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Privacy Policy

Last updated on August 10th, 2018

This privacy policy describes what information we collect from and about you when you use our mobile apps, API, or website at thinklumo.com (collectively, the “Services”), how we store and secure that information, who we share the information with, and your choices as they relate to using our Services.
When we refer to “Lumo”, “we”, “our”, or “us” we mean Resilient Ops, Inc., the company that brings you these Services. This Privacy Policy is incorporated into and is subject to our Terms of Use.

Information we collect from you

Information you provide to us in order to use the Services

  • Account and Profile Information: Information you provide to us when you sign up for an account or API access, such as name and email address.

  • Content you provide through our website and app: This includes flight itineraries, labels or tags associated with the itinerary, and notification preferences you set via the app such as suppressing certain types of flight updates.

  • Content you provide by sending itineraries to trips@thinklumo.com: When you send us your itinerary at trips@thinklumo.com, we parse the email to extract information about your flights so we can track them for you. While we do not use anything other than your flight information contained in the email to provide our Service, the emails you send us may have information such as credit card data, addresses, or other personally identifiable information. We store these emails and ensure that they are encrypted. If you do not wish for us to have the information contained in these emails, you can choose not to send the emails to us, and instead register your flights using the app or website.

Information you provide through our support channels

If you email us for support, or submit one of the contact forms on the website, we will collect any data you provide to us such as screenshots, a description of your problem, or any other feedback that you share with us.

Information we collect automatically when you use the Services

  • Details on how you use the service: This may include information on the features you use, notifications you are receiving, when you use the app or API, or usage patterns, such as when or how often you use the Service.

  • Device and Connection Information: We collect information about the type of device you are using, device identifiers to enable push notifications, errors you encounter using our app or website, IP address to diagnose errors in our product, or other crash information.

  • Tracking Technologies:

    • “Cookies” are small text files of alphanumeric characters that uniquely identify your browser. We use cookies to store session information and improve your experience. Cookies can be either “persistent” (that stay on your machine after the browser is closed so that we can, for example, recognize you when you return to our site to log you in) or “session” cookies (that expire once you close your browser). You can change your browser settings to not allow cookies, or to indicate when cookies are being used. However, if you choose to disable acceptance of cookies in your browser, website functionality may be impaired.

    • “Log files” track actions occurring on our site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

    • “Tracking scripts” track your behavior within the website or app. Tracking scripts may collect information it includes data such as IP address, estimated location, pages you browse within our Services, Internet Service Provider, referring/exit pages, and date/time stamps, and other interactions with the Service.

Information we receive from other sources

We work with companies to track flights on behalf of their users or employees. In such cases, we may receive information about you from the third party (your employer, travel management company, or other third-party service provider) that allows us to track your flight. This may include your flight information, name, email, phone number, or other information that is needed to track your flight and send you or the third party information about your flight.

Third parties are allowed to share your data with us only if you have given them consent to do so.

How we use information we collect

To provide the Service

We use the information to authenticate you, and to share flight information with you by displaying your information about your flights on the site and app, sending you alerts on your mobile device, sending information through the API, and emailing you information about your flights.

To send you updates on the Services and Policies

We may contact you to let you know about changes in our Terms of Use or Privacy Policy, or security announcements.

For research and development

To improve the experience of our product, we use information about how people are using our Services, specific feedback we receive, crash data, the types of to identify aspects that our users aren’t enjoying.

To communicate with you

Contact information is used to send transactional messages, including updates about flights you are tracking. These communications are part of the product offering, and you can only opt out of them by not tracking any flights. We may contact you in one of two ways.

  • By email: When you sign up for our Service, you will receive an email from us asking you to verify your email. If you do not verify your email, we will not send you any flight alerts to you by email.

  • Using mobile push notifications: We use mobile identifiers to send you push notifications about your flights.

We also communicate by email with you about changes to our Services and to obtain feedback. To opt out, use the unsubscribe link at the bottom of the email.

Customer support

We may use the information we collect to resolve technical issues you are having, or answer questions you may have about your account or flights.

With your consent

In the case of using information in a manner not listed above, we ask specifically for content. For example, we may post your feedback or testimonials on our website, but only if you give us your consent.

Legal bases for processing (for EEA users)

We rely on four primary bases for processing EEA Personal Information.  

  1. The first one is our legitimate interests, which we weigh against any risks to your rights.  By “legitimate interests,” we mean the ordinary needs and objectives of a business that offers the types of services that we offer, including security, quality assurance (such as preventing the dissemination or malware and misuse of our Site and services), customer service, communicating with users to better serve them, and improving and developing new products and services.  

  2. The second is when processing is necessary to enter into or perform a contract with you.  

  3. The third basis is consent – you will know when we are relying on consent because we will have expressly asked you for your consent (and if you don’t give us consent, we won’t perform the processing in question).  

  4. We may also process your Personal Information on the basis that we need to do so to fulfill our legal obligations. We expect this would be a rare situation.

How we share information we collect

Sharing with service providers

We will not sell or lease your Information to any third party. However, we do share your information with third parties to provide our Services.
We work with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, infrastructure, payment processing, authentication, survey hosting, analysis and other services for us, which may require them to access or use information about you. A non-exhaustive list of third party service providers is listed below; all of our third party service providers abide by policies and procedures designed to protect your information.

