Lumens, Inc. Privacy Policy

Last updated: September, 2025

Lumens, Inc, its brands, affiliates, and subsidiaries (“Lumens,” “we,” “our,” or “us”) values your privacy. This Privacy Policy (“Policy”) describes how Lumens collects, uses, discloses, and otherwise processes personal information described in this Policy, as well as the rights and choices individuals have regarding such personal information.

For additional information about the privacy choices you have regarding your personal information, please review Section 6. Your Privacy Choices. If you are a resident of California, please refer to Section 12. Additional Information for California Residents for information about the categories of personal information we collect and your rights under California privacy laws.

By using our Services (as defined below), you agree that your personal information will be handled as described in this Policy. Your use of our Services and any dispute over privacy, is subject to this Policy and our Terms and Conditions, available at www.lumens.com/customer-service/terms-and-conditions.html, including their applicable terms governing limitations on damages and the resolution of disputes.

Table of Contents

1. Scope
2. Personal Information We Collect
3. Purposes for Collection and Processing
4. Disclosures of Personal Information
5. Cookies, Targeting, and Analytics
6. Your Privacy Choices
7. External Links and Features
8. User Generated Content
9. Security
10. Children’s Privacy
11. Data Retention and Localization
12. U.S. State Privacy Rights (California Privacy Rights)
13. U.S. State Privacy Rights (General)
14. Canada Privacy Rights
15. Changes to this Policy
16. Contact Us

1. Scope

Except as otherwise described below, this Policy applies to the personal information Lumens collects and processes related to: visitors of our website where this Policy is posted, including www.lumens.com (the “Site”); individuals who sign up for, or create an account with us to access and use certain features of our services; individuals who register for or participate in our events, surveys, research, promotions, and sweepstakes conducted by us; individuals who subscribe to receive news, information, and marketing communications and materials from us; current, former, and prospective business partners, and vendors and service providers; and individuals who communicate or otherwise interact or engage with us or the services available through our Site or other online services (collectively referred to as the “Services”).

For purposes of this Policy, the term “personal information” means any information that, alone or in conjunction with other information or data, identifies or is linked to a particular individual or household and that is subject to, or otherwise afforded protection under, a data protection law, statute, or regulation. The term “personal information” does not include anonymized or de-identified data that is not attributable to a particular individual or household and that is not otherwise subject to a data protection law, statute, or regulation. Lumens may anonymize or de-identify personal information, and such data is not subject to this Policy, and Lumens may use such data for any purpose.

Additional Notices. In some cases, we may provide you with additional or supplemental privacy notices with additional details about our privacy practices. These additional notices will control to the extent there is a conflict with this Policy, with respect to your personal information that is subject to that additional notice. For example, this Policy does not apply to the personal information that we collect and process about job applicants and candidates for employment with us, or to employees or contractors in the context of our working relationship with them.

2. Personal Information We Collect

As further described below, we may collect personal information directly from you, from third-party sources, and automatically through your use of our Services.

Personal Information Collected Directly from You. While the personal information we collect varies depending upon your use of our Services and our interactions with you, in general, we may collect the following personal information directly from you:

• Contact Information. When you contact us, including if you send us a message or sign up to learn more about our Services, we may collect your name, email address, phone number, or other similar identifiers, as well as your message, the nature of your inquiry, and any other information you so choose to provide.
• Account and Profile Information. When you sign in or create a Lumens account in connection with our Services, we may collect your first and last name, email address, username and password, as well as any other information used in connection with accessing your account or that you otherwise submit to us through your account.
• Purchases, Payments, and Rewards. When you make a purchase or payment through our Services, we may collect information such as payment type, payment card details, billing, shipping address, purchasing information, such as details of SKUs and products purchased, and any other financial or commercial-related information necessary for facilitating our Services.
• Communications and Interactions. When you email, call, or otherwise communicate or interact with us or with other Lumens users, including if you sign up for our mailing lists, complete forms on our website, interact with our social media pages, post a product review or testimonial, submit content in any online discussion groups, or otherwise enter information into public-facing comment fields, blogs, or community forums sponsored by or affiliated with Lumens, we may collect and maintain records of your contact details, communications and interactions, your posts or submissions, and our responses, if applicable. We may also collect any information you submit through our chat functions and/or virtual assistants we make available through the Services, and we may also maintain communication records regarding information provided to us related to any customer support requests.
• Promotional Information. If you agree to receive marketing communications from us, we may collect your name, email address, phone number, preferences, and if relevant, information about your account and profile, including the Services and features you use. If you participate in special activities, offers, programs, promotions or sweepstakes we offer, we may also collect certain contact details, your age, and any other information that may be required by law. If you win a contest, promotion, or sweepstakes, we may also collect certain tax information and/or waivers and releases, depending on the prize and as required by applicable law.
• Responses and Feedback. If you participate in surveys, questionnaires, or research activities or initiatives conducted by us, such as for market research, user satisfaction, or other similar purposes, we may collect your responses and feedback, and any other information you choose to provide.
• Events and Registration Details. We also may collect personal information related to your participation in our events, as well as other requests that you submit to us related to our Services. For example, if you register for or attend an event that we host or sponsor, we may collect information related to your registration for and participation in such event.
• Professional Information. If you sign up to join the Lumens Affiliate Program or the Lumens Trade Program, we may collect certain contact details, account and profile information, company or professional-related information, and other similar information related to your registration for, or participation in, these programs.
• Preferences and Other Requests. We also may collect information about your preferences, including communications preferences, preferences related to your use of our Services, and any other preferences or requests you provide when interacting with us.
• Business Development Information. To assess and pursue potential business opportunities, we may collect and receive personal information about current, former, and prospective business partners, and vendors and service providers, including contact information and other similar identifiers, company and professional-related information, and communications records.

