Privacy Policy

Effective November 8, 2024.

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Fujitsu Launchpad Limited (“Launchpad” or “we”) established this privacy policy (the “Policy”) to set forth guidelines regarding how we collect, handle, and manage Personal Data collected by us when you use the Lumi app (“Lumi App”), the Lumi website, and the services provided through the app or the website (the “Lumi Service” and, together with the Lumi App “Lumi”). Please also read our Terms of Service and the Lumi Service-Specific Terms (together, the “Terms”) which set out the terms governing Lumi.

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All Personal Data of our users (a “User,” “you” or “Data Subject”) shall be handled in the manner set out in this Policy. We only collect information where it is necessary for us to do so and we will only collect information if it is relevant in our dealings with our Users. We will only keep your Personal Data for as long as we are either required by law or as is relevant for the purposes for which the information was collected.

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The scope of this Privacy Policy is limited to information collected or received by us through your use of Lumi. We are not responsible for the actions of third parties or companies, the contents of their facilities, the use of information you provide to them, the information they provide to you, or any products or services they may offer. Links to third-party sites do not constitute our partnership with, sponsorship or endorsement of, or affiliation with, those parties or companies or their brands.

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Personal Data

In this policy, “Personal Data” refers to any information whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained by the entity holding the information, or when put together with other information would directly and certainly identify an individual, including the name, date of birth, address, telephone number and contact information of an individual, and any other description or information that can be used to identify a specific individual, such as the appearance and voice of an individual or other types of personal identification information. To the extent applicable, Personal Data shall also include “Personal Data” as defined in the Act on the Protection of Personal Data of Japan (the “APPI”), and Personal Data and Sensitive Personal Data as defined under the Philippine Data Privacy Act of 2012 (the “DPA”).

When We Collect Personal Data

We collect information about Users when:

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• a User creates or registers an account.
• a User updates his/her profile and other data submitted in Lumi.
• a User makes a request, call, or inquiry about a product, service, or in any manner contacts Launchpad or its customer support team.
• a User submits documentation or information.
• a User uses Lumi and any features that may be made available in the future.
• a User provides comments, suggestions, or feedback to Lumi about its products and/or services.
• a User participates in our marketing activities.

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What Personal Data We Collect

Below are the general categories of Personal Data we collect from Users:

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• Account Information - Basic account information and Personal Data such as your name, date of birth, address, telephone number, and email address. 
• User Usage Behavior or Profiling - User behavior available and/or accessible in the medium of access (i.e., mobile device, web browser, desktop) including but not limited to traffic, usage, device, location, GPS, gallery, device ID, application usage and history, connectivity and other information generated, collected, stored or found in the User’s device (i.e., mobile device), access medium, a portal, or any other medium of access.
• User Feedback – Your opinions and views regarding Lumi.
• Access Information - When you use the Lumi App, we may collect and record certain information such as your unique device ID (persistent/non-persistent), the hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the version of your operating system (“OS”), your device name, your email address, and your location based on your Internet Protocol (“IP”) address. This information is useful to us for troubleshooting and helps us to understand usage trends.
• Analytics Tools Data - Lumi may contain third-party tracking tools from our service providers (i.e., Google Analytics). Such third parties may use cookies, application programming interfaces, and software development kits in Lumi to enable them to collect and analyze user information on our behalf. The third parties may have access to information such as your device identifier, MAC address, IMEI, locale (specific location where a given language is spoken), geo-location information, and IP address.
• Browsing Behavior - Information collected using cookies, web beacons, web crawlers, flash cookies, general log information, mobile and browser information (in each case in accordance with your permission settings in the Lumi App and in such devices), your browsing behavior, searches, transactions, and referral information,
• Customer Support Information – Information to receive and respond to your requests, inquiries, and concerns.
• Marketing and Survey Information – Information collected as part of marketing activities.
• Legal Compliance – Information as may be required by any applicable law or regulation.

