LumenX
PRIVACY POLICY
This Privacy Policy is aimed to inform you (“You”) as a user of the LumenX app, a service available via the link https://quiz.lumenx.app (“Website”) and application software distributed via application store(s) App Store (“Application”, “App”), collectively referred to as the “Service,” about the collection, usage, and sharing of Your information:
BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) contact us and request deletion of your data; and (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android), any other app stores that may be available from time to time, or instructions on the Website; (c) delete the App from your devices; (d) leave the Website and not access or use it.
“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
“EEA” includes all current member states of the European Union and the European Free Trade Association. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.
“Process”, in respect of personal data, includes to collect, store, and disclose to others.
PERSONAL DATA CONTROLLER
Mara Apps FZC LLC, a company registered under the laws of the United Arab Emirates, having its registered office at BLB-S5-530, AMC- BOULEVARD-B BUILDING, Ajman Media City, Ajman, United Arab Emirates will be the controller of your personal data.
CATEGORIES OF PERSONAL DATA WE COLLECT
We collect data you give us voluntarily (for example, name or email address). We also collect data automatically (for example, your IP address).
2.1 Data you give us
We may ask you to provide information about yourself when you register for and/or use the Service. This information includes: email address, name, gender, date of birth, place of birth, and time of birth. We may also ask you to provide the date of birth, place of birth, and time of birth of your partner.
Note: Information about a third party
When You provide us with information about a third party, You must have the consent of that third party before providing us with that information. By providing us with information regarding a third party You warrant that You have their permission to provide that information to us.
2.2 Data we collect automatically:
2.2.1 Data about how you found us
We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).
2.2.2 Device and Location data
We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.
2.2.3 Usage data
We record how you interact with our Service. For example, we log your taps/clicks on certain areas of the interface, the features, and content you interact with, how often you use the Service, how long you are in the Service, your purchase orders.
2.2.4 Advertising IDs
We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).
2.2.5 Cookies
A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising.Cookies are used, in particular, to automatically recognize you the next time you visit our Website. As a result, the information, which you have earlier entered in certain fields on the Website may automatically appear the next time when you use our Service. Cookie data will be stored on your device and most of the time only for a limited time period.
2.2.6 Meta Pixel
We use "Meta Pixel" to collect data about your actions on our Service. This data may include which pages you visit, the time you spend on each page, and the actions you take. The data collected is used to measure the effectiveness of our advertising campaigns and to personalize the content and ads presented to you. The information collected through "Meta Pixel" is transmitted to Meta. Your browser establishes a direct connection with the Meta server as soon as you have agreed to the use of tracking technologies requiring your consent.The processing of this data by Meta takes place within the framework of Meta’s data policy - https://www.facebook.com/privacy/policy/. To opt-out from Meta’s interest-based ads follow these instructions from Meta: https://www.facebook.com/help/568137493302217.
2.2.7 If You purchase the access to or otherwise use the Service through the Website, we may additionally collect the following data.
Transaction data: when You make payments through the Website, You need to provide financial account data, such as Your credit card number, residence address, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used, payment transaction identification number.
FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
We process your personal data:
3.1 To provide our Service
This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.
To host personal data and enable our Service to operate and be distributed, we use Amazon Web Services, a hosting and backend service provided by Amazon, as well as Google Cloud Platform, a service provided by Google. These platforms ensure secure and efficient storage and distribution of the data necessary for our Service.
3.2 To customize your experience
We process your personal data, such as age, gender, date of birth, to adjust the content of the Service and provide content tailored to your personal preferences.
3.3 To provide you with customer support
We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you emails about, for example, the performance of our Service, payment transactions, notices regarding our Terms and Conditions of Use, this Privacy Policy or other documents that we make available from time to time.
3.4 To communicate with you regarding your use of our Service
We communicate with you, for example, by push notifications. These may include human design reminders, motivational messages or other information about the Service. As a result, you may, for example, receive a push notification every day at a particular time reminding you to check the app. To opt out of receiving push notifications, you need to change the settings on your device. We can also communicate with you via email when you make a purchase on the Website. These may include emails with information about the Service.
The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our Services’ users, as well as when they interacted with it, such as by tapping/clicking on links included in the message.
