General Privacy Notice
Updated 9th April 2021
This General Privacy Notice explains how your personal data is used in connection with your interactions with Lumina Learning and your use of the Lumina Platform, your Lumina Account and your Participant Profiles.
If you use our other services that are not covered by this Notice, we may hold additional data about you that is used for other purposes. Please consult our other privacy notices for details.
Reference to “Lumina Learning, we, us, our” in this Notice refers to Lumina Learning Limited (registered in England and Wales, Company Number 07021544), unless you are informed that a different Lumina Learning entity is gathering your data. We are committed to treating your data fairly and transparently. We encourage you to contact us if you have any questions about this Notice.
About Your Interactions with Us and Your Use of the Lumina Platform
You are most likely to interact with us via the “Lumina Platform”, which means our website located at https://luminalearning.com and our mobile apps. The Lumina Platform provides a way for you to interact with our services. Some features of the Lumina Platform require you to create a Lumina Account and Participant Profiles which hold your personal data.
You may also interact with us outside of the Lumina Platform, such as at one of our events, via email or via message submitted to our helpdesk.
The Lumina Platform allows you to interact with other users of the platform, who may be individuals or organisations. Other users can ask you to share data about yourself and complete tasks, such as questionnaires about yourself and others. After you complete a task, the other user may give you access to resources based on the task. These other users are not part of Lumina Learning and they control any data that you choose to share with them. If you have questions about how another user uses your data, please contact them directly.
We collect and receive the following types of data about you:
“Lumina Platform Data”:
• “Basic Account Details” – when you create a Lumina Account, you provide your name, email address and gender or pronoun preferences.
• “Usage Data” – we gather data about how you use the Lumina Platform. This includes details of the device you use, browser and plugin details and records of pages you visit. If you create a Lumina Account, we gather data about the tasks you complete, the other users and features you interact with and your approximate location based on your IP address.
• “Identity Provider Data” – if you sign into your Lumina Account using sign-in credentials from a third-party identity provider (for example, Google), we obtain some data from the identity provider. Details of the data we obtain are displayed the first time you sign in using your identity provider sign-in credentials.
• “Mobile App Data” – when you use our mobile apps, we gather a copy of data that you enter into the app. We also gather data about you that other people enter into their apps. For example, when you or someone else scans your Splash in the Lumina Splash app. We also log details about your mobile device and how you use the apps.
“Participant Profile Data”:
• “Profile Data” – when you create a Participant Profile you provide data, including your name, email address, gender or pronoun preferences, date of birth, education details, employment details and demographic information.
• “Task Data” – when another user asks you to complete a task, they gather data about you. They use this data for their own purposes. They may also share a copy of this data with us. For example, they may share your responses to questionnaires with us.
We hold data about you if you interact with us in other ways. For example, if you subscribe to our newsletters, make an enquiry about our services or submit a helpdesk ticket. We may also hold data about you submitted by other people who interact with us. For example, if you complete a task at the request of another user, they may submit a helpdesk ticket containing data about you.
How Your Data is Used
We use your data for the following purposes:
• To provide the Lumina Platform and give you access to your Lumina Account.
• To respond to your requests.
• To respond to requests from other users of the Lumina Platform, where you have already interacted or shared your data with them.
• To provide you with essential communications regarding technical, security and legal issues relating to your use of the Lumina Platform.
• To provide you with other communications you consent to receive.
• To provide you with services and resources you subscribe to or express an interest in.
• To research, analyse and enhance our products and services, including to avoid bias and discrimination.
• To analyse the performance of our business, such as to monitor the usage of our products and services.
• To support the maintenance, enhancement and security of our systems.
• For legal reasons, including our record keeping, to defend legal claims, comply with legal obligations and to prevent fraud and other illegal or harmful activities.
We process your Lumina Platform Data and Other Data based on our legitimate interest to provide the Lumina Platform to you and others. You have the right to object to this processing.
We process your Participant Profile Data based on your consent. You have the right to withdraw your consent at any time and we will erase this data.
For details about how to exercise your data rights, see ‘How to Exercise Your Data Rights’.
How Your Data is Shared
Data you choose to share with others
When you interact with other users of the Lumina Platform you share your Basic Account Details with them. When another user asks you to complete a task they may ask for additional data. The other user uses your data for their own purposes in accordance with their own privacy notice. To give you control, you can choose whether to share your data.
Please contact the other user if you have questions about how they use your data. You acknowledge that you are responsible for deciding to share your data and that it may not be possible to unshare it later.
Data we share with others
We share your data with the following third parties. We only share data with third parties that provide appropriate safeguards:
• The Lumina Learning Network – these third parties represent our business globally and perform some of our purposes on our behalf. They are typically termed ‘Lumina Learning Partners’, ‘Lumina Learning Strategic Alliances’, ‘Lumina Learning Associates’ or ‘Lumina Learning Practitioners’.
• Professional and service providers – these third parties help us run our business by providing their services and expertise. For example, providers of tools like helpdesk software and providers of professional advice like legal, accounting and consultancy services.
• Business sale or change of control – if the ownership of all or part of our business changes or if we enter administration, your personal data may be shared with the other parties involved. This includes where we take preparatory steps in connection with such activities.
• Legal obligations and defence of legal claims – we may share your data where we are subject to a legal obligation or if necessary to defend a legal claim against us.
We never sell your data to third parties for marketing purposes.
International Transfers of Your Data
We may share your data with third parties that are outside the UK and European Economic Area (EEA). Where we share your data, we do so only when there are appropriate safeguards in place. Where possible, we use third parties located in countries that the EU Commission has approved as providing appropriate safeguards, or third parties taking part in EU Commission approved schemes that provide adequate safeguards.. Where these options are not available, we ensure adequate safeguards by using model contract clauses provided by the EU Commission.
Retention of Your Data
We retain your data for seven years from when you last signed into your Lumina Account. This is to allow you continued access to your Lumina Account and its features.
You always have the option to exercise your data rights. Please see ‘How to Exercise Your Data Rights’.
How to Exercise Your Data Rights
You have the right to access, rectify, port and in some cases erase your personal data. You also have the right to:
• Object to processing – where data is processed based on our legitimate interests, you have the right to object to this processing based on grounds relating to your situation.
• Withdraw consent – where data is processed with your consent, you have the right to withdraw your consent at any time and we will erase your data.
To exercise your data rights, please contact us using the details below.
If you choose to share data with another user of the Lumina Platform, they control the shared data. To exercise your data rights in relation to the shared data, please contact the other user directly.
Updates to this Notice
We may update this Notice from time to time. We will post updates here and notify you of any changes that materially affect you.
Questions and Complaints
If you have concerns about how we have handled your personal data, we encourage you to contact us directly using our contact details below. We commit to resolving your issue wherever possible.
You also have the right to complain to a supervisory authority, including your local supervisory authority and our local supervisory authority, the United Kingdom’s Information Commissioner’s Office.
To contact us, please email email@example.com.