Lumen Research Privacy Policy

Lumen Research Ltd (“Lumen”) is a company registered in England, company number 8682432. Its registered office is at; Unit 215, 22 Highbury Grove, London N5 2EF. Its data protection registration reference is ZA130772.

This Privacy Policy describes the types of information collected, as well as how we use and disclose such information. Lumen Research is committed to protecting consumer privacy and to clearly informing users about the collection and use of data when using our services or visiting our website.

This document covers the privacy policy governing (1) the collection of data from panellists involved in our eye-tracking panels and (2) our operation of the Lumen Attention Measurement Platform (“LAMP”).

Privacy Policy governing our longitudinal, passive eye-tracking panels (the “Research”)

Lumen Research operates the world’s largest eye-tracking panels to drive high-precision attention measurement and optimization. Every panel is comprised of 100% opt-in, fully consented participants. Every participant is provided by Lumen with software (the “Software”) required for the collection of eye tracking and web-browsing data. This data is collected by Lumen on an anonymous basis and will be treated in accordance with data protection laws and market research ethical guidelines. A participant’s personal details will not be shared with any third parties without consent. When using Lumen’s eye-tracking software, you consent to our collection, use and disclosure of participant information as described in this Privacy Policy. Participants can also withdraw consent to our future collection of information by contacting us in the Contact Us section of this Privacy Policy or by uninstalling the Software. Withdrawal of consent will not apply retroactively to information that was previously collected with a participant’s consent.

What information is collected?

By participating in the Research, we will collect and use anonymized information about participants. This information includes:

Participant registration details;
information on web-browsing undertaken within the Software (“Web-Browsing Data”);
information on the content of participant web-browsing (“Web-Browsing Content Data”);
information on where participant’s eyes are focusing on the screen when the eye tracking is enabled (“Gaze Data”);
information about participant devices that can optimize the performance of our Software including information about the operating system’s name and version;
Panelist responses to specific surveys and activities administered as part of the project; and
any other information that participants give to use in participating in the Research; (together “Participant Information”).

How will the data be collected?

Participation in the Research will require use, during web-browsing, of Lumen’s eye tracking technology.  This will require the use of a front-facing camera on a mobile or laptop/desktop device (each, a “Browsing Device” or “Device”) . The eye tracking technology captures information about where a participant’s eyes are focusing on a device’s screen over time.

Participation will also require installation of Lumen’s Software (the Focus Project App) onto a Device . The Software will enable Lumen to collect information related to internet browsing activity undertaken within the App on a Browsing Device by participants or any other user of the app, on an ongoing basis, for as long as the Software remains installed and is turned on. The Software also enables Lumen to associate the Gaze Data with participant Web-Browsing Data (i.e., to see what was being viewed while participants were browsing).

Lumen’s software collects data about browsing activity within the Focus Project App, but not within any other apps on the mobile device.  Information on browsing undertaken in any other app will not be collected.

How will participant Information be used?

Participant information will be used to explore how individuals view and interact with online media. We may share the Research data with our affiliated companies and with our business partners and clients. While the Research data might be shared with our affiliates, partners and clients, it is only used anonymously and such affiliates, partners and clients use this anonymized data to create summary descriptions of a wide range of consumer behaviours and consumer segments to develop products or to provide marketing solutions to their customers or consumers.

We combine the information that we collect from participant use of the Software and, where applicable, the Device, and inferences that we draw from that information, with information we have collected from or about participants and their household in connection with the household’s participation in Lumen’s online and offline research studies. We analyze and use participant Information for our research purposes at an aggregated level. We also use it to create reports for our clients. These reports do not identify participants or any other person by name, address, telephone number, or other information that identifies participants individually but may include information about device usage and the operational information described above.

How Lumen Keeps Personal Information safe

The information we collect is analyzed in aggregate, and will not be attributed to any participant individually. Personally identifiable information will not be collected via the Software. We work with third parties to recruit and reward panellists.  Lumen will share with these third parties information pertaining to participant activity in the Research in order that they can administer Rewards in relation to the Research and to provide participants with support, as necessary.

The data collected by Lumen is encrypted using Secure Sockets Layer (SSL) technology. This is a commonly used high standard of encryption technology..

How Lumen uses and discloses information

We may disclose anonymised and non-personally identifiable information we collect from and about participants to our third party service providers, to enable them to provide services to us. We may also disclose any information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). We may also use or disclose the information we collect from and about participants as we believe to be necessary or appropriate: (a) under applicable law, including laws outside a participant’s country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside a participant’s country of residence; (d) to enforce our end user license agreement; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety, or property, and/or that of our affiliates, participants, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.


We take reasonable steps to protect participant Information using physical, electronic or procedural security measures appropriate to the sensitivity of the information in our custody or control, which include safeguards to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Only our authorized employees and agents who require access to personal information in order to fulfil their job requirements will have access to participant personal information.

Retention period

Any personal information that we collect will be retained for the period necessary to fulfil the purposes outlined. Any information supplied by participants will be handled and stored in accordance with the Privacy Statement, which must be accepted at the point of registering with Lumen’s eye-tracking software.

Contacting us

If you have any concerns about our use of your information, you can contact us at

You can also contact the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane




Helpline number: 0303 123 1113

ICO website: