Privacy Policy

Lumen is no longer operational. All profile-related personal data relating to Lumen has been deleted. Limited personal data may have been retained for legal and/or evidential purposes (for example, information concerning in-app purchases has been kept for compliance with applicable tax laws), this data will be deleted upon the expiry of the applicable retention period(s).

Who we are

Lumen is operated by Lumen App Ltd, a company registered in England at The Broadgate Tower, Third Floor, 20 Primrose Street, London, United Kingdom, EC2A 2RS with company number 11481021.

Lumen has designated a Data Protection Officer and they can be reached by emailing DPO@lumenapp.com or by post at the address above.

What information does Lumen process?

Lumen is a meeting place for adults aged 50 or over, and we provide that service by operating a social network site offering users the opportunity to connect to our global community of users. By joining Lumen, you enter a legal agreement with us and we process your data in order to provide your service under the terms of that agreement. You can only become a member of Lumen or use its features if you’re aged 50 years or over.

To join the Lumen network you will have to complete our online registration form, where we may ask you to provide us with information about you such as your name, your gender, your date of birth, your occupation, your location details and what you’re looking for on Lumen. We will also ask you to provide 3 photos and to write at least 200 characters of text about yourself. You have the opportunity to provide other details about yourself, but these are optional. Because you control your user profile, these details are available to you at any time by accessing your “Profile” page, which gives you the chance to correct or update your information (other than your gender) at any time by just logging in to Lumen. You can contact Lumen’s Customer Support Team at Feedback Page to change the gender on your profile.

Please be careful about posting sensitive details about yourself on your Profile such as your religious denomination and health details. While you may voluntarily provide this information to us when you create your Profile, including your sexual preferences and ethnic background, there is no requirement to do so. Please remember that any photographs that you post on Lumen may reveal these kinds of sensitive personal data. Where you do upload and choose to tell us sensitive data about yourself, you are explicitly consenting to our processing your information and making this public to other users.

For safety and security and to ensure you have the best possible user experience, we require users to verify their accounts and might ask for your phone number. We want to make sure you are not a robot! And we also want to avoid fake Lumen accounts being created which can be used for malicious activities and cyber crime – they threaten the Lumen network and spoil things for everyone. We use a third party provider for account verification who will keep your phone number for up to 90 days for fraud identification purposes.

It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.

To prevent abuse of the app/site, Lumen uses automated decisions to block accounts as part of its anti-spam procedures. In order to do this, our systems check accounts and messages for content that indicates breaches of our Terms and Conditions of Use. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will automatically be blocked. All users of accounts that have been blocked will be notified that their account has been blocked and affected users can contact Lumen to contest the decision.

Lumen also uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behaviour that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified that their transaction cannot be processed and affected users can contact Lumen to contest the decision.

Please note that if your account is blocked, any account(s) that you have on our other group platforms/applications may also be blocked as part of our anti-spam and anti-fraud procedures.

If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.

Finally, we want to keep in touch with you to make sure you know about any great promotions and offers we may have available. If you’ve told us it’s OK, we will use your email address and phone number to send you information on these. You can withdraw this consent at any time via Settings in the app or website.

What does Lumen collect about me if I use the mobile App?

Lumen offers you the opportunity to stay in touch with the friends and contacts you’ve made no matter where you are. You can do this by using your mobile phone or by downloading an application to your desktop that allows you to share your location with other users.

When you use your mobile or the desktop application, we will collect information about WiFi access points as well as other location information about your longitude and latitude. That information helps us identify your physical location so that we can display other members who are within a certain distance to you.

If you have enabled location services, but wish to turn them off, you can do so by the following methods:

1. iPhone app — settings, privacy, location services, Lumen
2. Android — settings, location, Lumen, permissions, location

For users who are California residents, the data we may collect falls within the following categories of “personal information,” as defined by the California Consumer Privacy Act (CCPA):

• A. Identifiers, such as name and location;
• B. Personal information, as defined in the California customer records law, such as contact (including email and telephone number) and financial information;
• C. Characteristics of protected classifications under California or federal law (if you choose to provide them), such as age, gender identity, marital status, sexual orientation, race, ancestry, national origin, religion, and medical conditions;
• D. Commercial information, such as transaction information and purchase history;
• E. Biometric information (not relevant here);
• F. Internet or network activity information, such as browsing history and interactions with our websites and apps;
• G. Geolocation data, such as mobile device location;
• H. Audio, electronic, visual and similar information, such as photos and videos;
• I. Professional or employment-related information, such as work history and prior employer;
• J. Non-public education information; and
• K. Inferences drawn from any of the personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.

