Privacy Policy

Effective Date: February 01, 2024

Thank you for choosing Adlumes and entrusting us with your privacy. This Privacy Policy (“Policy”) outlines how we collect, use, and protect your information when you use our services, visit our website, or engage with us. We value your trust and are committed to safeguarding your personal information.

1) About Us and This Policy

(a) Who We Are

Adlumes, LLC. (“Adlumes,” “we,” “our,” or “us”) is the operator of our services. This Policy supplements and is governed by our Terms of Service (“Terms”). If you have questions about the Terms or the Policy, please contact us at info@adlumes.com.

(b) When This Policy Applies

This Policy applies when you use our services, effective as of the Last Updated date above. By accessing or using our services, you acknowledge that you have read, understood, and agreed to abide by this Policy and our Terms.

Given that our services evolve over time, this Policy may be subject to changes. Whenever we make updates to the Policy, we will post a revised version on our services and update the Last Updated date above. If you have provided us with your contact information, we will notify you before significant changes become effective to ensure you have an opportunity to review them.

Please note that certain parts of our services may have additional terms and privacy disclosures that complement this Policy. For example, Learning at Adlumes may have its own specific terms and disclosures. Additionally, our services may contain links to third-party websites and services, and this Policy does not extend to those external sites. Please see our “Third Party Services” section for further information.

If you are a current or former employee or contractor of Adlumes, this Policy does not apply to your employment or contractual relationship with us. In such cases, you may contact us regarding privacy practices and rights at privacy@adlumes.com.

(c) Location-Specific Sections

While Adlumes primarily operates from the United States, this Policy applies worldwide. Our privacy practices are generally consistent, but your rights and choices may vary depending on your location and the applicable laws. For instance:

  • If you reside in a location where GDPR (General Data Protection Regulation) applies, such as the U.K., EU, or Switzerland, please consult the “Rights under GDPR” and “International Data Transfers” sections.
  • Residents of Mexico should refer to the “Aviso de Privacidad” addendum.
  • Canadian residents can find relevant information in the “Canadian Users” section.
  • California residents can review their rights under California law in the “Rights under California Law” section. If you reside in a U.S. jurisdiction with a data privacy law similar to CCPA (California Consumer Privacy Act) or GDPR, we extend the same rights CCPA provides to California residents to you, unless otherwise specified.

These location-specific sections supersede any conflicting descriptions elsewhere in the Policy as they pertain to you. If you have questions regarding your rights under other data privacy laws, please reach out to us at privacy@adlumes.com.

(a) Information You Provide

You can utilize our Services without the obligation to disclose personal information about yourself. However, to access certain features of our Services, we may require information from you, including but not limited to situations where you:

  • Make a purchase of our offerings or services.
  • Contact or communicate with us.
  • Subscribe or opt-in to receive our newsletters, alerts, or other communications.
  • Participate in contests, promotions, or prize redemptions.

The information you provide may include personal identifiers such as your name or email address.

At Adlumes, we prioritize the protection of sensitive information. We make every effort to limit the collection of sensitive personal data. For instance, if you make a purchase through our Services, your payment information, such as your full credit card number and any payment-related security information, is solely collected and processed by our trusted payment processor. In cases where sensitive personal information is shared with us, we use it exclusively for our operational business purposes, and we do not disclose it to others for any other purposes.

(b) Information Collected When You Use the Services

During your interactions with our Services, we utilize cookies and other technologies that generate technical data. This technical data encompasses details about the features you use, your interaction patterns, and the devices you employ to access our services. This information may include:

  • “Commercial Information”: Pertaining to your orders of offerings, products, or services from us and interactions with Adlumes products.
  • “Device Information”: Relating to the device you utilize to interact with our Services, such as your device’s IP address, advertising IDs (random, resettable numbers like Apple’s IDFA or Android Advertising ID), browser, operating system, internet service provider, and configuration.
  • “Internet Activity”: Tied to your use of the Services, encompassing the pages you visit, websites you access before or after visiting ours, your actions within our Services, your interaction with content or advertisements, general geolocation information, timestamps, and performance logs and reports.

