Last updated 30/10/2020

 

 

Lumo Education Ltd. (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website www.lumoeducation.com, including any other media form, media channel, mobile website, or mobile application related or connected thereto (collectively, the “Site”). Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the site.

 

We reserve the right to make changes to this Privacy Policy at any time and for any reason.  We will alert you about any changes by updating the “Last Updated” date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the Site, and you waive the right to receive specific notice of each such change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Site after the date such revised Privacy Policy is posted.

 

COLLECTION OF YOUR INFORMATION

​

We may collect information about you in a variety of ways.  The information we may collect on the Site includes:

 

PERSONAL DATA

 

Personally identifiable information, such as your name, email address, and telephone number, and demographic information, such as your age, gender, hometown, and interests, that you voluntarily give to us when you choose to participate in various activities related to the Site. You are under no obligation to provide us with personal information of any kind.

 

DERIVATIVE DATA​

 

Information our servers automatically collect when you access the Site, such as your IP address, your browser type, your operating system, your access times, and the pages you have viewed directly before and after accessing the Site.
 

DATA FROM SOCIAL NETWORKS

 

User information from social networking sites, such as [Facebook, Google+, Instagram, Pinterest, Twitter, LinkedIn], including your name, your social network username, location, gender, birth date, email address, profile picture, and public data for contacts, if you connect your account to such social networks.

 

MOBILE DEVICE DATA

 

Device information, such as your mobile device ID, model, and manufacturer, and information about the location of your device, if you access the Site from a mobile device.

 

THIRD PARTY DATA

 

Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Site permission to access this information.

​

 

USE OF YOUR INFORMATION

 

Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience.  Specifically, we may use information collected about you via the Site to:

 

●      Compile anonymous statistical data and analysis for use internally or with third parties.

●      Deliver targeted advertising, coupons, newsletters, and other information regarding promotions and the Site to you.

●      Generate a personal profile about you to make future visits to the Site more personalized.

●      Increase the efficiency and operation of the Site.

●      Monitor and analyze usage and trends to improve your experience with the Site.

●      Notify you of updates to the Site.

●      Offer new products, services, and/or recommendations to you.

●      Perform other business activities as needed.

●      Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.

●      Request feedback and contact you about your use of the Site.

●      Resolve disputes and troubleshoot problems.

●      Respond to product and customer service requests.

●      Send you a newsletter.

●      Solicit support for the Site.

 

DISCLOSURE OF YOUR INFORMATION

We may share information we have collected about you in certain situations. Your information may be disclosed as follows:

 

BY LAW OR TO PROTECT RIGHTS

 

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation.  This includes exchanging information with other entities for fraud protection and credit risk reduction. Any dispute concerning the termination, interpretation or use of our service shall be governed by Finnish Law and shall be submitted exclusively to the competent courts in Helsinki, Finland.

 

THIRD-PARTY SERVICE PROVIDERS

 

We may share your information with third parties that perform services for us or on our behalf, including payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.

 

MARKETING COMMUNICATIONS

 

With your consent, or with an opportunity for you to withdraw consent, we may share your information with third parties for marketing purposes, as permitted by law.

 

AFFILIATES

 

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

 

BUSINESS PARTNERS

 

We may share your information with our business partners to offer you certain products, services or promotions.

 

OTHER THIRD PARTIES

 

We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes, as permitted by law.

 

SALE OR BANKRPTCY

 

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity.  If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third party. You acknowledge that such transfers may occur and that the transferee may decline honor commitments we made in this Privacy Policy.

 

We are not responsible for the actions of third parties with whom you share personal or sensitive data, and we have no authority to manage or control third-party solicitations.  If you no longer wish to receive correspondence, emails or other communications from third parties, you are responsible for contacting the third party directly.

​

​

KEEPING YOUR INFORMATION

 

We only retain your personal data for as long as needed to fulfill the purposes for which it is collected, unless we are required or permitted by law to keep the personal data for longer.

 Your personal data will be anonymized or deleted if your last interaction with us was over 7 years ago. “Interaction with us” includes, for example, visiting the Site or opening marketing communications from us.

​

 

TRACKING TECHNOLOGIES

 

COOKIES AND INTERNET-BASED ADVERTISING

 

We do not use cookies, web beacons, tracking pixels, and other tracking technologies on the Site. However, we may use third-party software to serve ads on the Site, implement email marketing campaigns, and manage other interactive marketing initiatives. This third-party software may use cookies or similar tracking technology to help manage and optimize your online experience with us.  For more information about opting-out of interest-based ads, visit the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

 

WEBSITE ANALYTICS

 

We may also partner with selected third-party vendors, such as Google Analytics, to allow tracking technologies and re-marketing services on the Site through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Site, determine the popularity of certain content and better understand online activity. By accessing the Site, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can visit the third-party vendor or the Network Advertising Initiative Opt-Out Tool or Digital Advertising Alliance Opt-Out Tool.

​

You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

​

​

THIRD-PARTY WEBSITES

 

The Site may contain links to third-party websites and applications of interest, including advertisements and external services, that are not affiliated with us. Once you have used these links to leave the Site, any information you provide to these third parties is not covered by this Privacy Policy, and we cannot guarantee the safety and privacy of your information. Before visiting and providing any information to any third-party websites, you should inform yourself of the privacy policies and practices (if any) of the third party responsible for that website, and should take those steps necessary to, in your discretion, protect the privacy of your information. We are not responsible for the content or privacy and security practices and policies of any third parties, including other sites, services or applications that may be linked to or from the Site.

 

​

SECURITY OF YOUR INFORMATION

 

We use administrative, technical, and physical security measures to help protect your personal information.  While we have taken reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse.  Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide personal information.

 

​

POLICY FOR CHILDREN

 

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.

 

​

CONTROLS FOR DO-NOT-TRACK FEATURES

 

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.  No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.  If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

​

​

OPTIONS REGARDING YOUR INFORMATION

 

EMAILS AND COMMUNICATIONS

​

If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by contacting us using the contact information provided below. If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.

​

​

YOUR RIGHTS

 

If you are a “data subject” under applicable data protection law in the EU or United Kingdom, you will have the following rights in relation to personal data that we hold about you:

​

• Right to Information - information about the processing of your personal data

• Right to Access - obtain access to the personal data held about you

• Right to Rectification - ask for incorrect, inaccurate or incomplete personal data to be corrected

• Right to Erasure - request that personal data be erased when it’s no longer needed or if processing it is unlawful

• Right to Restriction of Processing - object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation

• Right to Data Portability - to request that we provide a copy of your personal data to you in a structured, commonly used and machine readable format in certain circumstances.

• Right to Object - ​request the restriction of the processing of your personal data in specific cases

• Right to Avoid Automated Decision Making - request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers. You also have the right in this case to express your point of view and to contest the decision​

 

To exercise your rights as set out above or to make a complaint or submit an inquiry about our privacy practices, please contact us at info@lumoeducation.com. To help protect your privacy and maintain security, we may take steps to verify your identity before we can action your request.

 

​

CONTACT US

 

If you have questions or comments about this Privacy Policy, please contact us at:

 

Lumo Education Ltd.

Business ID: FI27827913

info@lumoeducation.com

​

​