By providing your contact information to us, you acknowledge and agree that we may use automated dialing systems and pre-recorded or artificial voice messages, to contact you at the telephone numbers and email addresses you provide for any of the purposes described above. You may opt out of receiving such communications at any time by following the instructions provided in the communication or by contacting us at [email protected].

Personal Information Collected from Third Parties. We may also collect and receive certain personal information about you from third party sources, such as from business partners, customers and other Lumens users, data analytics and marketing providers, operating systems and social media platforms, public databases, and vendors and service providers who provide services or perform functions on our behalf. For example, we may collect your name, contact details, and other similar information from business partners and vendors and service providers for purposes of facilitating shipments and providing our Services. In addition, we may collect the following information from third-party sources:

• Social Media Information. If you choose to tag Lumens in your social media posts, we may collect personal information about you to communicate with you. For example, we may collect information related to your account and profile, such as your name, and email.
• Lead and Prospect Information. We may receive lead and prospect information from third parties about prospective customers that may be interested in our Services. We may also engage with third parties to enhance or update our customer information. For example, we may receive certain personal information about you from data analytics and marketing providers for marketing and advertising purposes, and for purposes of reaching new customers.
• Referral Information. We may offer you the ability to invite friends or refer other users to access or use our Services. In doing so, we may collect and receive certain personal information about you, including from other current or prospective Lumens customers who similarly engage in these activities.
• Integrated Service Information. We may make available the ability for you to access, register for, place orders, or otherwise interact, engage, or connect with the Services through certain third-party features or integrated services. By accessing our Services via these third-party connections or integrated services, such as your PayPal account credentials, we may collect or obtain certain personal information about you related to your use of such third-party connections or integrated services. You should check your privacy settings on each integrated service to better understand how your personal information may be used, disclosed, or otherwise processed by these parties.

Personal Information Collected Automatically. In addition, we may automatically collect or derive personal information about you related to your use of our Services, including through the use of cookies, pixel tags, and other similar technologies. The personal information we may automatically collect includes:

• Device and Browsing Information. When you use our Services, we may collect browser type, domain name, page views, access times, date/time stamps, operating system, language, device type, unique ID, Internet service provider, referring and exiting URLs, clickstream data, and other similar device and browsing information.
• Activities and Usage. We also may collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, time spent within the Services, your interactions with us within the Services, and other similar activity and usage information.
• Location Information. We also may collect or derive general location information about you, such as through your IP address.

For more information about our use of cookies and other similar technologies, please see Section 5. Cookies, Targeting, and Analytics below.

3. Purposes for Collection and Processing

Generally, we may collect, use, disclose and otherwise process the personal information we collect for the following purposes:

