Privacy Policy

The web site (the 'Site') you have entered is operated by or on behalf of LumiraDx ('LumiraDx' or 'Company'), which is the data controller of any data for purposes of applicable data regulations. The protection of your personal information is important to us. We respect your privacy and want you to understand what we do with the information we hold about you or the persons you collect data from.

This privacy policy explains how we (LumiraDx) collect, share and use your personal information or information collected from the instruments we provide. This Privacy Policy applies only to this Site. For example, it does not apply to linked web sites owned or controlled by third parties.

This privacy notice explains the purposes for which LumiraDx will collect, hold and use your personal data.  It also explains your rights under EU and UK data protection laws to access your data or seek to have it rectified or deleted. 

LumiraDx operates a global Data Protection Policy which takes into account data protection legislation and regulations in all the markets in which the business operates.  The framework we uphold is based on UK and EU GDPR principles and is adapted to comply with local legislation where these apply. 

We may collect the following types of personal information from you when you use LumiraDx products or services.

• Contact details: information that allows us to contact you directly such as your name, email address, telephone number and addresses associated with your account or order.
• Account details: when you download and use a LumiraDx app such as Engage, you will be asked to register with us and create an account. Your account details include your username, password and your contact details, such as your name, address and email address.
• Transaction information: records of the products and services you purchase from us.
• Delivery information: information relating to the delivery of our products to you.
• Installation and service history: records relating to the installation of our products at your home or business and information relating to the servicing of that product.
• Device information: information about the smartphones, mobiles, computers or other electronic devices you connect to our products, website or LumiraDx apps, such as details about the type of device (which can include unique device identifying numbers), its operating system, the browser you use and applications on the device that connect to our products and services. It can also include details of your internet service provider, mobile network and your IP address.
• Responses to surveys, competitions and promotions: we keep records of any surveys you respond to or your entry into any competition or promotion we run.
• Records of your discussions with our customer support teams: when you share comments and opinions with us, ask us questions or make a complaint we will keep a record of this. This includes when you send us emails or phone our customer service team. We may also monitor and record our phone calls with you to make sure we are living up to our high the standards, as well as relevant laws and regulations.
• How you use LumiraDx products: we will collect information about how you are using LumiraDx products and services in your home or business and their performance.
• How you use a LumiraDx app and our website: when you use a LumiraDx app or our website we collect information about the pages you look at and how you use them.
• Location information: we will collect information about your exact location when you choose to share that with us. Even when you don’t actively share your location with us, your smartphone or computer's IP address may tell us an approximate location when you connect to our website or products but this will be no more precise than the city, state or country you are using your device in.

For all of the above, LumiraDx is acting as the Data Controller and we manage the personal data you provide to fulfil our contract with you, with your consent or where we have a legitimate interest to do so. You are not required to provide any of the personal information described above to us, however, if you do not do so, you may not be able to use our products and services, or the functionality of our products may be reduced.

• Provide our services to you and maintain your account
• Take payment for our products and services
• Deliver products to you
• Installation and servicing
• Answer your queries or complaints
• Maintain and improve our products and services
• Ensure regulatory compliance
• Data analytics and statistical research to help us better understand how our products are used
• Staff training
• Develop new products and services
• Determine products and services that may be of interest to you
• Direct marketing
• Investigating misuse of your account, fraud and debt collection

We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site, apps and products, and developing new products and services.

We will collect personal information from a number of sources. These include the following:

• Directly from you: for example, when you create your LumiraDx account with us, purchase products and services from us, complete forms we provide to you, contact us by phone, email or communicate with us directly in some other way.
• Our website, app and LumiraDx products: provide us with information about how you use them.
• Other companies we work with: provide us with information to help us deliver our products and services to you, and to understand you better.
• Companies in the same group of companies as us: who may provide relevant information about your  account. 

We share personal information with the following parties:

• Companies in the same group of companies as us: for the purpose of providing a service to you and understanding your use of our products and services. LumiraDx has adopted Binding Corporate Rules (BCRs) to facilitate this. These are currently going through the EU approval process.  Until this process is completed, LumiraDx uses Standard Contractual Clauses to facilitate the transfer of personal data between our entities. 
• Other companies’ apps and products: for the purpose of helping you use apps and products you connect to LumiraDx products.
• Delivery companies: to deliver products that you have ordered from us.
• Other service providers and advisors: such as companies that support our IT, help us analyse the data we hold, process payments, send communications to our customers, provide us with legal or financial advice and generally help us deliver our services to you.
• Market research: occasionally we may ask our market research partners to contact our customers to help us find out how to improve our products and services.
• Purchasers of our business: buyers or prospective buyers who we sell or negotiate to sell our business to.
• The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives.
• Police and law enforcement: to assist with the investigation and prevention of crime when legally required.

We do not disclose personal information to anyone else except as set out above. We may provide third parties with aggregate statistical information and analytics about users of our products and services, but we will make sure no one can be identified from this information before we disclose it.

