Privacy Policy

Heallo corporation built the Luminara platform (hereinafter the “Platform”). This service is provided by Heallo corporation and intended for use as is (hereinafter the “Service”).

This page is used to inform visitors regarding our policies with the collection and processing of personal data if anyone decided to use the Platform.

Heallo is complying with the European Regulation (EU) 2016/679 and hereby provides with the following information in accordance with article 13 of the General Data Protection Regulation (hereinafter the “GDPR”).

1. Data controller

The data controller is Heallo S.A.S.U., located at 7 rue Keller 75011 Paris, registered in the Trade and Companies Registry under the number 882 911 662, whose VAT number is FR 36882911662, with email address contact@luminara.care.

2. Information collection and processing

Heallo collects personal data (hereinafter, the "Company") directly from the user (hereinafter, the "User"), in the context of the registration and use of the Platform and execution of the Service, for the following purposes:

• a) Availability of the Platform;
• b) Provision of the Service;
• c) Purposes connected to the requirements established by laws, regulations and EU legislation, as well as by any provisions issued by public bodies;
• d) Purposes of contract management, statistics;
• e) Provision of information relating to Company’s Service or information similar to those previously provided by the Company;
• f) Participation in users satisfaction surveys carried out through personal or telephone interviews and questionnaires.

The legal basis for processing is:

• a) User’s consent, for the activities referred to under purposes (a), (b), (c) and (f);
• b) The Company’s legitimate interest, for the activities referred to under purposes (d), and (e).

The data collection and processing shall be carried out through manual, computerized and telematics tools and with logic strictly related to the abovementioned purposes and, in any case, so as to guarantee the confidentiality and security of the data.

The Platform also does use third party services that may collect information used to identify the User. Link to privacy policy of third party service providers used by the app:

Luminara's use and transfer to any other app of information received from Google APIS will adhere to to Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy), including the Limited Use requirements.

• Google: https://www.google.com/policies/privacy/
• Apple: https://www.apple.com/legal/privacy/

3. Personal data collected

For a better experience, while using the Platform and benefiting from the Service, the Company will require the User to provide it with certain personal data, including: Name, Surname, Mobile phone number, Mail address, Calendar availability.

4. Data disclosure

The provision of the aforementioned personal data is optional. However, any refusal to provide such personal data for the purposes (a), (b), (c) of Section 2 shall make it impossible to make the Platform available, provide the User with the Service and fulfil the relevant legal obligations, if any.

Any refusal to provide the personal data for the purposes (d) and (e) of Section 2 shall lead to the impossibility to be informed about information from the Company.

5. Recipients of personal data

• a) Parties that carry out data processing as part of the provision of the Platform and the Service as accounting consultancy or other services, as it may be necessary for the fulfilment of the Company’s obligations and Service;
• b) Parties that carry out data archiving and data entry activities;
• c) Public authorities, in order to fulfil legal obligations;
• d) Company’s employees, collaborators or consultants.

6. Personal data retention period

Personal data collected for the purposes (a), (b), (c) of Section 2 are likely to be retained for the entire period of registration and use of the Platform. Subsequently, such data will be stored for a period not exceeding the statutory limitation period and for a further 1-year period as from the deletion of the User’s account.

Personal data collected for the purposes (d) and (e) of Section 2 are likely to be retained until the user objects to receive promotional communications, or the user requests the deletion of his/her personal data, without prejudice of any exceptional needs to retain the personal data to exercise or defend Company’s rights or upon request of any public authorities.

7. Transfer of personal data

User’s data shall be stored within the European Union. In the event that the Platform and/or the Service require so, User’s personal data may be transferred outside the European Union towards contractors of the Company. It is understood that any such transfers shall be carried out in compliance with the requirements and safeguards established by applicable law.

8. Users’ rights

The accuracy of personal data uploaded on the Platform is the sole responsibility of the User.

The User has the necessary technical tools on the Platform to change, update or delete any information that concerns him/her.

The User has the right to access, rectify, delete, request the portability of his/her personal data and restrict the processing of such data. Users have also the right to object to the processing of his/her personal data and to contact the Company to define instructions for the processing of his/her personal data after his/her death.

Users may lodge a complaint with the competent authority for the protection of personal data.

In order to exercise these rights, the User must write to the data controller at the following postal and/or email addresses stating the purpose of his/her request and his/her contact details.

9. Log Data

Company wants to inform that whenever the User uses the Platform and benefits from the Service, in a case of an error in the Platform, the Company collects data and information (through third party products) on the User’s phone called log data. This log data may include information such as the User’s device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the Platform when utilizing the Service, the time and date of use of the Platform and benefit from the Service, and other statistics.

10. Cookies

Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to User’s browser from the websites that the User visits and they are stored on User’s device's internal memory.

The Company places cookies on the User’s device in order for the Platform to function properly, including detecting problems in the Platform’s functionality and making improvements based on how the Platform is used. If the User has set his/her device to automatically deny the use of these cookies the Platform will not function as intended.

• Example 1: Purpose & description - to technically make the Platform work the Company places cookies on the User’s device. Storage period: persistent cookies stored on User’s device for as long as the User has the Platform.
• Example 2: Purpose & description - to detect problems in the Platform’s functionality in order to make improvements the Company places cookies on the User’s device. Storage period: persistent cookies stored on User’s device for as long as the User has the Platform.
• Example 3: Purpose & description - to analyse how the User uses the Platform the Company places cookies from Google Analytics on the User’s device. More information on how Google uses cookies can be found on Google’s own website.

If the User consents to the Company doing so, the latter will also use cookies to analyse in what way the User is using the Platform.

11. Security

The Company values User’s trust in providing it its Personal Information, thus we are striving to use commercially acceptable means of protecting it. However, no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and absolute security cannot be guaranteed.

12. Links to other Sites

This Service may contain links to other sites. If the User clicks on a third-party link, he/she will be directed to that site. Note that the Company does not operate these external sites. Therefore, we strongly advise you to review the privacy policy of these websites. The Company has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services.

13. Children’s privacy

The Service does not address anyone under the age of 13. The Company does not knowingly collect personally identifiable information from children under 13. If the Company discovers that a child under 13 has provided it with personal data, the Company immediately deletes this from its servers. If you are a parent or guardian and you are aware that your child has provided the Company with personal data, please contact the Company so that necessary actions can be taken.

Changes to this privacy policy

The Company may update its privacy policy from time to time. Thus, you are advised to review this page periodically for any changes. The Company will notify the User of any changes by posting the new privacy policy on this page and notifying the User by a pop-up on the Platform from the User's first connection to the Platform after the entry into force of the new version of the privacy policy.

This policy is effective as of 2024-01-01.

Contact Us

If you have any questions or suggestions about this privacy policy, please contact the Company at contact@luminara.care.