California Notice: Disclosures for California Residents

Last updated August 17, 2023

This privacy notice for California residents (the “CA Privacy Notice”) supplements the information contained in the Privacy Notice (“Lumio,” “we,” or “us”) Privacy Notice and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with applicable California law, including the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020 (collectively, the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this CA Privacy Notice. Any other capitalized but undefined terms shall have the meanings set forth in the Privacy Notice.

Please note that as used in this CA Privacy Notice “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include deidentified or aggregated consumer information, publicly available information from government records, or information outside of the CCPA’s scope.

Use the links below to toggle to each section. 

Contents

• Collection And Use Of Personal Information.
• Disclosure Of Information For A Business Purpose.
• Sale Or Sharing Of Your Personal Information.
• Rights And Choices Of California Residents.
• Opt-Out Rights.
• Access Rights.
• Data Correction Rights.
• Deletion Rights.
• Exercising Your Rights.
• Non-Discrimination.
• Other California Privacy Rights.
• Changes To Our Ca Privacy Notice.
• Contact Information.

Collection and Use of Personal Information. 

The Sites have collected the following categories of Personal Information from its consumers within the last 12 months and will continue to collect such information in the future:

In addition to the business or commercial purposes for collection described above, we have in the preceding 12 months collected all categories of Personal Information described above for the following purposes:

• to operate our Offerings and provide you with our Offerings;
• to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our Offerings;
• to fulfill or meet the reason you provided the information. For example, 
  • if you share your contact information to ask a question about our Offerings, we will use that Personal Information to respond to your inquiry,
  • if you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery;
• to respond to law enforcement requests and as required by applicable law, court order, or governmental regulation;
• as described to you when collecting your Personal Information or as otherwise set forth in the CCPA;
• for internal administrative and auditing purposes; and/or
• to detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities.

We may also use or disclose the Personal Information we collect for one or more of the following purposes:

• to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
• as described to you when collecting your Personal Information or as otherwise set forth in the CCPA; and/or
• to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Lumio assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Lumio about the users of this Offerings is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, and/or incompatible parties without providing you notice. We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

Retention.

The length of time we retain your Personal Information is as long as is necessary to provide you with the Offerings.

Disclosure of Information for a Business Purpose.

In the preceding 12 months, Lumio has disclosed the following categories of Personal Information for a business purpose:

• Identifiers; 
• Customer Records Data;
• Commercial information; and/or
• Internet or other similar network activity.

We disclose your Personal Information for a business purpose to the following categories of third parties:

• Third party service providers;
• Our affiliates; and/or
• Third-party vendors to whom you or your agents authorize us to disclose your Personal Information in connection with Offerings we provide to you.

Sale or Sharing of Your Personal Information. 

As defined in the CCPA, we may have sold or shared (for cross-contextual behavioral or targeted advertising purposes) Personal Information within the previous 12 months.  

The categories of Personal Information disclosed that may be considered a sale/sharing include: 

• Identifiers; 
• Customer Records Data;
• Commercial information; and/or
• Internet or other similar network activity.

The categories of third parties to whom Personal Information was disclosed that may be considered a sale/sharing include: advertisers and marketing partners, data analytics providers, and/or social media networks.

Rights and Choices of California Residents. 

The CCPA also provides California residents with specific rights regarding their Personal Information. This section describes the rights of California residents under the CCPA and explains how to exercise those rights. Certain requirements must be met for a California resident to exercise their rights, see Exercising Rights below for more information on what requirements must be met and how to exercise said rights.

Opt-Out Rights.

Sale or Sharing of Your Information.

As described above, we may sell or share your Personal Information. If you would like to opt-out of the sale/sharing of your Personal Information, you may click “Do Not Sell Or Share My Personal Information” (also found at the bottom of the page), or you may broadcast the Global Privacy Control signal or similar Universal Opt-Out Mechanism (see Universal Opt-Out Mechanism) through your web browser or device. More information on Global Privacy Controls can be found here, https://globalprivacycontrol.org.

Profiling.

You may have the right to opt-out of certain automated processing performed on your Personal Information to evaluate, analyze, and/or predict personal aspects of a person’s economic situation, health, personal preferences, interests, reliability, behavior, location, and/or movements.  If you wish to exercise this right please contact us at privacy@lumio.com. 

Access Rights.

You have the right to request that Lumio disclose certain information to you about our collection and use of your Personal Information over the past 12 months, including:

• The categories of Personal Information we collected about you;
• The categories of sources for the Personal Information we collected about you;
• Our business or commercial purpose for collecting or selling that Personal Information;
• The categories of third parties with whom we share that Personal Information;
• The specific pieces of Personal Information we collected about you (also called a data portability request); and/or
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
• sales, identifying the Personal Information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Once we receive and confirm your verifiable consumer request, we will provide you with the requested information. See Exercising Your Rights for more information.

Data Correction Rights.

You have the right to request that Lumio correct inaccurate Personal Information that we collected from you and retained, taking into account the nature of the Personal Information and the purposes of processing the Personal Information. Once we receive and confirm your verifiable consumer request (see Exercising Your Rights for more information), we will use commercially reasonable efforts to correct the inaccurate Personal Information (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

Deletion Rights.

You have the right to request that Lumio delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (See Exercising Your Rights for more information), we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

• Complete the transaction for which we collected the Personal Information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, and/or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and/or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, and/or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Rights.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative and that you have rights under this notice; and
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an account with us, but we may require authentication of the consumer that is reasonable in light of the nature of the Personal Information requested.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Initial Request Format and Timing.

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination.

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• deny you goods or services;
• charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• provide you a different level or quality of goods or services; or
• suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, and/or quality levels. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Other California Privacy Rights.

California’s “Shine the Light” law (Civil Code § 1798.83) permits users of the Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to privacy@lumio.com.

Changes to Our CA Privacy Notice.

From time to time, we may update this CA Privacy Notice. If our information practices materially change at some time in the future, we will post the updated notice to our Site to notify you of these changes, and we will only use data collected from the time of the notice change forward for these new or different purposes. In the event we make a material change to how we use your Personal Information, we will provide you with an opportunity to opt-out of such new or different use. The date this CA Privacy Notice was last revised is at the top of this page. You are responsible for periodically reviewing the Site and this CA Privacy Notice to check for any updates or changes.

Contact Information.