So you have purchased our Lumir Smart device hardware and are
starting to use the Lumir Smart device software and all its functionalities!
Any information you share with us (e.g. for creating a Lumir Account) will help
us to provide you with services related to Lumir Smart device and to improve them
to make them even better. We explain here our ways of collecting and using
data” means information that can be used to identify an individual, either from
that information alone, or from that information and other information we have
access to about that individual. We collect both personal and non-personal data
to enable and facilitate the best user experience possible.
information is collected and how do we use it?
of Personal Data Collected
In order to provide our
services to you, we will ask you to provide necessary personal data that
is required to provide those services. If you do not provide your personal
data, we may not be able to provide you with our products or services.
Set up and log in of Lumir
data that are collected for creating a Lumir Account may include your
email address or mobile phone number, device related information (e.g.
IMEI number) and various location related information (e.g. location area
code, mobile network and country codes).
Purchasing your Lumir
make purchases through the Lumir e-commerce website, we may collect your Lumir
Account ID (or mobile phone number or email addressed used to create your Lumir
Account), name, phone number, delivery address and order details, etc. Lumir
provides logistics services to deliver the products purchased on the
e-commerce website. Lumir has an after sales system to handle after sales
related matters as well as an after sales centre for walk-in support
services for users. When you use these services, we may also collect the
order number, invoice date, list of purchased items and your contact
details in order to process the services.
Activating Lumir Smart
device.When you activate the Lumir
Smart device, we may collect your age, height, weight and gender. We may
also collect other details you provide as part of your profile such as
your birthday, picture and signature.
Sync Lumir Smart device
data.When you synchronise the Lumir
Smart device data, e.g. to Lumir Smart device Cloud Service, we may
collect data relating to your activities and functionalities of Lumir
Smart device, such as those obtained from our sensors and features on Lumir
Smart device, your sleeping patterns, movement data and smart alarm
Sharing your content.When you share content or send information to
family and friends, we may collect personal information of those people,
such as their names, email addresses, telephone numbers, and mailing
addresses (if we need to send a product to them). You hereby represent and
warrant that you have obtained necessary consent for use of third parties’
personal data if you choose to provide them to us. When you share content
or invite users to use Lumir Smart device, please note that other users
may see personal data you share.
Processing the services.In providing the above services, we may also
collect data in relation to your device, including your Lumir Smart device
ID, firmware version, device OS version, model and system, and visiting IP
the Personal Data is used
To provide you with our
products and services, processing your orders, performing contractual
obligations between you and us, to ensure the functions and safety of our
products, to verify your identity, to prevent and trace fraudulent or
To develop our products and
services, together with general and statistical information
To communicate with you,
including providing you with notifications on products and services that
are updated or launched
To provide marketing and
promotional materials to you on our products and services (please note
that you may unsubscribe anytime)
To personalise product design
and to provide you with services tailored for you, for example,
recommending and displaying information and advertisements regarding
products suited to you, and to invite you to participate in surveys
relating to your use of Lumir Smart device
To conduct investigations
regarding our products and services
If you participate in our lottery,
contest or other promotions, we may use your personal data to manage such
To provide maintenance
services, monitor software licenses, to improve our products or analyse
the efficiency of our operations
We use statistical data that does not specifically identify you
(non-personal data) to help in our operations and improve our products and
services and provide a better user experience for you. Here are some of the
non-personal data we may collect and how we use them:
When you create a Lumir
Account, download our software, register in our e-commerce website,
participate in online surveys or interact with us in other ways, we may
collect your language preferences, postal code, area code number and time
zone in which you use our products and services, and your profession.
When you opt-in to
participate in our User Experience Improvement Program, we may gather
statistics relating to your use of our products functions, on an anonymous
basis. This may include information relating to your use of our official
website, products and services. If there is an abnormal shutdown or
breakdown, we may collect information relating to your mobile device to
diagnose the problem.
When you use our services or
functions that are based on location information, e.g. carry out a
location search, take advantage of advertising, use weather functions,
access information based on maps, etc., we may collect your geographical
When you use our website,
online services, interactive applications, email messages and advertising,
collect and store non-personal data. These enable us to provide you with a
better experience and improve our overall service quality, e.g. in saving your
preferred language settings, sending emails in a readable format, to
determine whether the emails have been opened or not, etc.
When you use the Internet
browser in using our products and services, we may collect log
information, e.g. IP address, browser type, language, reference source,
operating system, date and time marking and click rate data.
When you first use and
activate your Lumir Smart device, the device’s unique identification code
and approximate geographical information may be collected.
have control over your information!
We recognise that privacy concerns differ from person to person.
Therefore, we provide examples of ways we make available for you to choose to
restrict the collection, use, disclosure or processing of your personal data
and control your privacy settings, such as controlling the settings under the
User Experience Improvement Program, Location Access functions, and your Lumir
Updating or Correcting Your Personal Data
You have the right to request
access and/or correction or any other personal data that we hold about
you. When you update your personal data, you will be asked to verify your
identity before we proceed with your request. Once we obtain sufficient
information to accommodate your request for access or correction of your
personal data, we shall process in accordance with the laws of your
country. While we try our utmost in acceding to your requests,
unreasonably repetitive or unrealistic requests or those that put others’
privacy at risk may be declined.
We normally provide such
services for free but reserve the right to charge a reasonable fee.
If you believe any
information we are holding on you is incorrect or incomplete, please write
to or email us as soon as possible at the email address below. Email:
For details relating to the
personal data in your Lumir Account, you may also access and change them
at Email: email@example.com.