What is the legal basis that allows Lumen to use my data?

We are only permitted to use your data when we have a lawful basis to do so. The table below provides an overview of the legal bases that Lumen relies on to use your data. Where the legal basis is consent, you can withdraw consent at any time. Where the legal basis is legitimate interests, you have a right to object to our use of your data. We explain in the relevant sections in this privacy notice how you can withdraw consent or opt-out of certain data uses (where applicable).

Purpose for which data is used	Data	Source	Legal basis
To provide you with the Lumen social networking service	Name, email address, date of birth, location (CCPA Categories A and B)	You provide your name, email address and date of birth to us. We obtain location data from the device that you use to access the service	Contractual necessity
To facilitate networking opportunities on the Lumen site	Optional information that you choose to provide in your profile, which may include information about your sexual preferences, religion, ethnic background, photos etc. (CCPA Categories C, H, I, J)	You provide this information to us	Consent
To verify your identity and prevent fraud and to ensure the safety and security of users	Phone number (CCPA Category B)	You provide this information to us	Legitimate interests – it is in our legitimate interests to ensure that accounts are not set up fraudulently and to safeguard users of the site
To take payment for premium services	Payment card details (CCPA Categories B and D)	You provide this information to us	Contractual necessity and legitimate interests – we need card details to receive the payment due under our contract with you (where applicable) and we have a legitimate interest in using this data for fraud prevention purposes
To send you marketing information about our offers and services	Email address and mobile phone number (CCPA Category B)	You provide this information to us	Legitimate interests – it is in our legitimate interests to promote our products and services
To show “nearby” location information to you and other users of the site	Wifi access points and location data when you use the mobile app (CCPA Category G)	We obtain this information from the device that you use to access the service	Legitimate interests – it is in our legitimate interests to provide this functionality as part of the service
To carry out analysis to help us improve the app	Log and usage data, including IP address, browser type, referring domain, pages accessed, mobile carrier and search terms (CCPA Category F)	We obtain this information from your interaction with our service	Legitimate interests – it is in our interests to analyse the way in which users are accessing and using our services so that we can further develop the app and improve the service
To respond to correspondence and queries that you submit to us	Email address and IP address (CCPA Categories B and F)	You provide your email address to us when you contact us and we obtain your IP address from the device that you use to contact us	Legitimate interests – it is in our legitimate interests to respond to your queries to ensure that we provide a good service to users and troubleshoot problems
To block accounts as part of our anti-spam procedures	Email address, phone number, IP address and IP session information, username, user agent string (CCPA Categories B and F)	You provide your email address, phone number and username to us. We obtain the other information from the device that you use to access the service	Legitimate interests – it is in our legitimate interests to prevent unauthorised behaviour and to maintain the safety and security of our services
To block payment transactions as part of our anti-fraud procedures	Name, IP address, email address, mobile number, cardholder name, payments received, type of payment, user ID, country (CCPA Categories, A, B, and D)	You provide your name, email address, phone number and card details to us. We obtain your IP address from the device that you use to contact us. We obtain your payment information from your interactions with our service	Legitimate interests – it is in our legitimate interests to prevent fraudulent transactions and to maintain the security of our services

How long will Lumen keep my data?

We keep your personal information only as long as we need it for legitimate business purposes (as set out above) and as permitted by applicable law.

In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window), unless:

1. we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
2. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);
3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

Where Lumen uses machine learning, for example, to help us detect and prevent fraudulent card transactions, and to detect and prevent spam communications on the app (as explained above), we may need to keep personal information for a longer period than the retention periods explained above, to enable the machine learning to work properly. Where this is the case, we always seek to minimise the amount of personal information that is used and we ensure that it is ring-fenced and kept securely from other user personal information. We regularly review the period for which personal information is required for machine learning purposes and delete any identifiable information when it is no longer required.

What information does Lumen collect about me if I’m under 18?

Lumen does not knowingly collect any information about or market to children, minors or anyone under the age of majority, and it is only available to people aged 50 years or more. If we become aware that a child, minor or anyone under the age of 50 has registered with us and provided us with personal data, we will take steps to terminate that person’s registration and delete their Profile information from Lumen. If we do delete a Profile because you violated our age restriction rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new Profile.