3.5 To research and analyze your use of the Service
This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing.
We use Facebook Analytics, which is a service provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people launch our App, how often users make purchases, and other interactions. Learn more about Facebook’s approach to data from its Privacy Policy.
Amplitude is an analytics service provided by Amplitude Inc. We use this tool to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone, tablet or laptop), unique identifiers (including advertising identifiers). Amplitude also allows us to track various interactions that occur in our App. As a result, Amplitude helps us to decide what features we should focus on. Amplitude provides more information on how they process data in its Privacy Policy.
We also use Firebase Analytics, which is an analytics service provided by Google. In order to understand Google's use of data, consult Google`s partner policy. Firebase Privacy information. Google's Privacy Policy.
3.6 To send you marketing communications
We may show you advertisements on our Service, send you push notifications or emails for marketing purposes. To opt out of receiving push notifications from us, you need to change the settings on your device. To opt out of receiving marketing emails, you need to unsubscribe following instructions in the footer of the marketing emails.
3.7 To personalize our ads
We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have installed our App, you might see ads of our products in your Facebook’s feed.
How to opt out or influence personalized advertising
iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to have personalized ads) in the same section.
Android: To opt-out of ads on an Android device, go to Settings > Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section (this also may help you to see less personalized ads).
In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
Network Advertising Initiative – http://optout.networkadvertising.org/
Digital Advertising Alliance – http://optout.aboutads.info/
Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices
Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/
DAA AppChoices page – http://www.aboutads.info/appchoices
Browsers: It is also possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser
Cookie settings in Internet Explorer - http://windows.microsoft.com/en-GB/internet-explorer/delete-manage-cookies
Cookie settings in Firefox - http://support.mozilla.com/en-US/kb/Cookies
Cookie settings in Chrome - https://support.google.com/chrome/answer/95647
We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.
We use Facebook pixel on the Website.Facebook pixel is a code placed on the Website collecting data that helps us track conversions from Facebook ads, build targeted audiences and remarket to people who have taken some action on the Website (for example, purchased a meal plan).
We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the Service (for example, visited certain sections of the Website). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here - https://www.facebook.com/help/568137493302217.
Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here - https://www.facebook.com/help/146952742043748 or adjust your ads settings on Facebook - https://www.facebook.com/adpreferences/.
Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear, for example, only to users that have conducted certain actions with our Website (for example, show our ads to users who have made a purchase). Some other examples of events that may be used for tailoring ads include, in particular, visiting our Website. Google allows its users to opt out of Google’s personalized ads - https://adssettings.google.com/authenticated and to prevent their data from being used by Google Analytics - https://tools.google.com/dlpage/gaoptout/.
Google AdSense is an ad delivery service provided by Google. Google AdSense enables publishers to monetize content online. AdSense selects ads based on the content of the website and the website's audience. To know more about how Google processes your data, visit its Privacy Policy - https://policies.google.com/technologies/partner-sites.
We also use Snapchat Advertising Platform together with Snapchat Audience Based Match, which is an ad delivery service provided by Snapchat that can link the activity of some users of our Website with the Snapchat advertising network and show some of our ads to them. As a result, you may see more ads on Snapchat in case you use our Website. Snapchat allows you to Opt Out - https://support.snapchat.com/en-US/a/advertising-preferences of their audience based ads. Privacy Policy - https://www.snap.com/en-US/privacy/privacy-policy/.
The Snap Pixel is a piece of JavaScript code that helps Advertisers measure the cross-device impact of Campaigns. Advertisers will be able to see how many Snapchatters take action on their website(s) after seeing their Ad. Snapchat allows you to Opt Out - https://support.snapchat.com/en-US/a/advertising-preferences of their audience based ads. Privacy Policy - https://www.snap.com/en-US/privacy/privacy-policy/.
TikTok Ads is the service provided by TikTok that can deliver ads to its users. The ads can be tailored to specific categories of users (for instance, based on their geographical location). TikTok’s Privacy Policy - https://ads.tiktok.com/i18n/official/policy/privacy.
