Privacy Policy
Last updated April 01, 2026
This Privacy Notice for Liminal Innovation Technologies (Pty) Ltd (doing business as Lumr) ('we', 'us', or 'our'), describes how and why we might access, collect, store, use, and/or share ('process') your personal information when you use our services ('Services'), including when you:
- Visit our website at https://lumr.app or any website of ours that links to this Privacy Notice
- Engage with us in other related ways, including any marketing or events
Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at hello@lumr.app.
Summary of Key Points
This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information? Some of the information may be considered 'special' or 'sensitive' in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We do not process sensitive personal information.
Do we collect any information from third parties? We do not collect any information from third parties.
How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal information.
How do we keep your information safe? We have adequate organisational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.
Table of Contents
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
10. DO WE COLLECT INFORMATION FROM MINORS?
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?
16. AI TRAINING & MACHINE LEARNING
17. DO WE MAKE UPDATES TO THIS NOTICE?
18. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
19. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. What Information do we Collect?
Personal information you disclose to us
In Short: We collect personal information
that you provide to us.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:
- names
- email addresses
- contact or authentication data
Sensitive Information. We do not process sensitive information.
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, X, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in the section called 'HOW DO WE HANDLE YOUR SOCIAL LOGINS?' below.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information — such as your
Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically
when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps'), and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Google API
Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
2. How do we Process your Information?
In Short: We process your information to provide, improve, and
administer our Services, communicate with you, for security and fraud prevention, and to comply with
law. We process the personal information for the following purposes listed below. We may also
process your information for other purposes only with your prior explicit consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including:
- To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
- To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
- To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
- To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
- To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
- To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
- To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
- To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. What Legal Bases do we Rely on to Process your Information?
In
Short: We only
process your personal
information when we believe it
is necessary and we have a valid
legal reason (i.e. legal basis)
to do so under applicable law,
like with your consent, to
comply with laws, to provide you
with services to enter into or
fulfil our contractual
obligations, to protect your
rights, or to fulfil our
legitimate business
interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
- Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
- Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
- Analyse how our Services are used so we can improve them to engage and retain users
- Diagnose problems and/or prevent fraudulent activities
- Understand how our users use our products and services so we can improve user experience
- Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
- Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e. express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e. implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions are met
- If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
- For identifying injured, ill, or deceased persons and communicating with next of kin
- If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
- If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
- If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
- If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
- If the collection is solely for journalistic, artistic, or literary purposes
- If the information is publicly available and is specified by the regulations
- We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ('third parties') who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
The third parties we may share personal information with are as follows:
- User Account Registration and Authentication
WorkOS, Google Sign-In and GitHub OAuth
- Website Hosting
Railway
- Website Performance Monitoring
Sentry
We also may need to share your personal information in the following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honour this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.
We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.
To the extent these online tracking technologies are deemed to be a 'sale'/'sharing' (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section 'DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?'
Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or X logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.
7. Is your Information Transferred Internationally?
In
Short: We
may
transfer,
store,
and
process
your
information
in
countries
other
than
your
own.
Our servers are located in the United States. Regardless of your location, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?' above), including facilities in the United States, and other countries.
If you are a resident in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this Privacy Notice and applicable law.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal information, including by using the European Commission's Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
8. How Long do we Keep your Information?
In
Short: We
keep
your
information
for
as
long
as
necessary
to
fulfil
the
purposes
outlined
in
this
Privacy
Notice
unless
otherwise
required
by
law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. How do we Keep your Information Safe?
In
Short: We
aim
to
protect
your
personal
information
through
a
system
of
organisational
and
technical
security
measures.
We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
10. Do we Collect Information from Minors?
In
Short: We
do
not
knowingly
collect
data
from
or
market
to
children
under
18
years
of
age
or
the
equivalent
age
as
specified
by
law
in
your
jurisdiction.
We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at dup@litcorp.net.
11. What Are your Privacy Rights?
In
Short: Depending
on
your
state
of
residence
in
the
US
or
in
some
regions,
such
as
the
European
Economic
Area
(EEA),
United
Kingdom
(UK),
Switzerland,
and
Canada,
you
have
rights
that
allow
you
greater
access
to
and
control
over
your
personal
information. You
may
review,
change,
or
terminate
your
account
at
any
time,
depending
on
your
country,
province,
or
state
of
residence.
In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section 'HOW CAN YOU CONTACT US ABOUT THIS NOTICE?' below.
