Privacy Policy

Last updated on May 1, 2019

Since 1987, MicroLumen, Inc. (“MicroLumen”) has provided superior service to its customers through collaboration and mutual trust. We value the trust we have built with our clients and protection of your privacy is important to us. We provide this privacy policy (“Privacy Policy”) to describe how we handle information we collect about you and your options regarding your personal information. This Privacy Policy applies to all services and products, except those that have a separate privacy policy.

The Privacy Policy applies to your use of the website located at MicroLumen.com (the “Website”), any other MicroLumen websites and related applications (if any) (collectively the “Services”), as well as to information we collect from you (or about you) offline (e.g., when you provide information by phone or on a paper form) or on other websites unless otherwise stated where that collection occurs (for example, if there is a separate privacy statement).

By using any of the Services, you agree to this Privacy Policy. The Services are located in the United States of America and operated pursuant to the laws of Florida, United States, which may differ from privacy laws where you live. When you provide Personal Information (defined below) using the Services, you agree that we may transfer your information to any country and that we may use and disclose it as permitted by federal and state law and consistent with this Privacy Policy.

We may change our Privacy Policy, so please check this page from time to time. You can tell when the Privacy Policy (including the EU Privacy Notice and Cookie Notice) was last updated by the “Last Updated” date at the top of the page. Your continued use of the Services after we publish our changes means that you accept the revised Privacy Policy. If you do not agree to the revised Privacy Policy, please refrain from using our products or services.

Please note that supplementary rules apply in relation to individuals whose data we collect if they are located in the European Union (“EU”) or European Economic Area (“EEA”) (in which case, please see the EU Privacy Notice below). If you are a California resident, you may have additional rights. Please refer to “Your California Privacy Rights” below for more information.


This section generally outlines our policies on data collection, use and sharing and your options regarding your data. For additional details, simply click through the relevant box. We want you to be comfortable with our handling of your information, so we’ve tried to keep things as simple and straightforward as possible.

By using our services or websites, you are agreeing to this Privacy Policy, so please take time to review it and let us know if you have any questions by visiting the Contact us Section below.

What information do we collect?

We may collect Personal Information that you provide to us directly or that you provide by using certain applications or features and we may combine that information with information from other sources. We also may automatically collect some Personal Information relating to your use of our Services and to your device, as well as Other Information that does not identify you individually.

More about what information we collect

How do we use your information?

We may use Personal Information to respond to you, fulfill your requests, communicate with you or customize your experience, to analyze and improve our Services, protect our users, for other business purposes, as required by law, or otherwise disclosed to you when you provide your Personal Information. We may use Other Information for any legal purpose.

More about how we use your information

Do we share your information?

We may share information that does not identify you with third parties for marketing and analytical purposes. We may share Personal Information with trusted vendors who perform services for us, Co-Branded Parties when you provide your Personal Information through a Co-Branded Service, to select third parties for certain marketing purposes, and to an acquiring company in the event of a merger or similar asset transfer. We may also divulge Personal Information if required by law or if permitted to protect our company, users or the public.

More about how we share your information

How do we protect your information?

We use reasonable safeguards to help protect your Personal Information and we employ additional measures to protect billing or other sensitive information, such as SSL and access controls. Of course, data storage and transmission via the Internet can never be guaranteed to be 100% secure and we have no control over any third parties who may collect your data.

More about how we protect your information

What are your choices?

You have a number of choices regarding the collection, use and sharing of your information, including opting out of most general and marketing e-mails, revoking prior consent with respect to certain communications, and deleting your Personal Information. You can exercise most of these options by contacting us as noted in our Contact Us page.

More about your choices

If you live in California, what are your rights?

California residents may request information about our disclosure of information to third parties for direct marketing purposes under California’s Shine the Light law. We do not share Personal Information with third parties for their own direct marketing purposes.

More about your rights if you live in California

What about Children?

MicroLumen does not market to children and we do not knowingly collect information from children under 16.