We also use Twitter Ads provided by Twitter to deliver advertising. Twitter Ads allows us to choose specific audiences based on geographic areas or user’s interests. As a result, we may ask Twitter to deliver our ads to a certain list of users. Twitter allows you to opt-out its internet-based advertising - https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads. Privacy Policy - https://twitter.com/en/privacy.
3.8 To process your payments
We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment and we will be notified that the payment has been made. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors (Stripe, PayPal, Paddle, etc.). Our payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council. Payment processors who follow PCI-DSS requirements are committed to ensuring the secure handling of payment information.
3.9 To enforce our Terms and Conditions of Use and to prevent and combat fraud
We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).
3.10 To comply with legal obligations
We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (applies only to EEA-based users)
In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users.
4.1 We process your personal data under the following legal bases:
- to perform our contract with you;
Under this legal basis we:
- Provide our Service (in accordance with our Terms and Conditions of Use)
- Customize your experience
- Provide you with customer support
- Communicate with you regarding your use of our Service
- Process your payments
4.2 for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;
We rely on legitimate interests:
- to communicate with you regarding your use of our Service
This includes, for example, sending you an email to notify you that we have released a new product or reminding you to finish a purchase. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often.
- to research and analyze your use of the Service
Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Website easier and more enjoyable, or to introduce and test new features).
- to send you marketing communications
The legitimate interest we rely on for this processing is our interest to promote our Service, including new products and special offers, in a measured and appropriate way.
- to personalize our ads
The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
- to enforce our Terms and Conditions of Use and to prevent and combat fraud
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorized use of the Service, and non-compliance with our Terms and Conditions of Use.
4.3 to comply with legal obligations.
WITH WHOM WE SHARE YOUR PERSONAL DATA
We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:
5.1 Service providers
We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
- cloud storage providers (Amazon, Google Cloud)
- data analytics providers (Facebook, Amplitude, Google)
- measurement partners (AppsFlyer, Adapty)
- marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google, Snapchat, TikTok, Twitter, Pinterest)
- payment service providers (PayPal, Paddle, Stripe)
5.2 Law enforcement agencies and other public authorities
We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
5.3 Third parties as part of a merger or acquisition
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
To be in control of your personal data, you have the following rights:
Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Website.
Deleting your personal data. You can request erasure of your personal data as permitted by law.
When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such an event, we will fulfill your request after we have complied with our obligations.
Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof.
Additional information for EEA-based users:
If you are based in the EEA, you have the following rights in addition to the above:
The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send a respective request to us as described below.
To exercise any of your privacy rights, please send a request to the email - support@lumenx.app.
AGE LIMITATION
We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.
INTERNATIONAL DATA TRANSFERS
We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.
In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission, or (ii) the European Commission adequacy decisions about certain countries.
CHANGES TO THIS PRIVACY POLICY
We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.
FOR VIRGINIA RESIDENTS
This section supplements our Privacy Policy and only applies if you reside in the Commonwealth of Virginia. Where applicable, it describes how we use and process your personal data and explains your particular rights under Virginia Consumer Data Privacy Act (VCDPA).
Disclosures about the use of your personal data
We may collect and use certain information about you, some of which may be personal data (such as your age, gender, date of birth, or other information which may be reasonably linked to you), in order to operate the Service and to maximize your experience.
If you would like more information about the categories of your personal data we collect or the purposes for which we collect them, please read Section 2 and Section 3. To learn more about sharing your personal data with our business partners and other third parties, please read Section 5.
Data Rights
Section 6 of our Privacy Policy describes the data rights we offer to all users and how to execute these rights. This includes the right to access, review, correct, update your data, obtain a portable copy of your data, or delete data related to your stored preferences and your use of the Service. Before completing your request, we may require some information sufficient to authenticate your identity.
For App Store users
If we receive a refund request for an in-app purchase from a user, we reserve the right to provide Apple with information regarding the user's in-app purchase consumption. This includes the following data: time since the install, total app usage time, anonymous account identifier, whether the in-app purchase being refunded was fully consumed, whether the in-app purchase came with a trial period or not, the total amount spent, and the total amount refunded.
Additionally, VCDPA provides Virginia residents with these data rights:
Opt out of the Processing of your Personal Data for Targeted Advertising. In order to exercise your choice as a Virginia resident, please contact us: support@lumenx.app.