Who does Lumen share information with?

We may share aggregated information that includes your personal data (but which doesn’t identify you directly), together with other information including log data with third parties for industry analysis and demographic profiling.

We share your data with the following categories of third-parties:

Third party	Disclosed data
Information technology companies (hardware and software) which provide services to support our products	This could include all data, including all CCPA Categories listed above
Fraud prevention and anti-spam providers to protect the service from criminal activity	Transaction and payment data (CCPA Categories B and D)
Moderators to monitor activity on the site/apps and approve content	Name and user registration details, profile information, content of messages and photographs (CCPA Categories A, B, C, E, and H)
Law enforcement agencies, where we are required to by law or to protect the vital interests of a person	This could include any personal data that Lumen holds about you, depending on the nature of the request or the issue that we are dealing with, including all CCPA Categories listed above
Payment processing and telecommunications companies to facilitate payments for our premium services	Cardholder name, cardholder address, card number, payment amount, transaction date/time (CCPA Categories A, B, and D)
In the event that Lumen or any of its affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organisation, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data to a purchaser of all or part of the business or to an insolvency practitioner	This could include all personal data that Lumen holds about you, including all CCPA Categories listed above
Your data may be shared with other Lumen group companies, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures.	This could include CCPA Categories A, B, D and F.

We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible.

Lumen does not sell your data and has not sold your personal data in the previous 12 months.

Your rights

Under UK and EU law, you have the right to lodge a complaint with data protection regulators. Lumen has its main office in the UK and the Information Commissioners’ Office (ICO) is our lead regulator. You can find out how to raise a concern with the ICO by visiting their website at www.ico.org.uk. If you’re within the EU, you may also get in touch with your local Data Protection Regulator who may liaise with the ICO on your behalf.

You have a number of rights under European Data Protection law as detailed below. These rights apply to all of our users.

1. Right to be informed: what personal data an organisation is processing and why (we provide this information to you in this Privacy Policy).
2. Right of access: you can request a copy of your data.
3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
4. Right to erasure: you have the right to have your data deleted in certain circumstances.
5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
6. Right to data portability: you can request a copy of your data in a machine-readable form that can be transferred to another provider.
7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.
8. Rights related to automated decision making including profiling: there are several rights in this area where processing carried out on a solely automated basis results in a decision which has legal or significant effects for the individual. In these circumstances your rights include the right to ensure that there is human intervention in the decision-making process.

For users who are California residents, you also have the following rights (in addition to those listed above) under the California Consumer Privacy Act, and you have the right to be free from unlawful discrimination for exercising your rights under the Act:

1. You have the right to request that we disclose certain information to you and explain how we have collected, used and shared your personal information over the past 12 months.
2. You have the right to request that we delete your personal information that we collected from you, subject to certain exceptions.

If you want to exercise any of your rights listed above please visit Feedback Page or email us at DPO@lumenapp.com. You can also contact us by post at The Broadgate Tower, Third Floor, 20 Primrose Street, London, United Kingdom, EC2A 2RS.

How does Lumen protect my personal data?

Lumen has implemented appropriate security measures to protect and prevent the loss, misuse, and alteration of the information under our control, including your personal data. Our technical experts at Lumen work hard to ensure your secure use of our site.

While we take reasonable precautions against possible security breaches of our website, member database and records, no website or internet transmission is completely secure and we cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal data safe (including your password) and to log out of your account after use. If you lose your password or give it out, or another service provider that you use suffers a data breach and you have used the same credentials with that service provider as you have with Lumen, your personal data may be compromised. If that happens, please report it to Support via our Feedback Page.

Where is my personal data kept?

We want you to be able to access Lumen wherever you happen to be in the world. To enable us to provide that service, we operate a global network of servers including in the US, Hong Kong, Czech Republic and Russia. The hardware is located in third-party data centres but is owned by Lumen. We ensure that the data is adequately protected by ensuring that valid, legal mechanisms are in place such as: EU approved model clauses (which can be found here), US privacy shield certification (more information can be found here); and implementing robust contractual standards. If you want more information relating to the nature of the safeguards we have in place please email DPO@lumenapp.com.

Does Lumen collect any other personal data about me?