• Services and Support. To provide and operate our Services, manage your account, communicate with you about your use of the Services, provide troubleshooting, technical support, or for similar support purposes, and to respond to your inquiries, fulfill your requests, facilitate payment processing, and to otherwise run our day-to-day operations.
• Analytics and Improvement. To better understand how users access and use the Services, and for other research and analytical purposes, such as to evaluate and improve the Site, our Services, and business operations, including to develop our Services and its features, and for internal quality control and training purposes.
• Communication. To respond to your questions, send you requested materials and newsletters, as well as information and materials regarding our Services and offerings. We may also use this information to send administrative information to you, for example, information regarding the Services and changes to our terms, conditions, and policies.
• Administer Our Programs. To administer and operate the programs we offer, which may include, but not be limited to, the Lumens Affiliate Program, and Lumens Trade.
• Customization and Personalization. To tailor content we may send or display on the Services, including to offer location customization and to otherwise personalize your experiences and offerings.
• Marketing and Advertising. For marketing, advertising, and promotional purposes. For example, we may send you promotional information about our Services, including information about Lumens events, webinars, presentations, sales, deals, discounts, and new offerings, as well as any other information that you sign up to receive.
• Research and Surveys. To administer surveys and questionnaires, such as for market research or user satisfaction purposes.
• Insight Development and Data Enhancement. We may combine personal information collected through the Services with other information that we or third parties collect about you in other contexts. In most cases, the information that we may combine with the personal information collected through the Services for market research, such as demographic information, does not directly identify consumers.
• Planning and Managing Events. For event planning and other management-related purposes, such as event registration and attendance, connecting you with other event attendees and Lumens users, and contacting you about relevant events, presentations, and our Services. We may also use personal information for purposes of facilitating special events, sweepstakes, contests, and promotions, which may have their own specific rules to participate.
• Security and Protection of Rights. To protect the Services and our business operations, our rights and those of our stakeholders and investors, to prevent and detect fraud, unauthorized activities and access, and other misuse of our Site, including where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms and Conditions.
• Compliance and Legal Process. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, to respond to a subpoena, warrant, court order, or other legal process, in connection with disputes or litigation, or in connection with an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
• Auditing, Reporting, and Other Internal Operations. To conduct financial, tax and accounting audits, audits and assessments of our operations, including our privacy, security and financial controls, as well as for risk and compliance purposes. We may also use personal information to maintain appropriate business records and enforce our policies and procedures.
• General Business and Operational Support. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.

4. Disclosures of Personal Information

We may disclose the personal information we collect for the purposes described above, to provide you our Services, to respond to and fulfill your requests, as otherwise directed or consented to by you, and with the following recipients:

• Affiliates and Subsidiaries. We may disclose the personal information we collect to our corporate affiliates and subsidiaries.
• Business Partners. In some circumstances, Lumens may partner with other businesses to offer its Services, including to facilitate certain programs or special offerings, and we may disclose personal information to those business partners. In addition, we may disclose your personal information to retailers or manufacturers for warranty or recall purposes.
• Vendors and Services Providers. We may disclose the personal information we collect to vendors and service providers who perform functions on our behalf, such as IT and website hosting, payment processors, product shipment and order fulfillment facilitators, marketing and marketing research providers, customer support, data storage, data analytics providers, auditors, consultants and legal counsel.
• Other Lumens Users. With other users of the Services in the context of specific features that are social in nature. For example, if you invite others to use our Services, or if you submit or make available information through our public-facing, interactive features, community forums, or discussion blogs, including when you post reviews or testimonials, certain personal information, may be available to, and searchable by, other users of the Services.
• Third Party Marketing and Analytics Providers. We may also disclose your personal information, such as device and browsing, and activities and usage information, to third party marketing and data analytics providers, and other companies who provide marketing, advertising, campaign management, or analytics services on our behalf.

We may also disclose your personal information in the following circumstances:

• In Support of Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the personal information we have collected from you with or to the other company in accordance with applicable laws. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transaction such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
• Compliance and Legal Obligations. We may also disclose personal information to third parties to the extent required by applicable law and legal obligations. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators, government entities, and law enforcement, including responding to national security or law enforcement disclosure requirements, or as otherwise required by law or legal process. In addition, we may disclose the names of sweepstakes and contests winners in accordance with applicable law.   
• Security and Protection of Rights. Where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property, and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and take action in response to violations of our Terms and Conditions. We may also disclose personal information related to litigation or disputes and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
• Other Disclosures. We may disclose personal information in other ways not described above that we notify you of or that we obtain your consent for, or that are otherwise authorized or required by law.

Aggregate and/or Deidentified Data. Notwithstanding anything else described in this Policy, we may use and disclose aggregate, deidentified, and other non-identifiable data related to our business and the Services for quality control, analytics, research, development and other purposes. Where we use, disclose or process deidentified data (data that is no longer reasonably linked or linkable to an identified or identifiable natural person, household, or personal or household device) we will maintain and use the information in deidentified form and not to attempt to reidentify the information, except in order to determine whether our deidentification processes are reasonable and adequate pursuant to applicable privacy laws.

5. Cookies, Targeting, and Analytics

We and our third-party providers and service providers use cookies, pixels, local storage objects, log files, and other mechanisms to automatically collect browsing, activity, device and similar information within our Services. We use this information to, for example, analyze and understand how users access, use, and interact with our Services, to identify and resolve bugs and errors in our Services, to assess secure, protect, optimize and improve the performance of our Services, as well as for marketing and analytics purposes, and to personalize content in our Services. To manage your preferences regarding cookies, targeted advertising, and other similar tracking mechanisms within our Services, please see Section 6. Your Privacy Choices below.