Please note that we do not process personal data for purposes of (1) the sale of personal data, as defined by the VCDPA, or (2) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
Confirm whether your Personal Data is being Processed. You may confirm whether your personal data is being processed by contacting us: support@lumenx.app.
Appeal a Case with regard to your request. In the case where we declined to take action on your data rights request or have rejected your request, you may contact us: support@lumenx.app to initiate an appeal of this decision. Please use the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email. Once we receive your appeal, we will notify you in writing within 60 days of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
If your appeal is denied, you may contact the Office of the Virginia Attorney General via the contact details available at www.virginia.gov/agencies/office-of-the-attorney-general/#vagov.
CALIFORNIA PRIVACY RIGHTS
California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes.
To obtain this information from us, please send an email: support@lumenx.app which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.
DATA RETENTION
We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
HOW “DO NOT TRACK” REQUESTS ARE HANDLED
Except as otherwise stipulated in this Privacy Policy, this Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
CONTACT US
- If through the Website – by Mara Apps FZC LLC, a company having its registered address at BLB-S5-530, AMC-Boulevard-B Building, Ajman Media City, Ajman, United Arab Emirates; and
- If via the App – by Mara Apps FZC LLC, a company having its registered address at BLB-S5-530, AMC-Boulevard-B Building, Ajman Media City, Ajman, United Arab Emirates, – collectively referred to as “we,” “us,” “our,” acting as data controllers for Your data.
BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 16 YEARS OF AGE (OR HAVE HAD YOUR PARENT OR GUARDIAN READ AND AGREE TO THIS PRIVACY POLICY FOR YOU). If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must (a) contact us and request deletion of your data; and (b) cancel any subscriptions using the functionality provided by Apple (if you are using iOS) or Google (if you are using Android), any other app stores that may be available from time to time, or instructions on the Website; (c) delete the App from your devices; (d) leave the Website and not access or use it.
“GDPR” means the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
“EEA” includes all current member states of the European Union and the European Free Trade Association. For the purpose of this policy EEA shall include the United Kingdom of Great Britain and Northern Ireland.
“Process”, in respect of personal data, includes to collect, store, and disclose to others.
PERSONAL DATA CONTROLLER
Mara Apps FZC LLC, a company registered under the laws of the United Arab Emirates, having its registered office at BLB-S5-530, AMC- BOULEVARD-B BUILDING, Ajman Media City, Ajman, United Arab Emirates will be the controller of your personal data.
CATEGORIES OF PERSONAL DATA WE COLLECT
We collect data you give us voluntarily (for example, name or email address). We also collect data automatically (for example, your IP address).
2.1 Data you give us
We may ask you to provide information about yourself when you register for and/or use the Service. This information includes: email address, name, gender, date of birth, place of birth, and time of birth. We may also ask you to provide the date of birth, place of birth, and time of birth of your partner.
Note: Information about a third party
When You provide us with information about a third party, You must have the consent of that third party before providing us with that information. By providing us with information regarding a third party You warrant that You have their permission to provide that information to us.
2.2 Data we collect automatically:
2.2.1 Data about how you found us
We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).
2.2.2 Device and Location data
We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.
2.2.3 Usage data
We record how you interact with our Service. For example, we log your taps/clicks on certain areas of the interface, the features, and content you interact with, how often you use the Service, how long you are in the Service, your purchase orders.
2.2.4 Advertising IDs
We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).
2.2.5 Cookies
A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. Cookies can be either session cookies or persistent cookies. A session cookie expires when you close your browser and is used to make it easier for you to navigate our Service. A persistent cookie remains on your hard drive for an extended period of time. We also use tracking pixels that set cookies to assist with delivering online advertising.Cookies are used, in particular, to automatically recognize you the next time you visit our Website. As a result, the information, which you have earlier entered in certain fields on the Website may automatically appear the next time when you use our Service. Cookie data will be stored on your device and most of the time only for a limited time period.
