Smart Lumies, Inc.

Last update: July, 10  2020.

Smart Lumies, Inc. operates the website (“Website”) and Smart Lumies app (“App”), which provides our services (“Services”).

This page is used to inform website visitors about our privacy policies regarding the collection, use, and disclosure of personal information in relation to our Services.

If you choose to use our Service, then you agree to the collection and use of information in relation with this policy. The Personal Information that we collect is used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Policy.

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which are accessible at, unless otherwise defined in this Privacy Policy.

This Privacy Policy explains what information of yours will be collected and used by Smart Lumies, Inc. (“Smart Lumies,” “we,” “us,” or “our”) when you access our Website and App. We will not use or share your information with anyone except as described in this Privacy Policy. Each time you use our Service you are accepting the practices described in this Privacy Policy at that time.

You have to be over 13 years old to use our Services.


Personal Information Collection

For a better experience while using our Services, we may require you to provide us with certain personally identifiable information. The information that we collect will be used to contact or identify you (“Personal Information”).

We may collect the following Personal Information about you:

  •       name
  •       age or date of birth
  •       postal address; e-mail address; telephone number
  •       social media screen name or username
  •       photograph or photographs you may provide to our Website or App or through social media
  •       social media handle
  •       gender
  •       geolocation information


Use of Personal Information

We may use your Personal Information for the following purposes:

– Providing and managing your access to our Website and App;

– Personalising and tailoring your experience on our Website and App;

– Supplying our products and Services to you;

– Personalising and tailoring our products and/or Services for you; and/or

– Communicate with you.

Log Data

Whenever you visit our Website, we collect information that your browser sends to us that is called Log Data. This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser version, pages of our Services that you visit, the time and date of your visit, the time spent on those pages, and other statistics.

Personal Information and Log Data are collectively referred to as “data” in this Privacy Policy.

Legal bases for collecting your data

We collect and process your data under the following legally allowed bases:

Consent – We collect and process your data with your consent via positive opt-in. We will be clear and specific about what use you are consenting to.

Contract – We collect and process your data as required to fulfill contractual obligations to you, such as fulfillment of an order from our online store.

Legal obligation – If the law requires us to, we may need to collect and process your data.

Legitimate interest – In specific situations, we collect and process your data for our legitimate interests in a way that can be reasonably expected as part of running our business and which does not materially infringe upon your rights, freedom or interests.

Data Protection

We will take reasonable steps to maintain appropriate technical and organizational measures to protect the  data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your  data. 

How long do we retain information?          

Whenever we collect or process your  data, we’ll only keep it for as long as necessary for the purpose for which it was collected. At the end of that retention period, your data will either be deleted or anonymised so that it can be used in a non-identifiable way for statistical analysis.

Correspondence information: If you send us personal correspondence, such as emails or letters or third parties send us correspondence about your activities or postings on our Website, we may store such information in our servers.

Contact forms and email links: Should you choose to contact us via the contact form at our contact us page or an email link, none of the data that you provide will be stored in the Website or passed to / be processed by any of the Third Party Data Processors. The data will be compiled into an email and sent to us over the Simple Mail Transfer Protocol (SMTP). Our SMTP servers are protected by TLS (also known as SSL) meaning that the email content is encrypted using SHA-2, 256-bit cryptography. The email content is then decrypted by our local computers and devices.

Website visitation tracking: Our Website uses Google Analytics (“GA”) to track our Users’ interaction. We use the data to determine the number of people using our Website, to better understand how they locate and use our web pages. Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to Smart Lumies. GA also records your computer device’s IP address which could be used to personally identify you but google does not grant us access to this.

Service Providers

We may employ third-party companies and individuals for the following reasons:

  • To facilitate our Services;
  • To provide the Services on our behalf;
  • To perform Service-related services; or
  • To assist us in analyzing how our Services are used.

Facebook Pixel  helps us track conversions from Facebook ads, optimize ads based on collected data, build targeted audiences for future ads, and remarket to qualified leads.

  •         Info Shared: User’s information (name)

Google Analytics – gives us insights into how users find and use our Website.

  • Info Shared:  Customer information (device id)

Stripe – allows us to receive payments over the Internet. Stripe provides the technical, fraud prevention, and banking infrastructure required to operate on-line payment systems.

  •         Info Shared: User’s information (name, email, id), credit card.

Mailchimp – marketing automation platform that helps us to share email and ad campaigns with our Visitors, Users and other interested parties.