If you contact our Customer Support team via our Feedback Page, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other users (and from other users about you) for 6 years after deletion of your account.

Does Lumen use my personal data for any other purpose?

We may use your personal data to resolve disputes, troubleshoot problems and enforce our Terms and Conditions of Use.

What are 'cookies' and what 'cookies' does Lumen use?

We collect information by placing cookies on your computer or mobile. A cookie is a piece of text stored on your computer or mobile by your web browser. They are basically a tool that stores information about website visits, recognises you and your preferences each time you visit Lumen, and ensures site functionality and enables us to provide the services our members request.

When you visit the publicly available sections of Lumen, a session ID cookie is placed on your computer that only lasts while you’re visiting. We also place persistent cookies (also known as local storage devices) on members’ computers, so that Lumen remembers them and makes their login experience faster and easier. We may use persistent tracking cookies on your mobile device, mainly for security protection purposes, such as to prevent phishers, scammers, unauthorised log in attempts, and to help you access your hacked account. We do not use any information whilst you are logged off.

You may set your browser and your mobile settings to block cookies and local storage devices, but if you do so, you may not be able to access the features that Lumen offers.

Lumen’s use of cookies and local storage devices basically falls into the following categories:

• those that are strictly necessary to deliver the services and products you have requested, such as, for example, purchasing Lumen Premium;
• cookies related to the performance of Lumen’s site, such as analytics that help us determine how our site is performing and ensuring a smooth and trouble free experience for our members and visitors;
• cookies related to the functionality of Lumen’s site, such as remembering your preferences at log in or your preferred language or allowing you to chat, add photos and instant message Lumen members; and
• third party cookies which link to other social networks and which you request via social plugins.

Lumen uses cookies and local storage devices so that we know who you are, what interests you have and so that you can do the things online that you want to do, like chat with new people, share your content and buy Lumen Premium knowing that your data will be secure. Below is a table to explain Lumen’s cookie functions and why they’re used.

Cookie Functions	Cookie Purposes
Analytics and research	Lumen uses Google Analytics to collect information about how visitors use the Lumen site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. For more information about Google’s privacy policy, please visit http://www.google.com/intl/en/policies/
Authentication	These cookies help us to identify our members so that when you’re logged in, you can enjoy Lumen’s offerings, experiences and various features, such as uploading photographs, chatting and can localise your experience, such as when you’ve requested to view Lumen’s site in your local language or when you’ve asked Lumen to ‘remember me’. These cookies also help to remember who invited you to join Lumen.
Security and site integrity	We use cookies and other devices, such as CAPTCHAs, to help keep Lumen and our members safe and secure. These cookies do things like protect Lumen users from spam and fraud, by ensuring the safety of your personal data when you shop on Lumen for things like Lumen Premium. We may use persistent cookies, which will help us to ensure we have identified the same device is logging into the correct account. These types of cookies also help with our anti-spam measures and may help us to prevent phishers, scammers, unauthorised log-in attempts to your account and accessing any hacked accounts.
Site features and services	These cookies and local storage devices provide the functionality that our Lumen members enjoy, such as uploading of photographs, chats, instant messaging, your account settings and your request to have Lumen as your homepage or your search preference. In some cases, the site feature you choose may allow a third party to place cookies or local storage devices on your computer. The third party who places cookies on your device is responsible for how they process their data and Lumen recommends that you read their privacy policies. Third parties who place cookies on your device when you use Lumen include the following, and we have included a link to their privacy policies: Twitter, https://twitter.com/privacy Facebook, https://en-gb.facebook.com/policy.php YouTube, http://www.google.co.uk/intl/en/policies/privacy/ AddThis, http://www.addthis.com/privacy
Performance	We need to use certain cookies and local storage devices to ensure our members have the best possible experience, such as assisting with your navigation of our site, ensuring pages load up quickly and respond faster to your requests for Lumen services.

Our use of cookies and local share devices, including the specific cookie names, may change over time, but will generally fall into the above categories. We will notify you of any important changes to our use of cookies and local storage devices. If you would like to know more about cookies, including flash cookies/local storage devices, the following websites provide useful information:

• www.allaboutcookies.org
• www.youronlinechoices.eu
• http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html

In the event there is a discrepancy between this English language version and any translated copies of this Privacy Policy, the English version shall prevail.

This Privacy Policy was last updated on 1 July 2021.