At Lumhaa LLC., we offer a range of products and services focused on helping you collect, engage with, and share memories. By using our website and/or mobile app (“Our Products”), you accept these terms and privacy notice (“Terms”) in full. Your security and memories important to us. That’s why we have the following policies in place:

Your Memories: You own the memories that you post to Lumhaa and are free to share them at will. You can also choose whether you want other people to see your memories or not when you add them:

  • Memories Marked Private: When you mark a memory as private, it is encrypted using blockchain so that nobody outside of the people you choose to share the memory with can see it -- even we do not have access to your private memories.
    • If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction.
  • PMemories Marked Public: When you mark a memory as public, you grant us a non-exclusive, transferable, sub-licensable, royalty-free and worldwide licence to host, use, distribute, modify, run, copy, publicly perform or display, translate and create derivative works of your memory -- that is, you allow us to share it with other users as desired.

The Information We Collect

We do collect some information you provide when you use our Products. The information we collect helps us promote integrity, safety, and security as we try to give you the most personalized and authentic experience possible.

  • Registration information: To create an account, you need to provide data which may include your name, email address and/or mobile number, and a password. If you complete financial transactions with Lumhaa you will need to provide payment (e.g., credit card) and billing information.
  • Memories, posting, and uploading: When you create or share memories, and engage with memories we retain some of this information. It’s your choice whether to include sensitive information when you create/share memories and make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.
    • We collect personal data from you when you provide, post or upload it to Lumhaa. You don’t have to post or upload personal data; though if you don’t, it may limit your ability to fully engage with our community.
    • We collect information when you share memories or have memories shared with you. For example, if you have a memory shared with you, we retain data on when and with whom that memory was shared.
  • Data from product use: We collect information about how you use our Products, such as the types of content that you view or engage with, the features you use, the actions you take, your financial transactions with Lumhaa, and the time, frequency and duration of your activities.
    • We log usage data when you visit or otherwise use our Products, including our sites, app and platform technology (e.g., our off-site plugins), such as when you view or click on content or ads (on or off our sites and apps), perform a search, install or update one of our mobile apps, and share memories. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.
  • Additional information from device settings: We also collect information that you allow us to receive through device settings that you turn on, such as access to your GPS location, camera or photos.
    • When you visit or leave Lumhaa, we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Products from a mobile device, that device will send us data about your location based on your device settings.
    • We also collect data from cookies stored on your device, including cookie IDs and settings.
  • Other: Our Products are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.

How We Use Your Data

In general, we use the data that we have about you to provide and personalize, including with the help of automated systems and inferences we make, our Products (including ads) so that they can be more relevant and useful to you and others.

We also use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm our Members or Visitors.

  • Communications: We will contact you through email, mobile phone, notices posted on our websites or apps, and other ways through our Services, including text messages and push notifications. We will send you messages about the availability of our Products, security, or other related issues. We also send messages about how to use our Products, network updates, reminders, suggestions and promotional messages from us and our partners. You may change your communication preferences at any time. Please be aware that you cannot opt-out of receiving service messages from us, including security and legal notices.
  • Developing Services and Research: We use data, including public feedback, to conduct research and development for the further development of our Products in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement through our Products, and help people connect and share their memories.
    • Surveys – Polls and surveys may be conducted by us and others through our Products. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.
  • Customer Support: We use the data (which can include your communications) to investigate, respond to and resolve complaints and Product-related issues (e.g., bugs).

How We Share Your Information

  • Related Services and Service providers: We will share your personal data with our affiliates to provide and develop our Products. We may combine information internally across the different Products covered by this Privacy Policy to help our Products be more relevant and useful to you and others.
    • We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.
  • Legal Disclosures: It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Products (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Lumhaa, our members, personnel, or others. We attempt to notify members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
  • Change in control or sale: We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

Children’s Privacy

Lumhaa does not knowingly collect or solicit any information from anyone under the age of 4 or knowingly allow such persons to register for the Product. The Product and its content are not directed at children under the age of 4. Furthermore, in the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible.

Your Choices and Obligations

  • Data Retention: We retain your personal data while your account is in existence or as needed to provide you services. This includes data you or others provided to us and data generated or inferred from your use of our Products. Even if you only use our products infrequently, we will retain your information and keep your account open until you decide to close it. In some cases we choose to retain certain information in a depersonalized or aggregated form.
  • Right to Access and Control Personal Data: We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in memories and controlling the visibility of your memories to advertising opt-outs and communication controls. We offer you settings to control and manage the personal data we have about you.
    • Marking Memories Private: You may choose to mark your memories as private. Doing so will cause the memory to be encrypted, and the content of the memory will be inaccessible to anybody with whom the memory is not shared.
    • Deleting Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide services to you).
    • Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.
    • Object to, or Limit or Restrict, Use of Data: You can ask us to stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
    • Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
    • Residents in the Designated Countries may have additional rights under their laws
  • Account Closure: If you choose to close your Lumhaa account, your personal data will generally stop being visible to others on our Services within 24 hours. We generally delete closed account information within 1 day of account closure, except as noted below.
    • We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.
    • Information you have shared with others (e.g., through shared memories) will remain visible after you closed your account, and we do not control data that other Members copied out of our Products.

Other Important Information:

  • Security: We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
  • Cross-Border Data Transfers: We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.
  • Lawful Basis: We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the particular service you have requested)) and “legitimate interests.”
    • Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact our Data Protection Officer at s@lumhaa.com or +1-916-5179972
  • One Final Note: Lumhaa acknowledges and complies with the notice and take down procedures as defined in section 512(c) of the Digital Millennium Copyright Act (DMCA). If your content was removed due to a copyright claim, you will receive a communication explaining the removal. You will also receive instructions concerning how to file a counter-notification. Before filing such a counter-notification, we recommend determining whether the material was removed or disabled as a result of a mistake or misidentification.

Last Updated on December 29, 2018

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