This Privacy Notice applies to the operations of LUMA Care Co., Ltd (“LUMA”). At LUMA we respect your right to privacy and value the trust you have placed in us. We are committed to the responsible management, use and protection of our customers’ personal information as outlined in the Singapore Personal Data Protection Act 2012
This Privacy Notice supplements other applicable policies, practices and privacy notices that may relate to specific business relationships you have with LUMA.
This Privacy Notice applies to all the information we collect from you through LUMAhealth.com and other LUMA websites and Portals, from which you are accessing this Privacy Notice, or through mobile applications made available through LUMA. We will refer to these websites and mobile applications as “Services” throughout this Privacy Notice.
Consent to Use LUMA Services
By providing personal information to us through LUMA’s Services you are consenting to the collection, use, and disclosure of your personal information in accordance with this Privacy Notice. If you do not agree with the practices described in this Privacy Notice, please do not provide personal information through LUMA’s Services.
Information We Collect
We collect personal information that you voluntarily provide through our Services, including:
- Name, address, email address, and birthdate;
- Financial and health information;
- Credit or debit card numbers;
- Personal Identification numbers;
- Geolocation information; and
- Social media account IDs.
We may supplement the information you submit to us online with:
other personal information we have about you, including information from our affiliates and vendors; and information that we obtain about you from public and non-public records.
How We Use Personal Information
We use personal information you provide when you visit or use our Services to fulfill the purpose for which you provided the information and to enhance your experience with us. These uses include:
- Completing transactions, for example, processing your insurance payments;
- Processing claims;
- Sending administrative information to you, for example. information regarding the Services and changes to our terms, conditions, and policies;
- Providing and improving customer services, including through any chat or similar feature available through our Services;
- Sending marketing information, we think may be of interest to you;
- Providing a quote for one of our products;
- Sending you surveys;
- Authenticating or confirming your identity when you return to your LUMA accounts online;
- Conducting our business, such as data analysis, audits, developing new products, enhancing, improving or modifying our Services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities;
- Taking any action that we believe to be necessary or appropriate: (a) to investigate, prevent and detect illegal activities; (b) under applicable laws, including laws outside your country of residence; (c) to comply with legal process; (d) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (e) to enforce our Terms of Service and Privacy Notice (f) to protect our operations or those of our affiliates; (g) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (h) to allow us to pursue available remedies or limit the damages that we may sustain;
- Informing you of job opportunities and evaluating your suitability for a job; and
- Other purposes specifically disclosed at the time we request your information.
How We Share Personal Information
Sharing Among our Affiliates
LUMA and its affiliates may share your personal information with one another to ensure that your use of the Services is as helpful and beneficial as possible; to support our business operation, to provide services to you and for any other purpose described in this Privacy Notice.
Sharing with Third Parties
- We work with third parties that provide services to us, such as insurers, website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, credit card processing, auditing and other similar services. We may share your personal information with them so they can provide those services.
- We may share personal information with third parties to permit them to send you marketing communications, if you have opted in to such sharing
- We may share with your benefit plan’s plan sponsor or plan administrator the fact that you have visited or used features of our Services to permit your benefit plan’s plan sponsor or plan administrator to determine eligibility, qualification or confirmation of a promised incentive or reward to you. We will share any personal information you provide on our Services for the purposes stated on the page where we collected the information and in accordance with applicable laws and regulations.
We may share your information in other limited circumstances, including:
- Complying with applicable laws, including laws outside your country of residence;
- Responding to requests from government or public authorities or otherwise cooperating with authorities pursuant to a legal matter, including authorities outside your country of residence;
- Responding to matters of personal or public safety;
- In litigation, investigations, and other legal matters where the data is pertinent;
- Investigating security incidents;
- In the event of the sale or transfer of LUMA or some of our assets, or in the context of similar business negotiations; and
- Enforcing our Terms of Services.
- An “IP Address” (a number that is automatically assigned to the computer that you are using by your Internet Service Provider) may be identified and logged automatically in our server log files whenever a user access the Services, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice and is done automatically by many websites, applications and other services. We use IP Addresses for purposes such as calculating usage levels of the Services. helping
diagnose server problems, and administering the Services.
In some instances, we may combine Other Information with personal information (such as combining your name with your geographical location), in which we will treat the combined information as personal information as long as it is combined.
Anonymous and Aggregate Information
- LUMA may aggregate personal information so that it does not personally identify you or any other user of the Services (for example, we may aggregate personal information to analyze the percentage of our users who have a particular area code).
- LUMA may remove personal information to create anonymous data.
