Lumo Health Privacy Policy

1. Introduction

This privacy policy (Policy) relates to your personal information in connection with your use of and access to the Lumo Health website (https://www.lumohealth.care/) (the Lumo Health Platform) and any services
provided by Lumo Health (the Lumo Health Platform and services together forming the Lumo Health Services).

We are committed to protecting your information and your right to privacy. If you have any questions or
concerns about our Policy, or our practices with regards to your personal information, please contact us via hello@lumohealth.care.

When you use the Lumo Health Services, you trust us with your information and we take your privacy very
seriously. We seek to explain to you in the clearest way possible what information we collect, how we use it
and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is
important. If there are any terms in this Policy that you do not agree with, please discontinue your use of the Lumo Health Services.

2. Changes to this policy or your personal information

We review this Policy regularly and it is your responsibility to check regularly and determine whether you still agree to comply with the Policy. If you do not agree to any changes to this Policy then you must immediately stop using the Lumo Health Services. In the event we make any significant changes to this Policy we will use our reasonable endeavours to inform you of such changes in advance in writing.

It is important that the personal information we hold about you is true, complete, accurate and current. Accordingly, you must notify us of any changes to your personal information (for example, if you change your email address).

3. About us

The Lumo Health Services are owned and operated by Lumo Health LTD (trading as “Lumo Health”), a company registered in England and Wales with company number 13018371 and whose registered office is situated at 85 Great Portland Street, First Floor, London, United Kingdom, W1W 7LT (Lumo Health/we/us/our). Lumo Health is the controller (also known as a data controller) of, and is responsible for, your personal information. The term “you” refers to the user wishing to access and/or use the Lumo Health Services.

It is important that the personal information we hold about you is true, complete, accurate and current.
Accordingly, you must notify us of any changes to your personal information (for example, if you change your email address).

4. Information we may collect about you

4.1 Personal information you disclose to us

In Short: We collect personal information that you provide to us including information such as your name, address, contact information, date of birth, job title (in relation to therapists), social media handles/URLs and payment information.

(a) Where and how we collect personal information

We collect personal information that you voluntarily provide to us when registering to use and actually using the Lumo Health Services, or otherwise contacting us.

If you apply or are put forward for a role with us, or work for us (either directly or indirectly) for any period of time, we also collect your personal information, which may include your contact details, financial and payment details, details of your education, qualifications and skills, your marital status, your nationality, your NI number, your job title and your CV.

If you give us information on behalf of another individual, for example when putting that individual forward as your emergency/alternate contact or referee or next of kin, or by acting as that individual’s emergency/alternate contact, referee or next of kin, in providing that information to us you are confirming that you have sought and obtained, from that individual, permission for you to:

Consent on their behalf to the processing of their personal data;
Receive on their behalf any data protection notices; and
If relevant, consent to the transfer of their personal data abroad,

and you shall indemnify us against any claims, actions, proceedings, losses, damages, costs (including
reasonable legal costs) and expenses (including taxation), in each case of any nature whatsoever, arising out of or in connection with your failure to obtain these permissions.

More particularly, the personal information that we collect depends on the context of your interactions with us, the choices you make and the products and features you use. For example:

We collect personal information via our website, mobile applications and other technical systems.
We collect personal information when you use our website or mobile applications to sign up to, participate in or receive a service from us, for example where you contact us, request information online, report an issue, provide feedback or enter a live chat. We also collect personal information where you share documents, messages, photos, videos and/or messages with us through the Platform.
Our website also uses cookies and collects IP addresses (for more information on this, see section 17, Cookies).
We may monitor and record communications with you (such as telephone conversations and emails). We may do this for a number of reasons, such as to check the quality of our customer service, for training purposes, to prevent fraud or to make sure we are complying with legal requirements.
If you visit our offices, some personal data may also be collected from monitoring devices and systems such as closed-circuit TV (CCTV).

