PRIVACY POLICY – LUMINI SOLUÇÕES EM ILUMINAÇÃO
Last update: 2021-08-23
Lumini Soluções em Iluminação
LTDA. (“us”, “ours”, “LUMINI”)
is committed to protect your privacy and personal data. This document describes
our practices related to the privacy of personal data processed throughout the
apps, products and services listed below:
App Mobile Lumini
Connect
In this privacy policy:
“Personal Data”: information that, by itself,
can be used to identify an individual.
“Smart Devices” refers to those non-standard
computing devices, produced or manufactured by hardware manufacturers with a
human-machine interface and the ability to transmit data that connect
wirelessly to a network, including: smart home appliances, portable devices
smart, etc.
“Apps”: mobile
apps developed by Lumini that provides remote control to end users of the smart
devices with the ability to connect to the Lumini Connect platforms other
mobile apps with the brand technology Lumini, our clients can control all
personal data collected throughout our products. We collect information by
demand of our clients and the processing of this information its limited in
connection with the provision of our services. If you are a client of one of
our clients and have a request about your personal data, contact the Client
responsible for the service, product or device you are using.
PERSONAL DATA
PROCESSED
To provide our services, we will ask you to
provide us your Personal Data. The Personal Data processed are essential to the
providing of our services and products.
1.Information
provided by you:
a.Information from your login and
profile: when you create a new account with us, we may collect your e-mail
address, phone number, user name and access credentials. During your
interaction with our products we can collect your name, profile image, country
code, your language preferences and information of your time zone.
b.Feedback: when using the feedback resources
and suggestions of new products we will collect your e-mail address, phone
number and the content of your feedback to provide you with a resolution of
eventual problems and bugs of the device.
2.Information
collected automatically:
a.Device information: when you
interact with our Product, we collect automatically information of the device
you are using such as MAC address, IP address, wireless information, type and
version of the operational system, number of the app’s version, push
notifications, register archives and information of the mobile network.
b.Use information: during your
interaction with our websites and services, we collect automatically information
of use such as visits, clicks, downloads, messages sent and received, and other
use of our websites and services.
c.Register information: when you use
our app, register archives can be object of upload.
d.Location information: we can collect
information about your geolocation in real time when you access specific products
and services, app Lumini Connect and luminaires with the smart technology.
3.Information
related to Smart Devices:
a.Basic information of Smart Devices:
when you connect your Smart Devices to our products and services, we can
collect basic information such as: device name, device’s ID, online status,
time of activation, firmware version and update information.
b.Information related to the Smart
Device: depending on the different types of Smart Devices you choose to connect
to our products and services we can collect different information related to
your Smart Device.
PURPOSES AND LEGAL
BASIS FOR PROCESSING PERSONAL DATA
The purposes for processing your personal data are:
1.To
provide services: we process your data from your account and profile,
information of use, geolocation and information related to Smart Devices to
provide our products and services to the buyer or solicitor. The legal basis for
this processing is the “execution of contract” according to the Terms of Use.
2.To
better provide our services: we process information of your device and use,
geolocation and Smart Device’s information, to guarantee that the functions and
security of our products, to developed and improve our services and products,
to analyze the efficiency of our operations and prevent as well as track
inappropriate and fake data. The legal basis for this processing is the
“execution of contract” according to the Terms of Use.
3.Communication
not related to marketing: we process your personal data to send important
information about Services, alterations of our terms, conditions and policies
and other administrative information. Considering that this information can be
important to you and the providing of our services, you cannot cancel the
receiving of such communications. The
legal basis for this processing is the “execution of contract” according to the
Terms of Use.
4.Communication
related to marketing: we can process your personal data to provide marketing
material and promotions about our services and products. When this type of
communication is made, you will be able to provide us with instructionsnot to receive future communications of this
nature. The legal basis for this processing is your consent.
5.Personalization:
we can process data from your login and profile, data of use, information from
the device to personalize the design of the product and services personalized
by you, as well as recommend and exhibit information and adds related to the
products that better suits your, and invite you to participate in surveys about
our products. The legal basis for this processing is your consent.
