Luma is brought to you by Entia Ltd. (“Entia”, “Company”, “our”, “we” or “us”). This policy explains how we use your personal information to provide you with the Luma Website and products and services.
Entia is committed to protecting our user’s privacy and takes its responsibility regarding the security of user information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.
This Policy sets out the following:
- What personal data we collect and process about you in connection with your relationship with us as a user of the Luma Website and products and services
- Where we obtain the data from
- What we do with that data
- How we store the data
- Who we transfer/disclose that data to
- How we deal with your data protection rights
- And how we comply with the data protection rules
All personal data is collected and processed in accordance with UK and EU data protection laws.
Entia is the “data controller” of all personal information that is collected and used about users of Luma products and services and the Luma Website for the purposes of the General Data Protection Regulation (GDPR).
What Personal Data we collect
Personal data means any information relating to you which allows us to identify you, such as your name and contact details. There are certain areas of the Luma Website where we collect personal data in order to provide support, products and services to you. Specifically, we may collect the following categories of information:
- Name, home address, e-mail address, telephone number, credit/debit card or other payment details.
- The communications you exchange with us or direct to us via letters, emails, chat service and calls.
- Details about your current and past health conditions. We will only collect this data with your explicit consent.
- Information about your use of our website.
- Location, including real-time geographic location of your computer or device through your IP Address.
Personal details about your physical or mental health, alleged commission or conviction of criminal offences are considered “sensitive” personal data under applicable data protection laws. We will process any such data with strict confidentiality and only if we are required to by law or you have given explicit consent to do so.
We will also collect personal data from you (e.g. name, email and address and phone number) if you call our customer service line for assistance or support.
How is your personal data collected?
We collect information about you if you use our Website or if you fill in forms (paper or online) or correspond with us (for example, by email or chat) or by registering to use our support or training services or call our customer service line. If you contact us, we will keep a record of that correspondence
What we use your personal data for, why and for how long
Your data may be used for the following purposes:
- Providing products and services you request: we use the information you give us to perform the services you have asked for in relation to our devices and services.
- Credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes.
- Customer Services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us.
- Marketing: from time to time we will contact you with information regarding our devices and services via e-communications. You will have the choice to opt in to receiving such communications by signing up via our website. You will also be given the opportunity on every e-communication that we send you to indicate that you no longer wish to receive our direct marketing material.
- Security, health, administrative, crime prevention/detection: we may pass your information to government authorities or enforcement bodies for compliance with legal requirements
- Research: we regularly carry out user research and may collect your personal data in order to inform our decisions about what products and services we provide.
We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for.
In most cases we will need to process your personal data so we can provide you with support with regards to using the Luma Website and products and services.
We may also process your personal data for one or more of the following:
- To comply with a legal obligation (e.g. criminal law)
- You have consented to us using your personal data (e.g. for marketing related uses);
- To protect your vital interests or those of another person (e.g. in case of a medical emergency)
- It is in our legitimate interests in operating as a company (e.g. for administrative purposes).
We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.
We must also consider periods for which we might need to retain personal data in order to meet our legal obligations or to deal with complaints, queries and to protect our legal rights in the event of a claim being made.
When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.
Security of your personal data
We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage. The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry standard method of encrypting personal information so that they can be securely transferred over the Internet.
International Data Transfer
Entia uses service providers who operate in multiple jurisdictions, some of which are not located in the European Economic Area (EEA), such as the USA. While countries outside the EEA do not always have strong data protection laws, we require all service providers to process your information in a secure manner and in accordance with UK and EU law on data protection. Entia will avoid where possible transferring your data outside the EEA. We utilise standard means under EU law to legitimise data transfers outside the EEA.
Sharing your personal data
a. Government authorities, law enforcement bodies and regulators for compliance with legal requirements
b. Trusted service providers we are using to run our business such as bookkeeping agents, cloud service and email service providers which provide our computing infrastructure and email marketing service providers assisting our marketing team with running customer surveys and providing targeted marketing campaigns.
c. Legal and other professional advisers, law courts and law enforcement bodies in all countries we operate in in order to enforce our legal rights in relation to our contract with you
Cookies and site tracking
Cookies are small text files that are transferred to your computer's hard drive through your web browser to enable us to recognise your browser and help us to track visitors to our site; thus enabling us to understand better the products and services that will be most suitable to you. A cookie contains your information to allow us to identify your computer when you travel around our site for the purpose of helping you buy our products. Most Web browsers automatically accept cookies, but, if you wish, you can change these browser settings by accepting, rejecting and deleting cookies. The "help" portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to change these settings, you may find that certain functions and features will not work as intended. The cookies we use do not detect any information stored on your computers.
For more information about cookies and how to stop cookies being installed visit the following website: http://www.allaboutcookies.org... use tracking software to monitor customer traffic patterns and site usage to help us develop the design and layout of the websites. This software does not enable us to capture any personal information.
Data Protection Officer
We have appointed a Data Protection Officer (“DPO”) to oversee compliance with this policy. You have the right to make a complaint at any time to a supervisory authority. The Information Commissioner's Office is the lead data protection supervisory authority for Entia as a UK data controller.
Your data protection rights
Under certain circumstances, by law you have the right to:
- Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
- Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Object to automated decision-making including profiling, that is not to be subject to any automated decision-making by us using your personal information or profiling of you.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
- Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically usable format and to be able to transfer your data to another party in an electronically usable format.
- Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you want to exercise any of these rights, then please contact our DPO by email: firstname.lastname@example.org.
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
- August 2020:
- First version.