Privacy Policy - Luz

last updated Aug 31, 2019

Protecting your privacy is really important to us. Accordingly, we’re providing this Privacy Policy to explain our practices regarding the collection, use and disclosure of information that we process in the course of our business, including information we receive through our Services and other online or offline offerings. This Privacy Policy doesn’t apply to any third-party websites, services or applications, even if they are accessible through our Services. Also, please note that, unless we define a term in this Privacy Policy, all capitalized words used in this Privacy Policy have the same meanings as in our Terms of Service. This Privacy Policy is incorporated by reference into our Terms of Service. So, please make sure that you have read and understand our Terms of Service.

All individuals whose responsibilities include the processing of any information relating to an identified or identifiable natural person (“Personal Information”) on behalf of Luz are expected to protect that data by adherence to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, APAC, and other jurisdictions.

Revisions to this Privacy Policy

Any information that is collected via our Services is covered by the Privacy Policy in effect at the time such information is collected. We may revise this Privacy Policy from time to time. If we make any material changes to this Privacy Policy, we’ll notify you of those changes by posting them on the Services or by sending you an email or other notification as required by applicable law, and we’ll update the “Last Updated Date” above to indicate when those changes will become effective. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt-out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Luz will endeavor to comply with the law or contract.

Transparency / Notice — Types of Personal Information We Collect and How We Use It

The types of Personal Information we may collect (directly from you or from third party sources) and our privacy practices depend on the nature of the relationship you have with Luz and the requirements of applicable law. Some of the ways that we may collect Personal Information include:

We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.

Collection and Use of Information

Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our Services.

Types of Personal Information We Collect

Luz collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, guests, and employees (collectively “Individuals”).

Information You Provide Directly to Us

When you use the Services or engage in certain activities, such as registering for an Account, responding to surveys, requesting Services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:

Communications with Us

Surveys

Posting on the Site

Registration for Sweepstakes or Contests

Automatic Data Collection

Information Submitted Via Services

You agree that Luz is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. We will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.

Information from Other Sources

We may receive information about you from other sources, including through third party services and organizations to supplement information provided by you. For example, if you create an Account using your login credentials from one of your SNS Accounts, we’ll be able to access and collect your name and other Personal Information that your privacy settings on the SNS Account permit us to access. If you create an Account through the Services or one of your SNS Accounts, we may also collect your gender, date of birth and other information that is not considered Personal Information because it cannot be used by itself to identify you. This supplemental information allows us to verify information that you have provided to Luz and to enhance our ability to provide you with information about our business, products, and Services.

Information Collected Using Cookies and other Web Technologies

Like many website owners and operators, we, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a “device”) that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools, and to recognize you across devices. We use automated data collection tools such as Cookies and Web Beacons to collect certain information.

Cookies

Pixels

Widgets

Analytics

Our uses of such Technologies fall into the following general categories:

Operationally Necessary

Performance Related

Functionality Related

Advertising or Targeting Related

Location Information

In some cases we may collect and store information about where you are located, such as by converting your IP address into a rough geolocation or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalize our Services for you. If you do not want us to collect location information, you may disable that feature on your mobile device.

Social Media Platforms

Luz’s Services may include publicly accessible blogs, community forums, or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online, or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when interacting with a social media platform, and by using such services you assume the risk that the Personal Information provided by you may be viewed and used by third parties for any number of purposes.

Third-Party Payment Processing

We may sell subscriptions or merchandise through our Services. When you make purchases through the Services, we process your payments through a third party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”), Social Networking Sites (“SNS”) such as Facebook, and other third-party payment processers, including Stripe. The third party application may collect certain financial information from you to process a payment on behalf of Luz, including your name, email address, address and other billing information.

Human Resources Data

Luz collects Personal Information from current, prospective, and former employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.

We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:

How We Use Your Information

We acquire, hold, use, and process Personal Information about Individuals for a variety of business purposes, including:

To Provide Products, Services, or Information Requested

We may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:

Administrative Purposes

We may use Personal Information about you for administrative purposes, including to:

Marketing Luz Products and Services

We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. We may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:

You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in this Privacy Policy.

Research and Development

We may use Personal Information to create nonidentifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Luz may perform research (online and offline) via surveys. We may engage third party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.

Direct Mail, Email and Outbound Telemarketing

Individuals who provide us with Personal Information, or whose Personal Information we obtain from third parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on our or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in this Privacy Policy.

Services via Mobile Devices

From time to time, Luz may provide Services that are specifically designed to be compatible and used on mobile devices. We will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of our Services may require that users log in with an Account. In such cases, information about use of mobile versions of the Services may be associated with Accounts. In addition, Luz may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Luz to enable Individuals to access Accounts and to enable us to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. We may use personal or non-identifiable information transmitted to Luz to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices Luz provides.

Anonymous and Aggregated Information Use

We may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Luz’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Luz and with third parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

Sharing Content with Friends or Colleagues

Luz’s Services may offer various tools and functionalities. For example, Luz allows you to provide information about your friends through our referral services, such as “Tell a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by us or any other third parties for any other purpose.

Other Uses

We may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

Information That We Share With Third Parties

We will not share any Personal Information that we have collected from or regarding you except as described below

Information Shared with Our Services Providers

We may engage third party service providers to work with us to administer and provide the Services. These third-party services providers have access to your Personal Information only for the purpose of performing services on our behalf. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) in connection with the provision of the Site. Luz has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.

We may also share your Personal Information with our marketing service providers to help us better market our products and services to you. Our marketing service providers may use your Personal Information only for the purpose of helping us better market our products and services to you and are prohibited from transferring your Personal Information to others. If you don’t want Luz to use your information for these purposes, you can opt out by contacting us.