(c) Information We Generate

We may draw new insights from the data we collect, including the use of automated methods to generate information about your likely preferences or other characteristics. These inferences enable us to enhance your experience and tailor our offerings to better suit your needs.

2) How We Use Your Information

We utilize each of the categories of personal information as described above for the following business and commercial purposes. These activities may involve external companies, agents, or contractors (“service providers”) to whom we may disclose your information for these specific purposes (further discussed in Section 4).

(a) To Provide Our Content, Services, and Products to You

  • Deliver the content you request.
  • Provide you with exceptional customer support and promptly respond to your inquiries.
  • Ensure the completion and delivery of your orders.
  • Maintain communication with you regarding our services.

(b) To Manage Your Subscriptions or Fulfill Product Orders

  • Manage your content subscriptions efficiently.
  • Process and facilitate payments for offerings you have ordered.

(c) To Improve Our Services and Develop New Ones

  • Administer focus groups, market studies, and surveys to better understand and cater to your preferences.
  • Review interactions with our customer teams to enhance the quality of our services.
  • Continuously develop new content and services to serve you better.

(d) To Allow Personalized Ads and Create Audiences for Third-Party Advertisers

  • Administer sweepstakes, contests, discounts, or other promotional offers.
  • Collect data and collaborate with third parties to display personalized ads on behalf of advertisers.
  • Measure and evaluate the effectiveness of advertising campaigns on our services and marketing campaigns beyond our Services.
  • Keep you informed about products or services that we believe may align with your interests.

(e) To Prevent, Detect, and Fight Fraud and Other Illegal or Unauthorized Activities

  • Identify and address ongoing, suspected, or alleged violations of our Terms.
  • Retain data related to violations of our Terms to prevent future occurrences.
  • Enforce or exercise our rights, as outlined in our Terms.

(f) To Create Broader Findings with Aggregate and Deidentified Data

  • Aggregate or deidentify information so that it can no longer identify you, in compliance with applicable laws.
  • Utilize deidentified data to gain a better understanding of our user base, measure ad performance, create interest-based advertising segments, or compile survey results.

(g) To Ensure Legal Compliance

  • Verify copyright or intellectual property claims.
  • Comply with legal requirements and obligations.
  • Provide assistance to law enforcement agencies when necessary.

(h) Purposes

We rely on the following purposes to collect and use your information as described in this Policy:

  • Commercial purposes: Occasionally, we process your information to advance your economic interests or our economic interests. These purposes encompass fulfilling contractual obligations outlined in our Terms that serve both your and our economic interests. For example, when you place product orders with us, we use your information to facilitate payments and deliver your products.
  • Business purposes: Most frequently, we process your information for operational reasons in a reasonably necessary and proportionate manner, aligning with business purposes under CCPA (California Consumer Privacy Act). These purposes involve analyzing user behavior on our services to enhance our offerings continually, suggesting content that may interest you, ensuring the safety of our members, and processing data necessary to enforce our rights, assist law enforcement, or defend ourselves in legal actions.
  • Compliance with applicable laws and regulations: We also process your information when it’s necessary to comply with relevant laws and regulations while demonstrating our adherence to them. This includes retaining traffic data and transaction data in accordance with our accounting, tax, and other statutory data retention obligations, as well as responding to valid access requests from law enforcement.
  • Consent: On occasion, we may seek your consent to collect specific information or use your information for particular purposes, such as obtaining precise geolocation data or using your email address or phone number for direct marketing. In general, you can withdraw your consent by adjusting your settings (e.g., browser or device settings) or following instructions provided in information sent to you on a consent basis (e.g., clicking ‘unsubscribe’ in emails). You can withdraw your consent at any time by contacting us at privacy@adlumes.com.

3) Our Disclosures Of Information To Others

Our primary objective is to help you discover exceptional products, content, and services, and the primary reason we disclose your information is to enhance your experience with our Services and provide you with relevant content.

(a) With Affiliates

Our corporate affiliates may access your information for the purposes mentioned here, always in accordance with the terms outlined in this Policy.

