Luum Mobile Application
Privacy Statement

Last Updated: June 11, 2021

This privacy statement (“Statement”) explains how Luum and its subsidiaries, and other affiliated and related companies ("Luum", "We" or “us”) collect and use personal information through our Luum mobile app (“App”) for your employer or other providing entity (e.g. your employer etc.) that makes the Luum Commute Hub available to you (“Providing Entity”).  This App is only for use in connection with your use of Luum Commute Hub. Personal information we collect on behalf of the Providing Entity is ultimately governed by our agreements with the Providing Entities. We neither control nor direct, nor are we responsible for the Providing Entity’s practices with respect to that information.  You should contact the Providing Entity that granted you authorization to use the Luum Commute Hub to learn more about their practices.

We collect and process personal information about you with your consent and/or as necessary to provide the products you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.

 

Information Collected

We collect information from and about you when you use our App:

  • Directly from you when you provide it to us or when we receive it from your Providing Entity.
  • Automatically when you use the App.

 

Information You Provide to Us or We Receive it From Your Providing Entity

When you download, register with or use this App, we may ask that you provide information to Luum or sync information provided by your Providing Entity with your Luum Commute Hub account profile, including information by which you may be personally identified, such as name, employee ID, e-mail address, password, home address, work address, and other basic contact, vehicle, and profile information. Your Providing Entity may choose to provide us other information about you at their discretion.

We may also collect information:

  • About Commute Hub activities that you participate in.
  • About the locations you enter in connection with your use of the Commute Hub and related carpool and vanpool services.

 

Automatic Information Collection

When you download, access and use the App, it may use technology to automatically collect and send to Luum:

  • Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including time and date of use, data about actions taken and pages viewed within the app, logs and other communication data and the resources that you access and use on or through the App.
  • Device Information. We may collect information about your mobile device and internet connection, including IP address, operating system and browser type.
  • Location Information. This App may collect real-time information about the location of your device (GPS and Wi-Fi location) while searching for commute locations.

We may use analytics, including analytics conducted by third parties, such as Google Analytics and others, to automatically track information to help improve this App, your user experience and understanding your preferences and interests. See “How Google uses data when you use our partners' sites or apps”, located at www.google.com/policies/privacy/partners.

 

App Permissions

This App requires permission to access certain features on your mobile device which we use for the following reasons and may include the following types of permissions.

  • Location Services - this lets us use the GPS and Wi-Fi location of the handset to determine your location for Commute Hub purposes. This may be precise geolocation information that reveals your home, workplace, or other places you use the App from.
  • Notifications – this lets us send push notices to you using alert, sound and icon notices
  • Cellular Data – this gives this App access to the 3G/4G connection on your device to send and load data
  • Background App Refresh – this lets this App automatically check for new content and updates and synchronize/load data in the background upon receiving a push notification.

 

Use of Information Collected

We use personal information collected through this App to support Luum Commute Hub and other services for the Providing Entity and subject to use limitations and permissions in our agreement with the Providing Entity. We may use this information to provide support and operate, maintain, and improve the services on behalf of you and on behalf of the Providing Entities.

The Providing Entity may use personal information for purposes other than listed above and may store and process personal information in other locations. You should contact the Providing Entity who granted you rights to use this App to learn more about their practices.

 

Transfers of Your Personal Information

Personal information we collect may be stored and processed in your region, in the United States or in any other country where we or our affiliates, subsidiaries or service providers maintain facilities. We maintain primary data centers in the United States. We take steps designed to ensure that the data we collect under this Statement is processed according to the provisions of this Statement and applicable law wherever the data is located. When we transfer personal information from the European Economic Area and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection, we use a variety of legal mechanisms, including contracts, in an effort to help ensure your rights and protections.

 

Sharing of Personal Information

We may disclose aggregated information about you and information that does not identify you or any individual or device without restriction. In addition, we may disclose personal information that we collect or you provide on or through this App to the Providing Entity and as agreed to with that Providing Entity, which may include the following types of disclosures:

  • To your Providing Entity, including reports about commuter behavior and trips.
  • With other users, including records of your Commute Hub activities, your name and leaderboard status.
  • To our subsidiaries and affiliates.
  • With third party vendors, consultants, and other service providers who work for us and need access to your information to do that work.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • To comply with any court order, law or legal process, including responding to any government or regulatory request.
  • Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
  • In connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company.

 

The Providing Entity on whose behalf we provide our services may share personal information to others beyond the types of third parties listed above. You should contact the Providing Entity who granted you rights to use this App to learn more about their practices.

 

Security of Your Personal Information

Luum takes reasonable steps to help protect your personal information in an effort to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

 

Your Information Choice and Changes

You can review and change certain personal information used in association with this App by logging into Luum Commute Hub and visiting your account profile page. This App provides you with certain choices, for example, you can choose to turn off third-party integrations (such as Strava or Scoop), push notifications, or access to location data by changing the settings in the App or mobile device.

If you wish to ask for access, correction, or deletion of any of your personal information held by us or a change in the way we use your information (for which we reserve the right to charge you a fee, as permitted by applicable law), please contact us at . However, we may decline requests that are unreasonable, prohibited by law, or are not required to be honored by applicable law.

 

Storage and Retention of Your Personal Information

We retain your personal information for as long as necessary to provide services requested by you and your Providing Entity, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.  Because these needs can vary for different data types in the context of different services, actual retention periods can vary significantly. The criteria used to determine retention include:

  1. How long is the personal information needed to provide applicable services? This includes such things as maintaining and improving the performance of the App, enabling system security measures, and maintaining appropriate business and financial records.
  2. Do users provide, create, or maintain the data with the expectation we will retain it until they affirmatively remove it? In such cases, we may maintain the data until actively deleted by the user.
  3. Is the personal information of a sensitive type? If so, a shortened retention time may be appropriate.
  4. Are we subject to a legal, contractual, or similar obligation to retain the data? Examples can include our agreement with your Providing Entity, mandatory data retention laws in the applicable jurisdiction, government orders to preserve data, or data that must be retained for the purposes of litigation. 

 

Your European Privacy Rights

We adhere to applicable data protection laws in the European Economic Area, which, if applicable to you, includes the following rights:

  • If we are processing personal information based on your consent, you have a right to withdraw consent at any time for future processing;
  • You have a right to request access to, rectification, or erasure of your personal information, or to transfer or receive a copy of your personal information in a usable format;
  • You have a right to object to the processing of your personal information under certain circumstances; and
  • You have a right to lodge a complaint with a data protection authority.

If you contact us to exercise these rights, but we may be unable to fulfill them directly and so may need to refer them to your Providing Entity.

 

Changes To This Statement

Luum may change this Statement from time to time. If we make any changes to this Statement, we will change the "Last Updated" date above or by providing such notice about or obtaining consent to changes as may be required by applicable law.

 

Questions

If you have any questions about this Statement, or if you wish to lodge a complaint about our privacy practices, please contact us at or Luum, 119 S Main Street, Suite 310, Seattle, WA 98104.