(b) The types of personal information we may collect

When you use the Lumo Health Services and/or when you otherwise deal with us, we may collect the following information about you (the Information):

Identity Data, which includes your first name, last name, date of birth and gender.
Contact Data, which means the data we use to contact you including your address, email address and phone number.
Therapist professional data, which includes a therapist’s professional title, training details and qualifications, details of any professional registrations or accreditations, details of any Disclose and Barring Service checks.
Financial Data, which means the payment method and card association used to process any payments you make. We do not store or process your card details ourselves, they are processed and stored via one of our contracted third-party service providers. We encrypt your payment card details in your browser and securely transfer this data to our relevant third-party payment provider to process a payment.
Health data, which includes clinical information, and any information about your health and wellbeing, which you share with us in response to questions or surveys when using the Lumo Health Services.
Emergency contact information, including your GP’s name and contact details, and the name and contact details of your next of kin or emergency contact.
Health insurance information, which includes the name of your health insurance provider and its contact details, your policy number and the authorisation code issued to you by the health insurance provider.
Transaction Data, which means details about transactions you have made in connection with the Lumo Health Services, including the payments to and from you along with other details of services you have purchased from us on your own behalf or on behalf of others.
Profile Data, which includes your username, email address and log-in data, details of any purchases or orders made by you, and your interests, preferences, feedback and survey or questionnaire responses. If you are a therapist, this will also include details of any sessions booked with patients through the Lumo Health Platform (e.g. session date; price; date of the booking; date the session was provided).
Usage Data, which includes Information about how you use the Lumo Health Services. This includes your browsing patterns and Information such as how long you might spend on one of our webpages on the Lumo Health Platform and what you look at and for, the page that referred you to the Lumo Health Platform and the click stream during your visit to our website, page response times, and page interaction Information (for example, clicks you make on a page).
Marketing and Communications Data, which includes your preferences with regards to receiving marketing from us and your other communication preferences.
Other Information relevant to services, customer surveys, questionnaires and/or offers.

More particularly, the personal information that we collect depends on the context of your interactions with us, the choices you make and the products and features you use. For example:

We collect personal information via our website, mobile applications and other technical systems.
We collect personal information when you use our website or mobile applications to sign up to, participate in or receive a service from us, for example where you contact us, request information online, report an issue, provide feedback or enter a live chat. We also collect personal information where you share documents, messages, photos, videos and/or messages with us through the Platform.
Our website also uses cookies and collects IP addresses (for more information on this, see section 17, Cookies).
We may monitor and record communications with you (such as telephone conversations and emails). We may do this for a number of reasons, such as to check the quality of our customer service, for training purposes, to prevent fraud or to make sure we are complying with legal requirements.
If you visit our offices, some personal data may also be collected from monitoring devices and systems such as closed-circuit TV (CCTV).

4.2 Sensitive personal information

In Short: We collect sensitive personal data due to the nature of the services we provide.

Due to the nature of the services we provide, you will be asked to provide sensitive personal information. When we request such information, we will explain why we are requesting it and how we will use it, either in this Policy or separately.

Sensitive personal information includes information relating to your ethnic origin, your physical or mental health, your political opinions, religious beliefs, whether you belong to a trade union, your sexual life, and whether you have committed a criminal offence. We will only collect your sensitive personal information with your explicit consent.

4.3 Personal information from third parties

In Short: We may receive information about you from third parties, and we may use this information to provide, improve and personalise the Lumo Health Services.

Occasionally we may receive information about you from other sources, which we will add to the information we already hold about you in order to help us provide, improve and personalise the Lumo Health Services. If you apply for a job with us, we may also receive information from those who provide references relating to your prospective or actual engagement or employment.

4.4 Information automatically collected

In Short: Some Information – such as IP addresses and/or browser and device characteristics – is collected automatically when you use the Lumo Health Platform.

We automatically collect certain Information when you visit, use or navigate the Lumo Health Platform. This Information does not reveal your specific identity (unless your device name is the same as your name) but may include device and usage Information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, Information about how and when you use the Lumo Health Platform and other technical Information. This Information is primarily needed to maintain the security and operation of the Lumo Health Platform, and for our internal analytics and reporting purposes.

Like many businesses, we also collect Information through cookies and similar technologies. You can find out more about this in Section 17, Cookies.