(b) With Service Providers

In addition to the use of trackers as described earlier, we engage service providers to fulfill various functionalities and features of our Services. These services include payment processing, email and hosting services, software development, shipping and fulfillment, data management, and the administration of contests and promotions.

We may share information about you, such as Personal Identifiers, Commercial Information, Internet Activity, and Device Information, with service providers as necessary for them to carry out their services. Service providers are not allowed to use your information for any other purpose. Over the past twelve (12) months, we have disclosed these types of information to the following types of service providers:

  • Analytics providers, like Google Analytics, to provide insights into the performance of our Services, such as which parts interest visitors and how long they spend on our site. Among other data, they may receive your IP address. You can learn more about how Google Analytics uses data and how to opt out.
  • Various hosting services and data processors to maintain the infrastructure of our Services, such as Cloudflare, which helps ensure that traffic is generated by real people rather than automated programs. Among other data, they may receive your IP address.
  • Payment processors, such as Stripe, to facilitate payments between you and us, particularly for Offerings. To understand how Stripe processes payment information, please see their privacy policy. Payment providers receive information about your order to link your payment process to your order. We do not receive all the information you may provide to them (for instance, we don’t receive full payment-account numbers).

In some cases, we allow service providers to use aggregated or deidentified information for other purposes, in compliance with applicable laws.

(c) For Personalized Ads

We share information with advertising partners to make the ads presented to you on our Services more relevant. We may also promote our Services to you through ads facilitated by marketing vendors.

For instance, we use Google to serve ads on our Services, and we may market our Services to you on third-party platforms through Google. Google uses cookies or unique device identifiers, in combination with their own data, to display ads based on your visits to our website and other sites. You can opt out of the Google cookie by referring to Google’s privacy policy.

We aim to limit how our third-party advertising technology vendors utilize information they collect from you. Most providers require us to enter contracts that enable them to optimize their ad services and products. Essentially, they combine the information they gather about you through our Services with information received from their other clients. This helps them target ads to you on behalf of their other clients, not just us.

Over the past twelve months, we have shared these categories of personal information with third parties to personalize advertising:

  • Device Information
  • Commercial Information
  • Internet Activity
  • Geolocation

(d) For Legal Reasons

We may disclose personal information:

  • In response to subpoenas, court orders, or other legal processes, or to establish, exercise, or defend our legal rights, or as otherwise required by law. We reserve the right to assert or waive any legal objections or rights available to us.
  • When we believe it’s appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend our company, our users, or others; and in connection with the enforcement of our Terms and other agreements.
  • In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

(e) With Your Consent or at Your Request

We may occasionally seek your consent to disclose your information to third parties. When we request your consent for this reason, we will provide a summary of the purpose and scope of the disclosure.

For example, we may offer you discounts if you consent to join our mailing list or participate in a promotion that involves direct marketing communications. In such cases, the Services will display a checkbox near an email-entry field explaining that, by submitting your information, you agree to share your email with the content provider.

To be clear, we only exchange information about you with third parties for direct marketing purposes if you opt in, and we will only do so until you opt out.

4) How Long We Retain Your Information

We maintain your information only for as long as it is necessary to fulfill the purposes outlined in the “How We Use Information” section, unless longer retention is mandated by our compliance policies and obligations related to legal, tax, accounting, and regulatory requirements.

The specific duration for which we retain information varies depending on the category and can differ even within categories. These retention periods take into account factors such as the quantity, nature, and sensitivity of personal information, the potential risks associated with unauthorized use or disclosure, and whether we can fulfill these purposes without requiring the use of personal information.

For instance:

  • We promptly delete certain Internet Activity data as soon as you exit the Services, ensuring your privacy and data protection.
  • However, we may retain records of your orders for services and products for several years. This extended retention is necessary to comply with legal obligations or contractual agreements, such as those with our payment processors or in accordance with our accounting standards.

It is essential to maintain an appropriate balance between retaining data for legitimate purposes and safeguarding your privacy rights. We continually evaluate and refine our data retention practices to ensure compliance with applicable laws and regulations and to protect your personal information effectively.