2.2.6 Meta Pixel
We use "Meta Pixel" to collect data about your actions on our Service. This data may include which pages you visit, the time you spend on each page, and the actions you take. The data collected is used to measure the effectiveness of our advertising campaigns and to personalize the content and ads presented to you. The information collected through "Meta Pixel" is transmitted to Meta. Your browser establishes a direct connection with the Meta server as soon as you have agreed to the use of tracking technologies requiring your consent.The processing of this data by Meta takes place within the framework of Meta’s data policy - https://www.facebook.com/privacy/policy/. To opt-out from Meta’s interest-based ads follow these instructions from Meta: https://www.facebook.com/help/568137493302217.
2.2.7 If You purchase the access to or otherwise use the Service through the Website, we may additionally collect the following data.
Transaction data: when You make payments through the Website, You need to provide financial account data, such as Your credit card number, residence address, to our third-party service providers. We do not collect or store full credit card number data, though we may receive credit card-related data, data about the transaction, including: date, time and amount of the transaction, the type of payment method used, payment transaction identification number.
FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
We process your personal data:
3.1 To provide our Service
This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.
To host personal data and enable our Service to operate and be distributed, we use Amazon Web Services, a hosting and backend service provided by Amazon, as well as Google Cloud Platform, a service provided by Google. These platforms ensure secure and efficient storage and distribution of the data necessary for our Service.
3.2 To customize your experience
We process your personal data, such as age, gender, date of birth, to adjust the content of the Service and provide content tailored to your personal preferences.
3.3 To provide you with customer support
We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. For this purpose, we may send you emails about, for example, the performance of our Service, payment transactions, notices regarding our Terms and Conditions of Use, this Privacy Policy or other documents that we make available from time to time.
3.4 To communicate with you regarding your use of our Service
We communicate with you, for example, by push notifications. These may include human design reminders, motivational messages or other information about the Service. As a result, you may, for example, receive a push notification every day at a particular time reminding you to check the app. To opt out of receiving push notifications, you need to change the settings on your device. We can also communicate with you via email when you make a purchase on the Website. These may include emails with information about the Service.
The services that we use for these purposes may collect data concerning the date and time when the message was viewed by our Services’ users, as well as when they interacted with it, such as by tapping/clicking on links included in the message.
3.5 To research and analyze your use of the Service
This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the Service and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what categories of users use our Services. As a consequence, we often decide how to improve the Service based on the results obtained from this processing.
We use Facebook Analytics, which is a service provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people launch our App, how often users make purchases, and other interactions. Learn more about Facebook’s approach to data from its Privacy Policy.
Amplitude is an analytics service provided by Amplitude Inc. We use this tool to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone, tablet or laptop), unique identifiers (including advertising identifiers). Amplitude also allows us to track various interactions that occur in our App. As a result, Amplitude helps us to decide what features we should focus on. Amplitude provides more information on how they process data in its Privacy Policy.
We also use Firebase Analytics, which is an analytics service provided by Google. In order to understand Google's use of data, consult Google`s partner policy. Firebase Privacy information. Google's Privacy Policy.
3.6 To send you marketing communications
We may show you advertisements on our Service, send you push notifications or emails for marketing purposes. To opt out of receiving push notifications from us, you need to change the settings on your device. To opt out of receiving marketing emails, you need to unsubscribe following instructions in the footer of the marketing emails.
3.7 To personalize our ads
We and our partners use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have installed our App, you might see ads of our products in your Facebook’s feed.
How to opt out or influence personalized advertising
iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to have personalized ads) in the same section.
Android: To opt-out of ads on an Android device, go to Settings > Privacy > Ads and enable Opt out of Ads personalization. In addition, you can reset your advertising identifier in the same section (this also may help you to see less personalized ads).
In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:
Network Advertising Initiative – http://optout.networkadvertising.org/
Digital Advertising Alliance – http://optout.aboutads.info/
Digital Advertising Alliance (Canada) – http://youradchoices.ca/choices
Digital Advertising Alliance (EU) – http://www.youronlinechoices.com/
DAA AppChoices page – http://www.aboutads.info/appchoices
Browsers: It is also possible to stop your browser from accepting cookies altogether by changing your browser’s cookie settings. You can usually find these settings in the “options” or “preferences” menu of your browser. The following links may be helpful, or you can use the “Help” option in your browser
Cookie settings in Internet Explorer - http://windows.microsoft.com/en-GB/internet-explorer/delete-manage-cookies
Cookie settings in Firefox - http://support.mozilla.com/en-US/kb/Cookies
Cookie settings in Chrome - https://support.google.com/chrome/answer/95647
We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.