5. How do we use your information?

In Short: We process your Information for purposes based on legitimate business interests, the fulfilment of our contract with you, compliance with our legal obligations, and/or your consent.

We use your Information collected via the Lumo Health Services for a variety of business purposes described below. We process your Information for these purposes in reliance on our legitimate business interests (Business Purposes), in order to enter into or perform a contract with you (Contractual Reasons), with your consent (Consent), and/or for compliance with our legal obligations (Legal Reasons). We indicate the specific processing grounds we rely on next to each purpose listed below.

We may process your Information for the following purposes:

To take steps towards entering into a contract with you, to provide the Lumo Health Services and to claim any right to be paid under our Terms (Contractual Reasons). This includes collecting and using your personal information to:
Enter into a contract with you;
Manage any accounts you hold with us;
Contact you for reasons related to the Lumo Health Services;
Enable us to follow up on enquiries made by you in relation to the Lumo Health Services and/or to provide information you have requested;
Contact your GP and/or next of kin or your emergency/alternate contact(s) in order to get in touch with you when we have failed to do so using your own contact details;
Contact your referee(s) or to obtain a reference for a job that you are applying for;
Deal with payment for the Lumo Health Services;
Notify you of any changes to our Lumo Health Platform or to the Lumo Health Services that may affect you; and
Resolve disputes or collect overdue payments.
To provide you with information and support in relation to your use of the Lumo Health Platform, including facilitating introductions to therapists and appointment bookings, in connection with the Lumo Health Services (Contractual Reasons).
To pass it onto third party therapists in connection with your use of the Lumo Health Services (Contractual Reasons).
To contact you regarding enquiries you have made in relation to the Lumo Health Services.
To facilitate a recruitment process in which you are involved.
To deal with any health insurance company in connection with your health insurance policy (where applicable).
To follow up on enquiries in accordance with industry guidelines and providing quotes for software/details of offers (Business Purposes).
To send administrative Information to you for Business Purposes, Legal Reasons and/or possibly Contractual Reasons. We may use your Information to send you product, service and new feature information and/or information about changes to our Terms and policies, as may be in place from time to time.
To send you marketing and promotional communications for Business Purposes and/or with your Consent. We and/or our brand partners may use your Information for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails (see below for further details).
To facilitate account creation and the log-in process with your Consent. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the Information we are consequently allowed to collect from those third parties to facilitate account creation and the log-in process. See the section below headed "How Do We Handle Your Social Media Log-ins" for further information.
To administer promotions for our Business Purposes and/or with your Consent.
To request feedback for our Business Purposes and/or with your Consent. For example, we may use your Information to request feedback and to contact you about your use of the Lumo Health Platform.
To protect the Lumo Health Services for Business Purposes and/or Legal Reasons. We may use your Information as part of our efforts to keep the Lumo Health Services safe and secure (for example, for the purposes of monitoring and/or preventing fraud).
To enforce our Terms and policies for Business Purposes, Legal Reasons and/or possibly Contractual Reasons.
To respond to legal requests and prevent harm for Legal Reasons. For example, if we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
We may use your Information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the Lumo Health Services, our products and services, our marketing and your experience.

6. Will your information be shared with anyone?

In Short: We only share Information for Contractual Reasons, to fulfil our Business Purposes, or with your Consent.

We only share and disclose your Information in the following situations:

