Privacy Policy


Lume Strategies, Inc. (hereinafter referred to as “us, “we,” “our,” or “Company”) has created the following Privacy Policy for when you visit our website:, mobile and other applications, and any other online services where this Privacy Policy is posted (hereinafter the “Website”). This Privacy Policy describes, among other things, the types of information we collect about you when you visit and use our Website, how we use it, and how you can access your information.

This Privacy Policy is governed by our Terms and Conditions of Use, which is also available on our Website. If there are inconsistencies between our Privacy Policy and the Terms and Conditions of Use, the Privacy Policy controls.

This Privacy Policy applies to all information that you provide to us and that we process, whether you provide the information through our Website, or through other means.
We may collect the following types of information about you which are described in more detail below: (A) information you provide to us, (B) information we may automatically collect, and (C) information we may receive from third parties. All of the information listed in (A)-(C) above, are detailed below, and hereinafter referred to as “Information.” Before submitting your Information to us, please read this Privacy Policy carefully. By accessing and using our Website, you are consenting to the practices described herein. This Privacy Policy places no restriction on the use of Information that has been de-identified or anonymized.
A. Information You Provide to Us:
In using our Website, you may provide us with Information, including, without limitation:
1. Your name;
2. Email address; and/or
3. Any other information you choose to disclose to us through our message submission box or other means.
B. Information We May Automatically Collect About You:
Our Website may automatically and passively collect Information about you from your visit to our Website. We use this Information to help us design our site to better suit our users’ needs. This Information may include:
1. IP address;
2. Your geographic location;
3. Date and time of your visit;
4. Domain server;
5. Type of computer, web browsers, search engine used, operating system, or platform or web browser you use;
6. Data identifying the web pages you visited prior to and after visiting our Website; and/or
7. Your movement and activity within the Website, which is aggregated with other information.
We use a few different technologies to collect this Information:

Cookies. A cookie is a data file placed on a device when it is used to access a website. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to the Website. Our Website may use cookies when you sign in in order to identify you and keep track of your personal session and preferences. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you visit the Website.
Managing Cookie Preferences: Most web browsers automatically accept cookies, unless you have configured yours not to accept them. You can program your browser not to accept cookies, but if you do, you may not be able to use certain portions of the Website and the Website will not be able to customize certain features according to your preferences. You may change and manage your cookie preferences through your browser’s settings:
Through your Browser Settings: If you wish to block or delete the cookies received from our Website or any other website, you can do so by changing your browser’s settings. You can find below the links to the instructions of the following browsers:
• Internet Explorer –
• Chrome –
• Firefox –
• Opera –
• Safari –
Please note that if you disable all cookies, including navigation and functional cookies, your navigation may be affected, and you may not be able to use some of our Website’s functionalities.

Web Beacons. Small graphic images or other web programming code called web beacons (also known as “1×1 GIFs” or “clear GIFs”) may be included on the Website. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web or mobile page or email can act as a web beacon. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count users of the Website, to monitor how users navigate the Website, to count how many emails sent were actually opened or to count how many particular articles or links were actually viewed. In contrast to cookies, which are stored on a user’s computer hard drive, clear GIFs are embedded invisibly on web pages. The Company does not tie web beacons to identifying Information. The Company may use a third-party tracking service that uses cookies to track non-personally identifiable information about visitors to our Website in the aggregate – e.g., usage and volume statistics to enhance and improve our Website and user experience.

Analytics. Analytics are tools we use, such as Google Analytics, to help provide us with information about traffic to our Website. These services use the data collected to track and monitor the use of our Website, which it shares with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network. Google services make use of Google’s Tag Manager. For more information about Google’s use of data for marketing purposes, please see the summary page:, Google’s privacy policy is available at
▪ You can opt-out of having your activity on the Website made available to Google Analytics by installing the Google Analytics opt-out browser add-on ( for your web browser.

Mobile Application Technologies. If you access our Website through a mobile device, we may automatically collect information about your device, your phone number, and your physical location. You may opt-out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at
o Opting Out of Targeting & Do Not Track. We, or third parties with whom we collaborate or contract with to perform services on our behalf, may use your Information to text, email, or contact or share with you information that we believe may be useful to you, such as information about products or services provided by or through us through permissible targeted advertisements or related to our Website. You may opt-out of receiving permissible targeted advertisements by using the NAI Opt-out tool available at
▪ Some users engage a Do Not Track (DNT) setting to indicate a preference regarding tracking by advertisers and other parties. Our Website does not respond to DNT signals.
C. Information We May Receive from Third Parties
We may collect additional Information about you from third-party websites, social media platforms, and/or sources providing publicly-available information to help us provide services to you.

A. Use and Purpose of Processing Your Information
We use and process your Information above for things that may include, but are not limited to, the following:
1. To respond to your inquiries and provide you with requested information;
2. Communicate with you regarding our services, provided that you have not already opted-out of receiving such communications;
3. Improve our Website and resolve any technical problems;
4. Provide targeted advertisements to you;
5. Comply with our Terms and Conditions of Use;
6. Comply with any applicable laws and regulations and respond to lawful requests; and/or
7. For any other purposes disclosed to you at the time we collect your Information and/or pursuant to your consent.

B. Lawful Basis for Processing Your Information
On what Information we collect from you and how we collect it, we rely on various grounds for processing your Information, including the following reasons:
1. In order to administer our contractual relationship, including setting up or responding to any services you may request;
2. Because it is in our legitimate interest to effectively and efficiently operate our business and provide you with the services offered through the Website and other useful content and for other marketing, design, and advertising purposes;
3. In order to fulfill any legal obligations we may have to collect this Information from you; and/or
4. Because you have provided your consent for us to do so.

