Our privacy obligations

Lumin.gg ("Lumin") is governed by the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth). The APPs regulate how personal information is handled by Lumin.'Personal information' means information or an opinion about an identified individual, or an individual who is reasonably identifiable. Lumin’s Privacy Policy applies to personal information collected and/or held by Lumin.This Privacy Policy also explains how we process 'personal data' about people in the European Union (EU), as required under the General Data Protection Regulation (GDPR).We will review this policy regularly, and we may update it from time to time.

The types of personal information we collect and hold

We collect personal information about our users in order to provide our products, services, and customer support. Our products, services, and customer support are provided through many platforms including but not limited to: websites, phone apps, and email. The specific platform and product, service, or support you interact with may affect the personal data we collect.Not all information requested, collected, and processed by us is "Personal Information" as it does not identify you as a specific natural person. This will include most "User Generated Content" that you provide us with the intention of sharing with other users. Such "Non-Personal Information" is not covered by this privacy policy. However, as non-personal information may be used in aggregate or be linked with existing personal information; when in this form it will be treated as personal information. As such, this privacy policy will list both types of information for the sake of transparency.In some situations users may provide us with personal information without us asking for it, or through means not intended for the collection of particular types of information. Whilst we may take reasonable steps to protect this data, the user will have bypassed our systems, processes, and controls, and thus the information provided will not be governed by this privacy policy.In some situations users may provide us personal information over platforms that are outside our control; for example through social media or forums. Whilst any information collected by us is governed by this Privacy Policy, the platform by which it was communicated will be governed by its own Privacy Policy.

How we collect personal information

Information that you specifically give us
While you use our products and services you may be asked to provide certain types of personal information. This might happen through our website, applications, online chat systems, telephone, paper forms, or in-person meetings. We will give you a Collection Notice at the time, to explain how we will use the personal information we are asking for. The notice may be written or verbal.

We may request, collect, or process the following information:‍

• Account Details - username, password, profile picture.
• Contact Details - email address, phone number.
• Location Details - physical location,  timezone.
• User Generated Content - user messages, posts including videos.

Information that we collect from others
‍We do not currently collect personal information about users from others.

Information we collect as you use our service
‍We maintain records of the interactions we have with our users, including the products, services and customer support we have provided. This includes the interactions our users have with our platform such as when a user has viewed a page or clicked a button.
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In order to deliver certain products or services we may passively collect your GPS coordinates, where available from your device. Most modern devices such as smartphones will display a permission request when our platform requests this data.

When we are contacted we may collect personal information that is intrinsic to the communication. For example, if we are contacted via email, we will collect the email address used.

We may collect or process the following information:‍

• Metadata - IP address, computer and connection information, referring web page, standard web log information, language settings, timezone, etc.
• Device Information - device identifier, device type, device plugins, hardware capabilities, etc.
• Location - GPS position.
• Actions - pages viewed, buttons clicked, time spent viewing, search keywords, etc.

Links to other sites
‍On our website, you will encounter links to third party websites. These links may be from us, or they may appear as content generated by other users. These linked sites are not under our control and thus we are not responsible for their actions. Before providing your personal information via any other website, we advise you to examine the terms and conditions of using that website and its privacy policy.

How we use personal information

The information we request, collect, and process is primarily used to provide users with the product or service they have requested. More specifically, we may use your personal information for the following purposes:

• to provide the service or product you have requested;
• to provide technical or other support to you;
• to answer enquiries about our services, or to respond to a complaint;
• to promote our other programs, products or services which may be of interest to you (unless you have opted out from such communications);
• to allow for debugging, testing and otherwise operate our platforms;
• to conduct data analysis, research and otherwise build and improve our platforms;
• to comply with legal and regulatory obligations;
• if otherwise permitted or required by law; or
• for other purposes with your consent, unless you withdraw your consent for these purposes.

The 'lawful processing' grounds on which we will use personal information about our users are (but are not limited to):

• when a user has given consent;
• when necessary for the performance of a contract to which the user is party;
• processing is necessary for compliance with our legal obligations;
• processing is necessary in order to protect the vital interests of our users or of another natural person.
• processing is done in pursuing our legitimate interests, where these interests do not infringe on the rights of our users.

We may use automated decision making for the following purposes:

• Choosing how to display content in any feed.
• Choosing what advertising or promotional material is shown to you.
• Making moderation decisions to protect the integrity, safety, and security of our platform and other users.

When we disclose personal information

Our third party service providers
The personal information of users may be held, transmitted to or processed on our behalf outside Australia, including 'in the cloud', by our third party service providers. Our third party service providers are bound by contract to only use your personal information on our behalf, under our instructions.
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Our third party service providers include:

• Cloud hosting, storage, networking and related providers
• Marketing and analytics providers

Other disclosures and transfers
We may also disclose your personal information to third parties for the following purposes:

• if necessary to provide the service or product you have requested;
• we receive court orders, subpoenas or other requests for information by law enforcement;
• if otherwise permitted or required by law; or
• for other purposes with your consent.

Accessing, correcting, or downloading your personal information

You have the right to request access to the personal information Lumin holds about you. Unless an exception applies, we must allow you to see the personal information we hold about you, within a reasonable time period, and without unreasonable expense for no charge. Most personal information can be accessed by logging into your account. If you wish to access information that is not accessible through the platform, or wish to download all personal information we hold on you in a portable data format, please contact our Privacy Officer.
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You also have the right to request the correction of the personal information we hold about you. All your personal information can be updated through the user settings pages. If you require assistance please contact our customer support.

Exercising your other rights

You have a number of other rights in relation to the personal data Lumin holds about you, however, there may be restrictions on how you may exercise the rights. This is largely due to the nature of the products and services we provide. Much of the data we collect is in order to facilitate contracts between users, facilitate payments, and provide protection for the legitimate users of our marketplace - these data uses are protected against the below rights.

You have the right to:

• seek human review of automated decision-making or profiling
• opt-out of direct marketing, and profiling for marketing
• erasure, commonly referred to as “the right to be forgotten”
• temporary restriction of processing.

Users may exercise any of the above rights by contacting our Privacy Officer.

To contact our Privacy Officer

If you have an enquiry or a complaint about the way we handle your personal information, or to seek to exercise your privacy rights in relation to the personal information we hold about you, you may contact our Privacy Officer as follows:
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By Email:
privacy@lumin.gg
For the purposes of the GDPR, our Privacy Officer is also our Data Protection Officer (DPO).

While we endeavour to resolve complaints quickly and informally, if you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Privacy Officer, by email as above. We will acknowledge your formal complaint within 10 working days of receipt.
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If we do not resolve your privacy complaint to your satisfaction, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) by calling them on 1300 363 992, making a complaint online at www.oaic.gov.au, or writing to them at OAIC, GPO Box 5218, Sydney NSW 2001.
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If you are in the European Union, you can choose to instead lodge a complaint with your local Data Protection Authority (DPA). The list of DPAs is at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.