Contractual. We may share Information with third parties and partners to enable any orders for products or services, or obligations arising out of any such orders, to be fulfilled.
Compliance with Legal Obligations. We may disclose your Information where we are legally required to do so in order to comply with applicable laws, governmental requests, judicial proceedings, court orders, or legal processes, such as in response to a court order or a subpoena (including in response to requests from public authorities in order to meet national security or law enforcement requirements).
Vital Interests. We may disclose your Information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, illegal activities or situations involving potential threats to the safety of any person, or where we believe it is necessary for the purpose of providing evidence in connection with litigation proceedings in which we are involved.
Third Party Service Providers. We may share your Information with third party vendors, service providers, credit reference agencies, trade associations of which we are a member, credit card associations, contractors or agents who perform services and require access to such Information to carry out that work. Examples include: software developers working for Lumo Health or therapists with whom you connect through the Lumo Health Platform. Such third parties will only have access to your Information to the extent that they need to perform those services. They are required to keep your Information confidential and may not use it other than as we ask them to and always in accordance with this Policy.
Business Transfers. We may share or transfer your Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Third Party Advertisers. We may use third party advertising companies to serve ads when you visit the Lumo Health Platform. These companies may use Information about your visits to the Lumo Health Platform and other websites that are contained in web cookies and other tracking technologies in order to provide personalised advertisements about goods and services that may be of interest to you. See Section 17, Cookies, for further Information.
Business Partners. Provided you have given us Consent to do so we may share your Information with our business partners to offer you certain products, services or promotions.
With your Consent. We may disclose your Information for any other purpose with your Consent, including with any person who you have named as a person we can contact to discuss your account and any agent or representative of yours].

We may disclose aggregated, anonymous Information (i.e. Information from which you cannot be personally identified), or insights based on such anonymous Information, to selected third parties (including your employer or health insurance company, if they are paying for the Lumo Health Services on your behalf), including (without limitation) analytics and search engine providers to assist us in the improvement and optimisation of the Lumo Health Services. In such circumstances we will not disclose any Information which can identify you personally.

7. Is your information transferred internationally?

In Short: We currently do not transfer any personal data outside of the UK/Europe. If this changes, we may transfer, store, and process your Information in countries other than the UK and Europe, but will take all reasonable steps to ensure it is protected.

If we transfer your Information outside of the UK/Europe, we will take all reasonably practicable measures to protect your Information in accordance with this Policy and applicable laws. To the extent that any transfer requires approved safeguards to be in place we will only transfer your Information to countries that have been deemed to provide an adequate level of protection for personal data. Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK. Please contact us if you want further information on the specific mechanism(s) used by us when transferring your personal data out of the UK/Europe.

8. Third party websites

In Short: We are not responsible for the safety of any Information that you share with third party providers who feature or advertise, but are not affiliated with, the Lumo Health Services.

The Lumo Health Platform may feature links to third party websites or social media channels that are not affiliated with us and which may link to other websites, online services or mobile applications. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Policy.

We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services or applications that may be linked to or from the Lumo Health Platform. You should review the policies of such third parties and contact them directly if you have any related questions.

9. For how long do we keep your information?

In Short: We keep your Information for as long as necessary to fulfil the purposes outlined in this Policy, unless a longer retention period is permitted or required by law.

We will only keep your Information for as long as it is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law (such as tax law, accounting requirements or other legal or regulatory requirements).

When we have no ongoing Business Purpose to justify the processing of your Information, we will either delete or anonymise it, or, if this is not possible (for example, because your Information has been stored in backup archives), then we will securely store your Information and isolate it from any further processing until deletion is possible.

10. How do we keep your information safe?

In Short: We aim to protect your Information through a system of organisational and technical security measures.

We have implemented appropriate technical and organisational security measures designed to protect the security of any Information we process. For example, we store your personal data on secure servers and company data is stored on separate secure encrypted disks when not in use.

We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable supervisory body of a suspected data breach where we are legally required to do so.

However, please also remember that we cannot guarantee that the Internet itself is 100% secure. Although we will use our reasonable endeavours to protect your Information, we cannot guarantee the security or integrity of personal Information that is transferred from you or to you via the Internet. Transmission of personal Information to and from the Lumo Health Platform is therefore at your own risk. You should only access our services within a secure environment.

11. Do we collect information from minors?

In Short: We take steps to ensure that the Lumo Health Services are only used by those over 16 years of age and we do not knowingly collect data from or market to children under 16 years of age.

We do not knowingly solicit data from or market to children under 16 years of age. By using the Lumo Health Services, you represent that you are at least 16 years of age. If we learn that Information from users less than 16 years of age has been collected, we will deactivate the relevant account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under 16 years of age, please contact us immediately via hello@lumohealth.care.