5) Your Rights

(a) In General

We want you to have control over your information, so we provide the following options and tools:

Content opt-outs: You can opt-out of newsletters or promotional communications from us by following the unsubscribe instructions in the communication you receive or through our Opt-Out Request Form. However, we may continue to send you communications related to the Services, such as administrative updates and changes to the Policy or Terms.

Personalized ads: You can learn more about targeted advertising and how to opt out using your specific browser and device settings through resources like the DAA Webchoices Browser Check and NAI Opt Out of Interest-Based Advertising. You can also download the AppChoices app to opt out of personalized ads in mobile apps.

(b) Rights under GDPR

This subsection applies if you reside in a jurisdiction where GDPR applies:

Lawful bases: We collect, use, or share information about you based on valid reasons, known as “lawful bases.” These bases align with the purposes mentioned above and may include your consent, contract performance, legal obligations, or legitimate interests.

GDPR rights: Depending on your jurisdiction’s implementation of GDPR, you may have rights such as the right to access, correct, delete, object to processing, restrict processing, data portability, and withdrawal of consent. We do not charge for access to your personal data or the exercise of these rights, except in cases of unfounded, repetitive, or excessive requests.

(c) Canadian users

This subsection applies if you reside in Canada:

Canadian residents have the right to request access to and correction of their Personal Information, subject to limited exceptions set out in applicable laws. You may also withdraw your consent to the collection, use, and disclosure of Personal Information, although this may affect our ability to provide certain Services.

(d) Mexican users

This subsection applies if you reside in Mexico:

Mexican residents should refer to the Aviso de Privacidad addendum for information on ARCO rights, mechanisms to limit personal data processing, revoking consent, and other data privacy rights.

(e) International Data Transfers

If you reside outside the United States, we may transfer your information to the United States for processing. By providing your information to us, you consent to its processing in the United States. We use appropriate mechanisms, such as standard contract clauses, to transfer personal data subject to GDPR outside of Adlumes.

(f) Rights under California law

This subsection applies if you reside in California or another U.S. state with similar rights:

Under the California Consumer Privacy Act (CCPA), you have rights related to your personal information. You can request information about what we collect, correct, or delete your data, limit and opt-out of sharing/sale, and receive equal service and price. We do not discriminate against you for exercising CCPA rights.

(g) Requesting information

To exercise these rights, use Our Opt-Out Request Form or contact us at info@adlumes.com. We verify requests and respond in accordance with applicable laws. We may deny requests if they create security risks, or if we cannot verify the requester’s identity.

We reserve the right to retain an archive of deleted information and may retain deidentified or aggregate data derived from your information.

6) Security

Adlumes has taken measures to protect your information through technical, administrative, and physical security measures to prevent unauthorized access, use, or disclosure. However, no data transmission over the Internet is entirely secure, and we cannot guarantee or warrant the security of any information you provide. You use the Services at your own risk, and we cannot promise that your information will remain absolutely secure in all circumstances. We are not responsible for any circumvention of privacy settings or security measures we may offer.

7) Use by Minors

The Services are intended for adult users, and we do not knowingly collect information from anyone under the age of majority in their jurisdiction (e.g., 16 in the UK or 18 in Mexico) without affirmative authorization. If we become aware that we have collected information from a child under age 16, we will promptly delete that information. If you are under 16, please leave the Services, and if you’ve already provided us with information, please contact us for its deletion. Parents or guardians of children under 16 who believe their child has provided us with information should also contact us.

8) Third-Party Services

Certain areas of the Services may contain links to third-party websites, resources, and advertisers. These third parties are not part of the Services, and we do not control or assume responsibility for third-party content or privacy practices. Information you provide to third parties is not covered by this Policy, and they have their own policies and practices regarding data. We encourage you to review their privacy policies and terms of use.

9) Contact Us

If you have any questions or feedback regarding this Policy, you can contact us by emailing privacy@adlumes.com or by writing to us at the following address:

Adlumes, LLC.
141 W Winspear Ave,
Buffalo, NY 14214