Practitioner Privacy Notice

Updated 3rd June 2019

This Practitioner Privacy Notice explains how Lumina Learning and your Lumina Learning Partner or Strategic Alliance use your personal data in connection with the Services that we provide under our Agreement.

If you use our other services not covered by this Notice, we may hold data about you for other purposes. Please see our other privacy notices for details.

 

About Us

Reference to “we, us, our” refers collectively to:

                  “Lumina Learning”: Lumina Learning Limited (registered in England and Wales, Company Number 07021544).

                  “Lumina Learning Partner or Strategic Alliance”: Lumina Learning’s distributor who provides Services to you, whose identity is communicated to you before you accept use of the Services.

We are committed to treating your data fairly and transparently and encourage you to contact us if you have any questions about this Notice.

 

About the Services

“Services” are products and services that we provide to you under our Agreement. When you use the Services you are usually a ‘Lumina Learning Practitioner’ or you work with a Lumina Learning Practitioner. You use the Services either as a party to the Agreement or on behalf of an entity who is party to the Agreement (for example, your organisation).

You can use the Services to interact with other people using our website and mobile apps (the “Lumina Platform”). Any data you gather about others is used and controlled by you.

The “Agreement” refers to our business relationship with you, or the entity you represent, governed by the General Terms and Conditions of Business.

 

Your Data

We collect and receive the following types of data about you:

“Lumina Platform Data”:

                  “Usage Data” – we gather data about how you use the Lumina Platform. This includes details of the device you use, browser and plugin details and records of pages you visit. When you create a Lumina Account, we gather data about who and what you interact with, the tasks you complete and your approximate location based on your IP address.

                  “Basic Account Details” – when you create a Lumina Account you provide your name, email address and pronoun preferences.

                  “Identity Provider Data” – if you sign in to your Lumina Account using credentials from a third-party identity provider (for example, Google), we may obtain data from the identity provider. Details of the data we obtain are displayed when you sign in.

                  “Cookies Data” – we use cookies to ensure the security of the Lumina Platform and to allow you to sign in to your Lumina Account. We also use cookies to track activity on our website in order to monitor and improve it. Cookies may store information about the device you use and your location, based on your IP address.

                  “Mobile App Data” – when you use our mobile apps, we gather a copy of data that you enter into the app. We also gather data about you that other people enter into their apps. For example, when you or someone else scans your Splash in the Splash App. We also log details about your mobile device and how you use the apps.

“Practitioner Profile Data”:

                  “Profile Details” – you provide your name, email address and postal address, or those of the entity you represent.

                  “Billing Details” – you provide the financial and legal details of yourself or the entity you represent.

“Other Practitioner Data”:

You may provide other data when you use the Services. For example, if you attend our events or engage with our learning resources. Others may also provide data about you in connection with the Services. For example, details provided by your organisation or colleagues.

 

How Your Data is Used

We collect your data for the following purposes:

                  To provide the Services and fulfil our obligations under the Agreement.

                  To fulfil orders and process payments.

                  To provide the Lumina Platform.

                  To give you access to your Lumina Account.

                  To respond to your requests.

                  To respond to requests from other users of the Lumina Platform, where you have already interacted or shared your data with them.

                  To provide you with communications relating to the Services where we have a legitimate interest to do so. This includes some marketing communications and will always include essential communications relating to technical, security and legal issues.

                  To provide you with other communications you consent to receive.

                  To provide you with services and resources you subscribe to or express an interest in.

                  To research, analyse and enhance our products and services, including to avoid bias and discrimination.

                  To conduct customer and market research.

                  To support the maintenance, enhancement and security of our systems.

                  For legal reasons, including our record keeping, to defend legal claims, comply with legal obligations and to prevent fraud and other illegal or harmful activities.

We process your data based on our legitimate interest to provide you with the Services and to fulfil our obligations under the Agreement. You have the right to object to this processing.

For details about how to exercise your rights, please see ‘How to Exercise Your Data Rights’.

 

How Your Data is Shared

Data you choose to share with others

When you interact with other users of the Lumina Platform, you share your Basic Account Data and Profile Details with them.

If you choose to share access to the Services with someone else, they may be able to view some of your data.

You acknowledge that you are responsible for deciding to share your data and that it may not be possible to unshare later.

Data we share with the entity you represent

When you access the Services on behalf of an entity (for example, your organisation) we may share your data with that entity and other individuals who represent that entity (for example, your colleagues). We share data only to the extent necessary to perform our obligations under the Agreement.

Data we share with others

We share your data with certain third parties. We only share data with third parties that provide appropriate safeguards:

                  The Lumina Learning Network – third parties who are typically termed ‘Lumina Learning Partners’, ‘Lumina Learning Strategic Alliances’, ‘Lumina Learning Associates’ or ‘Lumina Learning Practitioners’. These third parties represent our business globally and perform some of our purposes on our behalf.

                  Professional and service providers – third parties that help us run our business. For example, providers of tools like helpdesk software and providers of professional advice like legal, accounting and consultancy services.

                  Business sale or change of control – if the ownership of all or part of our business changes or if we enter administration, your personal data may be shared with the other parties involved. This includes where we take preparatory steps in connection with such activities.

                  Legal obligations and defence of legal claims – we may share your data where we are subject to a legal obligation or if necessary to defend a legal claim against us.

 

International Transfers of Your Data

Your Lumina Learning Partner or Strategic Alliance and other third parties we share your data with may be outside the European Economic Area (EEA). We share data only when there are appropriate safeguards. Where possible, we use third parties located in countries that the EU Commission has approved as providing adequate safeguards, or third parties taking part in EU Commission approved schemes, such as the EU-U.S. Privacy Shield Framework. Where these options are not available, we ensure adequate safeguards by using model contract clauses provided by the EU Commission.

Please note, we share your data with the entity you represent, including other individuals who represent that entity. These third parties may be outside the EEA and may not provide adequate safeguards for your data. We transfer data to these third parties to allow us to perform our obligations under the Agreement. This benefits you by allowing you to access the Services.

 

Retention of Your Data

We retain your data for as long as necessary for the purposes it is collected for. This is typically until the termination of the Agreement. We may retain your data for longer where it is necessary for legal reasons.

You always have the option to exercise your data rights: How to Exercise Your Data Rights.

 

How to Exercise Your Data Rights

You have the right to access, rectify, port and in some cases erase your personal data.

Where data is processed based on our legitimate interests, you have the right to object to this processing based on grounds relating to your situation.

To exercise your rights, please contact us using the details below.

 

Updates to this Notice

We may update this Notice from time to time. We will post updates here and notify you of any changes that materially affect you.

 

Complaints

If you have concerns about how we have handled your personal data, you have the right to complain to a supervisory authority, including your local supervisory authority and our local supervisory authority, the United Kingdom’s Information Commissioner’s Office.

We encourage you to contact us directly to resolve issues using the contact details below. We commit to resolving your issue wherever possible.

 

Contact us

We, Lumina Learning and your Lumina Learning Partner or Strategic Alliance, are joint controllers of your data. Lumina Learning will respond to your queries on behalf of both of us.

To contact us, please email legal@luminalearning.com or write to us at:

Lumina Learning Limited
St George’s House
Knoll Road
Camberley
GU15 3SY
United Kingdom