Information Shared with Business Partners

We may share Personal Information with our business partners, and affiliates for our and our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also provide Personal Information to business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to you. In such cases, our business partner’s name will appear, along with Luz. We require our affiliates and business partners to agree in writing to maintain the confidentiality and security of Personal Information they maintain on our behalf and not to use it for any purpose other than the purpose for which Luz provided them.

Information Shared with Other Systems, Such As HealthKit or Google Fit

You may instruct us to share certain of your information with systems such as Apple’s HealthKit or Google Fit, and to access information from those systems which we will use to improve the services we provide to you. Before you tell us to share your information with another system, however, you should review the applicable privacy policy of that system, since any information you have instructed us to share will become subject to those policies (Apple’s policy can be found here and Google’s Privacy Policy can be found here). In addition, in the event that you use one of those services, you should be careful about allowing other applications, services or people to access your information through that service. While much information collected by those services is innocuous, people who see Luz data may be able to determine a variety of personal information.

Information Shared with Other Third Parties

We may share aggregated information and non-identifying information with third parties for industry research and analysis, demographic profiling and other similar purposes.

Information Disclosed in Connection with Business Transactions

Information that we collect from our users, including Personal Information, is considered to be a business asset. As a result, if we go out of business or enter bankruptcy or if we are acquired as a result of a transaction such as a merger, acquisition or asset sale, some or all of our assets, including your Personal Information, may be disclosed or transferred to a third-party acquirer in connection with the transaction.

Information Disclosed for Our Protection and the Protection of Others

We cooperate with government and law enforcement officials and/or private parties to enforce and comply with the law. We may access, preserve, and disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims or legal process and comply with law enforcement or national security requests (including subpoenas, warrants or court orders); (ii) to protect your, our, or other’s property, rights and safety and the rights, property and safety of a third party or the public in general; (iii) to prevent or stop any activity we consider illegal, unethical or legally actionable activity; (iv) to respond to your requests; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

Your Choices & Opt-Out

You have the right to opt out of certain uses and disclosures of your Personal Information. Where you have consented to Luz’s processing of your Personal Information, you may withdraw that consent at any time and opt-out to further processing by contacting us. Even if you opt-out, we may still collect and use non-Personal Information regarding your activities on our Sites and/ or information from the advertisements on third party websites for non-interest based advertising purposes, such as to determine the effectiveness of the advertisements.

We may periodically send you free newsletters and e-mails that directly promote our Services. When you receive such promotional communications from us, you will have the opportunity to “opt-out” (either through your Account or by following the unsubscribe instructions provided in the e-mail you receive). We do need to send you certain communications regarding the Services and you will not be able to opt out of those communications – e.g., communications regarding updates to our Terms of Service or this Privacy Policy or information about billing.

We maintain “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

Mobile Devices

We may occasionally send you push notifications through our mobile applications with updates and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. We may also collect location-based information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.

Human Resources Data

With regard to Personal Information that Luz receives in connection with the employment relationship, we will use such Personal Information only for employmentrelated purposes as more fully described above. If Luz intends to use this Personal Information for any other purpose, we will notify the Individual and provide an opportunity to opt-out of such uses.

Modifying Your Information

You can access and modify the Personal Information associated with your Account through your Account settings or by contacting us. If you want us to delete your Personal Information and your Account, please contact us with your request. We’ll take steps to delete your information as soon we can, but some information may remain in archived/backup copies for our records or as otherwise required by law.

Responding to Do Not Track Signals

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Our Services do not have the capability to respond to “Do Not Track” signals received from various web browsers.

Cookies and Interest-Based Advertising

As noted above, you may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp , or youronlinechoices.eu/ and aboutads.info/choices. You can also choose not to be included in Google Analytics here.

To be clear, whether you are using our opt-out or an online industry opt-out, these cookiebased opt-outs must be performed on each device and browser that you wish to have opted-out. For example, if you have opted-out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt-out on each device. Advertisements on third party websites that contain the AdChoices link and that link to this Privacy Policy may have been directed to you based on anonymous, non-Personal Information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt-out of the advertising partners’ use of this information for interest-based advertising purposes.

Rights of Access, Rectification, Erasure, and Restriction

You may inquire as to whether Luz is Processing Personal Information about you, request access to Personal Information, and ask that we correct, amend or delete your Personal Information where it is inaccurate. Where otherwise permitted by applicable law, you may contact us or use any of the methods set out in this Privacy Policy to request access to, receive (port), seek rectification, or request erasure of Personal Information held about you by us. Please include your full name, email address associated with your Account, and a detailed description of your data request. Such requests will be processed in line with local laws.

Although Luz makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

Data Retention

Luz retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

The Security of Your Information

We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your Personal Information) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. We do not accept liability for unintentional disclosure.

By using the Site or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Site. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.

Links to Other Sites

Our Services may contain links to websites and services that are owned or operated by third parties (each, a “Third-party Service”). Any information that you provide on or to a Third-party Service or that is collected by a Third-party Service is provided directly to the owner or operator of the Third-party Service and is subject to that owner’s or operator’s privacy policy. We’re not responsible for the content, privacy or security practices and policies of any Third-party Service. To protect your information we recommend that you carefully review the privacy policies of all Third-party Services that you access.

International Transfer

Your Personal Information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside Brazil and choose to provide your Personal Information to us, we may transfer your Personal Information to Brazil and process it there. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the Brazil and the State of Rio de Janeiro, and the adjudication of any disputes arising in connection with Luz or the Site will be in accordance with the Terms.

Our Policy Toward Children

Our Services are free for any age.

Questions?

Please contact us if you have any questions about our practices or this Privacy Policy.