1. About this Policy
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1.1 This Privacy Policy applies to any information you provide to Lumio Technologies Ltd (”Lumio”) via Lumio websites, and the software applications hosted or made available by us, however you access them, whether via the website or via mobile or tablet app (collectively, the “Service”). Together with our Terms of Use, it forms part of our agreement with you.

1.2 The Service is owned and operated by Lumio Technologies Ltd (referred to as “we”, “our”, “us”, “Lumio”). We are a limited company registered in England and Wales (company reg. no. 10257486) and have our registered office at Suite 2, Bellevue Mansions, 18-22 Bellevue Road, Clevedon, England, BS21 7NU. Our VAT number is 321444929.

1.3 We are committed to protecting your personal information and other data provided to us via the Service. Please read this Privacy Policy carefully as it contains important information about the use of any information you provide to us. This Privacy Policy explains what information we collect about you, how we use your information and sets out the circumstances where it could be provided to third parties.

1.4 Because of the financial nature of our business, our products and services are not designed to appeal to or to be sold to persons under the age of 18. Therefore, we do not knowingly attempt to solicit or receive any information from persons under the age of 18.

2. Information we collect and what we do with it

2.1 To take advantage of some parts of the Service you may be required to log in or register with us. We and any third parties who host or maintain the Service may need to collect information about you and your computer to enable you to use the Service. The information will be collected when you register with or log in to the Service.

2.2 We may use the information we collect to personalise your experience of the Service, to help you to maintain a logged-in session, and to help us select services or materials for inclusion in the Service which may be of interest to you. We may, from time to time, use your information to send you important notifications, updates and information regarding the Service. If you do not want to receive communications regarding the Service, you must cease to use the Service and ask us to delete your account. You can request this by contacting us through the in-app chat or via our website, www.lumio-app.com

2.3 We will not, without your consent, provide your information to third parties so that such third parties can market their goods or services direct to you. However, as part of the Service you may be able to opt in to emails from third parties so that they can market to you. You should be able to unsubscribe from these emails by clicking the unsubscribe link in the footer of the email that you receive from such third parties.

2.4 We may provide you with information about third party products or services that may be of interest to you.

2.5 We may use your information to notify you of news about changes to the Service, special events or new services of ours that we think may interest you. If, at any time, you would rather not receive any such information, please contact us.

2.6 The nature of our business is such that we may on occasions ask you to provide sensitive personal data. Where we do so, we will request your explicit consent to the use of such sensitive personal data. Where you consent to provide us with this information we will take appropriate measures to protect such sensitive personal data.

2.7 ‍When you use our Services we will have access to your personal data that you submit to us and personal data held by Account Servicing Payment Service Providers (i.e. any payment service provider, such as a bank or a credit card issuer that maintains an online payment account on your behalf) (“ASPSPs”) for the duration of the transmission. Such personal data may include your date of birth, gender, account information, account balance, transactions, information on loans, insurance data and investments data.

2.8 We, together with third party licensors providing functionality for us or third parties hosting servers on our behalf, may monitor traffic patterns and usage of the Service to help improve the functionality, design and layout.

2.9 Please note that we are not responsible for what any third party websites linked to from the Service may propose to do with information about you, so please ensure you read their terms and conditions carefully if you choose to engage with those third party websites.

3. Sharing of information with third parties

3.1 We may need to share information about you with certain service providers who help us to deliver the Service to you (for example third party technology companies who may provide elements of the Service’s functionality, and other members of our group of companies). We refer to such service providers as (“Data Service Providers”). Data Service Providers will only use your information to help provide the Service, they will not market to you.

3.2 We reserve the right to access and disclose personal data or information to comply with applicable laws and lawful government requests, to operate our systems properly, or to protect ourselves or our users.

3.3 We may disclose your personal information to third parties:

3.3.1 if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request;

3.3.2 in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

3.3.3 in order to:

3.3.4 who you interact with via the Services and/or confirm that you wish to be contacted by (for example, product providers).