We use Facebook pixel on the Website.Facebook pixel is a code placed on the Website collecting data that helps us track conversions from Facebook ads, build targeted audiences and remarket to people who have taken some action on the Website (for example, purchased a meal plan).
We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the Service (for example, visited certain sections of the Website). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here - https://www.facebook.com/help/568137493302217.
Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here - https://www.facebook.com/help/146952742043748 or adjust your ads settings on Facebook - https://www.facebook.com/adpreferences/.
Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear, for example, only to users that have conducted certain actions with our Website (for example, show our ads to users who have made a purchase). Some other examples of events that may be used for tailoring ads include, in particular, visiting our Website. Google allows its users to opt out of Google’s personalized ads - https://adssettings.google.com/authenticated and to prevent their data from being used by Google Analytics - https://tools.google.com/dlpage/gaoptout/.
Google AdSense is an ad delivery service provided by Google. Google AdSense enables publishers to monetize content online. AdSense selects ads based on the content of the website and the website's audience. To know more about how Google processes your data, visit its Privacy Policy - https://policies.google.com/technologies/partner-sites.
We also use Snapchat Advertising Platform together with Snapchat Audience Based Match, which is an ad delivery service provided by Snapchat that can link the activity of some users of our Website with the Snapchat advertising network and show some of our ads to them. As a result, you may see more ads on Snapchat in case you use our Website. Snapchat allows you to Opt Out - https://support.snapchat.com/en-US/a/advertising-preferences of their audience based ads. Privacy Policy - https://www.snap.com/en-US/privacy/privacy-policy/.
The Snap Pixel is a piece of JavaScript code that helps Advertisers measure the cross-device impact of Campaigns. Advertisers will be able to see how many Snapchatters take action on their website(s) after seeing their Ad. Snapchat allows you to Opt Out - https://support.snapchat.com/en-US/a/advertising-preferences of their audience based ads. Privacy Policy - https://www.snap.com/en-US/privacy/privacy-policy/.
TikTok Ads is the service provided by TikTok that can deliver ads to its users. The ads can be tailored to specific categories of users (for instance, based on their geographical location). TikTok’s Privacy Policy - https://ads.tiktok.com/i18n/official/policy/privacy.
We also use Twitter Ads provided by Twitter to deliver advertising. Twitter Ads allows us to choose specific audiences based on geographic areas or user’s interests. As a result, we may ask Twitter to deliver our ads to a certain list of users. Twitter allows you to opt-out its internet-based advertising - https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads. Privacy Policy - https://twitter.com/en/privacy.
3.8 To process your payments
We provide paid products and/or services within the Service. For this purpose, we use third-party services for payment processing (for example, payment processors). As a result of this processing, you will be able to make a payment and we will be notified that the payment has been made. We will not store or collect your payment card details ourselves. This information will be provided directly to our third-party payment processors (Stripe, PayPal, Paddle, etc.). Our payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council. Payment processors who follow PCI-DSS requirements are committed to ensuring the secure handling of payment information.
3.9 To enforce our Terms and Conditions of Use and to prevent and combat fraud
We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use).
3.10 To comply with legal obligations
We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.
UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (applies only to EEA-based users)
In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 3. This section applies only to EEA-based users.
4.1 We process your personal data under the following legal bases:
- to perform our contract with you;
Under this legal basis we:
- Provide our Service (in accordance with our Terms and Conditions of Use)
- Customize your experience
- Provide you with customer support
- Communicate with you regarding your use of our Service
- Process your payments
4.2 for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;
We rely on legitimate interests:
- to communicate with you regarding your use of our Service
This includes, for example, sending you an email to notify you that we have released a new product or reminding you to finish a purchase. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often.
- to research and analyze your use of the Service
Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the Website easier and more enjoyable, or to introduce and test new features).
- to send you marketing communications
The legitimate interest we rely on for this processing is our interest to promote our Service, including new products and special offers, in a measured and appropriate way.
- to personalize our ads
The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.
- to enforce our Terms and Conditions of Use and to prevent and combat fraud
Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorized use of the Service, and non-compliance with our Terms and Conditions of Use.
