EDITED 10 MAR 2021
Please acknowledge that it is your responsibility to review this Policy as we may update the Policy from time to time. In the event of modification of the Policy, we may contact you via email, in-app message, and notification regarding the changes in the Policy, if you have permitted us.
We want to start this off by addressing the information we do not collect to offer better clarity for our users.
WE DO NOT COLLECT:
How you utilize VPN connection. (We do not see the applications, service or websites you use while connected to our Service nor do we store them).
Original IP address and server IP address(that you connected to).
As an internet privacy & security service provider, we make sure your privacy is our primary concern, and we will be 100% transparent with our users. We believe the relationship between the users and us is built on trust, and trust is built on the truth.
The following data have been break down into different categories to help you better understand what information we collect, how we collect it, and why do we collect it:
Registration date (e.g., 2018/09/01; this information is automatically collected during account registration.)
Subscription status (e.g., 2018/09/01 - 2018/10/01; this information is automatically collected when users make the purchase.)
We collect these account information strictly for the user support purpose.
Operating system (e.g., iOS 11.3.1-10,000,000; this information is collected when user open LumiVPN app.)
App version (e.g., Version 6.1_132_432908b; this information is collected when user open LumiVPN app.)
Daily active user (e.g., 2018/09/01-19,000,000; this information is collected when user open LumiVPN app.)
User geodemographics (e.g., US-100,000,000; this information is provided by the App store & the Google Play store.)
This information helps us to understand our user better and in product planning, to further improve the user experience and user satisfaction.
Server location(e.g., US-California server 1; this information is automatically collected during VPN connection.)
Connection time stamp (e.g., Connected@15:30 2018/05/15; this information is automatically collected during VPN connection.)
Error report (e.g., Error_Userdoesnotallowconfiguration; this information is automatically collected when VPN connection failed due to error.)
Network type (e.g., 4G; this information is collected by analytic service provider)
This information is used for troubleshooting, VPN service optimization ONLY, all the information WILL BE AUTOMATICALLY ERASED PERMANENTLY from the system after 96 HOURS.
Analytics data (e.g., App crash report, in-app page engagement; this information is collected when using the LumiVPN.)
Advertising data (e.g., iOS ad identifier - IDFA), Android ad master identifier)
This information helps us to track the performance of the app and certain features and to provide necessary support to sustain our free VPN service, please note that we do not share your share the information that you provide to LumiVPN with the third party advertisers.
You may find more information about analytic service providers:
We are committed to protecting our users’ privacy and put it into several practices:
The support team and accounting team have limited access to the data respectively.
The VPN connection data in our system will be permanently erased 96 hours after it is collected.
We have designated staff regularly review the relevant regulation, rule, law changes to enforce the privacy protection. For requests or inquiries concerning user privacy, feel free to contact us at firstname.lastname@example.org, our designated staff will respond to requests or inquiries within 48 hours.
Session cookies: These cookies store your preference, logins on our site.
Google Analytics: We use this service to track the performance of certain pages on our site and to understand the impact of our advertising campaign. Google Analytics reference link: https://policies.google.com/technologies/types
In compliance with the GDPR (General Data Protection Regulation), all users subject to the GDPR have rights in relation to the personal data:
You have the right to be informed regarding what data does LumiVPN collect, as you are reading this Policy.
You have the right to be provided with a copy of the data we collect from you upon request. Please do note that this may take up to 30 calendars days to complete.
You have the right to request us to correct any information about you that may be incomplete or inaccurate.
You have the right to request us to delete the information that we have about you. Do keep in mind that this may not apply to some payment information as per tax law we are required to retain certain information.
You have the right to request us to suspend processing your personal data.
You have the right to be provided with a copy of the data we collect from you in common format upon request(e.g., to reuse the data for your own purpose). Please do note that this may take up to 40 calendars days to complete.
You have the right to object to us processing your personal data.
You have the right to be informed in relations to the profiling or any automated decision making.
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through the Service, and indicate the date of the latest revision. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood, and agreed to the current version of this Policy. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you in advance of the change (e.g., through prominent Policy on the Service, via contact information you may have provided to us, or through other reasonable means).