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Privacy Policy

While respecting the value and importance of sensitive information and personal data of participants to the educational process, we adhere to the principles of confidentiality and privacy of the information (data) received from users of the online platform Lummio.
Our privacy policy applies to any data or information that the platform receives while being in use. By using the Lummio platform, you agree to the collection (processing), storage, transfer of personal data and information used within the platform.
Please read our Privacy Policy carefully. If you do not agree with it, please refrain from using the Lummio platform.

General part

For the purpose of this document, the terms in this document shall have the following meanings: Educational online platform Lummio (hereinafter referred to as the Platform) is an automated information and communication system consisting of software services and modules developed by the New Educational Technologies, Ltd (hereinafter referred to as the Founder) in order to digitize and increase the efficiency of educational and management processes of educational institutions. User is an individual authorized / identified / registered on the platform.
Other terms are used according to the definition of the Law of Ukraine On Personal Data Protection dated 01.06.2010 № 2297-VI (as amended) (hereinafter referred to as the Law)

Purpose of personal data processing

Personal user data shall be processed in order to provide electronic services to support the educational and management processes of the educational institution. The Lummio platform is designed to increase the efficiency of processes in an educational institution by introducing modern and optimal forms of interaction for all participants to the educational process and creating a paperless document flow of the institution.
In order to ensure the effective operation of the platform, the founder will carry out the following:

  • registration / identification / authorization of platform users;
  • fulfillment of its obligations to users, institutions, and educational administrations;
  • interaction with and support for platform users;
  • assessment and analysis of platform performance, recovery of both individual modules and the entire platform in case of unforeseen situations.

User Rights and Obligations

The user has the right to receive information about the processing of his/her personal data, as well as other rights defined in part 2 of Article 8 of the Law, in particular:

  • the right to access, amend and update his/her personal data;
  • the right to be aware of the location of his/her personal data, the purpose, content and mechanism of its processing, the location of the holder or manager of the personal data;
  • the right to revoke consent to data processing and / or in some cases delete it (right to be “forgotten”);
  • the right to make a reasoned request to change or destroy personal data if this data is processed illegally or is inaccurate;
  • the right to send complaints about their processing in certain cases or apply remedies.

The User is obligated, including but not limited to:

  • not to cause actions aimed at deceiving or limiting the rights and opportunities of other users
  • not to share your personal information with third parties, as well as your login, password, and other confidential information;
  • not to collect, organize, store, process or distribute personal information of other Users;
  • not to try to gain access to the personal data of other Users in any way, including, but not limited to, by fraud, breach of trust, trial and error selection of authentication and identification data;
  • update information in case of changes.

Platform usage

The use of the platform is voluntary and shall be governed by this Privacy Policy and the Law.
The educational institution, based on the request of parents or other guardians, shall conclude a corresponding contract in writing with the Company and provide the Founder with the necessary data for use.
The Founder shall inform the educational institution, as the owner of personal data, of the need to inform parents of students, pupils and teachers about the processing of their personal data while using the platform, as well as to obtain their Consent to the processing of personal data while using the platform. The educational institution shall independently regulate these relations with the participants to the educational process and the Founder shall not be responsible for these relations and their documentation as part of the subscription and use of the platform.
The educational institution shall provide a mobile phone number / email address and username for the user to gain authorized access to the platform.

Taxes and refund

The User shall be responsible for determining the taxes, if any, that apply to transactions made via the Platform Lummio. The User shall be responsible for reporting and transferring the applicable tax to the appropriate tax authority, and all his/her actual and potential tax obligations under his/her liability.
The User agrees that the Platform Lummio shall in no event and under no circumstances be responsible for determining whether taxes apply to its transactions or services, or for collecting, reporting, withholding or transferring any taxes that arise from any transactions or services.
User also agrees that the Platform Lummio shall in no event and under no circumstances be obligated to compensate him/her for his/her tax liability or to give him/her any tax-related advice.
The User can request a refund by sending an e-mail to [email protected].

Data Breach Notification Policy in Compliance with SOPPA

In compliance with the Student Online Personal Protection Act (SOPPA), our platform is committed to protecting the privacy and security of student data. In the event of a data breach that involves student information, we will promptly notify the affected schools within the timeframe mandated by SOPPA regulations. This notification will include detailed information about the nature of the breach, the type of data affected, and the steps being taken to mitigate the issue. We are dedicated to maintaining transparency and working closely with schools to ensure the ongoing safety and privacy of student data.

The Founder reserves the right to change the Privacy Policy and inform users about it.

If you have any questions about the Privacy Policy, please email [email protected].