personal Information where you have consented to certain processing of your Personal Information.  For example, we may process your Personal Information to send you marketing communications or to use Cookies where you have consented to such use.

• • Contractual Necessity.  We may process your Personal Information where required to provide you with our Services.  For example, we may need to process your Personal Information to respond to your inquiries or requests.

• • Compliance with a Legal Obligation.  We may process your Personal Information where we have a legal obligation to do so.  For example, we may process your Personal Information to comply with tax and accounting obligations.

• • Legitimate Interests.  We may process your Personal Information where we or a third party have a legitimate interest in processing your Personal Information.  Specifically, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services.  We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

HOW WE SHARE THE INFORMATION WE COLLECT 

Affiliates.  We may share any information we receive with our affiliates for any of the purposes described in this Privacy Policy.

Vendors and Service Providers.  We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.

Marketing.  We do not rent, sell, or share information about you with nonaffiliated companies for their direct marketing purposes unless we have your permission.

Analytics Partners.  We use analytics services such as Google Analytics to collect and process certain analytics data.  These services may also collect information about your use of other websites, apps, and online resources.  You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

As Required by Law and Similar Disclosures.  We may access, preserve, and disclose your Personal Information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety.  For the avoidance of doubt, the disclosure of your Personal Information may occur if you post any objectionable content on or through our Services.

Merger, Sale, or Other Asset Transfers.  We may disclose and transfer your Personal Information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our business or assets. 

Consent.  We may also disclose Personal Information from or about you or your devices with your permission.

YOUR RIGHTS AND CHOICES

Marketing Communications.  You can unsubscribe from our promotional emails via the link provided in the emails.  Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Do Not Track.  There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals. 

Your European Privacy Rights.  If you are located in the EEA or the UK, you have additional rights described below.

• • You may request access to the Personal Information we maintain about you, update, and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have your Personal Information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company.  In addition, you also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.
  • You may withdraw any consent you previously provided to us regarding the processing of your Personal Information at any time and free of charge.  We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

You may exercise these rights by contacting us using the contact details at the end of this Privacy Policy.  Before fulfilling your request, we may ask you to provide reasonable information to verify your identity.  Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain Personal Information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

How to Block Cookies.  You can block Cookies by setting your internet browser to block some or all Cookies.  However, if you use your browser settings to block all Cookies (including essential Cookies) you may not be able to access all or parts of our Services.  By using our Services, you consent to our use of Cookies and our processing of Personal Information collected through such Cookies, in accordance with this Privacy Policy.  You can withdraw your consent at any time by deleting placed Cookies and disabling Cookies in your browser, or as explained below.  You can change your browser settings to block or notify you when you receive a Cookie, delete Cookies or browse our Services using your browser’s anonymous usage setting.  Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings.  If you do not agree to our use of Cookies or similar technologies which store information on your device, you should change your browser settings accordingly.  You should understand that some features of our Services may not function properly if you do not accept Cookies or these technologies.  Where required by applicable law, you will be asked to consent to certain Cookies and similar technologies before we use or install them on your computer or other device.

If you choose not to provide us with information we collect, some features of our Services may not work as intended.

THIRD PARTIES

Our Services may contain links to other websites, products, or services that we do not own or operate (“Third-Party Services”).  We are not responsible for the privacy practices of these Third-Party Services.  Please be aware that this Privacy Policy does not apply to your activities on these Third-Party Services or any information you disclose to these Third-Party Services.  We encourage you to read the privacy policies of these Third-Party Services before providing them with your Personal Information.

RETENTION

When you request that we do so, we take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period.  When we process Personal Information for our own purposes, we determine the retention period taking into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrollment with our Services, the impact on our Services we provide to you if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.

SECURITY

We make reasonable efforts to protect your Personal Information by using physical and electronic safeguards designed to improve the security of the Personal Information we maintain.  As our Services are hosted electronically, however, we can make no guarantees as to the security or privacy of your Personal Information.

INTERNATIONAL USERS AND VISITORS

Our Services are hosted in the United States (“U.S.”) and intended for customers and visitors located within the U.S.  If you choose to use our Services from the EEA, the UK, or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your Personal Information outside of those regions to the U.S. for storage and processing.  We may transfer Personal Information from the EEA or the UK to the U.S. and other third countries based on European Commission-approved or UK Government-approved Standard Contractual Clauses, or otherwise in accordance with applicable data protection laws.  Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating our Services.  By providing any information, including Personal Information, on or to our Services, you consent to such transfer, storage, and processing.

CHILDREN’S PRIVACY

We do not knowingly collect, maintain, or use Personal Information from children under 13 years of age (“Minors”), and no parts of our Services are directed to Minors.  If you learn that a Minor has provided us with Personal Information in violation of this Privacy Policy, then you may alert us at [email protected].

CHANGES TO THIS PRIVACY POLICY

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted.  If we materially change the ways in which we use or share Personal Information previously collected from you through our Services, we will attempt to notify you through our Services, by email, or other means.

CONTACT INFORMATION

If you have any questions, comments, or concerns about our processing activities, please email us at [email protected].

Lumeo, Inc.

66 Franklin St. Ste. 300

Oakland, CA 94607