More about children’s privacy


This Privacy Notice is the official statement of our privacy practices relating to the Services and it governs over any non-English version or translation of the document to the extent of any inconsistencies.

More about our international policy

How can you contact us?

We hope this information is helpful but if you have any questions about our data practices, please reach out to us as set out in our Contact Us page.

More about our how you can contact us

What about EU/EEA residents?

If you live in the European Union (“EU”) or European Economic Area (“EEA”), you have specific legal rights regarding your personal data, including certain rights of notice, access, control, and reporting. For an explanation of MicroLumen’s legitimate purposes for processing your personal data, your rights or additional assistance, please see our EU Privacy Notice.

More about the privacy rights of EU/EEA residents

Click on any link below to jump to a specific area of our Privacy Policy or read on for the full Privacy Policy:

  • What information we collect
  • How we use your information
  • Do we share your information?
  • How we protect your information
  • Your Choices
  • California privacy rights
  • Children
  • International
  • Contact Us
  • EU Privacy Notice
  • Cookie Notice

What information do we collect?

MicroLumen or third-party contractors and other service providers working on our behalf (“Service Providers”) may collect information that can be used to directly or indirectly identify you (“Personal Information”). Personal Information may also include anonymous information that is linked to information that can be used to directly or indirectly identify you.

We also may collect information and data elements that do not identify you as an individual (“Other Information”). Other Information can also include information that has been deidentified or anonymized so that it cannot be used to personally identify you.

Information you provide

You can access some of our Services without providing any Personal Information to us. However, to take advantage of some features of our Services, you may be asked or required to provide Personal Information. For example, depending on the feature you wish to access, we may ask you for Personal Information such as your contact information (e-mail address, phone number, region, etc.), or billing or shipping information (for purchases or sample requests).

Information we may collect automatically

When you use our Services, MicroLumen or our Service Providers may collect information about how you access, use, or otherwise interact with the Services, our e-mails, and online advertising. This information is collected for various reasons, including to help ensure that the Services continue to work correctly, to improve the Services, to support marketing campaigns, to understand our customers and how they use the Services, and to offer you a more personalized experience.

The information collected may include technical information about the device you use to access the Services, such as its IP address, operating system, temporary or persistent device identifiers, browser, referring website or service information, usage information (such as content you viewed or interacted with).

Our Services may also collect precise information about the location of your device after you permit us to obtain such information from technologies such as Bluetooth beacons, GPS, Wi-Fi signals, or cell tower signals. We may collect this information to provide you with services, content and offers based on your location. You can adjust some location information-related permissions on your device.

We may collect the information above using cookies (“Cookies”) or similar technologies. Cookies are small bits of information that are stored by your web browser. For more information about Cookies, please review our Cookie Notice.

We use Google Analytics to learn about how you and others use the Services. You can learn more about how Google uses the information it collects at: https://www.google.com/policies/privacy/partners.

Information we receive from other sources

We may combine the information that we collect with information that we obtain from other sources, such as third-party services and organizations, including business partners and marketing agencies. We may use the combined information to contact you with offers relevant to your location.

If you access third-party social network services (“Social Networks”), such as Facebook, Google, or Twitter, through the Services to log in to the Services or to share information about your experience on the Services with others, we also may collect information from these Social Networks.

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How do we use your information?

Personal Information

We may use Personal Information we collect (including in combination with Other Information) to:

  • Recognize new or past customers or users, customize your experience when you use the Services or serve you with advertising content that we believe will interest you;
  • Communicate with you about your account, your use of the Services, or related issues or respond to or fulfill your requests for products, services, and information;
  • Provide you with information about the Services and update you on any changes or improvements;
  • Engage in general marketing efforts, such as sending you information about special promotions, offers, new features or products, whether for MicroLumen or trusted third parties;
  • Provide, maintain, protect and improve the Services and other products and to develop new ones;
  • Further our business or operational purposes, for example, data analysis, audits, fraud monitoring and prevention of fraud or other illegal activities or other prohibited conduct in accordance with our Terms of Use (which can be found at https://www.microlumen.com or otherwise protect our company, our users, or our Services; and
  • For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

Other Information

Because Other Information (as defined above) does not personally identify you or relate to you individually, MicroLumen may collect, share, disclose and otherwise use Other Information for any legal purpose, such as sharing such Other Information publicly to demonstrate trends in the use of our Services and for other purposes.

