Last Updated 24^th March 2023

At Luminate, your privacy and data security are our top priority. We strive to be transparent about who we are, as well as how and why we collect, store, use, and share information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“Personal Information”). This policy explains your rights regarding your Personal Information and how to contact us or certain supervisory authorities in the event you have a complaint.

When we collect, use, and take responsibility for certain Personal Information about you, we are subject to various state laws in the United States, such as the California Consumer Privacy Act (“CCPA”), amended by the California Privacy Rights Act (“CPRA”), as well as the General Data Protection Regulation (GDPR), which applies across the European Union (including the United Kingdom).

By collecting Personal Information, we may be responsible as a “controller” or “processor” for the purposes of the GDPR, or as a “business” or “service provider” for purposes of the CCPA. Any reference to “Luminate”, “we”, “us”, “our”, or the “Company” is a reference to Luminate Technology LLC., its affiliates, and its subsidiaries. Please see the “Contacting Us” section below for our contact information.

Please read this policy carefully to understand how Luminate processes your personal data, as well as your rights surrounding that data.

This policy applies to customer information collected from individuals residing in the United States only. It is not intended for individuals within other countries, including the European Union and European Economic Area.

What Personal Information do we collect?

We require certain Personal Information to provide the Solution to you. If you do not provide the Personal Information that we ask for, it may delay or prevent us from providing the Solution to you.

This policy describes the privacy-related practices of Luminate Technology LLC. (“Luminate”) applicable to the information we collect or that you may provide to us as an individual. The policy covers:

• Websites (including their subdomains) maintained by Luminate which link to this policy (“Website”).
• Web and mobile application-based technology platforms provided to you by Luminate which link to this policy (“Services”).

This policy explains how Luminate processes your personal data as you use our Website and Services. Processing includes collection, storage, transfer, sharing, disclosure and handling of personal data. This policy does not apply to any third-party web domains and services that may be linked to our Website or Services which Luminate does not control or maintain.

By using our Website or our Services, you acknowledge that you have read this policy and consent to Luminate’s privacy practices as described below.

You further affirm your consent by submitting content, materials and/or personal data to or through our Website or Services. If you are accessing the Website or Services on behalf of a legal entity, references to you refer to you as an individual, and to the legal entity you are representing.

If you do not consent to the practices described in this Privacy Policy, you may choose not to use our Website or Services.

This policy may change from time to time as our privacy practices are updated. We will notify you of any changes to this policy by posting the revised text and the policy’s last modified date on our Website. You may receive email notifications surrounding changes to this policy. If you continue to use our Website or Services after policy changes are made, you will be deemed to have granted consent to those changes.

If we make a material change surrounding personal data processing, we will notify you at the current email address specified in your account (if you are a Luminate customer) or through the email address you supply to us via the Subscribe link on our website.

Data Category	Data Types
Identifiers	Name, address, IP address, email address, account name, sign-in, and online identifiers, Signature, telephone number, employment information
Financial	Bank account number Routing number Loan ID number Payments activity (within our platform).
Internet or other electronic network activity information	Browsing history and information regarding interaction with social media profiles, advertisements, and the Luminate services
Commercial	Individual purchases, such as products and services listed in change orders or selections
Biometric	Luminate does not collect this data
Device & Location	Cookie data, IP address, Geolocation data, Photo location, Access timestamp, Device or browser identifier
Professional or employment-related information	Company name, company contact information, services provided, Professional insurance

We may also collect other information that you or others may provide to us, including the content that you or others submit, post to, or create within the platform, such as photos, comments, reviews, searches, photo notes, discussions, project details and costs, and style preferences.

We may record, monitor, or otherwise collect details about your communications when you communicate with us (via email, phone, through the platform, or otherwise) and when you use our software to communicate with others. If required by applicable law, we will provide you notice or obtain consent before recording or monitoring any of these calls.

How do we collect Personal Information?

Most of the Personal Information we collect comes directly from you, either through email, telephone, the Luminate website, or the platform. However, we may also collect information about you from other sources, including but not limited to third parties. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. In particular, we collect Personal Information from the following sources:

• Luminate customers who may supply information directly to us, including Personal Information regarding their own business, clients, contacts, or sub-contractors;
• From publicly accessible sources, such as property or permit records, corporate websites, trade and business licenses, professional certifications, permits, trade association membership, and e-commerce marketplace profiles (from these sources, we may obtain business information on both business people and companies);
• Directly from third party providers of business information, such as home marketing sources, social media profiles, or customer due diligence providers;
• From a third party with your consent, such as a financial providers;
• From cookies on our website (see our Cookie Policy for more information); and
• From market research surveys and/or interviews conducted by our own employees or by third-party vendors. 

