PRIVACY POLICY

Australia

1. Introduction

When you use Lumi Ride, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read.

Last modified: September 12, 2020

2. Overview

  • (A) Scope

    This notice applies to users of Lumi Ride’s services anywhere in the world, including users of Lumi Ride’s apps, websites, features, or other services.

    The Services are made available solely for your personal, non-commercial use, unless Lumi Ride has agreed with you otherwise in a separate agreement. Lumi Ride accepts liability for the Services and Application that it provides to you subject to these Terms.

    This notice describes how Lumi Ride collect and use personal data. This notice applies to all users of our apps, websites, features. This notice specifically applies to:

    Riders: individuals who request or receive transportation, including those who receive transportation requested by another individual

    Drivers: individuals who provide, or submit applications to Lumi Ride to provide, transportation individually or through partner transportation companies

    Delivery recipients: individuals who request other products and services

    Delivery partners: individuals who provide, or submit applications to Lumi Ride to provide, delivery or other services

    This notice also governs Lumi Ride’s other collections of personal data in connection with Lumi Ride’s services. For example, we may collect the contact information of individuals who use accounts owned by Lumi Ride for Business partners.

    All those subject to this notice are referred to as “users” in this notice.

  • (B) Data controller and transfer

    Lumi Ride Pty Ltd are the data controllers for the personal data collected in connection with use of Lumi Ride’s services in the Australia.

    Questions, comments, and complaints about Lumi Ride’s data practices can be submitted here. DataPrivacy@LumiRide.com

3. Data collections and uses

  • (A) The data we collect

    Lumi Ride collects:

    Data provided by users to Lumi Ride, such as during account creation

    Data created during use of our services, such as location, app usage, and device data

    Data from other sources, such as Lumi Ride partners and third parties that use Lumi Ride APIs

    The following data is collected by or on behalf of Lumi Ride:

    • (1) Data provided by users. This includes: Lumi Ride User profile: We collect data when users create or update their Lumi Ride accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), government identification documents, including driver’s license numbers and images, birthdate, signature, and photo. This also includes vehicle or insurance information of drivers and delivery partners, and user settings.

      Background check and identity verification: We collect background check and identity verification information for drivers. This may include information such as driver history or criminal record (where permitted by law), and right to work. This information may be collected by an authorised vendor on Lumi Ride’s behalf.

      Demographic data: We may collect demographic data about users, including through user surveys.

      User content: We collect the information users submit when they contact Lumi Ride customer support, provide ratings or compliments, or otherwise contact Lumi Ride. This may include feedback, photographs or other recordings collected by users.

    • (2) Data created during use of our services. This includes: Location data: We collect precise or approximate location data from a user’s mobile device if enabled by the user to do so. For drivers, Lumi Ride collects this data when the Lumi Ride app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device. Lumi Ride may also collect this data when the Lumi Ride app is running in the background of the user’s mobile device. Riders, may use the Lumi Ride apps without enabling Lumi Ride to collect location data from their mobile devices. However, this may affect some functionality available in the Lumi Ride app. For example, a user who has not enabled location data collection will have to manually enter their address. In addition, the location data collected from a driver during a trip will be linked to the rider’s account, even if they have not enabled location data to be collected from their device, including for purposes of receipt generation, customer support, fraud detection, insurance, and litigation.

      Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, date and time the service was provided, amount charged, distance travelled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.

      Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.

      Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.

      Communications data: We enable users to communicate with each other and Lumi Ride through Lumi Ride’s mobile app and websites. For example, we enable drivers and riders, to call, text, or send other files to each other (generally without disclosing their telephone numbers to each other). To provide this service, Lumi Ride receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. Lumi Ride may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services, and for analytics.

    • (3) Data from other sources. This includes:

      User feedback, such as ratings, feedback, or compliments.

      Users participating in our referral programs. For example, when a user refers another person, we receive the referred person’s personal data from that user.

      Lumi Ride account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts. This includes owners of Lumi Ride for Business accounts.

      Users or others providing information in connection with claims or disputes.

      Lumi Ride business partners through which users create or access their Lumi Ride account, such as payment providers, social media services, or apps or websites that use Lumi Ride’s APIs or whose APIs Lumi Ride uses.

      Vendors who help us verify users’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes.

      Insurance, vehicle, or financial services providers for drivers and/or delivery partners.

      Publicly available sources.

      Marketing service providers.

      Lumi Ride may combine the data collected from these sources with other data in its possession.

    (B) How we use personal data

    Lumi Ride collects and uses data to enable reliable and convenient transportation, and other products and services. We also use the data we collect:

    To enhance the safety and security of our users and services

    • For customer support

      For research and development

      To enable communications between users

      To send marketing and non-marketing communications to users

      In connection with legal proceedings

      Lumi Ride does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

      Lumi Ride uses the data it collects for purposes including:

      • (i) Providing services and features. Lumi Ride uses the data we collect to provide, personalise, maintain, and improve our products and services. This includes using the data to:

        Create and update users’ accounts.