You may withdraw your consent
for the collection, use and/or disclosure of your personal data in our
possession or control by submitting a request. This may be done by
accessing your Lumir Account management center at Email: firstname.lastname@example.org
. We will process your request within a reasonable time from when the
request was made, and thereafter not collect, use and/or disclose your
personal data as per your request.
Please recognise that your
withdrawal of consent could result in certain legal consequences.
Depending on the extent of your withdrawal of consent for us to process
your personal data, it may mean that you will not be able to enjoy Lumir’s
products and services.
do we share your information with?
personal information confidential. We may disclose your personal data on
occasion to third parties in order to provide the products or services that you
have requested. Some of these third parties may be located outside your home
Disclosure may include the scenarios listed in this section
below. In each case described in this section, you can be assured that Lumir
will only share your personal data in accordance with your consent. You should
know that when Lumir shares your personal data with a third party under any
circumstance described in this section, Lumir will ensure that the third party
is subject to practices and obligations to comply with the relevant data
protection and privacy laws of your country. Lumir will contractually ensure
compliance by any foreign Third Party Service Providers with the privacy
standards that apply in your home jurisdiction.
to Lumir group companies and Third Party Service Providers
In order to conduct business
operations smoothly, the Lumir entity which collects your personal data
may disclose your personal data from time to time to other Lumir group
companies (in communications, social media, technology or cloud business),
or our third party service providers which are our mailing houses, delivery
service providers, telecommunications companies, data centres, data
storage facilities, and customer service providers, agents, related
corporations, and/or other third parties (together “Third Party Service
Providers”). Such Third Party Service Providers would be processing your
personal data on Lumir’s behalf or for one or more of the purposes listed
Personal data will only be
shared by Lumir to provide or improve our products or services and will
not be shared for use for marketing purposes.
Lumir may disclose your personal data without further consent if
required or permitted by law in the following cases:
cases in which the disclosure
is required or authorized based on the applicable laws and/or regulations;
cases in which the disclosure
is necessary to respond to an emergency that threatens the life, health or
safety of the individual or another individual;
cases in which the disclosure
is necessary for the prevention of crime or legal proceedings;
cases in which the purpose of
such disclosure is clearly in the individual’s interests, and if consent
cannot be obtained in a timely way;
cases in which the disclosure
is necessary for any investigation or proceedings;
cases in which the disclosure
is to any officer of a prescribed law enforcement agency upon production
of written authorisation signed by the head or director of that law
enforcement agency, or a person of a similar rank, certifying that the
personal data is necessary for the purposes of the functions or duties of the
cases in which the disclosure
is to a public agency and such disclosure is necessary in the public
Not Requiring Consent
We may share anonymised
information and statistics in aggregate form with third parties for business
purposes, for example with advertisers on our website, or we may tell our
business partners the number of customers in certain demographic groups
who purchased certain products or who carried out certain transactions.
For the avoidance of doubt,
in the event that we are permitted by law to collect, use or disclose your
personal data without your consent, such permission granted by the law
shall continue to apply.
We are committed to ensuring that your personal data is secure.
In order to prevent unauthorised access, disclosure or other similar risks, we
have put in place reasonable physical, electronic and managerial procedures to
safeguard and secure the information we collect. We have put in place the
following security procedures and technical and organisational measures to
safeguard your personal data:
Your personal data is stored
on secure servers that are protected in controlled facilities.
All data saved in the
back-end is classified into different levels based on the importance and
sensitivity of the data, e.g. whether the data contains personal data.
In the data centers, clusters
that contain sensitive data are grouped together in the network topology,
and will be placed in rooms with additional physical security protection.
Data exchanged between Lumir
devices and servers are encrypted using Secure Sockets Layer (“SSL”).
There is an optional two-step
verification process when users access their Lumir Account.
There is regular review of
information collection, storage and processing practices, including
physical security measures, to guard against unauthorized access to
Access is restricted to Lumir
employees and Third Party Service Providers who need to know that the
information in order to process it, and who are subject to strict
contractual confidentiality obligations and may be disciplined or
terminated if they fail to meet such obligations.
There are also access
controls for all server clusters used for cloud-based data storage and
Most data used for Lumir’s
products and/or services is stored in a storage system. By using column
family based access control mechanism, Lumir employees are only allowed
access to the data column families they are granted access to.
Please note also that for the
above, Lumir may use overseas facilities operated and controlled by Lumir
to process or back up your personal data. Currently, Lumir has data
centres in Beijing and Singapore. As a result, we may transfer to and
store your personal data at our overseas facilities. However, this does
not change any of our commitments to safeguard your personal data in
Information safety is very important to us. We will take all
practicable steps to safeguard your personal data. Through our protective
measures above, especially encrypted storage and transmission, your data is as
secure as it can be. Certain details of encrypted data cannot be accessed by
anyone except by you.
offered by a third party. Lumir products and services may include third party’s
products or services. When you use such products or services, they may collect
your information too. For this reason, we strongly suggest you to read the
responsible for and cannot control how third parties use personal data which
from our services.
We consider it the responsibility of parents to monitor their
children’s use of our products and services. Nevertheless, it is our policy not
to require personal data from minors or offer to send any promotional materials
to persons in that category. Lumir does not seek or intend to seek to receive
any personal data from minors. Should a parent or guardian have reasons to
believe that a minor has provided Lumir with personal data without their prior
consent, please contact us to ensure that the personal data is removed and
unsubscribe them from any of the applicable Lumir services.
you may be aware of the information we collect and how we use it. Such changes
websites. Your continued use of products and services on the websites, mobile
phones and/or any other device will be taken as acceptance of the updated
data from you or when we wish to use or disclose your personal data for new