- LUMA uses and shares anonymous and aggregate information for historical, statistical, or business planning purposes. Additionally, we may use and share this information for any purpose except where we are required to do so otherwise under applicable law. If we are required to treat this information as personal information under applicable law, then we may use it as described above in “Other Information,” as well as for the purposes for which we use and share personal information.
Our Data Protection and Security Policy
- We take reasonable precautions to safeguard the personal information transmitted between visitors and the Services and the personal information stored on our servers.
- Unfortunately, no method of transmitting or storing data can be guaranteed to be 100°/o secure. As a result, although we strive to protect your personal information, we cannot ensure the security of any information you transmit to us through, or in connection with, the Site. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.
Our Privacy Commitment to Employment Applicants
- We collect information, including personal contact information, education and work history, as well as Social Security numbers in order to process and consider your application.
- We will not sell your application information to unaffiliated third parties for marketing purposes.
- The information on your application may be shared for background check services and our affiliates and used for certain regulatory, compliance and legal purposes.
- LUMA maintains profiles and/or pages on various social media Services including Facebook and Twitter.
- If you choose to “Like” LUMA on Facebook, “Follow” LUMA on Twitter, or take any other similar action on another social media site, you are providing your consent to receive information updates, including solicitations, from LUMA.
- To stop receiving this information from LUMA on a social media site, you must follow the procedure established by the site. For example, on Facebook, you must click “Unlike” on LUMA’s page, and on Twitter, you must click “Unfollow” on LUMA’s profile.
Additional Information for Users of a LUMA Mobile Application
- When using certain functions via a LUMA mobile application, we may use your location information if your mobile device uses global positioning system (“GPS”) technology, trackers or other location tools, if you allow your device to provide this information to the mobile application.
- We will use this information to estimate your location and to provide you with more personalized content and/or services.
- LUMA does not monitor your GPS tracking or location information and does not save this information.
- A LUMA mobile application may also permit you to upload a photograph from your mobile device. LUMA will not upload it to a LUMA server. This paragraph does not apply to scans or images of documents you submit to LUMA in connection with your use of the Services or any services provided by LUMA.
Cross Border Transfers
We offer Services on a global network basis and the Services are not intended to subject LUMA or any affiliated entity to the laws or jurisdiction of any state, country or territory other than the laws of Thailand and the Singapore Personal Data Protection Act 2012. Your personal information may be stored and processed in any country where we work with insurers, have facilities or in which we engage service providers, and by using the Services, you consent to the transfer of information to countries outside of your country of residence, which may have different data protection rules than your country. LUMA does not represent or warrant that the Services, or any part of them, are appropriate or available for use in any particular jurisdiction. Those who choose to access the Services, do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations.
Changes to this Privacy Notice
- We reserve the right to amend this Privacy Notice at any time.
- We will post the revised Privacy Notice on our websites or announce the change on the homepage of the website.
- You can determine when we revised the Privacy Notice by referring to revision date at the bottom of the notice.
- Any changes will become effective when we post the Privacy Notice on our websites. By continuing to use the Services following such changes, you will be deemed to have agreed to such changes.
- If you do not agree with the terms of this Privacy Notice, in whole or in part, you can choose to not continue to use the Services.
Links to Other Websites
- The Services contain links to websites operated by third parties. If you provide personal information to any third party’s website, your transaction will occur on that website (not LUMA’s websites) and that website operator will collect the personal information you provide and will be subject to its privacy policies.
- We encourage you to read the legal notice posted on those sites, including their privacy policies.
The Privacy Notice does not apply to your use of and activity on those other websites. We provide links through the Services to other websites only as a convenience, and the inclusion of these links does not imply endorsement of the linked site. We have no responsibility or liability for your use of third party websites.
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer providers, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any personal information you disclose to other organizations through or in connection with our mobile applications or other websites.
Online Communication Practices
If you email us, please do not include information you want to keep private. It is possible that your e-mail communication may be accessed or viewed inappropriately by another Internet user while in transit to us. If you wish to send us information that you want to keep completely private, please use a method other than e-mail.
Other Online Communications
We may send you electronic newsletters, information about products or services we offer, and other marketing communications. If you no longer want to receive marketing-related e-mails from us you may opt-out of receiving these
marketing-related emails by clicking on the unsubscribe link at the bottom or each email.
We will try to comply with your request(s) as soon as reasonable practicable. Please also note that if you do opt-out of receiving marketing-related e-mails from us, we may still need to send you important administrative messages, and you cannot opt-out from receiving administrative messages.
If you have any questions about this Privacy Notice please feel free to contact us under +66 2 2665 3600 or [email protected]