Cookies. “Cookies” are a small text file stored on a user's device (such as a computer or smartphone) by a website they visit. It is created by the website's server and sent to the user's browser, where it is stored for future reference. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track aggregate and statistical information about user activity within the Services.

Pixel Tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, and help us manage content and compile usage statistics. We may also use these in our emails to let us know when they have been opened or forwarded, so we can track response rates and gauge the effectiveness of our communications.

Third Party Analytics. We may use automated devices, applications, and tools, such as Google Analytics, which are operated by third party companies, to evaluate usage of our Services. These third-party companies may use cookies, pixels, and other tracking technologies to collect usage data about our Services and provide us with reports and metrics that help us evaluate usage of our Services and enhance performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.

Third-Party Advertising. We work with third-party ad networks, analytics, marketing partners, and others (“third-party ad companies”) to personalize content and display advertising within our Services, as well as to manage our advertising on third-party sites. We and these third-party ad companies may use cookies, pixels tags, and other tools to collect browsing and activity information within our Services (as well as on third-party sites and services), as well as IP address, unique ID, cookie and advertising IDs, and other online identifiers. We and these third-party ad companies use this information to provide you more relevant ads and content within our Services and on third-party sites, and to evaluate the success of such ads and content.

Cross-Device Use. We and our third-party service providers may use the information we collect about you (whether directly from our Site, through your device(s), or from third party sources) to help us and our third-party service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We and our third-party service providers may also use the information we learn about you to serve targeted advertising or personalize content within our Services. To opt-out of cross-device advertising, you may follow the instructions set forth below. Please note, if you opt-out of these targeted advertising cookies, the opt-out will be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt-out each browser or device that you use.

Custom Lists and Matching. We may share or make available certain customer list information (such as your name, email address and other contact information) with third parties (i) so that we can better target ads and content to you across third party sites, platforms and services, and (ii) in some cases, these third parties may help us to enhance our customer lists with additional demographic or other information, so we can better target our advertising and marketing campaigns. 

6. Your Privacy Choices

Managing Your Preferences. We make available several ways for you to manage your preferences and privacy choices, as described below:

• Your Lumens Account. You can review and update some of the personal information we maintain about you by logging into your Lumens account and updating your account and profile information.
• Marketing Communications. We may send periodic promotional emails or other similar communications to you. You may opt-out of these communications by following the instructions provided to you in the communication, and you can opt out of receiving marketing and other texts from us by replying STOP to any text we send to you. If you opt-out of receiving promotional content from us, we may still send you communications about your account or any services you have requested or received from us. Additionally, you can manage your communication preferences at https://www.lumens.com/customer-service/subscribe-unsubscribe.html.

Cookie Preferences/Targeted Advertising. We also make available several ways for you to manage your preferences regarding cookies, targeted advertising, and other similar tracking mechanisms within our Services. Many of these choices are browser and device specific, which means that you may need to set the preference for each browser and device you use to access our Services. In addition, if you delete or block cookies, you may need to reapply these preferences to each browser and/or device. Further, opting out of cookies and advertising does not mean that you will no longer receive advertising content from us, and you may continue to receive generic or “contextual” ads from us.

• Cookie Settings. To prevent cookies from tracking your activity on our Site or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set. You can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Site who disable cookies will be able to browse the Site, but some features may not function.
• Cookie Preferences. You can review or change your preferences for many cookies on our Site, other than those that are necessary, by adjusting your cookie settings through our cookie manager. Manage Cookie Preferences, accessible via the footer of our website.
• Browser Signals. To the extent required by applicable law, if our Site detects that your browser is transmitting an opt-out preference signal, such as a “global privacy control” (or GPC) signal, we will apply that signal to opt that particular browser on your device out of targeting cookies on our Site. If you come to our Site from a different device or from a different browser on the same device, you will need to apply GPC for that browser and/or device as well.
• Industry Ad Choice Programs. You can also control how participating third-party ad companies use the information that they collect about your visits to our Site and those of third parties, in order to display more relevant targeted advertising to you. For more information, and to opt out of receiving targeted ads from participating third-party ad networks, go to:
  • U.S. Users: aboutads.info/choices (Digital Advertising Alliance). You may also download the DAA AppChoices tool in order to help control interest-based advertising on apps on your mobile device.
  • Canada Users: youradchoices.ca/choices/ (Digital Advertising Alliance of Canada).

Residents of certain jurisdictions may have additional rights to their personal information, as set forth below in Section 13. Additional Information for California Residents.

