Privacy Policy

In an effort to communicate our commitment to actively protect the privacy and personal information of all visitors to stemcity.com, ondemand.mopi16.com, and enuggetlearning.com, Luma, Inc. ("We") makes the following statement in regard to the information that may be collected on our website(s) ("website"). We may modify this Privacy Policy at any time and without further notice to you. Amendments to this statement will be posted on our website and will be effective when posted. Your continued use of this website following the posting of any amendment, modification, or change constitutes your acceptance thereof.

I. INFORMATION WE COLLECT

We collect information about you in a number of ways, including tracking your activities through your IP address, computer settings or most-recently visited URL. We may also ask you to provide certain information about yourself, such as your age, gender, city, etc. We also collect personal information about you when you voluntarily submit such information to us, by, for example, filling out a survey or registration form. “Personal Information” is information that identifies, relates to, describes, or is reasonably capable of being associated with or could reasonably be linked, directly or indirectly, with a particular person. The types of information that may be requested include your name, address, e-mail address, telephone number, and payment information. We may use a third party processor to process your payment information. Please visit the website of such processor if you have questions about their privacy practices.

We do not knowingly collect information from any person under the age of 18. If you are under the age of 18, you are not authorized to, and may not, use this site or any of our services.

We may also collect personal information that you voluntarily share with us through the Luma platform. For example, we collect information from you when you fill out an online form in Luma. Examples of information collected may include contact information, information your employer needs to complete your personnel or driver qualification file, images of your licenses, or images of you to prove your identity. The information collected through forms is encrypted while stored in our databases. We also collect photographs or other still images of you and your end users using LumaLens or LumaPrompt.

We also collect information about your device in order to better serve content to you. This information includes browser and device information and IP addresses.

II. USE OF INFORMATION

We do not and will never sell or rent personal information to third parties, except as provided in this Privacy Policy and our Terms of Use.

We do not direct market to our end users, nor do we share any personal information for the purpose of direct marketing to end users.

In general, we will only use the information you provide to us for the purpose for which such information was collected by us. We may also use this information to effectively administer our website and conduct our business operations. Your information may also be used to contact you when necessary regarding your usage and experience with the website.

Non-personal demographic and profile data is used to enhance your experience at our site. This non-personal information may also be shared with advertisers on an aggregate basis.

The following are other purposes for which we share and process your personal information:

• In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
• We may also disclose your personal information as required by law, such as to comply with a subpoena, contract, law or regulation, or other legal process, or when we believe in good faith that disclosure is necessary to protect our rights and property, protect our safety, your safety, or the safety of others, investigate fraud or other unauthorized or illegal conduct, or respond to a government request.
• We may share personal information with your employer for the purposes of maintaining compliance with your employment obligations.
• We may disclose your personal information at the direction of, and on behalf of, your employer. Please contact your employer with questions about the employer’s use and sharing of your personal information.
• We may share your personal information with third-party service providers under contract with Luma to help us provide services to you. For example, we may share information that you provided through Luma's online form tool with your employer's other services in order to keep your driver qualification file current.
• We may share aggregated data with third parties when the data has been de-identified or otherwise anonymized in such a manner that the information would not be able to identify you.
• We reserve the right to sell, share, disclose and transfer your information, including your personal information:
• To a subsequent owner, co-owner, or operator of Luma or successor database.
• In connection with a corporate merger, consolidation, bankruptcy, the sale of substantially all of our membership interests and/or assets or other corporate change, including to any prospective purchasers.
• To our attorneys, and such other investigative, business, or compliance entities, as may be needed to protect our legal rights.

III. USE OF IP ADDRESSES

We use your IP Address to verify your performance in Luma, to help diagnose problems with our server, administer our website, and to collect aggregated metrics on site usage.

IV. USE OF COOKIES

When you view our website we might store some information on your computer. This information will be in the form of a "cookie" or similar file. Cookies are small pieces of information stored on your hard drive, not on our site, to help you navigate a website as easily as possible. We use cookies to deliver content specific to your interests and to facilitate reentry of all your registration data at each connection.

We use both necessary and analytics cookies on our site. Necessary cookies are always active to ensure the site functions properly. Analytics cookies are used to understand website traffic and performance. Our third party partners may also utilize cookies, such as to track your activities across multiple websites. Please visit their websites to answer any questions you may have about their cookie practices.

