PRIVACY POLICY

Introduction

This privacy policy is designed to inform users of the Lumo website available at https://www.lumodraw.com (the “Site”), and the Lumo mobile application (the “Application”, the Site and the Application collectively, the “Service”) about how Left Right Studios Inc. (“Lumo”, “we” or “us”) gathers and uses personal information collected by Lumo through the Service. Lumo will take reasonable steps to protect user privacy consistent with the guidelines set forth in this policy and with applicable U.S. laws. In this policy, “user” or “you” means any person viewing or using the Lumo Site, downloading, accessing or using the Application, or submitting any personal information to Lumo in connection with the Service. By visiting the Site and downloading, accessing or using the Application, you are indicating your consent to this Privacy Policy. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU SHOULD NOT USE THE SERVICE.

What Information Do We Collect?

Personal Information: If you contact Lumo through the Site, we ask you for certain personal information (the “Personal Information”), including your first and last name and e-mail address. If you disclose additional personal information to us, we may store that Personal Information.

Web Tracking Information: We, and third party service providers that we engage to provide services to us (“Contractors”), may use web tracking technologies such as cookies, web beacons, pixel tags and clear GIFs in order to operate the Site efficiently and to collect data related to usage of the Site. Such collected data (“Web Tracking Information”) may include the address of the websites you visited before and after you visited the Lumo Site, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Site you visit and what links you clicked on, and whether you opened email communications we send to you. In order to collect Web Tracking Information and to make your use of the Site more efficient, we may store cookies on your computer. We may also use web tracking technologies that are placed in web pages on the Site or in email communications to collect information about actions that users take when they interact with the Site or such email communications, and our Contractors may also do so. We do not correlate Web Tracking Information to individual user Personal Information. Some Web Tracking Information may include data, such as IP address data, that is unique to you. You may be able to modify your browser settings to alter which web tracking technologies are permitted when you use the Site, but this may affect the performance of the Site.

Mobile Users: If you access the Service from a mobile device, we may collect unique identification numbers associated with your device, your geographic location data including GPS coordinates, or similar information regarding the location of your mobile device. If you purchase the Application, your payment information is provided to a third-party payment processor, and Lumo cannot access this information and receives only limited information about your purchase.

How Do We Use the Information We Collect?

Personal Information: We will use and store Personal Information for the purpose of analyzing and enhancing the operation of the Service. We may also use Personal Information for the internal operational and administrative purposes of the Service. We may enter Personal Information into our contact management database, and may use such database to send you marketing materials and to contact you regarding your interest in the Service.

Aggregate Information: We may also create statistical, aggregated data relating to our users and the Service for analytical purposes. Aggregated data is derived from Personal Information but in its aggregated form it does not relate to or identify any individual. This data is used to understand our customer base and to help us develop, improve and market our products and services.

Web Tracking Information: We use Web Tracking Information to administer the Site and to understand how well our Site is working, to store your user preferences, and to develop statistical information on usage of the Site. This allows us to determine which features visitors like best to help us improve our Site, to personalize your user experience, and to measure overall effectiveness.

Legal Exception: Notwithstanding the above, Lumo may use Personal Information to the extent required by law or legal process, or if in Lumo’s reasonable discretion use is necessary to investigate fraud or any threat to the safety of any individual, to protect Lumo’s legal rights or to protect the rights of third parties.

What Information Do We Disclose to Third Parties?

Lumo’s Disclosure of Personal Information: Lumo will not disclose Personal Information to any third party except as described in this section.

We may disclose Personal Information to our Contractors who are bound by written obligations of confidentiality. Our Contractors help us perform statistical analysis, send you email or postal mail, conduct marketing and promotional activities, operate the Service, and provide customer support. Our Contractors are prohibited from using your personal information except to provide these services to Lumo.

Web Tracking Information: We disclose Web Tracking Information to Contractors, in order to analyze the performance of the Site and the behavior of users, and to operate and improve the Site. Certain Web Tracking information, such as the popularity ranking of certain pages of the Site, may be published on the Site and so disclosed to all users of the Site.