12. How do we handle your social media log-ins

Summary: If you choose to register or log into our website using a social media account, we may have access to certain Information about you.

The Lumo Health Platform may offer you the ability to register and log-in using your third-party social media account details (e.g. Facebook etc). Where you choose to do this, we will receive certain Information from your social media provider. The Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture and other Information that you choose to make public. If you log-in using Facebook, we may also request access to other information related to your account, such as friends, check-ins and likes, and you may choose to grant or deny us access to each individual permission.

The Information that you post, transmit, or otherwise make available on such social media platforms may be viewed and/or used by other users of those networks and we have no control over that viewing and use and cannot prevent further use of that Information by third parties.

If you choose to link your Lumo Health profile to a social media account, Information that you provide to us in the process may be included on your Lumo Health profile. Additionally, your contacts on the social media platform(s) (Friends) may be able to see your activity on the Lumo Health Platform. A link to your public profile on the social media site may be added to your Lumo Health profile and other members and users of the Lumo Health Services may be able to see any Friends or links (e.g. friends of Friends) via the social network(s) that you have in common with them.

When you interact with us through social media networks, you acknowledge that we may access your Information that is held by that account, solely in accordance with your social media privacy settings. Any links to social media are not under our control and remain solely your responsibility. You acknowledge that any Information posted via social media through the Lumo Health Platform, or via any third party which you allow to access your content, is posted entirely at your own risk and that by posting to a public platform you make that Information visible to third parties who can use that Information at their discretion.

Please note that we do not control, and are not responsible for, other uses of your Information by your third-party social media provider(s). We recommend that you review their privacy policies to understand how they collect, use and share your Information, and how you can set your privacy preferences on their sites and apps.]

13. Your consent to processing

You will be required to give Consent to certain processing activities before we can process your Information. Where applicable, we will seek Consent from you when you first submit Information to or through the Lumo Health Services.

If you have previously given your Consent you may freely withdraw such Consent at any time. You can do this by emailing hello@lumohealth.care or, where applicable, clicking the ‘Unsubscribe’ button that appears in mailing list communications.

If you withdraw your Consent, and if we do not have another legal basis for processing your Information, then we will stop processing your Information. If we do have another legal basis for processing your Information, then we may continue to do so subject to your legal rights.

Please note that if we need to process your Information in order for you to use the Lumo Health Services and you object or do not provide Consent to us processing your Information, you accept that the Lumo Health Services will no longer be available to you.

14. Marketing and opting out

If you have given Consent to marketing we may contact you about our products, services, promotions and special offers. If you no longer wish to receive such Information, you can withdraw your Consent at any time by sending an email to hello@lumohealth.care or unsubscribing from the communications.

If you have given Consent, we may share your Information with carefully selected third party organisations and business partners and they may contact you directly. If you would prefer to no longer receive direct marketing communications from third parties and partners after previously giving your Consent, please contact those third parties and partners directly to withdraw the Consent.

Where you opt out of receiving marketing messages, this will not apply to personal data provided to us in connection with your purchase of a product or service or your involvement in other related transactions.

15. Account information

You may at any time review or change the Information in your account by logging into your Lumo Health account.

If you wish to terminate your Lumo Health account, please contact us via hello@lumohealth.care and we can arrange this for you. Some Information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and/or comply with legal requirements.

16. What are your privacy rights?

In Short: You have certain rights in respect of your Information.

You have certain rights in relation to the Information that we hold about you. Details of these rights and how to exercise them are set out below. Please note that we will require evidence of your identity before we are able to respond to any requests. This is a security measure to ensure that your Information is not disclosed to a person who does not have the right to receive it. We may also contact you to ask you for further Information in relation to your request to speed up our response. To exercise or discuss any of your rights, please contact us via hello@lumohealth.care.