Use of Third Party Services:

We use third party providers to provide the Services to you and to help understand your usage of our services. We utilize these third party services to collect data for analytics purposes when you visit our website or use our product. As data processors acting on our behalf, these third parties analyze your use of our website and app and track our relationship by way of cookies and similar technologies so that we can improve our service to you.

We may share your Personal Data with selected third parties, including business partners, suppliers and subcontractors that assist us in the provision of our Services to you. The third-party providers used by us will only collect, use and disclose your information as instructed by us to provide Services to you.

We may also use third parties as a medium for communications, either through email or through messages within our website or app, including to help gather your feedback on your experience with Lumio. As part of our service agreements, these third parties collects publicly available contact and social information related to you, such as your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses, to enhance your user experience. If you would like to opt out of having this information collected by or submitted to our third party providers, please contact us.

We may also share anonymous aggregated data with Third Party Members so they can understand trends and preferences across groups of users in a non-personalised way such as how spending habits are evolving or which new technologies or payment-types are being used more than others. These insights in turn allows Third Party Members to refine or pivot their own service-offers to their clients or create new partnerships with other organisations to provide better, more relevant functionality, products and services which users may want to use.

4. Your consent
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4.1 You acknowledge and agree that:

4.1.1 in the course of using or registering with the Service, certain information about you will be captured electronically (including sensitive personal data where required, but this will be subject to you giving your explicit consent in such cases) or otherwise and transmitted to us and, potentially, to any third parties as set out above, or to Data Service Providers; and

4.1.2 We usually store your information on servers located in the European Economic Area (“EEA”), however we may send your information outside of the EEA for processing or use in accordance with this Privacy Policy. If we do send your information outside the EEA, we will take steps to prevent the transfer of personal data without adequate safeguards being put in place and will take all reasonable steps to ensure that your personal data is afforded the same level of protection as it would be inside the EEA.

4.2 By using the Service, you expressly agree to the collection and use of your information for the purposes set out in this Privacy Policy.

4.3 If after you provide your consent under clauses 4.1 and 4.2 above, you change your mind, you may withdraw your consent by messaging through the in-app chat or via our website, www.lumio-app.com, and requesting your account with Lumio to be deleted. This will permanently delete your entire account with Lumio, including all your personal data, all transactions, balance data and categorisations. It will not be possible to recover this data.

5. Our responsibilities

As required by GDPR and the Data Protection Act 1998, we follow strict security procedures in the storage and disclosure of information which you have provided via the Service to prevent unauthorised access.

6. What are cookies and how do we use them?

6.1 We use cookies to distinguish you from other users of the Service. This helps us to provide you with a good experience. By visiting and using the Service, you agree to our use of cookies.

6.2 A cookie is a small file of letters and numbers that we store on your browser, computer, or device. We may use the following cookies:

6.3 Please note that third parties (including, for example, providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

6.4 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the Services.

7. Changes to Privacy Policy

We reserve the right to add to or change the terms of this Privacy Policy at our sole discretion, without prior notice. If we change this Privacy Policy, we will post the new Privacy Policy on the Service, and it will become effective from the time of posting to the Service. Please visit this Privacy Policy on a regular basis at https://www.lumio-app.com/privacy-policies to make sure you have read the latest version and you understand what we do with your information. Wherever possible, we will give you notice of any changes prior to their implementation.

8. Links to third parties

The Service may contain links to other websites and services. Please be aware that we cannot be held responsible for the privacy policies of such other sites and services. We encourage our users to be aware when they leave the Service and to read the privacy statements of each and every site or service that collects personally identifiable information. This Privacy Policy applies solely to information collected by us.

9. Feedback

If you have any queries about this Privacy Policy or how we use your information, please contact us through the in-app chat or via our website, www.lumio-app.com.

10. Access to your information

GDPR and the Data Protection Act 1998 gives you the right to access information held about you. To exercise this right please write to us using the in-app chat or via our website, www.lumio-app.com.

Last updated: 30th Sep 2022