7. External Links and Features

Our Services may contain links to third-party websites or features or provide certain third-party connections or integrated services. Any access to and use of such linked websites, features, or third-party connections or integrated services is not governed by this Policy, but instead is governed by the privacy policies of those third parties. We are not responsible for the information practices of such third parties, including their collection, use, and disclosure of your personal information. You should review the privacy policies and terms for any third parties before proceeding to those websites or using those features or third-party connections or integrated services.

Social Media/ Platform Data Rights. We may engage with you on various social media platforms (e.g., Facebook, Twitter, Pinterest, Instagram). If you contact us on a social media platform for customer support or for other reasons, we may contact you via the social media's direct message tools. Those communications to and from us are governed by this Policy. However, your use of a social media platform is also subject to the policies and terms of the relevant social media platform. Certain social media platforms may also automatically provide us with your personal information, the information we receive will depend on the terms that govern your use of the social media platform(s) and any privacy settings you may have set. The Site includes social media features and widgets (e.g., the “Facebook Like” button, the “Share This” button) or interactive mini-programs that run on the Site. These features may collect your IP address and which Site page you are accessing and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the relevant social media platform that provides them.

According to the terms and conditions governing certain social media platforms, you may request that the information, data, or other content we obtain from or through the social media platform (“Platform Data”) be deleted or modified. If you would like Platform Data related to you deleted or modified, please contact us in accordance with the “Contact Us” section below and (i) identify the social media platform at issue and (ii) the Platform Data that you would like deleted and/or modified, and if modified, the modification to said Platform Data. We may also delete Platform Data if requested by the social media platform.

Video Links. We may include videos and similar media players on our Site. By clicking on such videos and similar media players on our Sites, (i) you may be redirected to a third party's website to play the video, or (2) it may play the video on our Site, although this functionality may be supported by a third party's website or technology (e.g., YouTube, YouTube API, Vimeo). In any such case, by playing the videos or similar media players, you shall become subject to the third party's terms and conditions, including, but not limited to, its terms of service and personal information privacy policies and practices, including the terms governing YouTube and Vimeo.

8. User Generated Content

We may offer public-facing interactive features, community forums, or discussion blogs in connection with our Services that enable you to share information about the Services, or other issues of interest (e.g., product reviews, testimonials, and questions). You should be aware that any communications you submit or post to any such interactive features on the Services may be viewable and searchable by others, including Lumens users and the public. By submitting or posting to such public-facing, interactive features you acknowledge that you have no expectation of privacy or confidentiality in the content you submit for such features, whether or not it contains personal information about you.

9. Security

We have implemented reasonable precautions aimed to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security. There are also certain steps you can take to better protect against unauthorized access to your personal information. For example, when registering for an account, you should choose a strong password that is unique to the Services. You should not reuse passwords across multiple websites or services, and you should never share your password with others.

10. Children’s Privacy

Our Services are not designed for children, and we do not knowingly collect personal information from children under the age of eighteen (18). If we learn that personal information has been collected on the Services from persons under the age of 16, then we will take the appropriate steps to delete this information. If you are a parent or legal guardian and you believe we have collected your child’s information in violation of applicable law, please contact us using the contact information below.

11. Data Retention and Localization

Lumens is based in the United States, and the personal information that we collect and process is retained and stored in the United States. Lumens uses service providers that store personal information on our behalf in the United States and in other countries where you may not be a resident. Please be aware that the United States, and these other countries, may not provide the same level of protection of personal information as in your country, state, or other jurisdiction of residence or nationality, and when transferred to the United States or elsewhere, your personal information may be accessible by, or otherwise made available to, local government authorities and officials pursuant to judicial and/or administrative orders, decrees, and demands, and/or other domestic laws, statutes, and regulations. Lumens does not participate in the U.S. Data Protection Framework. By continuing to provide us such information, you hereby acknowledge and agree that your personal information will be transferred to, and stored in, the United States and in the countries where our service providers are located.

12. Additional Information for California Residents

This section of the Policy provides additional information for California residents and describes our information practices pursuant to applicable California privacy laws, including the California Consumer Privacy Act, as amended (the “CCPA”). To the extent you are a California resident, and we collect “personal information” subject to the CCPA, the following applies. This section does not address or apply to our handling of publicly available information or personal information that is otherwise exempt under the CCPA.

