Note if you are in the United States of America, this Privacy Notice does not cover Protected Health Information (“PHI”) under the Health Insurance Portability and Accountability Act (“HIPAA”). For more information, see our HIPAA Notice of Privacy Practices.
This Privacy Notice describes how Luminoah, Inc. (“Luminoah,” “us,” “we,” or “our”) collects, uses, and discloses your personal information through products and services that include a link to this Privacy Notice (collectively, our “Services”), which includes, but is not limited to certain of our:
We may also collect personal information through other online services you use to interact with us such as online webinars and social media platforms, where we may be unable to directly provide a link to this Privacy Notice because the online service is owned by another party.
Some of our other products and services will contain a link to their own privacy notice, which applies in lieu of this Privacy Notice.
If you are in the United States of America, please note this Privacy Notice does not cover our use, collection, or disclosure of your Protected Health Information (“PHI”) under the Health Insurance Portability and Accountability Act (“HIPAA”). For more information about these practices, see our HIPAA Notice of Privacy Practices. If you are a California resident, please see section 12 below (“Notice for California Consumers and Your California Rights”), which sets forth additional information and rights you may have under California law relating to your information that is not HIPAA-covered PHI.
This Privacy Notice does not cover personal information that may be collected about you as an applicant for a job at Luminoah or as a member of Luminoah’s workforce.
If you have any questions or concerns about our use of your personal information, please contact us using the contact details provided at the bottom of this Privacy Notice.
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1. Collection of Personal Information
Personal information generally means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly with you. Personal information does not include information that is de-identified or aggregated. We may combine your personal information with data we obtain from our Services, other users, or other parties. We reserve the right to convert, or permit others to convert, your personal information into deidentified, anonymized, aggregated, or pseudonymized data, as permitted by law.
What personal information we collect may differ depending on how you interact with us. For example, we collect personal information when you use our Services, such as when you use our Apps which track your enteral nutrition. This personal information may differ from personal information we collect from health care providers, clinic administrators appointed by a health care provider (collectively referred to as “HCPs”), visitors to our Websites or physical offices or individuals who contact us or voluntarily share personal information with us.
Personal information we collect about you may include:
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2. Sources of Personal Information
We may collect your personal information directly from you, from other parties, or from you indirectly through cookies and other technologies, including through the following sources.
Directly from You, When You:
Additional Sources:
We may also receive your personal information from a variety of sources, including external parties such as advertising networks, internet service providers or ISPs, contractors, data analytics providers, government entities, and social networks, as defined by applicable law.
We may collect some information automatically from your computer, mobile phone, tablet, or other device when you visit our Websites or use our Services or participate in Offline Activities as well as security surveillance footage when you are physically present on our premises.
In addition, we work with distributors in order to provide our Services to you. Personal information will therefore be provided by you to the relevant distributor when using a Luminoah Service. The distributor may pass on some of this information to us if necessary, for example, to return a faulty device for investigation. Please check your relevant distributor’s privacy notice to find out more about the information which it will process.
We may also receive personal information from partner services when you allow third parties to provide it to us. For example, when you connect our connected devices or our Services to them or integrate a third party’s product with a product or service provided by us, or where you choose to use a Services feature provided by an external party. For example, we may also receive personal information about you from partners when you integrate a partner’s product with our connected devices or Services or otherwise authorize a partner service to provide personal information about you to us. Examples of such third parties include, without limitation, data received through Apple Health and/or Google Fit, data received from Amazon Alexa, Intercom, Siri Shortcuts, and iCloud.
We may also collect personal information about you from third parties who host social media webpages that we manage.
Any use of an external online service may be subject to that service’s terms and privacy policies.
Indirectly Through Cookies and Other Technologies:
We may receive your personal information through the use of cookies and other tracking technologies. For more details, see the Cookies and Other Tracking Technologies section of this Privacy Notice.