Aggregate Information: We may disclose aggregated data that does not contain Personal Information to any third parties, such as potential customers, business partners, advertisers, and funding sources, in order to describe our business and operations.

Successors and Law Enforcement: Notwithstanding the foregoing, Lumo reserves the right to disclose any information Lumo collects in connection with the Service, without further notice to you (a) to any successor to Lumo’s business as a result of any merger, acquisition or similar transaction; and (b) to any law enforcement or regulatory authority to the extent required by law or if, in Lumo’s reasonable discretion, disclosure is necessary to investigate fraud or any threat to the safety of any individual, to protect Lumo’s legal rights or to protect the rights of third parties.

Consent: Lumo may disclose your Personal Information with your consent.

How Can You Opt Out of Use and Disclosure of Your Information?

If you wish to be removed from our mailing list, please contact us at privacy@lumodraw.com. In the event of any such removal, Lumo may retain copies of information for its archives. If you wish to opt out of promotional emails, you may do so by following the “unsubscribe” instructions in the email, or by editing your account settings, or by sending a request to privacy@lumodraw.com.

Access and Updating of Information

You can update your Personal Information by contacting us. Lumo will respond to any reasonable request by a user to review or amend his or her Personal Information held in our mailing list or database. Lumo reserves the right to verify your identity in order to provide such access. Please contact us by sending an email to privacy@lumodraw.com.

Security: We use reasonable security precautions to protect the security and integrity of your Personal Information in accordance with this policy and applicable law. Lumo secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information is transmitted through the Service, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.

However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur. Without limitation of the foregoing, we are not responsible for the actions of hackers and other unauthorized third parties that breach our firewalls, secure server software, and other reasonable security procedures. BY USING OUR SERVICE, YOUR ACKNOWLEDGE THAT YOU UNDERSTAND AND AGREE TO ASSUME THIS RISK.

Links: The Site may contain links to other websites. Lumo is not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave our Site and review the privacy statements of each website they visit that collects information. This Privacy Policy applies solely to personal information collected by Lumo.

Amendments: Lumo may modify or amend this policy from time to time. If we make any material changes, as determined by Lumo, in the way in which Personal Information is collected, used or transferred, we will notify you of these changes by modification of this Privacy Policy, which will be available for review by you on the Service.

Service Visitors from outside the United States: The Service is provided from servers located in the United States, is subject to the applicable state and federal laws of the United States, and is directed toward users in the United States. If you choose to access the Service, you consent to the use and disclosure of information in accordance with this privacy policy and subject to such laws.

California Online Privacy Protection Act Notice

On September 27, 2013, California enacted A.B. 370, amending the California Online Privacy Protection Act to require website operators like us to disclose how we respond to "Do Not Track Signals"; and whether third parties collect personally identifiable information about users when they visit us.

(1) We honor “do not track” signals and do not track, use cookies, or use advertising when a “do not track” mechanism is in place.

(2) We do not authorize the collection of personally identifiable information from our users for third party use through advertising technologies.

California Civil Code Section 1798.83 also permits our users who 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 email to privacy@lumodraw.com. Please note that we are only required to respond to one request per user each year.

Children: Lumo does not knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of the Service is directed at persons under 18. If you are under 18 years of age, then please do not use the Service (other than under the supervision of a parent or guardian who has downloaded the Application for simultaneous use). If Lumo learns that personal information of persons less than 13 years of age has been collected without verifiable parental consent, then Lumo will take the appropriate steps to delete this information. To make such a request, please contact us at privacy@lumodraw.com.

Contact Information

Lumo welcomes your comments regarding this Privacy Policy. If you believe that Lumo has not adhered to this Privacy Policy, please contact us at privacy@lumodraw.com. We will use commercially reasonable efforts to promptly investigate and remedy the problem.

Effective Date of this policy: May 6, 2020

© Left Right Studios Inc. 2020