Categories of Personal Information Collected and Disclosed. The following table identifies the categories of personal information we may collect about you (and may have collected in the prior 12 months), as defined by the CCPA, as well as the categories of third parties to whom we may disclose this information for a business or commercial purpose. Depending on how you use the Services, we may collect and disclose the following categories of personal information:

Categories of Personal Information	Third Party Disclosures for Business or Commercial Purposes
Identifiers. Includes direct identifiers such as name, alias, email, phone number, address, user ID or username, unique personal identifier, online identifier, IP address, or other similar identifiers.	Advisors and agents Affiliates and subsidiaries Regulators, government entities and law enforcement Other Lumens users Data analytics providers Others as required by law
Customer Records. Incudes information such as name, user ID or username, account name, contact information, and financial or payment information (i.e., payment type, payment card details, billing and shipping address).	Advisors and agents Affiliates and subsidiaries Regulators, government entities and law enforcement Data analytics providers Others as required by law
Commercial Information. Includes records of Services purchased, obtained, or considered, or other purchasing or use histories or tendencies.	Affiliates and subsidiaries Regulators, government entities and law enforcement Data analytics providers Others as required by law
Internet or Other Electronic Network Activity Information. Includes, but is not limited to, browsing history, clickstream data, search history, and information regarding interactions with our Site and the Services, advertisements, or emails, including other usage data related to your use of any of our Services or other similar online services.	Affiliates and subsidiaries Regulators, government entities and law enforcement Data analytics providers Advertising networks Others as required by law
Location Data. Such as general location information about a particular individual or device.	Affiliates and subsidiaries Regulators, government entities and law enforcement Data analytics providers Others as required by law
Audio, Electronic, Visual, or Similar Information. Includes, but is not limited to, information collected via call recordings if you are interacting with us in a customer service capacity or if you call us on a recorded line, recorded meetings and webinars, videos, photographs, and user profile images.	Affiliates and subsidiaries Regulators, government entities and law enforcement Others as required by law
Professional Information. Includes, but is not limited to, job title, company name, business email, business phone number, and other similar professional-related information.	Affiliates and subsidiaries Advisors and agents Regulators, government entities and law enforcement Others as required by law
Inferences. Such as inferences drawn from any of the information described in this section about a consumer including inferences reflecting the consumer’s preferences, characteristics, behaviors, attitudes, abilities, and aptitudes.	Affiliates and subsidiaries Regulators, government entities and law enforcement Data analytics providers Others as required by law
Protected Classifications. We may collect some information that is considered a protected classification under California or federal law, such as your gender, age, and date of birth.(Note: generally, this information is collected on a voluntary basis through our rewards programs and customer surveys.)	Affiliates and subsidiaries Regulators, government entities and law enforcement Others as required by law
Sensitive Personal Information. In some circumstances, If you win a contest, promotion, or sweepstakes, we may collect [certain government-issued identifiers, such as social security number or driver’s license number,] in accordance with applicable law.	Affiliates and subsidiaries Regulators, government entities and law enforcement Others as required by law

Sources of Personal Information. We generally collect personal information from the following categories of sources: directly or indirectly from you; affiliates and subsidiaries; business partners; vendors and service providers; other Lumens users; Internet service providers; operating systems and platforms; social media platforms; and marketing and data analytics providers.

Purposes of Collection, Use, and Disclosure. As described above in Section 3. How We Use Personal Information and Section 4. Disclosures of Personal Information, in general, we may collect, use, disclose, and otherwise process personal information for the following business or commercial purposes and as otherwise directed or consented to by you:

• Services and support;
• Analytics and improvement;
• Communicate with you;
• Customization and personalization;
• Marketing and advertising;
• Administer our programs;
• Research and surveys;
• Insight development and data enhancement;
• Planning and managing events;
• Security and protection of rights;
• Compliance and legal process;
• Auditing, reporting, and other internal operations; and
• General business and operational support.

Sensitive Personal Information. We do not collect, use, or disclose “sensitive personal information” beyond the purposes authorized by the CCPA. Accordingly, we only use and disclose sensitive personal information as reasonably necessary and proportionate: (i) to perform our services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; (v) for compliance with our legal obligations; (vi) to our service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you.

Retention. We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection. For example, we will retain your account information for as long as you have an active account with us and additional information as necessary to comply with our tax, accounting and recordkeeping obligations, to provide you with the services you have requested, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with our legal obligations. In some cases, rather than delete your personal information, we may deidentify or aggregate it and use it in compliance with the CCPA.

Sales and Sharing of Personal Information. The CCPA defines “sale” as disclosing or making available personal information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available personal information to a third-party for purposes of cross-context behavioral advertising. While we do not disclose personal information to third parties in exchange for monetary compensation, we may “sell” or “share” the following categories of personal information: identifiers, Internet and network activity information, and commercial information. We may disclose these categories to third-party advertising networks, analytics providers, and social networks for purposes of marketing and advertising and to improve and measure our ad campaigns. We do not sell or share sensitive personal information, nor do we sell or share personal information about individuals we know are under age sixteen (16).

