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.
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.
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.
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.
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.
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.
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.
What about Children?
MicroLumen does not market to children and we do not knowingly collect information from children under 16.
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.
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.
- What information we collect
- How we use your information
- Do we share your information?
- How we protect your information
- Your Choices
- California privacy rights
- 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.
How do we use your information?
- 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;
- For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
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.
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.
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?
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.
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.
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.
How do you contact us?
If you have any questions regarding MicroLumen’s privacy practices, please do not hesitate to contact us as follows:
- Write to us at: MicroLumen, Inc., 1 MicroLumen Way, Oldsmar FL 34677, Attn: Chief Privacy Officer
- E-mail us at:
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.
|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.
|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.
|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.
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.
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.
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.
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.
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.
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.
Changes to this Privacy Notice
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).