However,
please
note
that
this
will not
affect
the
lawfulness
of the
processing
before
its
withdrawal
nor,
when
applicable
law
allows,
will it
affect
the
processing
of your
personal
information
conducted
in
reliance
on
lawful
processing
grounds
other
than
consent.
Account
Information
If
you
would at
any time
like to
review
or
change
the
information
in your
account
or
terminate
your
account,
you can:
- Contact us using the contact information provided.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.
If you have questions or comments about your privacy rights, you may email us at hello@lumr.app.
12. Controls for Do-not-track Features
Most
web
browsers
and some
mobile
operating
systems
and
mobile
applications
include
a
Do-Not-Track
('DNT')
feature
or
setting
you can
activate
to
signal
your
privacy
preference
not to
have
data
about
your
online
browsing
activities
monitored
and
collected.
At this
stage,
no
uniform
technology
standard
for
recognising
and
implementing
DNT
signals
has been
finalised.
As such,
we do
not
currently
respond
to DNT
browser
signals
or any
other
mechanism
that
automatically
communicates
your
choice
not to
be
tracked
online.
If a
standard
for
online
tracking
is
adopted
that we
must
follow
in the
future,
we will
inform
you
about
that
practice
in a
revised
version
of this
Privacy
Notice.
California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognising or honouring DNT signals, we do not respond to them at this time.
13. Do United States Residents Have Specific Privacy Rights?
In
Short: If
you
are
a
resident
of
California,
Colorado,
Connecticut,
Delaware,
Florida,
Indiana,
Iowa,
Kentucky,
Maryland,
Minnesota,
Montana,
Nebraska,
New
Hampshire,
New
Jersey,
Oregon,
Rhode
Island,
Tennessee,
Texas,
Utah,
or
Virginia,
you
may
have
the
right
to
request
access
to
and
receive
details
about
the
personal
information
we
maintain
about
you
and
how
we
have
processed
it,
correct
inaccuracies,
get
a
copy
of,
or
delete
your
personal
information.
You
may
also
have
the
right
to
withdraw
your
consent
to
our
processing
of
your
personal
information.
These
rights
may
be
limited
in
some
circumstances
by
applicable
law.
More
information
is
provided
below.
Categories
of
Personal
Information
We
Collect
The
table
below
shows
the
categories
of
personal
information
we have
collected
in the
past
twelve
(12)
months.
The
table
includes
illustrative
examples
of each
category
and does
not
reflect
the
personal
information
we
collect
from
you. For
a
comprehensive
inventory
of all
personal
information
we
process,
please
refer to
the
section
'WHAT
INFORMATION
DO
WE
COLLECT?'
| Category | Examples | Collected |
|---|---|---|
|
A. Identifiers |
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name |
YES
|
|
B. Personal information as defined in the California Customer Records statute |
Name, contact information, education, employment, employment history, and financial information |
NO
|
|
C. Protected classification characteristics under state or federal law |
Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data |
YES
|
|
D. Commercial information |
Transaction information, purchase history, financial details, and payment information |
NO
|
|
E. Biometric information |
Fingerprints and voiceprints |
NO
|
|
F. Internet or other similar network activity |
Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements |
YES
|
|
G. Geolocation data |
Device location |
NO
|
|
H. Audio, electronic, sensory, or similar information |
Images and audio, video or call recordings created in connection with our business activities |
NO
|
|
I. Professional or employment-related information |
Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us |
NO
|
|
J. Education Information |
Student records and directory information |
NO
|
|
K. Inferences drawn from collected personal information |
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics |
NO
|
| L. Sensitive personal Information |
NO
|
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
We will use and retain the collected personal information as needed to provide the Services or for:
- Category A - As long as the user has an account with us
- Category C - As long as the user has an account with us
- Category F - As long as the user has an account with us
Sources
of
Personal
Information
Learn
more
about
the
sources
of
personal
information
we
collect
in
'WHAT
INFORMATION
DO
WE
COLLECT?'
How
We
Use
and
Share
Personal
Information
Learn
more
about
how
we
use
your
personal
information
in
the
section,
'HOW
DO
WE
PROCESS
YOUR
INFORMATION?'
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information to in the section, 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be 'selling' of your personal information.
We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:
The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under 'WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?'
Your
Rights
You
have
rights
under
certain
US
state
data
protection
laws.
However,
these
rights
are
not
absolute,
and
in
certain
cases,
we
may
decline
your
request
as
permitted
by
law.
