Privacy Policy for Lumo Climbing

Last updated: January 21, 2024

Lumo Climbing ("Company," "We," "Us," or "Our") is committed to protecting Your privacy. This Privacy Policy explains how We collect, use, disclose, and safeguard Your information when You use Our mobile application ("Lumo" or "Application") and related services ("Service"). It also outlines Your rights under applicable laws, including the General Data Protection Regulation (GDPR). By using the Service, You agree to the terms of this Privacy Policy.

1. Interpretation and Definitions

Interpretation

Words with capitalized initial letters have defined meanings. These definitions apply regardless of whether the terms appear in singular or plural.

Definitions

  • Account: A unique account created for You to access the Service.

  • Application: The Lumo software program provided by the Company.

  • Company: Lumo Climbing ApS, Copenhagen, Denmark.

  • Country: Denmark.

  • Device: Any device capable of accessing the Service, such as a smartphone, tablet, or computer.

  • Personal Data: Any information that relates to an identified or identifiable individual.

  • Service: The Application and any related services provided by the Company.

  • Service Provider: A third party processing data on behalf of the Company.

  • Usage Data: Data collected automatically when using the Service.

  • You: The individual or entity accessing or using the Service.

2. Collecting and Using Your Personal Data

Types of Data Collected

Personal Data: While using the Service, You may provide Us with the following information:

  • Email address

  • First and last name

  • Account preferences and settings

Usage Data: Automatically collected data includes:

  • IP address, browser type, and browser version

  • Pages visited and time spent on those pages

  • Device type, unique device identifiers, and operating system information

  • Diagnostic data to improve the Service

Purpose of Data Collection

The Company processes Your Personal Data for the following purposes:

  1. To Provide and Maintain the Service: This includes monitoring usage and ensuring optimal performance.

  2. Account Management: Facilitating Your registration and access to features available to registered users.

  3. Contract Fulfillment: Managing and delivering products or services You purchase through the Service.

  4. Communications: Sending notifications, updates, and support messages related to the Service.

  5. Marketing: Sending promotional materials about related goods and services, unless You opt out.

  6. Business Operations: Conducting data analysis and usage trend assessments to improve the Service.

  7. Compliance: Fulfilling legal obligations or responding to valid government requests.

Legal Basis for Processing Data (GDPR)

We process Your Personal Data based on the following legal grounds:

  • Consent: When You provide explicit consent (e.g., for marketing communications).

  • Contract Necessity: To fulfill a contract or provide services You request.

  • Legal Obligations: To comply with legal or regulatory requirements.

  • Legitimate Interests: To enhance security, improve services, and conduct analytics.

3. Sharing Your Personal Data

We may share Your Personal Data in the following circumstances:

  1. With Service Providers: To facilitate the Service, such as hosting, analytics, and customer support.

  2. With Affiliates: To ensure affiliates honor this Privacy Policy.

  3. For Business Transactions: During a merger, acquisition, or sale of assets.

  4. With Business Partners: For co-promotions or joint offerings.

  5. With Other Users: When You choose to interact in public areas of the Service.

  6. With Your Consent: For any additional purposes You explicitly agree to.

We ensure all third-party data recipients comply with GDPR requirements, including implementing adequate data protection measures.

4. Data Retention

We retain Your Personal Data only for as long as necessary to:

  • Fulfill the purposes outlined in this Privacy Policy.

  • Comply with legal obligations.

  • Resolve disputes and enforce policies.

Usage Data is retained for a shorter period unless required to strengthen security or improve functionality.

5. International Data Transfers

Your Personal Data may be processed outside Your country of residence, including in countries with differing data protection laws. We ensure adequate safeguards are in place, such as:

  • Standard Contractual Clauses approved by the European Commission.

  • Binding Corporate Rules.

By using the Service, You consent to such data transfers, provided they meet GDPR requirements.

6. Your Rights Under GDPR

As an EU resident, You have the following rights:

  1. Access: Request a copy of the Personal Data We hold about You.

  2. Correction: Rectify any inaccurate or incomplete information.

  3. Erasure: Request deletion of Your Personal Data, subject to legal obligations.

  4. Restriction: Limit processing of Your Personal Data under specific circumstances.

  5. Data Portability: Obtain a copy of Your data in a structured, machine-readable format.

  6. Objection: Object to processing based on legitimate interests or direct marketing.

  7. Withdraw Consent: Withdraw consent at any time for data processing based on consent.

To exercise Your rights, contact Us at benjamin@lumoclimbing.com.

7. Security of Your Personal Data

We implement technical and organizational measures to protect Your Personal Data. However, no method of transmission over the Internet or electronic storage is 100% secure. While We strive to protect Your data, We cannot guarantee absolute security.

8. Children's Privacy

Our Service is not intended for children under the age of 13. We do not knowingly collect data from children without parental consent. If You become aware that Your child has provided Personal Data, contact Us, and We will take steps to remove the information.

9. Changes to This Privacy Policy

We may update this Privacy Policy periodically. Changes will be notified via email and/or a prominent notice in the Service. The "Last updated" date will reflect the most recent changes. Please review this policy regularly.

10. Contact Us

If You have questions about this Privacy Policy or wish to exercise Your rights, contact Us:

  • By email: info@lumoclimbing.com