Privacy Policy

Introduction

Luma Netlock is a product provided by LUMA (hereinafter referred to as "we"). When you use our services, we may collect and use your relevant information. Through this Privacy Policy, we aim to explain how we collect, use, store, and share this information when you use our services, as well as the ways we provide for you to access, update, control, and protect your information. This Privacy Policy is closely related to the Luma Netlock services you use. Please read it carefully and, when necessary, make choices you deem appropriate according to the guidance of this Privacy Policy. We have tried to express relevant technical terms in this Privacy Policy in a concise manner and provide further explanations where necessary for your understanding.

Your use or continued use of our services means that you agree to our collection, use, storage, and sharing of your relevant information in accordance with this Privacy Policy.

If you have any questions about this Privacy Policy or related matters, please contact us at +34 943335066.

Address: Avenida de la Libertad 7, 5A, 20004, Donostia - San Sebastian, Spain.

1. Information We Collect

When we or our third-party partners provide services, we may collect, store, and use the following information about you. If you do not provide relevant information, you may not be able to register as our user or enjoy certain services we provide, or achieve the intended effect of related services.

• Location Information: When you enable device location services and use our location-based services, we collect information about your location, including:
  • Your geographic location information collected via GPS, WiFi, etc. when you use our services on a device with location capabilities;
  • You can stop the collection of your geographic location information by disabling location services.
• Personal Information: Information you provide to us when registering an account or using our services, such as phone number, email address, etc.
• Log Information: When you use our services, the system may collect information through cookies, identifiers, and related technologies, including your device information, browsing information, click information, and store such information as log data to provide you with a personalized user experience and ensure service security. You can refuse or manage the use of cookies, identifiers, or related technologies through your browser settings.

2. Information Storage

• We store your information securely, including local storage (such as app data caching), databases, and server logs.
• Generally, we only store your personal information for the period necessary to achieve the service purpose or as required by laws and regulations.

• We store user personal information collected within China in China in accordance with laws and regulations.
• Currently, we do not transfer or store your personal information across borders. If cross-border transfer or storage is required in the future, we will inform you of the purpose, recipient, security measures, and risks, and obtain your consent.

• If our product or service is discontinued, we will notify you via push notifications, announcements, etc., and delete or anonymize your personal information within a reasonable period, except as otherwise required by laws and regulations.

3. Information Security

We use various security technologies and procedures to prevent information loss, misuse, unauthorized access, or disclosure. For example, in some services, we use encryption technologies (such as SSL) to protect the personal information you provide. However, please understand that due to technical limitations and possible malicious means, even with our best efforts, it is impossible to guarantee 100% security of information in the internet industry. You need to understand that the systems and communication networks you use to access our services may encounter problems due to factors beyond our control.

4. How We Use Information

We may use the information collected during the process of providing services to you for the following purposes:

• To provide you with services;
• For identity verification, customer service, security protection, fraud monitoring, archiving, and backup purposes during service provision, to ensure the security of our products and services;
• To help us design new services and improve existing services;
• To better understand how you access and use our services, so as to respond to your personalized needs, such as language settings, location settings, personalized help services and instructions, or other responses to you and other users;
• To provide you with more relevant advertisements instead of general ads;
• To evaluate and improve the effectiveness of advertisements and other promotional activities in our services;
• For software certification or management of software upgrades;
• To allow you to participate in surveys related to our products and services.

5. Information Sharing

Currently, we do not actively share or transfer your personal information to third parties. If there is a need to share or transfer your personal information, or if you request us to share or transfer your personal information to third parties, we will directly or confirm that the third party obtains your explicit consent for such actions.

For advertising, evaluating, and optimizing advertising effectiveness, we may share some of your data with advertisers and their agents or other third-party partners, requiring them to strictly comply with our data privacy protection measures and requirements, including but not limited to processing according to data protection agreements, commitments, and related data processing policies, to avoid identifying individuals and ensure privacy security.

We will not share information that can identify you personally (such as your name or email address) with partners unless you explicitly authorize it.

We will not publicly disclose the personal information we collect. If public disclosure is necessary, we will inform you of the purpose, type of information, and possible sensitive information involved, and obtain your explicit consent.

As our business continues to develop, we may engage in mergers, acquisitions, asset transfers, etc. We will inform you of such situations and continue to protect your personal information according to laws and regulations and standards no less than those required by this Privacy Policy, or require the new controller to continue to protect your personal information.

Additionally, according to relevant laws, regulations, and national standards, we may share, transfer, or publicly disclose personal information without your prior authorization or consent in the following circumstances:

• Directly related to national security or defense security;
• Directly related to public safety, public health, or major public interests;
• Directly related to criminal investigation, prosecution, trial, or judgment enforcement;
• For the protection of the life, property, or other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the individual's consent;
• The personal information subject discloses personal information to the public on their own;
• Personal information collected from legally disclosed information, such as legitimate news reports, government information disclosure, etc.

6. Your Rights

During your use of our services, we may provide you with relevant settings based on the specific product, so that you can inquire, delete, correct, or withdraw your relevant personal information. Please refer to the specific instructions for operation. In addition, we have set up complaint channels, and your feedback will be handled promptly. If you cannot exercise your rights as a personal information subject through the above methods, you can submit your request through the contact information provided in this Privacy Policy, and we will respond according to laws and regulations.

When you decide to stop using our products or services, you can apply to cancel your account. After account cancellation, unless otherwise required by laws and regulations, we will delete or anonymize your personal information.

7. Changes

We may revise the terms of this Privacy Policy from time to time. When changes occur, we will notify you of the new Privacy Policy during version updates and inform you of the effective date. Please read the revised Privacy Policy carefully. If you continue to use our services, you agree to our processing of your personal information in accordance with the updated Privacy Policy.

8. Protection of Minors

We encourage parents or guardians to guide minors under the age of eighteen to use our services. We recommend that minors encourage their parents or guardians to read this Privacy Policy and seek their consent and guidance before submitting personal information.

Address: Avenida de la Libertad 7, 5A, 20004, Donostia - San Sebastian, Spain.
Tel: +34 943335066