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Why We Collect Personal Data

We collect and use Personal Data for the following purposes (the “Purposes”). We may use your Personal Data in combination with your account data or other information such as your usage data, usage history, or other similar data to fulfill the Purposes listed below:

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• To identify Users.
• To provide or improve the Lumi Service.
• To manage and perform analysis of the usage of the Lumi Service.
• To handle inquiries and requests.
• To investigate any unauthorized access to or misuse of Lumi or breach of our Terms.
• To Users when necessary to provide updates, important notices, etc.
• All other purposes incidental to the purposes listed above.

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Sharing Your Information

We will not share your Personal Data with third parties without your prior consent unless we are permitted or required by applicable laws. 

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In accordance with the applicable law, in order to run our business, provide the Lumi Service, and fulfill any of the Purposes listed above, we may retain a third party to handle all or part of the processing of your Personal Data. If we retain a third party to process your Personal Data, we may share your Personal Data to the extent that it is necessary for the processing of your Personal Data and we will supervise the third-party processor to ensure that your Personal Data is processed in a manner that is compliant with applicable laws. The third party handling your Personal Data will not be allowed to use the Personal Data it receives for any other purpose except as directed by us. Here are the situations where we may share your Personal Data:

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• We may share information with third parties who provide services that we use to support, improve, promote, or secure Lumi, including cloud storage, payment processing, and content management. The service providers will only have access to the Personal Data necessary to perform their limited functions on our behalf and they are required to protect your information.
• We may share information, including with law enforcement, public or governmental agencies, or private litigants, within or outside of your country of residence, if we are required to do so by law. This may include situations where we are asked to respond to court orders, warrants, subpoenas, or other legal or regulatory requirements.
• We may share information if it is reasonably necessary to protect the life, body, or property of Launchpad, Fujitsu Limited and its subsidiaries and affiliates (the “Shared Parties”), our Users, or a third party, and it is difficult to obtain your consent. 

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Additionally, in accordance with our Terms, we may share information as necessary to enable us to provide the Lumi Service or to address important matters:

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• We may share information to address any issues of national security or of public importance, to prevent or detect fraud, security or technical issues, or violations of our Terms, or to address any abuse of the Lumi Service or our Users.
• We may share information with our legal counsel and other consultants or third parties to protect our business operations or our legal rights. 

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To the extent permitted by applicable law in your jurisdiction, we may also share Personal Data collected from you with our Shared Parties and the Shared Parties may use your Personal Data for the Purposes set forth in this Policy, or so that the Shared Parties may provide their services to you or improve their services. Depending on the purpose, we may share basic information such as your name, address, telephone number, and e-mail address, or non-personally identifiable information and aggregated data. We will be responsible for the management and control of any Personal Data to be shared with the Shared Parties and you should contact us if you would like to know more about how your information may be used by the Shared Parties.

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Additionally, we may share non-personally identifiable information publicly or with our business partners (such as publishers, advertisers, or developers) to help support, improve, promote, or secure the Lumi Service.

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Data Privacy Information Rights

Users have the following rights regarding Personal Data:

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• Right to Request Special Privacy Protections. You have the right to request restrictions on certain uses and disclosures of your Personal Data by a written request specifying what information you want to limit, and what limitations on our use or disclosure of that information you wish to have imposed. If you tell us not to disclose information, we will abide by your request, unless we must disclose the information for legal reasons. We reserve the right to accept or reject any other request and will notify you of our decision.
• Right to Inspect and Copy. You have the right to inspect and copy your Personal Data, with limited exceptions. To access your Personal Data, you must submit a written request detailing what information you want access to, whether you want to inspect it or get a copy of it, and if you want a copy, your preferred form and format. We will provide copies in your requested form and format if it is readily producible, or we will provide you with an alternative format you find acceptable, or if we cannot agree and we maintain the record in an electronic format, your choice of a readable electronic or hard copy format. We will also send a copy to any other person you designate in writing. We will charge a reasonable fee that covers our costs for labor, supplies, postage, and if requested and agreed to in advance, the cost of preparing an explanation or summary. We may deny your request under limited circumstances. If we deny your request to access your personal records or the personal records of an individual you are representing because we believe allowing access would be reasonably likely to cause substantial harm to the Data Subject, you will have a right to appeal our decision.
• Right to Request Confidential Communications. You have the right to request that you receive your Personal Data in a specific way or at a specific location. You may ask that we send information to a particular e-mail account or your work address. We will comply with all reasonable requests submitted in writing which specify how or where you wish to receive these communications.
• Right to Amend or Supplement. You have a right to request that we amend your Personal Data that you believe is incorrect or incomplete. You must make a request to amend in writing and include the reasons you believe the information is inaccurate or incomplete. We may deny your request if we do not have the information, if we did not create the information, if you would not be permitted to inspect or copy the information at issue, or if the information is accurate and complete as is. All information related to any request to amend will be maintained and disclosed in conjunction with any subsequent disclosure of the disputed information.
• Right to Revoke Authorization. Your consent is necessary before we can lawfully collect and process your Personal Data. You may revoke (take back) your consent at any time. For the avoidance of doubt, this does not invalidate any previous processing that we have performed in accordance with your consent originally given.
• Right to Erasure or Blocking. You have the right to suspend, withdraw, or order the blocking, removal, or destruction of your Personal Data. You can exercise this right upon discovery and substantial proof of any of the following:

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• Your Personal Data is incomplete, outdated, false, or unlawfully obtained.
• Your Personal Data is being used for purposes you did not authorize.
• The data is no longer necessary for the purposes for which they were collected.
• You decided to withdraw consent, or you object to the processing and there is no overriding legal ground for processing.
• The data concerns information prejudicial to you — unless justified by freedom of speech, of expression, or of the press; or otherwise authorized by law.
• The processing is unlawful.
• We or our third-party processor(s) have violated your rights.

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• Right to Be Notified of a Breach. You have the right to receive notifications of breaches of your Personal Data, as may be required by law. Aside from protecting you against unfair means of Personal Data collection, this right also requires that we notify you in a timely manner if your Personal Data has been compromised. If you have provided us with a current e-mail address, we may use e-mail to communicate information related to the breach.
• Right to a Paper or Electronic Copy of this Policy. You have a right to be notified of our legal duties and privacy practices with respect to your Personal Data, including a right to an electronic copy of this Policy, even if you have previously requested its receipt by e-mail.

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If you would like to exercise one or more of these rights, please contact our data privacy team at [email protected].

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Our Retention Period

We will retain your Personal Data only for the period necessary to carry out the Purposes set forth in this Policy subject to any internal or legal obligations to retain your Personal Data for further periods. 

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Data Security

We have implemented technical, physical, and organizational measures and controls to safeguard and protect the transmission and storage of the information we collect. We employ reasonable protections for your Personal Data that are appropriate to its sensitivity. While we endeavor to use reasonable security measures to protect against unauthorized access to your Personal Data under our control and strive to prevent any leak or loss of, or damage to, Personal Data, we cannot guarantee absolute security to the Personal Data you provide or that our security measure will prevent unauthorized or illegal access to your Personal Data. If any leakage of Personal Data or other security incident occurs, we will notify you and take necessary actions in accordance with the procedures set forth under the relevant laws and regulations.

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Changes to this Policy

We may update this Policy at any time and for any reason in our sole discretion. Any time we make changes to this Policy, we will provide you with reasonable advance notice of the revisions before the effective date of the amended Policy. The amended Policy will be posted on the Lumi website and in the Lumi App and will become effective on the effective date. 

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Contact Information

If you have any questions regarding this Policy, please contact the Fujitsu Launchpad data privacy team at [email protected].