You are not required to create a Lumosity account to gain access to many areas of Lumosity. If you do create an account, we ask for certain information to process your registration, including an email address and password. If you subscribe to a paid account, we request additional information, including your full name and payment method details.
We also ask for certain, limited demographic information, including your first name, gender, date of birth and education level. Providing most of this information is optional. We also allow you to upload a photo of yourself and select your preferences for training, language, and receiving email communications.
If you sign in to Lumosity using your Facebook or other third party credentials, we will use that service to authenticate you. We may also receive other information that you have agreed may be provided by that third party, such as your username, name, e-mail address, date of birth and gender. We receive this information so that it can be used for the purposes explained in this Policy.
We may supplement the information you provide to us with additional information gathered from other sources, such as publicly available information.
In addition to the information you provide to us, when you use Lumosity, you may automatically submit information about the computer, mobile device, or other devices you use to access Lumosity and about how you use Lumosity. For example, we receive data about the games you play and your performance in those games. We may also receive information such as your browser type, IP address, language, the type of device you use, operating system version, unique device identifier ("UUID"), the date and time of your visit and files you viewed on our site (e.g., HTML pages, graphics, etc.), Internet service provider, clickstream data, the pages you view and the websites you visited immediately before and after visiting Lumosity. In some cases, we link this automatically collected data to other information we collect about you. We do this to improve the services and marketing we offer you.
From time to time, we use push notifications in our mobile applications to send you messages about Lumosity or your account. You may opt out from receiving push notifications through your device settings. We do not access or track any location-based information from your mobile device.
The third-party advertising and analytics companies with whom we or our advertisers partner, including Google, Rollbar and New Relic, may place a unique cookie or utilize similar technologies on your browser in order to collect non-personal information about your visits to Lumosity. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads, but the ads that you see will not be personalized.
Mobile Analytics. We use mobile analytics tools to better understand the functionality of our mobile applications. These tools may record information about your usage, including how often you use the application, the events that occur within the application, and where the application was downloaded from. We may link the information recorded in analytics software to personal information you submit to us.
Research Accounts. If you are a subject in a research project or study involving Lumosity, that project may involve the collection of different information than is described in this Section. For example, many research projects are done on an anonymous basis. For further information, please refer to the materials distributed to you as part of the study, contact the researcher leading your study, or contact us using the contact information below.
We use your information to operate and provide you with Lumosity. This includes, but is not limited to:
You can opt out of receiving marketing emails by navigating to your Email Notifications page or by following the unsubscribe instructions included in each email. Please note you may not opt out of certain transactional emails, such as when we email you to confirm transactions, address account issues, or communicate about customer support.
We also reserve the right to use non-personal information (e.g., de-identified or aggregate data) for any purpose. For example, we show aggregate performance measures to users to allow them to evaluate their performance against other Lumosity users. Also, in connection with our Human Cognition Project, we may disclose performance statistics to university collaborators to evaluate, study, and improve the effectiveness of our programs or human cognition more generally. In these situations, all data is disclosed either in aggregate form or with information that can identify you removed. In addition, when we work with university collaborators, we contractually prohibit them from attempting to re-identify individuals from data that has been de-identified.
We believe in protecting your privacy, and therefore do not provide your personal information to third parties for their marketing purposes.
We may share your personal information only in the following ways:
You may access, review, correct and delete your registration information through your Account page. You may also access or delete the personal information we have collected about you by contacting us at the contact information listed below. Upon request Lumos Labs will provide you with information about whether we hold your personal information. While we will make reasonable efforts to accommodate your requests, if allowed by applicable laws, we reserve the right to impose certain requirements and restrictions on such requests, such as limiting our production of information to certain formats and not deleting information that is no longer identifiable. We will respond to your request to access in a reasonable timeframe, not longer than 30 days.
We will retain your information for as long as your account is active, or we think you may return as a user, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
We have implemented and maintain reasonable security practices to protect against the unauthorized access, use, modification, destruction or disclosure of your personal information. For example, when you enter sensitive information on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. However, no method of transmission or storage is completely secure, and we therefore cannot guarantee absolute security. If you have any questions about security on our website, please contact us using the contact information below.
If you access Lumosity outside of the United States, you fully understand and unambiguously consent to the transfer of your personal information to, and the collection and processing of such personal information in the United States.
Lumos Labs participates in and has certified its compliance with the EU – U.S. Privacy Shield Framework. Lumos Labs is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. https://www.privacyshield.gov/list
Lumos Labs is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Lumos Labs complies with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.
With respect to personal data received or transferred pursuant to the Privacy Shield Framework, Lumos Labs is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Lumos Labs may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (at no cost) at https://feedback-form.truste.com/watchdog/request.
Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
Lumos Labs, Inc. complies with the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. Lumos Labs, Inc. has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view Lumos Labs, Inc.’s certification, please visit https://safeharbor.export.gov/swisslist.aspx.
We do not track our customers’ personal information over time and across third-party websites to provide targeted advertising and therefore do not respond to "Do Not Track" (DNT) signals.
Director of Privacy
140 New Montgomery Street, Floor 19
San Francisco, CA 94105