3. How and why do we use your Personal Information?

Providing our websites and services	To perform our contracts with you for the use of our websites and services and to fulfil our obligations under applicable terms and conditions or terms of use; where we have not entered into a contract with you, we base the processing of your Personal Information on our legitimate interest to operate and administer our websites and to provide you with the content you access and request (e.g., to interact with content from our websites)
Promoting the security of our websites and services	In order to promote the safety and security of the services, systems, and applications, and to protect our rights and the rights of others, we track the use of our websites and services, verify accounts and activity, investigate suspicious activity, and enforce our terms and policies
Providing necessary functionality	To perform our contract with you for the use of our websites and services; where we have not entered into a contract with you, we base the processing of your Personal Information on our legitimate interest to provide you with the necessary functionality required during your use of our websites and services
Managing user registrations	If you have registered for an account with us, we process your Personal Information by managing your user account for the purpose of performing our contract with you according to applicable terms and conditions
Handling contacts and user support requests	If you fill out a web form or request customer support, or if you contact us by other means including via a phone call, we process your Personal Information to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you
Managing payments	If you have provided financial information to us, we process your Personal Information to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you
Developing and improving our websites and services	To analyze trends and to track your usage of and interactions with our websites and services to the extent it is necessary for our legitimate interest in developing and improving our websites and services and providing our users with more relevant content and service offerings, or where we seek your valid consent
Reviewing compliance with applicable usage terms	To review compliance with the applicable usage terms in our customer’s contract to the extent that it is in our legitimate interest to ensure adherence to the relevant terms
Identifying customer opportunities	To assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the interests of our customers and their users’ experiences
Legitimate business opportunities	To supply commercial data about businesses to other businesses; to license and sell business contact information for marketing and other purposes; to supply data about Luminate customer’s business, clients, contacts, or sub-contractors to other businesses for business opportunities
Displaying personalized advertisements	To conduct marketing research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest in advertising our websites or, where necessary, to the extent you have provided your prior consent
Sending marketing communications	To send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interest in conducting direct marketing or to the extent you have provided your prior consent; this may include device and usage data
Complying with legal obligations	To cooperate with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Information to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes or to respond to lawful requests.

 

Who do we share Personal Information with?

We may share your Personal Information with:

• Our affiliates, subsidiaries, advisors, and consultants;
• Our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support, and data enrichment for the purposes and pursuant to the legal bases described above;
• If you use our services as an Authorized User, with the affiliated customer responsible for your access to the services to the extent this is necessary for verifying accounts and activity, investigating suspicious activity, or enforcing our terms and policies;
• Third parties approved by you, including social media sites you choose to link your account to or third-party payment providers;
• Our contracted joint marketing partners and other business partners, who may process your Personal Information for purposes such as marketing and providing products and services that may be of interest to you and/or your business;
• If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by third party, with such third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Information to an unaffiliated third party;
• Law enforcement, public, and government authorities, and other entities as we deem reasonably necessary to comply with law, support investigations, and protect the rights and property of you, us, and others.

We may also collect, process, and use non-personal, aggregated, or anonymized data in any way, including by disclosing, sharing, or otherwise making it available to third parties for various research, marketing, analytics, and measurement purposes. Additionally Luminate may share such anonymous usage on an aggregate basis in the normal course of operating our business. This may include, but is not limited to, sharing information publicly to show the general use of our services.

Any Personal Information or other information you choose to submit in communities, forums, blogs, on our websites may be read, collected, and used by others who visit these forums.

We only allow our service providers and joint marketing partners to handle your Personal Information if we are satisfied that they take appropriate measures to protect your Personal Information. We also impose contractual obligations on service providers and joint marketing partners to ensure they can only use your personal information for the purposes outlined in our contracts.

Data Belonging to Children

Our websites and services are not created for nor directed at children. We do not knowingly collect Personal Information from children under the age of 18. If you are a parent or guardian and believe we have information about your child or that your child has provided us with Personal Information without your consent, please email  [email protected]

How long do we keep your Personal Information?

We may retain your Personal Information for a period of time consistent with the original purpose of collection. We determine the appropriate retention period for Personal Information on the basis of the amount, nature, and sensitivity of your Personal Information processed, the potential risk of harm from unauthorized use or disclosure of your Personal Information, and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitations). We will only retain your data for a period of time that is reasonably required for legal or business purposes.

Your Data Rights

As an individual, you have specific privacy-related rights surrounding the personal data you submit to us and that we process during the course of providing our Services. These are described below.

Consent for Processing

By submitting your personal data to us, whether manually or through your use of our Website and Services, you agree that Luminate may use the data in accordance with this privacy policy.

You have the right to deny or withdraw consent for the collection and/or processing of your personal data in certain circumstances, using several methods.