Right of Access. You have the right at any time to ask us for a copy of the Information that we hold about you and to check that we are lawfully processing it. Where we have good reason, and where data protection law permits, we can refuse your request for a copy of your Information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reason(s) for doing so.
Right of Correction or Completion. If Information we hold about you is not accurate or is out of date and requires amendment or correction, you have a right to have the data rectified or completed.
Right of Erasure. In certain circumstances, you have the right to request that the Information we hold about you is erased (for example, if the Information is no longer necessary for the purposes for which it was collected or processed or our processing of the Information is based only on your Consent and there are no other legal grounds on which we may process the Information).
Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your Information (for example, if we are processing your Information on the basis of our legitimate interests but there are no longer any compelling legitimate grounds to justify our processing overriding your rights and interests).
You may also have the right to restrict our use of your Information, for example during a period in which we are verifying the accuracy of your Information in circumstances where you have challenged the accuracy of that Information.
Right of Data Portability. In certain instances, you have a right to receive the Information that we hold about you (or a portion thereof) in a structured, commonly used and machine-readable format.

In such circumstances, you can ask us to transmit your Information to you or directly to a third-party organisation on your behalf.

While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organisation’s systems. We are also unable to comply with requests that relate to personal Information of others without their consent.

If we are relying on Consent to process your Information, you have the right to withdraw your Consent at any time. Please note however that this will not affect the lawfulness of the processing that occurred before the withdrawal of such Consent.

17. Cookies

The Lumo Health Platform uses cookies to distinguish you from other users of the Lumo Health Platform. This helps us to provide you with a good experience when you browse the Lumo Health Platform and also allows us to improve the Lumo Health Platform. By continuing to browse the Lumo Health Platform, you are agreeing to our use of cookies. Please be aware that restricting cookies may impact on your user experience and may prevent you from using parts of the Lumo Health Platform.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer, if you consent. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

Strictly necessary cookies. These cookies are required for the operation of the Lumo Health Platform. They include, for example, cookies that enable you to log in to secure areas of the Lumo Health Platform, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. These cookies allow us to recognise, and count the number of, visitors and to see how visitors move around the Lumo Health Platform when they are using it. This helps us to improve the way the Lumo Health Platform works, for example by ensuring that users are finding what they are looking for easily.
Functionality cookies. These cookies enable us to recognise you when you return to the Lumo Health Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to the Lumo Health Platform, the pages you have visited and the links you have followed. We will use this information to make the Lumo Health Platform and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for related purposes.

You can find more information about the individual cookies we use and the purposes for which we use them in the below table:

Purpose

Name/Details

Third Party Tracking

iubenda Cookie Solution (consent Cookie) (iubenda srl)
iubenda consent Cookie (_iub_cs-X) is set by the iubenda Cookie Solution and stores user preferences related to Trackers in the local domain.
Personal Data processed: Tracker.Place of processing: Italy – Privacy Policy.Storage duration:_iub_cs-*: 1 year

Registration & Authentication

By registering or authenticating, users allow Lumo Health to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Lumo Health will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Auth0 (Auth0, Inc)
Auth0 is a registration and authentication service provided by Auth0, Inc. To simplify the registration and authentication process, Auth0 can make use of third-party identity providers and save the information on its platform.Personal Data processed: email address, first name, last name, password, picture, Tracker and various types of Data as specified in the privacy policy of the service.
Place of processing: European Union – Privacy Policy.

Facebook Authentication (Facebook Ireland Ltd)
Facebook Authentication is a registration and authentication service provided by Facebook Ireland Ltd and is connected to the Facebook social network.
Personal Data processed: Tracker and various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Storage duration:
_fbp: 3 months
fbssls_*: duration of the session
Facebook Oauth (Facebook Ireland Ltd)
Facebook Oauth is a registration and authentication service provided by Facebook Ireland Ltd and is connected to the Facebook social network.
Personal Data processed: Tracker and various types of Data.
Place of processing: Ireland – Privacy Policy.
Storage duration:
_fbp: 3 months

Experience enhancement – access to third-party accounts

This type of service allows Lumo Health to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the user.
Linkedin account access (LinkedIn Corporation)
This service allows Lumo Health to connect with the user's account on Linkedin, provided by LinkedIn Corporation.
Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy.
Storage duration:lang: duration of the session
lissc: 1 year

Experience enhancement – Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of Lumo Health and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when users do not use it.
Google Maps widget (Google Ireland Limited)
Google Maps is a maps visualization service provided by Google Ireland Limited that allows Lumo Health to incorporate content of this kind on its pages.
Personal Data processed: Tracker and Usage Data.
Place of processing: Ireland – Privacy Policy.