However, if MicroLumen combines Other Information with Personal Information in a way that can identify you or be used to identify you personally, we will treat that information as Personal Information, subject to the provisions of this Privacy Policy.

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Do we share your information?

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.

Service Providers

We may share your Personal Information with Service Providers that provide business, professional or technical support functions, assistance in operating our business, or other activities in support of the Services or our businesses. Our Service Providers are not authorized to use your Personal Information for purposes other than those related to the services they are providing to us.


From time to time, we may offer sweepstakes, contests, or other promotions (each, a “Promotion”) through the Services, such as to incentivize a survey. If you enter a Promotion, we may disclose your Personal Information to third parties or the public in connection with the administration of such Promotion, as required by law or as permitted by the Promotion’s official rules or this Privacy Policy.

Business Partners

We may disclose Personal Information to our operational, business and marketing partners (collectively “Business Partners”) for operational, business, marketing, or other purposes consistent with this Privacy Policy. For example, Business Partners may send you information about events and products by mail or e-mail.

Co-Branded Services

From time to time, MicroLumen may partner with select third parties (each a “Co-Branded Party”) to provide content, website pages, services or other offerings (both within or outside of our Services) on a joint or “co-branded” basis (“Co-Branded Services”). By providing Personal Information through a Co-Branded Service, you agree that you are providing such Personal Information to both MicroLumen and each of the Co-Branded Parties without any other notice or further consent.

In addition, by signing up for updates or alerts or participating in promotions, surveys, or other interactive features contained within a Co-Branded Service, you agree that MicroLumen may share the Personal Information you provide through such Co-Branded Service with the relevant Co-Branded Parties.

MicroLumen has no control over, or responsibility for, the information collection and use practices of Co-Branded Parties, who may have privacy policies that differ from our own. So you should read these policies carefully to understand their policies and your options. You may avoid sharing your Personal Information with these third parties by choosing not to register or use the relevant feature.

Select third parties

We may share your Personal Information with select companies that we believe may have offers of interest to you.

Information transfers, storage, and processing

When we share your Personal Information with our Business Partners and Service Providers, your Personal Information may be transferred to and/or made accessible from countries out of the EU/EEA. In such circumstances, we will enter into model contractual clauses as adopted by the European Commission or rely on alternative legal bases such as the EU-U.S. Privacy Shield, where applicable, or binding corporate rules where our Business Partners or Service Providers have adopted such internal policies approved by European data protection authorities.

Legal purposes

We may disclose your Personal Information to verify or enforce compliance with our internal policies and applicable laws and whenever we believe disclosure is necessary to limit our liability or to protect or enforce the rights, interests or safety of our Services, our users or others.

We may disclose your Personal Information to the government or third parties to comply with the law, applicable regulations, subpoenas, court orders, law enforcement requests, legal claims, government or quasi-government inquiries, or other legal process, for example, in connection with suspected illegal activity associated with the Services or our businesses.

If we are legally compelled to disclose your Personal Information to a third party, we will attempt (if permitted by law) to notify you at the e-mail address in our records (if any). MicroLumen reserves the right to release Personal Information collected through the Services to law enforcement or other government officials, as we deem necessary or appropriate in our sole discretion.

With your consent or at your direction

We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.

Business transfers

We may sell or purchase assets during the normal course of our business. If another company acquires MicroLumen, or if any bankruptcy or reorganization proceeding is brought by or against MicroLumen, your Personal Information may be a MicroLumen asset that can be sold or transferred. Please note that an entity receiving such information in connection with one of these transactions may not comply with all of the terms of this Privacy Policy.

