Luma Home, Inc.

Effective Date: September 27, 2016

Luma Home, Inc. (“Luma”, “we”, “us”, or “our”) recognizes the importance of privacy. In this Privacy Policy, we describe how we collect, use, and disclose information that we obtain about visitors to our website www.lumahome.com (the “Site”), users of the Luma application (the “App”), users of the Luma wireless routers (collectively, the “Devices”), and the services available through our Site, App, and Devices (such services, along with the Site, App, and Devices, are hereinafter collectively referred to as the “Services”).

By using any of our Services, you agree that your personal information will be handled as described in this Privacy Policy. Your use of our Services, and any dispute over privacy, is subject to this Privacy Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. Our Terms of Service are incorporated by reference into this Privacy Policy.

Information We Collect

We collect information about you directly from you, from third parties, and automatically through your use of our Services. We may combine all of the information we collect about you from these various sources.

Information We Collect Directly From You. We may collect certain information directly from you, such as your email address, password, and network name. We will also collect any information that you voluntarily provide to us, such as your name, photo, responses to surveys or questionnaires, or requests or inquiries that you submit through our Services.

Information We Collect from Third Parties. We may collect information about you from third parties. For example, the user who creates an account with Luma for your network will provide us with information about the other users on the network.

Information We Collect Automatically. We automatically collect information about your use of our Services through cookies and other technologies, including without limitation: domain name; browser type; device identifier; operating system type; device name and model; pages or screens you view; links you click; Internet protocol (“IP”) address; when and the length of time you visit or use our Services; and the referring URL, or the webpage that led you to our Site or App.

In order to provide our Services, we will also automatically collect information about your activity over your Luma WiFi network, including the top-level domain names of the websites you visit and mobile applications you use, when and for how long you visit or use them, and the amount of data that you use. If you are associated with a particular device, we will be able to associate your network activities with your device and the username associated with that device.

How We Use Your Information

We may use your information, including personal information, for the following purposes:

Providing and Improving Our Services. To provide and maintain our Services; to improve our Services; to develop new features or services; to authenticate users; to facilitate payments and communications; to perform technical operations, such as updating software; and for other customer service and support purposes.

Tailoring Content. To tailor the content and information that we may send or display to you, and to otherwise personalize your experiences while using our Services.

Marketing and Communications. To communicate with you about your account and use of our Services; to respond to your inquiries; to provide you with news and newsletters, special offers, promotions, and other information we think may interest you; and for other informational, marketing, or promotional purposes.

Research and Analytics. To analyze how you interact with our Services; to monitor and analyze individual and collective usage trends; and for other research, analytical, and statistical purposes.

Protecting Rights and Interests. To protect the safety, rights, property, or security of Luma, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that Luma, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Privacy Policy and our Terms of Service.

Legal Compliance. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.

How We Disclose Your Information

We may disclose your information, including personal information, with the following entities:

Affiliates. We may disclose your information to current or future affiliates or subsidiaries for research, marketing, and other purposes consistent with this Privacy Policy.

Service Providers. We may disclose your information to our vendors, service providers, agents, or others who perform functions on our behalf and for the purpose of our providing services to you.

We may disclose your information, including personal information, in the following ways:

Business Transfers. We may disclose your information to another entity in connection with, including during negotiations of, an acquisition or merger, sale or transfer of a business unit or assets, bankruptcy proceeding, or as part of any other similar business transfer.

Protecting Rights and Interests. We may disclose your information to protect the safety, rights, property, or security of Luma, the Services, any third party, or the general public; to detect, prevent, or otherwise address fraud, security, or technical issues; to prevent or stop activity that Luma, in its sole discretion, may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity; to use as evidence in litigation; and to enforce this Privacy Policy and our Terms of Service.

Legal Compliance. We may disclose your information to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; in response to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.

Aggregate and De-Identified Information. We may disclose aggregate, anonymous, or de-identified information about users for research, compliance, marketing, advertising, or other purposes.

Cookies and Other Tracking Mechanisms

We and our service providers use cookies and other tracking mechanisms to track information about your use of our Site, App, or Services. We or our service providers may combine this information with other personal information we collect from you.

Cookies. We or our service providers may use cookies to track visitor activity on our Site. A cookie is a text file that a website transfers to your computer’s hard drive for record-keeping purposes. We or our service providers may use cookies to track user activities on our Site, such as the pages visited and time spent on our Site. Most browsers allow users to refuse cookies. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies may not be able to browse certain areas of the Site.

Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages. We or our service providers may use clear GIFs (also known as web beacons, web bugs or pixel tags), in connection with our Site to track the activities of visitors to our Site, help us manage content, and compile statistics about usage of our Site. We or our service providers may also use clear GIFs in HTML emails to our users, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.

Third-Party Analytics

We may use third-party analytics companies, such as Google Analytics (see “How Google uses data when you use our partners’ sites or apps” to learn more) to evaluate use of our Services. We or our service providers use these tools to help us understand use of, and to improve, our Services, performance, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or local storage objects (LSOs), to perform their services.

Do Not Track Disclosure

Our Site does not respond to Do Not Track signals. For more information about Do Not Track signals, please click here.

Our Services may contain links to third-party websites or applications. Any access to and use of such linked websites or applications is not governed by this Privacy Policy but instead is governed by the privacy policies of those third-party websites or applications. We are not responsible for the information practices of such third parties.

Interest-Based Advertising

We use third parties such as network advertisers to serve advertisements on our Services and on third-party websites or other media (e.g., social networking platforms). This enables us and these third parties to target advertisements to you for products and services in which you might be interested. Third-party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other tracking technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information, including personal information, about you.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and their choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and their choices regarding having information used by NAI members.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website at www.networkadvertising.org.

Security

We have taken steps to help protect the personal information we collect about you from loss, misuse, unauthorized access, disclosure, alteration, and destruction. However, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your account by, among other things, choosing a robust password that nobody else knows or can easily guess and keeping your device login information private.

Your Choices

You may update or delete the personal information that we have about you by updating your Luma account or emailing us at [email protected] Please note that while we will honor certain requests (e.g., to update a username), we will not be able to honor requests not to track network activities if you desire to continue to use your Luma Devices.

We may send periodic promotional or informational emails to you. You may opt out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to ten (10) business days for us to process opt-out requests. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.

Children

Our Services are not targeted to children under thirteen (13) years of age, and we do not knowingly collect personal information from children under 13. If we discover that a child under 13 has provided us with personal information, we will promptly delete such personal information from our systems.

Contact Us

If you have questions about the privacy aspects of our Services, please contact us at [email protected]

Changes to this Privacy Policy

This Privacy Policy is current as of the Effective Date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes, including any material changes, to this Privacy Policy on our Site.

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