4.3 to comply with legal obligations.
WITH WHOM WE SHARE YOUR PERSONAL DATA
We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 3 of this Privacy Policy. The types of third parties we share information with include, in particular:
5.1 Service providers
We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:
- cloud storage providers (Amazon, Google Cloud)
- data analytics providers (Facebook, Amplitude, Google)
- measurement partners (AppsFlyer, Adapty)
- marketing partners (in particular, social media networks, marketing agencies, email delivery services; Facebook, Google, Snapchat, TikTok, Twitter, Pinterest)
- payment service providers (PayPal, Paddle, Stripe)
5.2 Law enforcement agencies and other public authorities
We may use and disclose personal data to enforce our Terms and Conditions of Use, to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.
5.3 Third parties as part of a merger or acquisition
As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
To be in control of your personal data, you have the following rights:
Accessing / reviewing / updating / correcting your personal data. You may review, edit, or change the personal data that you had previously provided on the Website.
Deleting your personal data. You can request erasure of your personal data as permitted by law.
When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases, we may be legally required to keep some of the data for a certain time; in such an event, we will fulfill your request after we have complied with our obligations.
Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof.
Additional information for EEA-based users:
If you are based in the EEA, you have the following rights in addition to the above:
The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.
The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send a respective request to us as described below.
To exercise any of your privacy rights, please send a request to the email - support@lumenx.app.
AGE LIMITATION
We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us.
INTERNATIONAL DATA TRANSFERS
We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.
In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission, or (ii) the European Commission adequacy decisions about certain countries.
CHANGES TO THIS PRIVACY POLICY
We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified by available means such as email and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.
FOR VIRGINIA RESIDENTS
This section supplements our Privacy Policy and only applies if you reside in the Commonwealth of Virginia. Where applicable, it describes how we use and process your personal data and explains your particular rights under Virginia Consumer Data Privacy Act (VCDPA).
Disclosures about the use of your personal data
We may collect and use certain information about you, some of which may be personal data (such as your age, gender, date of birth, or other information which may be reasonably linked to you), in order to operate the Service and to maximize your experience.
If you would like more information about the categories of your personal data we collect or the purposes for which we collect them, please read Section 2 and Section 3. To learn more about sharing your personal data with our business partners and other third parties, please read Section 5.
Data Rights
Section 6 of our Privacy Policy describes the data rights we offer to all users and how to execute these rights. This includes the right to access, review, correct, update your data, obtain a portable copy of your data, or delete data related to your stored preferences and your use of the Service. Before completing your request, we may require some information sufficient to authenticate your identity.
For App Store users
If we receive a refund request for an in-app purchase from a user, we reserve the right to provide Apple with information regarding the user's in-app purchase consumption. This includes the following data: time since the install, total app usage time, anonymous account identifier, whether the in-app purchase being refunded was fully consumed, whether the in-app purchase came with a trial period or not, the total amount spent, and the total amount refunded.
Additionally, VCDPA provides Virginia residents with these data rights:
Opt out of the Processing of your Personal Data for Targeted Advertising. In order to exercise your choice as a Virginia resident, please contact us: support@lumenx.app.
Please note that we do not process personal data for purposes of (1) the sale of personal data, as defined by the VCDPA, or (2) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
Confirm whether your Personal Data is being Processed. You may confirm whether your personal data is being processed by contacting us: support@lumenx.app.
Appeal a Case with regard to your request. In the case where we declined to take action on your data rights request or have rejected your request, you may contact us: support@lumenx.app to initiate an appeal of this decision. Please use the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email. Once we receive your appeal, we will notify you in writing within 60 days of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
If your appeal is denied, you may contact the Office of the Virginia Attorney General via the contact details available at www.virginia.gov/agencies/office-of-the-attorney-general/#vagov.
CALIFORNIA PRIVACY RIGHTS
California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes.
To obtain this information from us, please send an email: support@lumenx.app which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.
DATA RETENTION
We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you). We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
HOW “DO NOT TRACK” REQUESTS ARE HANDLED
Except as otherwise stipulated in this Privacy Policy, this Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
CONTACT US
You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us: support@lumenx.app.