If you access Social Networks through the Services to log in to the Services or to share information about your experience on the Services with others, these Social Networks may be able to collect Personal Information about you, including information about your activity on the Services, and they may notify your connections on the Social Networks about your use of the Services, in accordance with their own privacy policies.

When you use the Services, you could be directed to other websites, applications or services (together with Social Networks, referred to as “Third-Party Sites”), for example, by “clicking” on banner advertisements, links from advertisers, sponsors and marketing partners (including those who may advertise the Services as part of a Co-Branding Service).

MicroLumen has no control over, and therefore no responsibility for, the data collection and privacy practices of Third-Party Sites, which may use Cookies, pixel tags and other technologies to serve and offer relevant ads. When you visit such Third-Party Sites, you are bound by their privacy policies, which you should review to understand their information practices.

Of course, if you choose to engage in public activities relating to the Services on any Third-Party Sites, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing Personal Information while participating in these areas. We are not responsible for the information you choose to submit in these public areas.

Aggregate, anonymous, or deidentified information

We may share aggregate, anonymous, or deidentified information with third parties without restriction, including for their marketing or analytics uses.

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How do we protect your information?

Technical and administrative safeguards

MicroLumen uses Secure Socket Layer (“SSL”) technology to encrypt or scramble billing information (if any) and other Personal Information during transmission. In addition, we review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems, and we restrict access to Personal Information to MicroLumen personnel and agents who need to know that information in order to process it for MicroLumen, and who are subject to strict contractual confidentiality obligations and appropriate consequences for failing to meet such obligations. Please be aware that, despite our efforts, no security system is impenetrable. In the event of a security breach, we will promptly notify you and the proper authorities if required by law.

User precautions

Again, no system or online transmission of data can be guaranteed to be 100% secure and you should always take appropriate steps to protect your Personal Information, including updated antivirus and anti-malware software and strong and confidential passwords. In the interest of protecting your account security, MicroLumen recommends that you change your password on a regular basis and immediately if you suspect that your account security has been jeopardized.

How long do we keep your information?

We will keep Personal Information as long as it is necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. If you believe that your MicroLumen account or any information you provided to us is no longer secure, please notify us immediately through the Contact Us information provided below.

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What are your choices?

You may opt out of receiving general and marketing e-mails via the “unsubscribe” link in such e-mails or by e-mailing us at . You may still receive transactional messages. You may also request that we delete your Personal Information by sending us an e-mail at , and MicroLumen will attempt to comply with your request, unless MicroLumen needs to keep that information for legitimate business or legal purposes. For your protection, when you seek to access or change your Personal Information, MicroLumen may require you to verify your identity before MicroLumen can act on such request.

Your instructions to MicroLumen to limit the use of your Personal Information for these purposes will be processed as soon as reasonably practicable. Please note that MicroLumen is not responsible for informing third parties (including without limitation our Service Providers or Business Partners) with whom we have already shared your Personal Information of such changes or for removing or causing removal of your Personal Information from the databases of such entities.

In addition, you may set your browser to block all Cookies, including Cookies associated with the Services, or to indicate when a Cookie is being set by us. Consult the instructions provided by your web browser (typically in the “help” section). For more information about MicroLumen’s use of Cookies, refer to our Cookie Notice. For general information about Cookies, how to identify, manage and delete them, visit http://allaboutcookies.org.

We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how we do so in this Privacy Policy. Visit the following website, http://www.allaboutdnt.org for more information on this developing area.

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Your California privacy rights

California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of Personal Information to third parties for their direct marketing purposes in the preceding calendar year. We do not share Personal Information with third parties for their own direct marketing purposes.

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What about children?

MicroLumen does not market to children or knowingly collect, use, or disclose information from children under 16. If we learn that we have collected the Personal Information of a child under 16 — or the equivalent minimum age depending on the jurisdiction, such as 13 in the United States—we will take steps to delete the information as soon as possible. Please contact us immediately if you become aware that a child under 16 has provided us with personal information.

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This English-language Privacy Policy is MicroLumen’s official statement of MicroLumen’s privacy practices with respect to the Services. In case of any inconsistency between this English-language Privacy Policy and its translation into any other language, this English-language document will take precedence over such translation.