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3. Use of Personal Information
We collect, use, disclose, or otherwise process your personal information for various purposes, including the following:
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4. Disclosing Your Information
With your consent, or as allowed by applicable law, we may disclose your personal information, as described above, to:
We may also disclose your personal information to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed sale or transfer of all or a portion of our business assets (e.g., further to an actual or proposed merger, reorganization, liquidation, bankruptcy, or any other business transaction), including negotiations of such transactions.
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5. Personal Information Provided to External Businesses
This Privacy Notice does not apply to the practices of companies we do not own or control. Our Services may provide a link or otherwise provide access to external services. We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for external services. External services and other businesses may have their own privacy policies which are applicable.
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6. Cookies and Other Tracking Technologies
We may use tracking technologies, such as cookies, web beacons, mobile analytics and advertising IDs, and similar technologies including tracking technologies managed by vendors or external parties.
Tracking technologies can generally be categorized as follows:
We may use technology vendors in connection with your activity on certain pages of our Websites. The tools these vendors provide help us control how user personal information is collected by online tracking technologies. These tools also allow us to limit how certain types of Website user data, such as details about your activity on our Websites, may be transmitted to other parties.
We may combine tracking technology information with other personal information about you. We or external parties, on our behalf and pursuant to contract, may collect personal information about your online activities over time and across different online services when you use our Services.
We may use Google Analytics or other providers (such as Google Tag Manager and New Relic) for analytics services. We may also implement Google Analytics Advertising Features such as remarketing with analytics and interest-based ads. We may use first-party cookies or other first-party identifiers as well as third-party cookies or other third-party identifiers to, e.g., deliver advertisements, measure your interests, and/or personalize content.
For more information on how these providers use data collected through our Services or to opt-out, visit:
You may also opt out of certain tracking technologies by visiting the opt out services by the Digital Advertising Alliance in the US. You can visit Ad Choices (US). Opting out through these services does not mean you will no longer receive advertising from us, or when you use the Internet.
Depending on your device settings, you may also opt out of certain interest-based advertising through the device’s “Limit Ad Tracking” or equivalent feature. Refer to your device for more information on what this opt out affects. For instance, you can generally adjust or reset the advertising identifiers on your mobile device in the device settings.
You can set your browser to refuse cookies from websites, but if you do so, you may not be able to access or use portions of our Services, and certain offerings on our Services may not function as intended or as well. In addition, iOS and Android operating systems provide options to limit tracking and/or reset advertising IDs.
To control web beacons, most email providers have settings which allow you to prevent the automatic downloading of images, which will disable web beacons in the email messages you read.
We are not responsible for opt out processes provided by external parties.
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7. Interactive Features
We may engage vendors to provide certain interactive features on our Services. Your use of these interactive features is voluntary, and we may retain the information that you submit through these features. For example, we may offer an interactive chat feature on our Services to answer questions and for other customer service purposes. When you participate in the interactive chat, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that our vendors may process the information obtained through the feature to provide the service on our behalf.
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8. Security
We use appropriate administrative, technical, physical, and organizational measures to protect the personal information we collect and process about you. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. This includes managerial measures, including establishment and implementation of internal management plan and periodic training for employees; technical measures, including controlling access rights and putting in place authentication controls for personal information processing systems and encryption of important data; and physical measures, including external security, event logging and management of system servers. While we implement security measures designed to be appropriate to the relevant risks, please note no data transmission over the Internet or any wireless network can be guaranteed as being 100% secure.
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9. Data Retention
We will store your personal information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be required or permitted under applicable law. To determine the appropriate retention period, we will consider the amount, nature, and sensitivity of the data; the potential risk of harm from unauthorized use or disclosure of the data; the purposes for which we process the data and whether we can achieve those purposes through other means; and the applicable legal requirements.
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10. Your Choices
Our Services may have settings available to you, depending on the Service, to allow you to set preferences. Information collected through our various Services, such as between our online portals and Apps, may not be synchronized (especially when you are not logged into one Service, and you are logged into another). Where information is not synchronized and you would like to have consistent settings, you may contact customer service if you have any issues or to make sure your settings across Services are consistent by accessing each Service independently.
