Practitioner Privacy Notice
Updated 30th April 2021
This Practitioner Privacy Notice explains how Lumina Learning and your Lumina Learning Partner or Strategic Alliance use your personal data in connection with the Services that we provide under our Business Agreement.
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 “we, us, our” refers collectively to:
• “Lumina Learning”: Lumina Learning Limited (registered in England and Wales, Company Number 07021544).
• “Lumina Learning Partner or Strategic Alliance”: Lumina Learning’s distributor who provides Services to you, whose identity is communicated to you before you accept use of the Services.
We are committed to treating your data fairly and transparently and encourage you to contact us if you have any questions about this Notice.
About the Services
“Services” are products and services that we provide to you under our Business Agreement. When you use the Services, you may be a ‘Lumina Learning Practitioner’, someone who works with or for a Lumina Learning Practitioner or someone who works for an entity that is our business client. You use the Services either as a party to the Business Agreement or on behalf of an entity that is party to the Business Agreement (for example, your organisation).
You can use the Services to interact with other people using our website and mobile apps (the “Lumina Platform”). Any data you gather about others is used and controlled by you.
“Business Agreement” refers to our business relationship with you, or the entity that you represent. The Business Agreement is governed by our General Terms and Conditions of Business or, where relevant, other agreed terms.
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.
“Practitioner Profile Data”:
• “Profile Details” – you provide your name, email address, phone number and postal address, or those of the entity you represent.
• “Billing Details” – you provide your financial and legal details, or those of the entity you represent.
“Other Practitioner Data”:
You may provide other data when you use the Services. For example, if you attend our events or engage with our learning resources. Other people or entities may also provide data about you in connection with the Services. For example, details provided by your organisation or colleagues.
How Your Data is Used
We collect your data for the following purposes:
• To provide the Services and fulfil our obligations under the Business Agreement.
• To fulfil orders and process payments.
• 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 communications relating to the Services where we have a legitimate interest to do so. This includes some marketing communications and will always include essential communications relating to technical, security and legal issues relating to your use of our Services and 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 conduct customer and market research.
• 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 data based on our legitimate interest to provide you with the Services and to fulfil our obligations under the Business Agreement. You have the right to object to this processing.
For details about how to exercise your data rights, please 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 Data and Profile Details with them. For example, when you ask another user to complete a task or questionnaire.
If you choose to share access to the Services with someone else, they may be able to view 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 the entity you represent
When you access the Services on behalf of an entity (for example, your organisation) we may share your data with that entity and other individuals who represent that entity (for example, your colleagues). We share data only to the extent necessary to perform our obligations under the Business Agreement.
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.
Please note, we share your data with the entity you represent, including other individuals who represent that entity. These third parties may be outside the UK and EEA and may not provide adequate safeguards for your data. We transfer data to these third parties to allow us to perform our obligations under the Business Agreement. This benefits you by allowing you to access the Services on behalf of the entity you represent.
Retention of Your Data
We retain your data for as long as necessary for the purposes it is collected for. This is typically until the termination of the Business Agreement. We may retain your data for longer where it is necessary for legal reasons.
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.
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.
To exercise your data rights, please contact us using the details below.
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.
Lumina Learning and your Lumina Learning Partner or Strategic Alliance are joint controllers of your data. Lumina Learning will respond to your queries on behalf of both parties.
To contact us, please email