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How do you contact us?

If you have any questions regarding MicroLumen’s privacy practices, please do not hesitate to contact us as follows:

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MicroLumen EU Privacy Notice

If you are a resident of the EU or EEA, please review the following EU Privacy Notice. To skip to a particular section, click on any of the links below.

Why are we providing this notice?

MicroLumen does not have an establishment in the EEA. The EU General Data Protection Regulation (“GDPR”) applies to MicroLumen’s processing of Personal Data (defined below) relating to individuals who are in the EEA where the processing relates to offering goods or services to such individuals. This Privacy Notice applies to you only if you are an individual in the EEA and to the extent that your Personal Data is processed in relation to services offered to you in a personal capacity. “Personal Data” means any information relating to you, such as your name and contact details, but does not include data where you can no longer be identified from it such as anonymized, aggregated data.

To the extent this Privacy Notice applies to you, MicroLumen is responsible for deciding how and why Personal Data about you is processed (a “Data Controller”). We may process your Personal Data ourselves or through others acting as “Data Processors” on our behalf.

If you have any questions about this Privacy Notice, you can contact us or our EU representative using the details set out in the Contact Us section below.

We may provide supplemental privacy notices on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. These supplemental notices should be read together with this Privacy Notice.

What Personal Data may we process about you?

If you contact us

When you contact us through the Services or otherwise, you may provide Personal Data to us, including for example, your name, address, place of business, e-mail address, other contact details, and other information. We also may generate Personal Data about you in connection with such communications, such as communication records. The purposes for which we may collect, store and use such Personal Data about you and our “Lawful Basis” for processing such Personal Data are set out in the table below. The GDPR specifies certain Lawful Bases for which we are allowed to use your Personal Data where that processing is subject to the GDPR.

Purpose Lawful Basis for processing
To communicate with you, respond to your inquiry or address matters raised by your communication. Our legitimate interests in responding to or addressing your inquiry or otherwise communicating with you in the course of our business.


If you register an account

If you register for MicroLumen-issued credentials to use our Services, we may collect the following types of Personal Data: name, e-mail address, phone number, company, title, user name and password. The purposes for which we may collect, store and use such Personal Data about you and our Lawful Basis for processing such data are set out in the table below.

Purpose Lawful Basis for processing
To provide information to you in a secure manner and to restrict access to sensitive information. Our legitimate interests in limiting access to information to appropriate persons.



Our Services may use Cookies, which collect information about how you use the Services and other technical data (such as your IP address, browser type and version, time zone setting and location). The purposes for which we may collect, store and use such Personal Data about you and our Lawful Basis for processing such data are set out in the table below. Further information about our use of Cookies is set out in our Cookie Notice.

Purpose Lawful Basis for processing
To administer and maintain the Services and record and monitor and analyze your use of the Services. Our legitimate interests in studying how the Services are used, keeping the Services updated and relevant, developing our business and informing our marketing strategy.


Other purposes

In addition to the uses above, we also may process your Personal Data where required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process. We also may process Personal Data for purposes other than those for which the Personal Data was originally collected. However, we will only do so for new purposes are not incompatible with the original purposes and we will provide you with information about that further processing.

Special categories of Personal Data

There are more limited bases for processing “Special Category Data,” which refers to Personal Data that reveals or contains racial or ethnic origin, political opinions, religious and philosophical beliefs, trade union membership, genetic data, biometric data, health data, sex life and sexual orientation. We do not intend to actively collect Special Category Data about you. While we will use reasonable efforts to limit our holding of such data, please be aware that we may hold such data incidentally. For example, where you volunteer Special Category Data to us, such as if you send us an e-mail containing Special Category Data.

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What if you do not provide the Personal Data requested?

Unless and until you decide to engage in a business transaction with us (at which point we will send to you a copy of any relevant privacy notice) you are not required to provide us with any information. However, please note that the Services may automatically collect certain technical data (further details information in this respect is set out in our Cookie Notice). We may not be able to grant you access to certain parts of the Services if you do not provide certain Personal Data.