If you receive marketing emails from us, you may opt out through the email’s instructions, as provided. Please note that regardless of your email preferences, we may send you notifications pertaining to the performance of our Services, such as revision of our Terms of Use or this Privacy Notice or other formal communications relating to Services you have purchased or use. If you receive texts from us, you may opt out by texting “STOP” to the number contacting you.
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11. Children’s Personal Information
Parts of our Services may be available and/or directed to children. Where required by law, we seek to obtain the verifiable parental consent from the child’s parent or guardian. Where the law requires us to obtain verifiable parental consent and we learn that a child, as defined under that legal requirement, has provided us personal information independently without the permission of their parent or guardian, we delete that information.
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12. Notice for California Consumers and Your California Rights
This California Privacy Notice is provided pursuant to the California Consumer Privacy Act, as amended (the “CCPA”) and describes how Luminoah may collect, use, and disclose personal information of consumers that reside in California. Please note certain information we collect, use, and disclose is considered PHI, as described above, and is therefore covered by our HIPAA Notice of Privacy Practices. For more information, please visit
www.luminoah.com/legal/privacy/hipaa-notice-of-privacy-practices.
Unless otherwise noted, the disclosures in Section 11 cover our activities in the twelve (12) months preceding the Effective Date, as well as our current practices.
How and Why We Collect, Use, and Disclose Your Personal Information
Luminoah may collect, use, and disclose personal information for business purposes consistent with applicable laws as identified below. Where Luminoah transfers applicable personal information to recipients, such as our service providers, it does so for the same business purposes described below. These examples may vary depending on the nature of your interactions with us.
Category of Consumer Personal Information | Categories of Sources from which Collected | Business Purposes for Collection, Use, or Disclosure | Categories of Recipients to Whom Consumer Personal Information May be Disclosed for a Business Purpose |
Identifiers (such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, or other similar identifiers). | Directly from you Automatically when you use our electronic systems From service providers that help us to run our business | Comply with applicable state and federal law Communicate with you Maintain business records Provide personalized advertising and marketing | Examples include service providers, data analytics providers, security providers, background check vendors, and information technology vendors. |
Internet or other electronic network activity information, (including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website application, or advertisement). | Directly from you Automatically when you use our electronic systems From service providers that help us to run our business | Comply with applicable state and federal law Communicate with you Maintain business records Provide personalized advertising and marketing | Examples include data analytics providers, security providers, and information technology vendors. |
Any personal information described in subdivision (e) of Section 1798.80 of the California Civil Code. | Automatically when you use our electronic systems From service providers that help us to run our business | Comply with applicable state and federal law Communicate with you Maintain business records Provide personalized advertising and marketing | Examples include data analytics providers, security providers, and information technology vendors. |
Approximate Geolocation data. | Automatically when you use our electronic systems From service providers that help us to run our business | Comply with applicable state and federal law Communicate with you Maintain business records Provide personalized advertising and marketing | Examples include data analytics providers, security providers, and information technology vendors. |
Commercial information, including records of personal property, Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Directly from you Automatically when you use our electronic systems From service providers that help us to run our business | Comply with applicable state and federal law Communicate with you Maintain business records Provide personalized advertising and marketing | Examples include service providers, data analytics providers. |
Professional or employment-related information. | Directly from you From service providers that help us to run our business | Comply with applicable state and federal law Communicate with you Maintain business records | Examples include background check vendors. |
We may also disclose each of the categories of personal information identified above to the respectively identified categories of recipients for operational or business purposes consistent with the purposes for collection or use designated, as is reasonably necessary and proportionate to achieve those purposes, or for another purpose that is compatible with the context in which the personal information was collected, including, but not limited to:
In addition to the other purposes for collection, use, and disclosure of personal information described in this Notice, we may collect, use, and disclose personal information as required by law, regulation or court order; to respond to governmental and/or law enforcement requests; to identify, contact or bring legal action against someone who may be causing injury to or interfering with our or others’ rights or property; to support any actual or threatened claim, defense or declaration in a case or before any jurisdictional and/or administrative authority, arbitration or mediation panel; or in connection with disciplinary actions/investigations. Likewise, we may use and disclose personal information to other parties in connection with the sale, assignment, merger, reorganization, or other transfer.