  • Amazon Web Services: We use AWS to run our Services, store your data, and manage our entire infrastructure.

  • Google Mail: All our @thinklumo.com email addresses are hosted by Google.

  • Typeform: When you submit feedback to flight notifications via our feedback form on our website, the information is sent to Typeform.

  • Google Analytics: When you use our desktop or mobile website, we use Google Analytics to track your interactions with our site.

  • Bugsnag: We use bugsnag for crash reporting on mobile apps; bugsnag only receives anonymous, non-personally identifiable data.

  • Segment: We use segment to track your interactions with our app.

  • AwardWallet: We use AwardWallet to parse itineraries that you send to trips@thinklumo.com. We forward your email to them and they return your flight information contained in the email.

  • Hubspot: We use Hubspot to manage web pages, capture data on website usage, and track and log communications through email and chat. 

Compliance with Enforcement Requests and Applicable Laws and Enforcement of Our Rights

We may share your information as required by law or regulation or as we believe in good faith that disclosure of such personal information is reasonably necessary to: (1) satisfy any applicable law or regulation, (2) to respond to claims and/or to comply with a judicial proceeding, court order or legal process served on us, (3) to protect and defend our rights or property, and/or the rights or property of our customers, or third parties, as permitted by law, (4) to detect, prevent or otherwise address fraud, security or technical issues; or (5) to enforce our Terms of Use

Sharing with our partners or corporate customers

When our Services are made available to you through an organization with whom you have an agreement (such as your employer, travel management company, airline, or third party service provider), we share your travel information and updates on your flights with that organization.

Merger or Sale

As with any other business, it is possible that in the future we could merge with or be acquired by another company. If such an acquisition occurs, the successor company would have access to the Information, but would continue to be bound by this Privacy Policy unless and until it is amended.

How we store and secure information we collect

Information storage and security

We host all data that we collect in the United States using a cloud hosting provider. We implement a variety of reasonable and standard safeguards to protect your information, but the internet is not completely secure and we cannot guarantee that your information will stay secure.

How long we keep information

We keep information for differing periods of time, depending on the type of data.

  • Account Information: We keep this until you delete your account. We may retain some of this data to comply with legal obligations or to support business operations and to continue to improve our service.

  • Usage information: We log usage information (such as when you started tracking a flight) to support our infrastructure and improve our product. This log data contains anonymized data whenever possible, and is archived within a year, with strict access control over who can review archives.

  • Managed accounts: if your flight information is provided through an organization (such as a travel management company), we keep your data as long as required by that organization.

Your choices to access and control your information

You may decline to submit Personally Identifiable Information to us, in which case we may be unable to provide our Services to you. You have the right to request us to do the following

  1. Delete your information

  2. Provide you with a  copy of your information

  3. Correct or rectify your information

  4. Restrict the use of your information

Contact us at privacy@thinklumo.com with your request.

We may be unable to fulfill your requests in certain cases where our legal obligations or other individuals’ privacy rights override your rights, in which case we will tell you that we have rejected your request and give you the reasons why.

As we note in our Terms, if you do not agree to the Terms of Use or do not consent to the use of your data as described in this Privacy Policy, please discontinue using our Services; by continuing to use our Services,  you consent to the use of your information as outlined in this Privacy policy and and accept our Privacy Policy and Terms of Use.

Other important privacy information

Individuals under 16

Our services are not intended for, or designed to attract, individuals under the age of 16 and as such, we do not intentionally gather information from individuals who are under the age of 16.  Upon notification that an individual under 16 has provided us with personally identifiable information, we will delete the child’s personally identifiable information from our records. We may require additional information to confirm that the request is a bona fide request concerning a child under the age of 16.

California Users/Visitors

California Civil Code Section 1798.83 permits users who are California residents and who have provided us with “personal information” (as that term is defined in Section 1798.83) to request certain information about the disclosure of that information to third parties for their direct marketing purposes. If you are a California resident, you may contact us by email at privacy@thinklumo.com.

Canadian Users/Visitors

Canadian citizens, except under circumstances defined by law, are entitled to access their own personal information collected by Lumo by emailing us at privacy@thinklumo.com. We may ask you to pay an administrative fee for accessing or copying your personal information, but will inform you of the anticipated charges and confirm that you want us to proceed before processing your request. If you believe that the personal information about you that we have collected is incomplete or inaccurate, we will correct the information upon verification of the omission or error and of the identity of the person requesting the change. If you wish to request additional information about our information management, or would like us to access, correct or have us investigate any matters in relation to your personal information, please contact us.

Notice to End Users

Our services are for use by both consumers and organizations. When our Services are made available to you through an organization with whom you have an agreement (such as your employer, travel management company, airline, or third party service provider), that organization is responsible for managing your information privacy. In such cases, please refer to the privacy policy and terms of use of that organization, as they may be different from ours, and please direct your privacy-related questions to that organization.

Updates to this Privacy Policy

We may update this policy from time to time. If there are significant changes, we will let you know by posting a notice on this site and via the email you use to access our Services.

Contacting Us

If you have any questions about this Privacy Policy, you can email, write or call us.
Email: privacy@thinklumo.com
Postal address: Resilient Ops, Inc., 50 Milk St Fl 16, Boston MA 02109, USA
Phone: +1 (866) 452-1961