C. How Long We Keep Your Information
We generally keep Information for so long as it may be relevant to the purposes listed above, consistent with any applicable laws and agreements. To dispose of Information, we may anonymize it, delete it, or take other appropriate steps. Information may persist in copies made for backup and business continuity purposes for an additional time.

D. Sharing Your Information
We may share your Information as disclosed at the time you provide your Information, as set forth in the Privacy Policy and in the following circumstances:

Third-Party Service Providers. In some cases we may employ third-party service providers to perform certain services on our behalf, including, without limitation: (i) processing and hosting your Information for data management and analytics; (ii) responding to your inquires and providing customer service; (iii) shipping or sending postal mail, texts, and/or emails; (iv) analyzing, updating, and correcting information we receive on the Website; (v) performing business analysis, data processing, and/or quality control; (vi) providing marketing assistance, search results, and links (including, without limitation, paid listings and links); and (vii) providing you with information you request. Consequently, we may share your Information with these third-party service providers if they need it to perform services on our behalf. Our contracts with such third-party service providers prohibit them from using any of your personal information for any purpose beyond the purpose for which it was shared.

Disclosure of Information for Legal and Administrative Reasons. We may disclose your Information without notice: (i) when required by law or to comply with a court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Information); (iv) to protect and defend the rights, property or safety of us, our subsidiaries and affiliates and any of their officers, directors, employees, attorneys, agents, contractors and partners, and the Website’s users; (v) to enforce or apply the Website’s Terms and Conditions of Use; and (vi) to verify the identity of the Website’s users.

Business Transfers. Your Information may be transferred, sold or otherwise conveyed (“Conveyed”) to a third party where we: (i) merge with or are acquired by another business entity; (ii) sell all or substantially all of our assets; (iii) are adjudicated bankrupt; or (iv) are liquidated or otherwise reorganize. You agree to any and all such Conveyances of your Information.

Online Postings. If you correspond with us by email, questionnaires, surveys, social media, or other digital online platform, we may retain such correspondence and the Information contained in it and use it to respond to your inquiry.
Except as provided in this Privacy Policy, we will not sell, rent, or license your Information we have collected to any third party without your consent.

Our Website may interface with social media sites such as LinkedIn and Twitter. We are not responsible for the privacy and security practices of those websites or social media platforms or the information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other party’s website or content do not constitute or imply an endorsement or recommendation by us of the linked website, social media platform, and/or content.

You agree we may contact you, or initiate communication with you on behalf of a third party with whom we contract, by way of text, newsletter, email, or telephone and you agree to us contacting you in these matters concerning our Website or related services or targeted information for which we believe you may be interested.
If you change your mind and do not wish to receive such communications, we provide customers with the opportunity to opt-out of receiving communications from us. If you no longer wish to receive specific communications or services, you have the following options:
1. You can click the unsubscribe link in the email or newsletter and follow the instructions providing for unsubscribing to future email correspondence.
2. If you wish to revoke your consent to receiving text messages, reply to the text with STOP
3. Send mail to the following postal address:
Attn: Privacy Office
250 International Drive
Williamsville, New York 14221
4. Call us toll-free at: 1-800-568-8310.

We use industry-standard procedures and various technical, administrative and physical safeguards to help protect the confidentiality of your Information. However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. We do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure. We do not guarantee that your information will not be misused by third parties. We will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Information.
If you believe that your Information has been accessed or acquired by an unauthorized person, you shall promptly notify us so that necessary measures can quickly be taken.

To the extent certain European data protection laws apply and we hold your Information in our capacity as a data controller as defined under those laws, you may request that we:
1. Restrict the way that we process and disclose your Information;
2. Transfer your Information to a third party;
3. Revoke your consent for processing of your Information;
4. Provide you with access to your Information;
5. Remove your Information if no longer necessary for the purposes collected;
6. Prevent the processing of your Information for direct-marketing purposes;
7. Update your Information so it is correct and not out of date; and/or
8. Object to our processing of your Information.
If you wish to object to the use and processing of your Information or withdraw consent to this Privacy Policy, you can contact us in the following ways:
1. Email:
2. Mail: Lume Strategies, Inc.
Attn: Privacy Office
250 International Drive
Williamsville, NY 14221
3. Call us toll-free at: 1-800-568-8310
The requests above will be considered and responded to in the time-period stated by applicable law. Note, certain Information may be exempt from such requests. We may require additional Information from you to confirm your identity in responding to such requests. Depending on your jurisdiction, you may have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try and resolve it directly.
In accordance with our routine record keeping, we may delete certain records that contain Information you have submitted through the Website. We are under no obligation to store such Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Information.

The Website is intended only for users over the age of eighteen (18). If we become aware that a user is under thirteen (13) (or a higher age threshold where applicable) and has provided us with Information, we will take steps to comply with any applicable legal requirement to remove such Information. Contact us if you believe that we have mistakenly or unintentionally collected Information from a child under the age of thirteen (13).

We reserve the right to change, modify or amend this Privacy Policy at any time to reflect changes in our products and service offerings. If we modify our Privacy Policy, we will update the “Effective Date” and such changes will be effective upon posting. It is your obligation to check our current Privacy Policy for any changes.

If you have any questions about this Privacy Policy, please send us an email at, call us toll free at 1-800-568-8310, or write us at Lume Strategies, Inc., Attn: Privacy Office, 250 International Drive, Williamsville, New York 14221.

Last Updated on: March 22, 2019