Privacy Notice

Who we are

The Lumimetrica public website and the Lumimetrica mobile applications (the “apps”) are operated by Graph25 Informatics Limited (“we”, “us”). This notice explains how we handle personal information in connection with the website and the apps. Contact details are at the end of this page.

Learner data that the apps display or process on behalf of a learning organization is handled under that organization’s instructions, as described in Enterprise Privacy and in each organization’s agreement with us. This notice covers the information we handle about the people who visit the website and use the apps.

The website

When you contact us

This website has no contact form and does not collect messages. To get in touch, you can email us at questions@graph25.uk or call us.

When you write to us by email or call us, we receive the information you choose to share — typically your name, organization, role, email address, country and the content of your message.

Technical information

Like any website, this site is delivered by servers that receive standard technical information with each request, such as your IP address, browser type, the page requested, and the date and time. Our hosting and content delivery provider processes this information to deliver the website, keep it secure and protect it against abuse.

Preferences stored on your device

If you choose a theme or language, that choice is stored in your browser’s local storage and is not sent to us. See the Cookie Policy.

What the website does not collect

The website does not use analytics services, advertising technology, tracking pixels or cookies. It does not offer user accounts and does not build profiles of visitors.

Mobile applications

Availability

The Lumimetrica apps have not yet been released. This section describes how they are designed to handle personal information. We will review it, and update it where needed, before the apps become available.

Who uses the apps

The apps are intended for educators and staff of learning organizations that use Lumimetrica, signing in with accounts provided by their organization. They are not intended for use by learners or by children.

Account information

To let you sign in and to apply the right permissions, the apps use the account details your organization provides, such as your name, work email address, role and organization.

Learner statistics

The learner statistics you view in the apps are processed on behalf of your organization. How that data is handled is governed by your organization’s agreement with us and described in Enterprise Privacy.

Diagnostics and crash reports

When an app crashes or does not perform as expected, it sends us diagnostic information, such as the device model, operating system version, app version and technical details of the error. We use this information only to find and fix problems.

Usage analytics

The apps collect information about how their features are used — for example, which screens are opened and which actions are taken — together with basic app and device information. We use it to understand how the apps are used and to improve them. We do not use it for advertising, and we do not sell it.

Push notifications

If you allow notifications, your device’s notification service (Apple Push Notification service on iOS, or Firebase Cloud Messaging on Android) provides a device token that lets us send notifications to the app. You can turn notifications off at any time in your device settings.

Camera, photos and files

Some features may ask for access to your device’s camera, photos or files — for example, to capture or attach an image or document. The apps request this access only when you use such a feature, and only with your permission. Images and files you choose to add are processed as part of the service on behalf of your organization. You can withdraw these permissions at any time in your device settings.

What the apps do not do

The apps do not request your location or access to your contacts, do not show advertising, and do not track you across other companies’ apps or websites.

How we use information

We use the information described above to:

• respond to your enquiry and continue the conversation you started;
• provide the apps, enable sign-in and apply the correct permissions;
• send notifications you have allowed;
• diagnose and fix technical problems;
• understand how the apps are used so that we can improve them;
• operate, secure and maintain the website and the apps;
• comply with legal obligations that apply to us.

We do not sell personal information, and we do not use it for advertising.

Legal basis

Where data protection law requires a legal basis for processing, we rely, as applicable, on our legitimate interests in responding to enquiries, operating secure services, and diagnosing and improving the apps; on the performance of our agreement with your organization; on your consent, where we ask for it (for example, for notifications and device permissions); or on compliance with a legal obligation.

Sharing

We share personal information only with service providers that help us operate the website and the apps and handle correspondence — such as our hosting, email, crash-reporting, analytics and notification providers — and only as needed for those purposes. App stores and device platforms (Apple and Google) process information under their own terms when you download or update the apps and when they deliver notifications. We may also disclose information where required by law.

International transfers

Our service providers may process information in countries other than your own. Where this happens, we take steps intended to ensure that your information remains appropriately protected.

Retention

We keep correspondence for as long as needed to respond to you and to maintain appropriate business records, and then delete it. Account information used by the apps is kept in line with your organization’s agreement with us. Diagnostic and usage information from the apps is kept only for as long as needed for the purposes described above. Technical information processed by our hosting provider is retained according to that provider’s standard practices.

Your choices and rights

You can control notifications and device permissions at any time in your device settings, and you can stop all collection by the apps by uninstalling them.

Depending on the law that applies to you, you may also have the right to request access to, correction of or deletion of your personal information, to object to or restrict certain processing, and to lodge a complaint with a data protection authority. To make a request, contact us using the details below. Requests about learner data or about accounts managed by your organization may be passed to your organization, which is responsible for them.

Children

The website and the apps are intended for professionals and organizations. They are not directed at children.

Changes to this notice

If our practices change — for example, when the apps are released, or if we add a contact form or any other way of sending information through the website — we will update this notice and the date at the top before the change takes effect.

Contact

Questions about this page can be sent to Graph25 Informatics Limited:

questions@graph25.uk
+256 756 494 518
3rd Floor, Kanjokya House
Plot 90–92 Kanjokya Street
Kampala, Uganda

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