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Privacy Policy

Effective Date: 8 May 2025

At Lumenara, we value your privacy. This Privacy Policy outlines how we collect, use, and protect your personal information when you engage with our services, including the Lumenara platform, SPARK assessment, Aria (AI-powered coach), programs, and website.

1. Scope

This policy applies to personal data we collect and process in our capacity as a data controller, including data collected through our website, platform, and services. For data processed on behalf of clients, such as employer-sponsored programs, we act as a data processor, and the client's privacy policy governs.

2. Information We Collect

  • Personal Identifiers: Name, email address, contact details, and login credentials.
  • Well-Being Data: SPARK assessment responses, journaling entries, feedback forms, and learning engagement.
  • Aria AI Coaching Data: Text-based interactions, emotional tone metadata, and usage history.
  • Demographic Data: Optional details like age, gender, occupation—collected only with consent.
  • Device & Usage Data: Browser type, device info, IP address, referring URLs, session timestamps, and interaction data.
  • Third-Party Data: Information from partners or services integrated with Lumenara, collected with consent.

3. How We Use Your Information

We use your data to:

  • Provide and personalise our services, including SPARK and Aria.
  • Support your progress through the Lumenara journey and reflect key milestones.
  • Analyse and improve our services, user experience, and platform performance.
  • Communicate with you about updates, offers, and relevant information.
  • Conduct research and analytics, using de-identified data where applicable.
  • Comply with legal obligations and enforce our terms and policies.

4. Legal Bases for Processing

We process your personal data based on the following legal grounds:

  • Consent: Where you have given explicit permission.
  • Contract: To fulfil our contractual obligations to you.
  • Legal Obligation: To comply with applicable laws and regulations.
  • Legitimate Interests: For purposes such as improving our services, provided these interests are not overridden by your rights.

5. Data Sharing and Disclosure

We do not sell your personal data. We may share your information with:

  • Service Providers: Trusted partners who assist in operating our services, under strict data protection agreements.
  • Legal Authorities: When required by law or to protect our rights.
  • Business Transfers: In the event of a merger, acquisition, or asset sale, your data may be transferred as part of that transaction.

6. International Data Transfers

Your information may be transferred to and maintained on servers located outside your jurisdiction, including in Australia and other countries with adequate data protection laws. We ensure appropriate safeguards are in place for such transfers.

7. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy, unless a longer retention period is required or permitted by law. Upon request, we will delete or anonymise your data, subject to legal obligations.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our security practices are regularly reviewed and updated.

9. Your Rights

You have the right to:

  • Access the personal data we hold about you.
  • Request correction or deletion of your data.
  • Withdraw consent at any time, where processing is based on consent.
  • Object to or restrict certain types of processing.
  • Request data portability.
  • Lodge a complaint with a supervisory authority.

10. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience, analyse usage, and deliver personalised content. You can manage your cookie preferences through your browser settings.

11. Children's Privacy

Our services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children without parental consent.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by posting the new policy on our website and updating the effective date.

13. Contact Us

For questions or concerns about this Privacy Policy or our data practices, please contact us at:
Email: privacy@lumenara.io
Address: 11, Wilson Street, South Yarra, Victoria, Australia