Measurement – analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of user behaviour.
Amplitude Analytics (Amplitude Inc.)
Amplitude Analytics is an analytics service provided by Amplitude Inc.
Personal Data processed: Tracker and Usage Data.
Place of processing: United States – Privacy Policy.
Storage duration:
amp_*: indefinite

LinkedIn conversion tracking (LinkedIn Insight Tag) (LinkedIn Corporation)
LinkedIn conversion tracking (LinkedIn Insight Tag) is an analytics and behavioural targeting service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on Lumo Health. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables to target groups of users on the base of their past use of Lumo Health.

users may opt out of behavioural targeting features through their device settings, their LinkedIn account settings or by visiting the AdChoices opt-out page.
Personal Data processed: device information, Tracker and Usage Data.
Place of processing: United States – Privacy Policy.
Storage duration:
AnalyticsSyncHistory: 1 month
JSESSIONID: duration of the session
userMatchHistory: 1 month
bcookie: 1 year
bscookie: 1 year
lang: duration of the session
lidc: 1 day
lms_ads: 1 month
lms_analytics: 1 month

Measurement – Anonymised analytics services

The services contained in this section allow the Owner, through the use of third-party Trackers, to collect and manage analytics in an anonymized form.
Google Analytics with anonymized IP (Google Ireland Limited)
Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of Lumo Health, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Personal Data processed: Tracker and Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Storage duration:
AMP_TOKEN: 1 hour
_ga: 2 years
_gac*: 3 months
_gat: 1 minute
_gid: 1 day

Targeting & Advertising – Remarketing and behavioural targeting

This type of service allows Lumo Health and its partners to inform, optimize and serve advertising based on past use of Lumo Health by the user.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioural targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, users may opt out by visiting the Network Advertising Initiative opt-out page.
users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Targeting & Advertising –user database management

This type of service allows Lumo Health to build user profiles by starting from an email address, a personal name, or other information that the user provides to Lumo Health, as well as to track user activities through analytics features. This Personal Data may also be matched with publicly available information about the user (such as social networks' profiles) and used to build private profiles that Lumo Health can display and use for improving Lumo Health.
Some of these services may also enable the sending of timed messages to the user, such as emails based on specific actions performed on Lumo Health.

Managing Cookies

The most popular web browsers all allow you to manage cookies. You can choose to accept or reject all cookies, or just specific types of cookies.

How to manage cookies in different web browsers

Most browsers will allow you to turn off cookies, although please note that turning off cookies may restrict your use of the Lumo Health Platform.

The following links provide information on how to modify the cookies settings on some popular browsers:

We strongly recommend that you leave cookies active, because they enable you to take advantage of the most attractive features of the Lumo Health Platform, but this remains your personal choice.

You can also visit the About Cookies website, for more information about cookies and how to manage them.

Third Party Cookies

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some 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 Lumo Health Platform.

If you would like more information about these third-party cookies, it is available from www.youronlinechoices.com/uk.

Embedded Content

Sometimes we embed content (for example images or videos) from third party websites such as YouTube. As a result, when you visit a page on our Lumo Health Platform that features such content, you may be presented with cookies from these third-party websites. We do not control these cookies and cannot prevent these websites or domains from collecting information relating to your use of such content.

You should check the relevant third-party website for more information about that third party, its website or domain, its use of cookies and your data, and how to opt out of cookies. Such third parties may still gather usage information about you (e.g. number of views, plays, loads etc.) and may also be able to work out who you are even if you are not logged in to their services.

18. Contact us

We welcome your feedback and questions on this Policy. If you wish to contact us about this Policy or have any other questions, please email us via hello@lumohealth.care.

You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK supervisory authority for data protection issues (https://ico.org.uk/concerns). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.