California Privacy Rights. The CCPA provides California residents with specific rights regarding personal information. Subject to certain conditions and exceptions, California residents have the following rights with respect to their personal information:

• Right to Know. You have the right to request: (i) the categories or personal information we collected about you; (ii) the categories of sources from which the personal information is collected; (iii) our business or commercial purposes for collecting, selling, or sharing personal information; (iv) the categories of third parties to whom we have disclosed personal information; and (v) a copy of the specific pieces of personal information we have collected about you.
• Right to Delete. You have the right to request we delete personal information we have collected from you.
• Right to Correct. You have the right to request that we correct inaccuracies in your personal information.
• Right to Opt-Out of Sales and Sharing. You have the right to opt-out of “sales” and “sharing” of your personal information, as those terms are defined under the CCPA.
• Right to Limit Use of Sensitive Personal Information. You have the right to limit use and disclose of your sensitive personal information. We do not use or disclose sensitive personal information beyond the purposes authorized by the CCPA; thus, this right is not available to California residents.
• Right to Non-Discrimination. You have the right not to be subjected to discriminatory treatment for exercising any of the rights described in this section.

Submitting CCPA Requests. California residents may exercise their CCPA privacy rights as set forth below:

• Right to Know, Delete, and Correct. California residents may submit CCPA requests to access/know, delete, and correct their personal information by using our webform or calling 1-800-743-0959.

When you submit a request, we will take steps to verify your identity and request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your identity, or where necessary to process your request. If we are unable to verify your identity after a good faith attempt, we may deny the request and, if so, will explain the basis for the denial.

You may also designate someone as an authorized agent to submit requests and act on your behalf. Authorized agents will be required to provide proof of their authorization in their first communication with us, and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

Right to Opt-Out of Sales and Sharing. To exercise your right to opt-out of the “sale” or “sharing” of your personal information, you may submit an opt out request via our webform. We will apply your opt out based upon the personal information in our records that is linked or reasonably linkable to the information provided in your request. You can also opt-out of the “sale” or “sharing” of your personal information via our cookie preference manager by opting out of the collection of targeting cookies. You may also click the link at the bottom of our Site.

In addition, if we detect that your browser or device is transmitting an opt-out preference signal, such as the “global privacy control” or “GPC” signal, we will opt that browser or device out of cookies that result in a “sale” or “sharing” of your personal information. If you come to our Site or use our Services from a different device or from a different browser on the same device, you will need to opt-out, or use an opt-out preference signal, for that browser and/or device as well. More information about GPC is available at: https://globalprivacycontrol.org/.

Notice of Financial Incentive. With respect to some of our Services, Lumens may make available certain programs or offerings, and other sweepstakes, contests, or similar promotional offerings (each a “Program”) which may include certain offers, rewards, discounts, services, perks and promotions (“Rewards and Offers”). These Programs may be considered “financial incentives” under the CCPA. As described below, Lumens collects, discloses, and retains personal information about participating customers as part of these Programs.

• Our Programs. We may provide Programs, including sweepstakes, contests and other promotional offerings or incentives. For example, we may make available Rewards and Offers to customers that participate in one of our customer satisfaction or market research surveys or requests for feedback. To participate in such as Program, you must register and provide us with certain personal information, which may include identifiers (i.e., name, email, address, and other similar contact information), and any feedback or responses. Some of these Programs may be administered by third party partners who may collect or receive your personal information to administer the Program and provide related services to us.

We provide these Rewards and Offers to participating customers in order to understand and improve customer satisfaction and experiences, and to foster positive customer relationships. As a basis for offering these Rewards and Offers, we have valued the personal information we obtain based on a reasonable and good faith calculation determined by considering expenses related to the programs. In doing so, we value the personal information collected through the programs as the equivalent of the costs and expenses incurred to provide the program, including IT, administration, direct costs, third party costs, discounts, and service development costs.

Your personal information is collected and retained, and may be disclosed to Lumens’ business partners, vendors and service providers, and other third parties, as described in this Policy, including in order (i) to administer the Program, (ii) for research and analytics purposes, (iii) to improve our products and services, (iv) to better reach you with more relevant, targeted offers, and (v) to send you Lumens news, updates and offers by email, postal mail, and text message (in accordance with your communications preferences).

You may withdraw from participating in a Program at any time by contacting us at [email protected]. Please note that if you withdraw from a Program (or submit a CCPA request to delete your Program information), your participation in that Program will be terminated, which means that you will no longer be eligible to earn, use, access or redeem any Program Rewards and Offers, subject to the applicable Program terms.

Complaints. You may file a complaint about our data processing activities with The California Privacy Protection Agency.