You may choose to decline the use of analytics cookies on our site. You may also disable cookies through your browser settings. Please understand that limiting or disabling cookies may impact how our site functions or our ability to provide you with goods or services.

Some clients may use an outside advertisement server company to display ads on our site. These ads may contain cookies. The advertisement server company may collect cookies received with outside banner ads. We do not have access to information that would confirm the use of cookies by any advertisement server company. We do not control the privacy practices of any third party and you should refer to such third party’s privacy policy for information about their collection and use of your personal information.

V. USE OF PHOTOGRAPHS

When you or your end users use LumaLens or LumaPrompt, we collect and store photographs or other still images of such user. By using LumaLens or LumaPrompt, you expressly consent to such collection and storage. You also agree that we are not responsible for storage or backups of any such images, may store any such images for up to one (1) year or as otherwise provided in our data retention policies, and may delete such images in our discretion at any time. You are responsible for storing and creating backups of any such images.

VI. SECURITY

Our site has industry standard security measures in place to protect the loss, misuse and alteration of the information under our control. While there is no such thing as "perfect security" on the Internet, we will take reasonable steps to ensure the safety of your personal information through physical, technical, and administrative security measures. We cannot, however, guarantee the security or confidentiality of your personal information. You expressly assume the risk of using our site and providing us with your personal information.

VII. OTHER WEBSITES; LINKS

Our website may contain links to other websites. We are not responsible for the privacy practices or the content of such websites, and you should refer to such websites for information about their privacy policies.

VIII. CORRECT; UPDATE

Our website allows its users the option to change, delete, or modify information previously provided, or to request such changes. This may be done through the following methods:

1. Login to your account at enuggetlearning.com
2. E-mail your request to info@learnwithluma.com
3. Submit a help ticket to Luma at enuggetlearning.com/connect

Unfortunately, to the extent that such information is also stored in other databases, we cannot always ensure that such corrections or deletions will reach the other databases. We will use all reasonable efforts to ensure that your information is removed from or corrected in our records.

IX. TCPA AND USER CONSENT

You and your users may provide to us data consisting of email addresses, telephone numbers and other contact information for you or your users. You acknowledge that, in performing our obligations to you, we will telephone and send text messages to or otherwise contact such users. You warrant that the contact information provided to us is true and correct, and that you have provided notice to, and obtained all necessary consents of, users for the transfer and use of user contact information to and by Luma as contemplated by this Agreement, including and not limited to permission for Luma to leave prerecorded/artificial voice messages and use an automatic telephone dialing system to call or text such users’ mobile/cellular telephone numbers. You also certify that Luma may rely on such user contact information as provided by you or any such user.

X. YOUR RIGHTS AND CALIFORNIA PRIVACY RIGHTS

Depending on your state of residence, you may have rights under applicable state law relating to our processing of your personal information. In addition to the rights we have described in this Privacy Policy, you may have the right to:

• Access and request a copy of your personal information
• Limit, restrict, or object to the use of your personal information
• Request correction or deletion of your personal information
• Notify and file a complaint with the appropriate government authority about our processing of your personal information
• Opt-out of cookies and marketing communications, or withdraw consent for marketing, if applicable

Opt-out of Marketing Communications: We do not currently engage in direct marketing to our users. If we do so at any time, you have the right to opt-out of and unsubscribe from such emails by selecting the Unsubscribe link on the email or by contacting us as described in this Privacy Policy.

Your California Privacy Rights:

If you are a California resident, you may have certain rights under California law in addition to those described in this Privacy Policy.

Do Not Track Signals: We do not currently recognize or respond to “Do Not Track” signals. To learn more about “Do Not Track,” you may visit https://fpf.org/thank-you-for-visiting-allaboutdnt-com/

Global Privacy Controls: California and some other states now require that, if a user enables a global privacy control, it should be treated as a consumer request to opt out of the sale of personal information. As noted elsewhere in this Privacy Policy, we do not currently sell your personal information, except in limited circumstances as described in this Policy. You may learn more about global privacy controls by visiting this website: https://globalprivacycontrol.org/

Shine the Light Law: In general, unless you consent, we do not sell, share, or otherwise disclose your personal information to third parties for direct marketing purposes, except as provided in this Privacy Policy. If you are a California resident, you have the right to ask us, at no cost to you and once a year, if we have shared your personal information with third parties for direct marketing. Please contact us as described below to exercise this right.

Contacting us:

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this website, or to exercise any of the rights described here, you can contact us at: