LUMII.ME PRIVACY POLICY

Privacy Policy of Lumii.me

Effective Date: 07/12/2024

1. Introduction

At Lumii.me (“we”, “us”, “our”), safeguarding your privacy is at the core of our mission. We are committed to ensuring that our platform enhances child wellbeing and staff mental health while maintaining the highest standards of data protection and security.

This privacy notice explains how we collect, process, and protect personal data from clients, users, and visitors who interact with our website and Services. It also underscores our commitment to adhering to relevant international data protection regulations, including GDPR, FERPA, and COPPA principles.

2. About Us and This Privacy Notice

Purpose of This Notice

This notice aims to provide transparency on how we manage personal data, ensuring you have a clear understanding of our practices. We encourage you to read it alongside any other notices or terms of service we may provide.

Who We Are

Lumii.me Limited is the data controller for any personal data processed through our platform. For queries or concerns about data protection, you can reach our Data Privacy Manager, Mark Beedles, at:

• Email: DPO@lumii.me
• Address: 1902 Fortune Executive Tower, Cluster T, JLT, Dubai, UAE

3. What Makes Lumii.me Unique?

No Personal Data Collection for Children

Lumii.me is designed to operate without collecting or storing any personally identifiable information (PII) about children. Our platform processes anonymised data to deliver insights and support, ensuring compliance with global privacy standards.

Cultural and Legal Sensitivity

Our platform incorporates culturally sensitive adaptations tailored for specific regions, including the UAE, India, Saudi Arabia, Qatar, and Bahrain. These adaptations respect local norms and values, providing effective and inclusive support. We are continually expanding this functionality to include more regions.

4. The Data We Collect

We collect and process only the data necessary to provide our Services to schools, staff, and administrators. Data categories include:

• Identity and Contact Data: Information provided by school administrators (e.g., anonymised reference IDs for students).
• Technical and Usage Data: Collected via cookies or similar technologies to monitor platform performance.
• Marketing and Communications Data: If you sign up for updates, newsletters, or demos.

All data collection complies with legal requirements, and no unnecessary information is gathered.

5. How and Why We Use Your Data

We process your data for specific purposes, including:

• Providing schools with anonymised wellbeing insights to support early intervention.
• Supporting staff mental health via Lumii.life, ensuring educators have access to tools that enhance their wellbeing.
• Complying with regulatory obligations.

Legal Bases for Processing

Our data processing is based on:

• Consent: Where required, such as for receiving communications.
• Contractual Obligations: To deliver Services to schools.
• Legitimate Interests: For anonymised data analysis and improving our Services.

6. Sharing and Disclosing Your Data

We may share your data with:

• Service Providers: To deliver core platform functionality securely.
• Professional Advisors: For audits and legal compliance.
• Regulatory Authorities: Only when legally required.

All third parties are contractually obligated to maintain the confidentiality and security of your data.

7. Cookies and Tracking Technologies

We use cookies and similar technologies to improve your experience on our website and to monitor platform performance. These include:

• Essential Cookies: Necessary for security and basic functionality.
• Analytics Cookies: To understand usage patterns and enhance our Services.

You can manage your cookie preferences via your browser settings.

8. International Data Transfers

For users outside the European Economic Area (EEA), some data may be transferred internationally. We ensure equivalent levels of protection through standard contractual clauses or other approved mechanisms to safeguard your data during transfers.

9. Data Security

We employ robust technical and organisational measures to protect your data, including:

• End-to-end encryption for all communications and data transfers.
• Regular security audits and compliance checks.
• Restricted access to sensitive data on a need-to-know basis.

10. Data Breach Policy

In the unlikely event of a data breach, we will notify affected individuals and relevant authorities as required by applicable data protection laws, including GDPR. Our incident response plan ensures swift and effective handling of any breaches.

11. Data Retention

We retain data only as long as necessary for the purposes it was collected. For example:

• Anonymised Student Insights: Retained as aggregate data for trend analysis.
• Staff Wellbeing Data: Retained only as long as necessary to deliver Services.

Specific retention schedules are available upon request.

12. Staff Data Privacy

Lumii.life is dedicated to supporting staff wellbeing through a private, AI-powered platform designed to help educators manage stress, build resilience, and improve their mental health. Staff data privacy is a cornerstone of our approach:

• No Moderation or Monitoring: Interactions within Lumii.life are not moderated, monitored, or reviewed by anyone. This ensures complete privacy for all staff users.
• No Visibility to Schools or Administrators: Schools or administrators have no access to staff interactions or data within Lumii.life. This confidentiality empowers educators to use the platform freely without concerns.
• No Collection of Personal Data: Lumii.life operates without collecting or storing personally identifiable information (PII) from staff. Data generated is limited to what is essential for delivering the service securely.

By upholding these principles, Lumii.life ensures a safe and confidential space for staff to access mental health and emotional support.

13. Accessibility of Privacy Policy

This Privacy Policy is accessible at all times via our website and platform interface. Updates to this policy will be communicated clearly, and the latest version will always be available for review.

14. Your Privacy Rights

Under applicable laws, including GDPR, you have the following rights:

• Access: Request access to the data we hold about you.
• Correction: Request corrections to inaccurate or incomplete data.
• Erasure: Ask us to delete your data where appropriate.
• Restriction: Request a limitation on how your data is processed.
• Data Portability: Obtain a copy of your data in a machine-readable format.

To exercise these rights, contact our Data Privacy Manager at DPO@lumii.me.

15. Contact Us

For more information about this privacy notice or any questions about your data, please contact:

• Data Privacy Manager: Mark Beedles
• Email: DPO@lumii.me
• Address: 1902 Fortune Executive Tower, Cluster T, JLT, Dubai, UAE