6.Legal
compliance: we can process your personal data to: a. comply with laws and
regulations; b. comply with due legal process; c. respond to public and government
authorities requests; d. comply with our terms and conditions; e. protect our
operations, business and systems; f. protect our rights, privacy, security as
well as your and our clients’ rights, privacy and security; g. to search for
solutions and limit damages that we can suffer.
SHARING OF PERSONAL
DATA:
LUMINI only share Personal Data for the purposes
informed below:
1.With
outsource service providers who perform functions related to business such as
website hosting, data analysis, payment and credit card processing,
infrastructure, information technology, customer service, e-mail services and
other services provided to better offer our services.
2.With
our clients and other business partners who provide, direct or indirectly, your
Mobile Services and/or networks and systems through which you access and use
our services.
3.With
partners or other third parties in case of reorganization, merger, selling,
joint venture, attribution, transfer or divestiture, or any part of our
business, assets and stocks (including, without limitation, any relations with bankruptcy
or procedure). In this case you will be notified via e-mail and/or a prominent
notice in our website about any alteration in the propriety, new uses
incompatible with your personal data and choices you may have in relation to
Personal Data.
4.When
we understand it is needed or appropriate: a. to follow legal obligations and
regulations; b. to follow due legal process; c. to respond to solicitations
from public and governmental authorities out of your country of residence; d.
to comply with terms and conditions; e. to protect our operations, business and
systems; f. to protect our rights, privacy, security and propriety, as well as
your and our clients’ rights, privacy and security; and g. to look for
solutions or limit damages.
5.With
subsidiaries companies or affiliates within our group, to regular commercial activities.
6.With
other parties, not listed above, only with your consent.
INTERNATIONAL SHARING
OF PERSONAL DATA
To facilitate our operation, we may transfer,
storage or process your Personal Data in another jurisdiction other than your
country of residence.
YOUR RIGHTS REGARDING
YOUR PERSONAL DATA
We respect your rights and control of your
personal data. You can adjust your preferences in the app:
Profile &rt; Configurations &rt; Account and
Security
You do not need to pay a fee and we will
respond to your request up to 15 days. If you decide to send us an e-mail, we
ask you to specify the information you would like to alter or any other action you may want
to take regarding your personal data.
We may ask you to confirm your identity for
security of information purposes.
You can ask to:
1.Access
the personal data we have about you;
2.Correct
imprecise or incomplete data about you;
3.Delete
your personal data when collected based on you consent;
4.Anonymize,
block or delete unnecessary or excessive data process violating the Brazilian
Data Protection Law.
SECURITY
We use reasonable physical, administrative and
technical protections to preserve the integrity and security of your personal
data. LUMINI provides strategies of security to effectively guarantee the
security of data from the user and the device.
Regarding the device access, the algorithms
propriety of LUMINI are made to guarantee the isolation of data, authentication
of access and authorization.
Regardingdata communication, communications that use security algorithms and
transmission cryptographyand
transmission of commercial level encrypted information based on dynamic keys
are supported.
Regarding data processing, filters and data validation
are applied as well as full data audit.
Regarding data storage , all user confidential
information is encrypted with storage security.
If you have any motive to believe that your
interaction with us is not secure, please inform us immediately about the
problem by sending an e-mail to privacidade@lumini.com.br WITHHOLDING OF DATA
We will process your personal data for the
minimum period of time necessary to fulfil the purposes established in this
Privacy Policy, unless a specific legalobligation to storage your data for a longer
period of time is in place. We determined an appropriate period based on the
volume, nature and sensibility of your personal data and, after the period of
withholding ends, your data will be destroyed. If we are not capable of
destroying for technical reasons, we assure you that appropriate measures will
be taken to avoid any later use of your personal data.
CHANGES IN THIS
PRIVACY POLICY
We can update this Privacy Policy to reflect
changes in our information practices. If we alter materials, we will notify you
by e-mail or through a notice in the mobile apps before the changes come into
force. We ask you to periodically check this page to obtain the current
information on our practices regarding privacy.
CONTACT US
If you have any doubts about our practices or
this privacy policy, please contact us at:
Lumini Soluções em Iluminação Ltda.
Address: R. Ferreira Viana, 716 -
Vila Socorro, São Paulo - SP, 04761-010