In accordance with the marketing preferences you set when creating your account or that you set with us at a later date, we may contact you by email, push notification, text, mail or phone with information about products and services we believe you may be interested in.

If you tell us not to email, send push notifications, text, mail or phone you with direct marketing information we won’t contact you in that way.

You can let us know at any time that you do not wish to receive marketing messages by sending an email to us at privacy@lumiradx.com or contacting the customer service team by phone or by webchat.

You can also unsubscribe from our marketing emails by clicking on the unsubscribe link in the emails we send to you.

We work with our advertising agencies to show you advertising about our products and services on websites or apps that you visit, at a time and in manner that we feel is relevant to you. To do this, our advertising agencies use anonymised information about the websites, apps, social media content and ads you interact with or view when connected to the Internet, to make sure the advertising you see is more relevant to you.

The techniques our advertising agencies use (to determine what advertising to show you), recognise the device you are using but are not aimed at you as a named individual. Typically, cookies and similar technologies are used to target this type of advertising. You can find out more about cookies and how to manage their use by reading our cookie section below.

The LumiraDx app will send service notifications directly to your smartphone or device through the app when we have something important or interesting to make you aware of, or when you have asked to be notified about certain events relating to your LumiraDx products.

Depending on the preferences you set, you may also receive these notifications by text message or email.

You can turn off service notifications at any time through the app, your smartphone system settings, or your online account.

If you use our website or app, we will collect information about how you interact with us online. We use cookies and other similar technologies to help us do this.

You may have heard of 'Cookies,' which are files or pieces of information that are stored by your browser on your computer’s hard drive. LumiraDx may use cookies to collect other information during your visit to the Site, such as the particular areas you visit and the services you utilise through the Site.

For example, the Site can recognise that you have provided Personal Information to LumiraDx and refrain from requesting the same information a second time. Most browsers are initially set to accept a cookie. If you’d prefer, you can set yours to refuse cookies or to alert you when cookies are being sent. Refusal of cookies at the Site may result in an inability to visit certain areas of the Site or to receive personalised information when you visit the Site.

In addition, LumiraDx is constantly trying to improve how we promote the Site. To help LumiraDx do this, the Company may measure the effectiveness of LumiraDx’s web presence by determining when you accessed the Site, and what you clicked on within the Site. Site measurement statistics may be used to personalise your web site experience, as well to evaluate - anonymously and in the aggregate - statistics about usage of the Site.

Information about your computer, such as your IP address (a number assigned to your computer whenever you surf the Internet), the type of Internet browser you are using and the type of operating system you are using may also be collected and linked to your Personal Information. This is to ensure that the Site presents the best web experience for visitors, and that they are effective information resources.

Some of the pages you visit may also collect information through the use of pixel tags (also called clear gifs) that may be shared with third parties that directly support LumiraDx’s promotional activities and web site development. For example, web site usage information about visitors to the Site may be shared with our third-party advertising agency in order to better target Internet banner advertisements on the Site. The information collected through the use of these pixel tags is not, however, personally identifiable, although it could be linked to Personal Information.

The personal information we collect may be transferred to and stored in countries outside of the European Union or the UK. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in.

We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy policy and applicable European and UK data protection laws and is respected and kept secure.  LumiraDx uses Standard Contractual Clauses to facilitate the transfer of personal data between our entities. 

We will keep your personal information for a period determined by national guidelines and regulatory requirements.

You have the following rights in relation to your personal information:

• the right to be informed about how your personal information is being used;
• the right to access the personal information we hold about you;
• the right to opt-out of receiving direct marketing messages;
• the right to request the correction of inaccurate personal information we hold about you;
• the right to request the blocking or deletion of your personal information where the processing does not comply with applicable data protection laws.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the ‘Contacting us’ section below or via privacy@lumiradx.com

If you are unhappy with the way we are using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.

While browsing this Site you may be offered automatic links to other web sites relevant to a particular aspect of this Site. This does not indicate that LumiraDx is necessarily associated with any of these other sites or their owners. You should contact those sites to access their policies regarding use of your Personal Information. Other LumiraDx sites may be governed by separate Privacy Policies. Upon your entry to another LumiraDx site, you should carefully read and review the Privacy Policy governing such site.

LumiraDx does not knowingly collect or use any personal information provided by children or minors under the age of eighteen (18). If you are a parent and become aware that a child or minor under the age of eighteen (18) has provided LumiraDx with Personal Information, please contact us. (See 'Contacting us' below). IF YOU ARE A CHILD OR A MINOR UNDER THE AGE OF EIGHTEEN (18), PLEASE DO NOT PROVIDE LumiraDx WITH ANY PERSONAL INFORMATION.

We may update this privacy notice from time to time. When we change this notice in a material way, we will update the version date at the bottom of this page. For significant changes to this notice we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.

n the event of any query or complaint in connection with the information we hold about you, please email us at: privacy@lumiradx.com

Date
20 March 2023