These
rights
include:
- Right to know whether or not we are processing your personal data
- Right to access your personal data
- Right to correct inaccuracies in your personal data
- Right to request the deletion of your personal data
- Right to obtain a copy of the personal data you previously shared with us
- Right to non-discrimination for exercising your rights
- Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ('profiling')
Depending upon the state where you live, you may also have the following rights:
- Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
- Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
- Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
- Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
- Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
- Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
- Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)
How
to
Exercise
Your
Rights
To
exercise
these
rights,
you
can
contact
us
by
submitting
a data
subject
access
request,
by
emailing
us
at
hello@lumr.app,
or
by
referring
to
the
contact
details
at
the
bottom
of
this
document.
Under
certain
US
state
data
protection
laws,
you
can
designate
an
authorised
agent
to
make
a
request
on
your
behalf.
We
may
deny
a
request
from
an
authorised
agent
that
does
not
submit
proof
that
they
have
been
validly
authorised
to
act
on
your
behalf
in
accordance
with
applicable
laws.
Request
Verification
Upon
receiving
your
request,
we
will
need
to
verify
your
identity
to
determine
you
are
the
same
person
about
whom
we
have
the
information
in
our
system.
We
will
only
use
personal
information
provided
in
your
request
to
verify
your
identity
or
authority
to
make
the
request.
However,
if
we
cannot
verify
your
identity
from
the
information
already
maintained
by
us,
we
may
request
that
you
provide
additional
information
for
the
purposes
of
verifying
your
identity
and
for
security
or
fraud-prevention
purposes.
If
you
submit
the
request
through
an
authorised
agent,
we
may
need
to
collect
additional
information
to
verify
your
identity
before
processing
your
request
and
the
agent
will
need
to
provide
a
written
and
signed
permission
from
you
to
submit
such
request
on
your
behalf.
Appeals
Under
certain
US
state
data
protection
laws,
if
we
decline
to
take
action
regarding
your
request,
you
may
appeal
our
decision
by
emailing
us
at
hello@lumr.app.
We
will
inform
you
in
writing
of
any
action
taken
or
not
taken
in
response
to
the
appeal,
including
a
written
explanation
of
the
reasons
for
the
decisions.
If
your
appeal
is
denied,
you
may
submit
a
complaint
to
your
state
attorney
general.
14. Do Other Regions Have Specific Privacy Rights?
In
Short: You
may
have
additional
rights
based
on
the
country
you
reside
in.
Republic
of
South
Africa
At
any
time,
you
have
the
right
to
request
access
to
or
correction
of
your
personal
information.
You
can
make
such
a
request
by
contacting
us
by
using
the
contact
details
provided
in
the
section
'HOW
CAN
YOU
REVIEW,
UPDATE,
OR
DELETE
THE
DATA
WE
COLLECT
FROM
YOU?'
If you are unsatisfied with the manner in which we address any complaint with regard to our processing of personal information, you can contact the office of the regulator, the details of which are:
The Information Regulator (South Africa)
General enquiries: enquiries@inforegulator.org.za
Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za & POPIAComplaints@inforegulator.org.za
15. How we Handle your Code
Lumr
never
transmits,
stores,
or
processes
your
source
code.
The
Lumr
binary
runs
locally
on
your
machine
and
extracts
only
abstract
structural
data(symbols
representing
files
and
packages,
and
relationships
between
them).
This
graph
data
is
encrypted
with
AES-256-GCM
before
transmission
and
no
source
code
content
is
included.
Lumr
servers
store
only
this
abstract
graph
—
never
your
actual
code.
16. AI Training & Machine Learning
Lumr
does
not
use
your
graph
data
to
train
machine
learning
models.
17. Do we Make Updates to This Notice?
In
Short: Yes,
we
will
update
this
notice
as
necessary
to
stay
compliant
with
relevant
laws.
We may update this Privacy Notice from time to time. The updated version will be indicated by an updated 'Revised' date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.
18. How Can You Contact Us about This Notice?
If
you
have
questions
or
comments
about
this
notice,
you
may
contact
our
Data
Protection
Officer
(DPO) by
email
at dup@litcorp.net,
or
contact
us
by
post
at:
Liminal Innovation Technologies (Pty) Ltd
Data Protection Officer
19. How Can You Review, Update, or Delete the Data we Collect from You?
You
have
the
right
to
request
access
to
the
personal
information
we
collect
from
you,
details
about
how
we
have
processed
it,
correct
inaccuracies,
or
delete
your
personal
information.
You
may
also
have
the
right
to
withdraw
your
consent
to
our
processing
of
your
personal
information.
These
rights
may
be
limited
in
some
circumstances
by
applicable
law.
To
request
to
review,
update,
or
delete
your
personal
information,
please
fill
out
and
submit
a data
subject
access
request.