        Verify drivers’ identity, background history, and eligibility to work.

        Enable transportation, deliveries, and other services.

        Offer, process, or facilitate payments for our services.

        Offer, obtain, provide, or facilitate insurance, vehicle, invoicing, or financing solutions in connection with our services.

        Track and share the progress of rides or deliveries.

        Enable features that allow users to share information with other people, such as when riders submit a compliment about a driver, refer a friend to Lumi Ride.

        Enable features to personalise users’ Lumi Ride accounts, such as creating bookmarks for favourite places, and to enable quick access to previous destinations.

        Enable Accessibility features that make it easier for users with disabilities to use our services, such as those that enable deaf or hard-of-hearing drivers to alert their riders of their disabilities, allow only text messages from riders, and enable receipt of flashing trip request notifications instead of sound notifications on their mobile device.

        Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

      • (ii) Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:

        Screening riders, drivers, before enabling their use of our services and at subsequent intervals, including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe drivers and/or riders.

        Using data from drivers’ devices to help identify unsafe driving behavior such as speeding or harsh braking and acceleration, and to inform them of safer driving practices.

        Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.

        Using user ratings and feedback to encourage compliance with our Community Guidelines and as grounds for deactivating drivers with low ratings or who otherwise violated such guidelines.

      • (iii) Customer support. Lumi Ride uses the information we collect (including recordings of customer support calls with notice to and the consent of the user) to provide customer support, including to:

        • Direct questions to the appropriate customer support person

          Investigate and address user concerns

          Monitor and improve our customer support responses and processes

      • (iv) Research and development. We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

      • (v) Enabling communications between users. For example, a driver may message or call a rider to confirm a pickup location, a rider may contact a driver to retrieve a lost item.

      • (vi) Marketing. Lumi Ride may use the data we collect to market our services to our users. This includes sending users communications about Lumi Ride services, features, promotions, news, updates, and events.

        We may use the data we collect to personalise the marketing communications (including advertisements) that we send, including based on user location, past use of Lumi Ride’s service, and user preferences and settings.

      • (vii) Non-marketing communications. Lumi Ride may use the data we collect to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of Lumi Ride or its partners.

      • (viii) Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to use of Lumi Ride’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

      • (ix) Automated decision-making

        We use personal data to make automated decisions relating to use of our services. This includes:

        Matching available drivers and delivery partners to users requesting services. Users can be matched based on availability, proximity, and other factors. Please see here for further information about our matching process.

        Determining driver ratings, and deactivating drivers, riders, with low ratings.

        Deactivating users who are identified as having engaged in fraud or activities that may otherwise harm Lumi Ride, its users, and others. In some cases, such as when a user is determined to be abusing Lumi Ride’s referral program, such behaviour may result in automatic deactivation.

        Using driver location information, and communications between riders and drivers, to identify cancellation fees earned or induced through fraud. For example, if we determine by using such information that a driver is delaying a rider pickup in order to induce a cancellation, we will not charge the rider a cancellation fee and will adjust the amounts paid to the driver to omit such a fee. To object to such adjustment, please contact Lumi Ride customer support.

    (c) Cookies and third-party technologies

    Lumi Ride use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice.

    Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Lumi Ride uses cookies and similar technologies for purposes such as:

    Authenticating users

    Remembering user preferences and settings

    Determining the popularity of content

    Delivering and measuring the effectiveness of advertising campaigns

    Analysing site traffic and trends, and generally understanding the online behaviours and interests of people who interact with our services

    (D) Data sharing and disclosure

    Some of Lumi Ride’s products, services, and features require that we share data with other users or at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

    Lumi Ride may share the data we collect:

    • 1. With other users. This includes sharing: Riders’ first name, rating, and pickup and/or dropoff locations with drivers.

      Riders’ first name with other riders in a carpool trip. Riders in carpool trips may also see the dropoff location of the other riders.

      For drivers, we may share data with the rider(s), including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during trip); average rating provided by users; total number of trips; length of use of the Lumi Ride app; contact information (depending upon applicable laws); and driver or delivery partner profile, including compliments and other feedback submitted by past users. We also provide riders with receipts containing information such as a breakdown of amounts charged, driver first name, photo, route map, and such other information required on invoices in the country or region where the driver or delivery partner operates.

      For those who participate in Lumi Ride’s referral program, we share certain personal data of referred users, such as trip count, with the user who referred them, to the extent relevant to determining the referral bonus.

    • 2. At the user’s request

      This includes sharing data with:

      Other people at the user’s request. For example, we share a user’s ETA and location with a friend when requested by that user, or a user’s trip information when they split a fare with a friend.