13. U.S. State Privacy Rights (General)

Data Privacy Rights. Pursuant to certain other U.S. state privacy laws (including as of August 31, 2025: Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, Virginia), you may have the following privacy rights with respect to your personal information:

• To confirm whether or not we are processing your personal information and access such personal information.
• To correct inaccuracies in your personal information, taking into account the nature of the personal information and the purposes of the processing of your personal information.
• To delete personal information provided by, or obtained about, you.
• To obtain a copy of your personal information processed by us, in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.

Submit a Privacy Request. If you make any request related to your personal information, Lumens will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, Lumens will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions.

Submit a Privacy Request. If you make any request related to your personal information, Lumens will ascertain your identity (and the identity of the authorized agent, to the extent applicable) to the degree of certainty required or permitted under the law before addressing your request. In particular, before granting you access to, erasing, or correcting, specific pieces or categories of personal information or otherwise responding to your request, Lumens will, to the extent required or permitted by law, (i) require you (or your authorized agent) to verify your request via email, (ii) request certain contact information or government identifiers, and (iii) match at least two pieces of such personal information with data that we have previously collected from you. None of your privacy rights are absolute, and such rights are subject to exceptions and exemptions.

Privacy Requests Appeals Process. If you would like to appeal a decision Lumens has made with respect to your privacy request, please email us at [email protected], with the subject line “ATTN: Privacy Appeals,” and describe the nature of your request, and the reason for requesting an appellate review.

Opt-Out Rights / The Sale of Personal Information. You may have the right to opt out of the “sale” of your personal information. Nevada residents may submit a request directing us to not sell personal information we maintain about them to third parties who will sell or license their personal information to others. If you would like to exercise this right, please contact us by (email) [email protected], (phone) 1-800-743-0959 or by using our webform.

Opt-Out Rights / Profiling. you may have the right to opt out of having their personal information used for profiling in furtherance of decisions that produce legal or similarly significant effects. However, Lumens does not engage in such activities.

Complaints. You may file a complaint about our data processing activities with your local authorities, which may include the following:

• The Connecticut Attorney General
• The Delaware Attorney General
• The Iowa Attorney General
• The Minnesota Attorney General
• The Montana Attorney General
• The Nebraska Attorney General
• The Nevada Attorney General
• The New Hampshire Attorney General
• The New Jersey Division of Consumer Affairs
• The Oregon Attorney General
• The Tennessee Attorney General
• The Texas Attorney General
• The Virginia Attorney General
• Utah Division of Consumer Protection

Opt-Out Rights / Targeted Advertising. You may have the right to opt out of having your personal information used for targeted advertising purposes. Lumens uses third-party analytical and targeted advertising features on our Site and similar web tools provided by our marketing partners. To opt out of this sharing of your personal information in these circumstances, please click on the cookie management tool (sometimes visible as a “Your Privacy Choices” link or a “Manage Cookie Preferences”) on the footer of the Site to set your cookie preferences.

14. Canada Privacy Rights

Personal data (as the term is defined in the Personal Data Protection and Electronic Documents Act of Canada (“PIPEDA”)) will be collected, stored, used and/or processed by Company in accordance with this Privacy Policy and Company's obligations under PIPEDA and other applicable Canadian provincial laws. Pursuant to these Canadian laws, you have a right to request access to your personal information and to request that inaccurate personal information be corrected. If you have submitted personal information to us and would like to have access to it, or have it corrected, please contact us in accordance with the “Contact Us” section listed below. When requesting access to, or correction of, your personal information, we will require that you verify our request via email, and we will request specific data from you to enable us to confirm the authenticity of the request and your identity, and to enable us to search our records and databases. We may charge you a fee to access your personal information, provided that we advise you of any such fee in advance. Your right to access personal information is not absolute, and we may not be able to allow you to access certain personal information in certain circumstances (e.g., if the information contains personal information of other persons or it is subject to legal privilege). In the event that we cannot provide you with access to, or the ability to correct, your personal information, we will use reasonable means to inform you of the reasons why, subject to any legal or regulatory restrictions. To delete your name from our electronic contact lists (text or email), please contact us in accordance with the “Contact Us” section listed below. If you have concerns with our data processing, you may file a complaint with the Office of the Privacy Commissioner of Canada. For more information about the Office of the Privacy Commissioner of Canada, please access its website.

15. Changes to this Policy

This Policy is current as of the date set forth above. We may change, update, or modify this Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy here. If we make any changes to this Policy that materially affect our practices regarding our use of the personal information we have previously collected from you, we will notify endeavor to provide you with notice, such as by emailing you or by posting prominent notice on our Site or within the Services.

16. Contact Us

If you have any questions or concerns regarding this Policy or our privacy practices, you may email us at [email protected], use our webform, or contact us at:

Lumens, Inc.
2020 L Street, Lower Level
Sacramento, CA 95811