• You may choose to customize or disable cookies while using our Website. See the Cookies and Other Web Processing section for more information.
• You may choose not to complete and submit certain web forms containing your personal information through our Website (e.g. marketing or product demo forms).
• You may use the unsubscribe link located at the bottom of marketing messages and other select emails you receive from Luminate, to stop receiving them. This does not include system messages that are generated as an integral part of our Services – you may choose to discontinue receiving these emails by cancelling use of the applicable Services.
• You may contact us directly to withdraw your consent for certain types of personal data processing (see the Contacting Us section for communication details). Submitted requests are reviewed by our compliance team against applicable regulatory or legal requirements.

Additional Rights

The additional rights below may apply in certain circumstances. If you wish to know more about our personal data processing practices or exercise any of these rights, please contact us (see the Contacting Us section for communication details).

Right to Access	The right to be provided with a copy of your Personal Information
Right to Rectification	The right to require us to correct any mistakes in your Personal Information
Right to be Forgotten	The right to require us to delete your Personal Information, in certain situations
Right to Restriction of Processing	The right to require us to restrict processing of your Personal Information, in certain circumstances
Right to Data Portability	The right to receive the Personal Information you provided to us, in a structured, commonly used and machine-readable formation, in certain situations
Right to Object	The right to object: (a) at any time to your Personal Information being processed for direct market; and (b) in certain other situations, to our continued processing of your Personal Information
Right Not to be Subject to Automated Individual Decision-Making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
Right to Withdraw Consent	Where you have provided personal data voluntarily, or otherwise consented to its use, you have the right to withdraw your consent

Luminate does not discriminate against any individual that wishes to inquire about and exercise any of the privacy rights available to you under applicable privacy regulations. We will do our best to inform and assist you following your request.

Contacting Us

By using our Services, or by providing your personal data to us, you grant us permission to communicate with you electronically regarding any legal, regulatory, technical, security, privacy and administrative or consumer notification obligations that may be related to your use of the Website and the Services.

If you have any questions about this policy and our data processing practices, or would like to submit a data subject access request, you can contact us by email or on

Email: [email protected]

All requests are promptly reviewed by our compliance team, who will communicate with you directly.

 

Cookies and Other Web Processing

What is a Cookie?

A cookie is a small file created by a web server that can be stored on your device (if you allow it) for use either during a particular browsing session (a session cookie) or a future browsing session (a persistent cookie). Session cookies are temporarily stored on your device and only last until they expire at the end of your browsing session. Persistent cookies remain stored on your device until they expire or are deleted by you. Persistent cookies are typically used to collect and store information about your preferences and navigation to, from, and on a website.

First-party cookies are set by the website you’re visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.

Other Web Processing

In addition to cookies, we utilize other web processing technologies to automatically gather information as you browse our Website and utilize our Services. These include the following:

Web beacons. These are tiny graphics (sometimes called clear GIFs or web pixels) with unique identifiers that are used to understand browsing activity. In contrast to cookies, which are stored on your device, web beacons are rendered invisibly on the web pages you visit.

Social Widgets. These are buttons or icons provided by third-party social media platforms that allow you to interact with social media services when you view a webpage or mobile app screen. These social widgets may collect browsing data, which may be received by the third party that provided the widget and are controlled by third parties.

UTM Codes. These are strings that can appear in a URL (the Uniform Resource Locator, which is typically the address entered to go to a webpage) when you move from one web page or website to another. The string can represent information about browsing, such as which advertisement, page, or publisher sent you to the receiving website.

Third-Party Technologies

Third parties connected to our Website and Services may use automated data collection technologies to collect information about you when you browse the Internet. The information they collect about your online browsing activities over time and across different websites and other online services may be associated with your personal information and used to provide you with targeted content.

We do not control these third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible party directly or consult their privacy policies.

How We Protect Data

Luminate maintains a security program designed to protect the personal data we process from being accidentally lost, used, altered, disclosed, or accessed in an unauthorized manner. We periodically review our security procedures to measure best practices, and consider appropriate new technologies and methods.

Data submitted via the internet, including through a web page or email, is subject to interception or incorrect routing, and the internet is not a fully secure communications channel. Please consider this prior to submitting any personal data to us via the Website or Services. No method of transmission over the internet is 100 percent secure. Therefore, while we strive to use commercially reasonable means to protect your personal data, Luminate cannot guarantee its absolute security.

User Responsibility

You also play a role in the safety and security of your personal data. You are responsible for maintaining the confidentiality of your login credentials, as well as ensuring you only disclose your personal data through secure means.

Breach Disclosure

If Luminate experiences a data breach which compromises your personal data, we will notify you and any appropriate regulation bodies when we are required to do so by applicable law.

International Users

This Website and Services are intended solely for Luminate customers residing in the United States. If you reside in another country and choose to use our Website and Services, be aware that we may transfer your personal data to our subsidiaries and affiliated entities, or to other third parties, across borders and from your country or jurisdiction to other countries or jurisdictions around the world. These countries and jurisdictions may not offer the same data protection laws as yours.