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With whom may we share your Personal Data?

We may share your Personal Data with a third party where this is required by law or where we have another legitimate interest in doing so.

We may need to share your Personal Data with:

  • Professional advisers, including lawyers, bankers, auditors and insurers to the extent such information is relevant to their performance of their services;
  • Regulators and government bodies; and
  • Any of our Service Providers where such information is relevant to their performance of such services.

We may share your Personal Data with third parties, for example in the context of the possible sale or restructuring of the business. We also may need to share your Personal Data with a regulator or to otherwise comply with applicable law or judicial process or if we reasonably believe that disclosure is necessary to protection our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.

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Where may your Personal Data be processed?

As we are domiciled in the USA, any Personal Data that we collect about you will be processed in the USA as the Services are hosted here and also in order for us to correspond with you or otherwise provide the information you have requested.

We may transfer the Personal Data we collect about you to countries within the EEA that the European Commission has determined offer an adequate level of protection in respect of Personal Data.

Where required by the GDPR, we will (or will require a Data Processor to) put in place appropriate safeguards such as the standard contractual clauses approved by the European Commission. If you require further information about this, you can request it using the details set out in the Contact Us section below.

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How long will we retain your Personal Data?

We will retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting or reporting requirements and our legitimate interests in maintaining such Personal Data in our records. In doing this, we are mindful of the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from its unauthorized use or disclosure, the purposes for which we process it (whether we can achieve those purposes through other means), and the applicable legal requirements. Generally, we will keep Personal Data relevant to our dealings with you for the number of years following the last date of activity corresponding to the relevant statutes of limitation.

In some circumstances, your Personal Data may be anonymized so that it can no longer be associated with you, in which case it is no longer Personal Data.

Once we no longer require your Personal Data for the purposes for which it was collected, we will securely dispose of or destroy your Personal Data in accordance with applicable laws and regulations.

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What if your Personal Data is not accurate?

It is important that the Personal Data we hold about you is accurate and current. Please let us know if your Personal Data that we hold changes during your relationship with us.

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What are your rights regarding your Personal Data?

Where the processing of your Personal Data is within the scope of the GDPR, you have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:

  • Request access to your Personal Data (commonly known as a “Data Subject Access Request”) and request certain information in relation to its processing;
  • Request rectification of your Personal Data;
  • Request the erasure of your Personal Data;
  • Request the restriction of processing of your Personal Data;
  • Object to the processing of your Personal Data; and
  • Request the transfer of your Personal Data to another party.

If you want to exercise one of these rights, please use the contact details set out in the Contact Us section below.

You also have the right to make a complaint at any time to a supervisory authority for data protection issues where you reside.


You usually will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your Data Subject Access Request is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the Data Subject Access Request in such circumstances.

What we may need from you

When you make a Data Subject Access Request, we may request specific information from you, so we can confirm your identity and fulfill your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it.

Right to withdraw consent

In the limited circumstances where we may require your consent to process your Personal Data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us using the contact details listed below (see Contact Us). Once we have received notification that you have withdrawn your consent, we will no longer process your Personal Data for the purpose(s) to which you originally consented unless we now have an alternative legal basis for doing so.

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Changes to this Privacy Notice

Our practices with respect to Personal Data may vary from time to time and we may update this Privacy Notice at any time. You can tell when this Notice was last updated by reviewing the “Last Updated” date at top of our Privacy Policy. The latest version of this Privacy Notice will be made available to you via the Services. If we intend to process your Personal Data for a purpose other than the purposes referred to above, we will provide you with additional information about that purpose.

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Contact us

This Privacy Notice was written with brevity and clarity in mind and is not an exhaustive account of all aspects of our collection and use of Personal Data. If you require any further information, contact us using the following contact details: Privacy Officer, MicroLumen, Inc., 1 MicroLumen Way, Oldsmar, FL 34677 USA (+1 (813) 886-1200).

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