Selling and Sharing of Personal Information
We may sell or share the following categories of personal information with third parties for the purposes of cross-context behavioral advertising: identifiers, internet or other electronic network activity, and approximate geolocation data. We sell and/or share this personal information with third parties for advertising purposes. The third parties to whom this personal information was sold and/or shared are advertisers and analytics vendors. When we use the terms sell, sold, or sale, we mean for valuable consideration and not monetary value.
We offer you the ability to opt out of sales and sharing of your personal information as set forth in the “California Privacy Rights” section below.
We do not have actual knowledge that we sell or share the personal information of consumers under sixteen (16) years of age.
Data Retention
To learn more about our data retention practices, please see Section 9.
California Privacy Rights
If you are a resident of California, you have the right to submit certain requests relating to your personal information as described below. If you would like to submit a request pursuant to your rights under HIPAA instead of CCPA, please contact us at privacy@dmw.310.myftpupload.com and indicate that you are making a HIPAA request. To exercise your CCPA rights, please submit a request by email to privacy@dmw.310.myftpupload.com, or by calling us at 1-8xx-xxx-xxxx. Please note that, depending on the nature of your request, you may be asked to provide information to verify your identity before your request can be processed.
We will confirm receipt of your request and respond to your request as soon as we reasonably can and no later than legally required. You may designate an authorized agent to make a request on your behalf; however, you will still need to verify your identity directly with us before your request can be processed.
Right to Know. You have the right to know what personal information we have collected about you, which includes:
Right to Delete Your Personal Information. You have the right to request that we delete personal information we collected from you, subject to certain exceptions.
Right to Correct Inaccurate Information. If you believe personal information we maintain about you is inaccurate, you have the right to request we correct that personal information.
Right to Opt Out of Sales and Sharing of Personal Information. You have the right to opt out of the sale or sharing of your personal information and to request that we do not share your personal information for cross-context behavioral advertising in the context of cookies and other tracking technologies. To opt out of the sale or sharing of your personal information via cookies and other tracking technologies, please click on the “Do Not Sell or Share my Personal Information” link in the footer of our website. You may also opt out of the sale or sharing of your personal information through an opt out preference signal. In order to process your request through an opt out preference signal, you must use a browser supporting the preference signal.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not use or disclose sensitive personal information for purposes to which the right to limit use and disclosure applies under the CCPA.
Right to Non-Discrimination for the Exercise of Your Privacy Rights. If you choose to exercise any of the privacy rights described above, we will not discriminate against you.
California Shine the Light
We do not share personal information with third parties or affiliates for those third parties’ or affiliates’ own direct marketing purposes. Californians may request information about our compliance with this law by contacting us at privacy@dmw.310.myftpupload.com.
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13. Do Not Track Disclosures
At this time, some of our Websites do not respond to Do Not Track (“DNT”) signals sent from your web browser. A uniform standard has not yet been adopted to determine how DNT signals should be interpreted and what actions should be taken by websites and third parties that receive them.
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14. Updates to this Privacy Notice
We may update this Privacy Notice from time to time. You can see when this Privacy Notice was last updated by checking the “Last Updated” date displayed at the top of this Privacy Notice. Any changes to this Privacy Notice take effect immediately after being posted or otherwise provided by Luminoah.
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15. How to Contact Us
Luminoah, Inc. Attn: Legal Department
1 Morton Dr, Suite 100, Charlottesville, VA 22903
Email: privacy@dmw.310.myftpupload.com