    • 3. With the general public

      Questions or comments from users submitted through public forums such as Lumi Ride blogs and Lumi Ride social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

    • 4. With the Lumi Ride account owner

      If a user requests transportation using an account owned by another party, we may share their order or trip information, including real-time location data, with the owner of that account. This occurs, for example, when:

      A rider uses their employer’s Lumi Ride for Business profile, such as when they take trips arranged through Lumi Ride Central

      A rider takes a trip arranged by a friend or under a Family Profile

    • 5. With Lumi Ride subsidiaries and affiliates

      We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, Lumi Ride processes and stores data in the Australia.

    • 6. With Lumi Ride service providers and business partners

      Lumi Ride provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

      Payment processors and facilitators

      Background check and identity verification providers (drivers and delivery partners only)

      Cloud storage providers

      Marketing partners and marketing platform providers, including social media advertising services

      Data analytics providers

      Research partners, including those performing surveys or research projects in partnership with Lumi Ride or on Lumi Ride’s behalf

      Vendors that assist Lumi Ride to enhance the safety and security of its apps

      Consultants, lawyers, accountants, and other professional service providers

      Fleet partners

      Insurance and financing partners

      Vehicle solution vendors or third-party vehicle suppliers

    • 7. For legal reasons or in the event of a dispute

      Lumi Ride may share users’ personal data if we believe it is required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Lumi Ride’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. If you use another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card.

      This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

    • 8. With consent

      Lumi Ride may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.

    (E) Data retention and deletion

    Lumi Ride retains user profile, transaction, and other personal data for as long as a user maintains their Lumi Ride account.

    Lumi Ride may retain certain user data after receiving an account deletion request if necessary, such as to comply with legal requirements.

    Lumi Ride retains user profile, transaction, and other information for as long as a user maintains their Lumi Ride account. For drivers, Lumi Ride also retains vehicle and background check information (to the extent permitted by law) for as long as they maintain their Lumi Ride account.

    Riders may request deletion of their account at any time through the Settings > Privacy menus in the Lumi Ride app. Following such requests, Lumi Ride deletes the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, Lumi Ride retains location, device, and usage data for these purposes for a minimum of 7 years; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, Lumi Ride may be unable to delete a user’s account, such as if there is an outstanding credit on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, Lumi Ride will delete the account as described above.

    Lumi Ride may also retain certain information if necessary, for purposes of safety, security, and fraud prevention. For example, if Lumi Ride deactivates a user’s account because of unsafe behaviour or security incidents, Lumi Ride may retain certain information about that account to prevent that user from opening a new Lumi Ride account in the future.

    (F) Grounds for processing

    We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of Lumi Ride’s legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent.

    We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our users are located, but generally include processing personal data:

    • A. To provide requested services and features

      In order to provide our services, we must collect and use certain personal data. This includes:

      User profile data, which we use to establish and maintain user accounts; verify user identity; communicate with users about their trips, orders, and accounts; and enable users to make payments or receive earnings

      Background trip information, which is used to verify an applicant’s eligibility to be a driver

      Driver location data, which we use to track trips and assist with navigation

      Usage data, which is necessary to maintain, optimise, and enhance Lumi Ride’s services, including to determine incentives, connect riders and drivers.

      Transaction information

      Information relating to customer support

    • B. For purposes of the legitimate interests of Lumi Ride or other parties

      This includes using personal data to maintain and enhance our users’ safety and security. For example, we use personal data to prevent use of our services by users who have engaged in inappropriate or dangerous behavior, such as by retaining data of banned users to prevent their use of Lumi Ride’s apps. We also use usage data to prevent matching of riders and drivers for whom there is higher risk of conflict (for instance, because they have been the subject of prior complaints from other users).

      This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing Lumi Ride’s Terms of Service.

      In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.

    • C. To fulfill Lumi Ride’s legal obligations

      For example, Lumi Ride is subject to laws and regulations that require it to collect and retain data about our users’ trips, and to provide copies of such data to the government or other authorities. We collect and use personal data to comply with such laws.

      Lumi Ride may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes.

    • D. With consent

      Lumi Ride may collect and use personal data based on the user’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.

      A user who has provided consent to a collection or use of their personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data.

4. Choice and transparency

Lumi Ride enables users to access and control the data that Lumi Ride collects, including through:

  • In-app settings
  • Device permissions
  • In-app ratings pages
  • Marketing opt-outs

Lumi Ride also enables users to request access to or copies of their data, changes or updates to their accounts, deletion of their accounts, or that Lumi Ride restrict its processing of user personal data.

  • A. Privacy settings

    Settings menus in the Lumi Ride app for riders give them the ability to set or update their location-sharing preferences and their preferences for receiving mobile notifications from Lumi Ride. Information about these settings are managed through the Lumi Ride app.

5. Updates to this notice

We may occasionally update this notice. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Lumi Ride apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.