          –  Info Shared: User’s email

Apple for mobile app downloads and in-app purchases.

  •         Info Shared: User information (device id), usage data, crash logs.

Google for mobile app downloads and in-app purchases.

  •         Info Shared: User information (device id), usage data, crash logs.


The third parties have access to your data in order to perform the tasks assigned to them on our behalf. These third parties are, however, obligated not to disclose or use the information for any other purpose.


If you are a registered user at our Website, you may receive monthly newsletters from us. If you subscribe to our newsletter, your email address will be forwarded to a third party for marketing purposes (“Campaign Monitor”). Your email address shall be saved in Campaign Monitor’s database for as long as we continue to use Campaign Monitor’s services for marketing purposes. You may request removal of your email address from Campaign Monitor’s list. You can do this by using the unsubscribe links included in our newsletter.

How do we protect your information?

–  All our employees, independent contractors and agents have executed non-disclosure agreements, which provide explicit confidentiality protections. Any employee, independent contractor or agent who violates such privacy and/or security policies is subject to possible termination and civil and/or criminal prosecution.

– We do not make any of your Personal Information available to third parties for their marketing purposes. Smart Lumies’ software runs on individual servers and no data given or collected is shared with other social media platforms. If however, we share your Personal Information with third parties, we will notify you. Please note that no transmission over the internet can guarantee confidentiality and non-disclosure, and as such, you transmit at your own risk.

– Smart Lumies uses robust security measures to protect data from unauthorized access, maintain data accuracy, and help ensure the appropriate use of data. When the Services are accessed using the internet, Secure Socket Layer (SSL) technology protects your information, using both server authentication and data encryption. These technologies help ensure that your information is safe, secure, and only available to you and to whom you have granted access. Smart Lumies also implements other advanced technology measures to prevent interference or access from outside intruders.

– All traffic (transferral of files) between the Website and your browser is encrypted and delivered over HTTPS.

– We do not tolerate Spam. To report Smart Lumies-related spam please contact us at You may not use our communication tools to send spam or otherwise send content that would violate our TOU. We may check for spam, viruses, phishing attacks and other malicious activity or illegal or prohibited content of the Website, but we will not permanently store messages sent through these tools.

– Smart Lumies does its utmost to secure communications and data storage in order to protect confidentiality of your Personal Information against loss and interception by third parties. However, it is important to know that there is no zero-risk against loss or interception by others of your information. You are responsible for maintaining the security and confidentiality of your Account’s username and password.

Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use Personal Information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our separate Cookie Policy.

Data retention

We retain Personal Information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). 

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

Opt In and Opt Out

You may have the right to opt in to or opt out of certain of our uses and disclosures of your data. For example, when you are asked to provide data on this Site, you may have the opportunity to elect not to receive promotional messages from us by e-mail or text messaging. You may unsubscribe from our promotional emails by clicking on the “unsubscribe” or opt-out link within the e-mail you receive. If we share personal information with third parties for their marketing purposes, you will be able to elect for us not to do so by emailing us at

Data Controller

The data controller of our Website and App is:

Smart Lumies, Inc.

General objections to the processing of your data

To the extent provided by applicable law, you may withdraw any consent you previously provided to us, or object at any time on legitimate grounds, to the processing of your data. In some circumstances, withdrawing your consent to our use or disclosure of your data will mean that we will not be able to provide products or services to you or to otherwise engage with you.

Access to data

You may request access to the data that we maintain about you. If we grant your request, we will provide you with a copy of the data we maintain about you in the ordinary course of business, in a commonly used format. You may request to correct any errors in your data. We may reject your request to access or correct your data, as permitted by applicable law.  If we reject your request, we will notify you of the reasons for the rejection.

Portability of data

You may request that we transfer your personal information to another data controller. We may reject your request, as permitted by applicable law.  If we reject your request, we will notify you of the reasons for the rejection.

Deletion of data

You may request that we delete your data. We may reject your request, as permitted by applicable law.  If we reject your request, we will notify you of the reasons for the rejection.

Transfer of data

We are a United States (US) headquartered company. If you are located outside the US and choose to provide information to us, we transfer your information to our servers in the US. The US may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to the US, we will protect it as described in this Privacy Policy. By visiting our Website and App or providing us with your data, you acknowledge this transfer, processing and storage of your information in the US.

We have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy.


Changes to This Privacy Policy

We may update our Privacy Policy from time to time. Thus, we advise you to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately, after they are posted on this page.

Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at