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.
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.
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.
If you have any concerns about our use of your information, you can contact us at email@example.com.
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
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
What is the Lumen Attention Measurement Platform?
The Lumen Attention Measurement Platform (“LAMP”) is a software platform used by brands and agencies to optimize and measure attention across advertising campaigns.
We collect various types of user data (described below), but as we do that we follow a simple set of principles:
Only store data for purposes that an average user would expect.
If data is sensitive then it’s too sensitive to be used for advertising purposes, so don’t store it. (e.g. racial origin, health data, sexual orientation…etc.)
Minimize the amount of data stored to what is strictly needed to advertise effectively.
Maximize anonymity and encryption for all data stored.
For what purposes does Lumen research collect data?
Ad fraud prevention.
Analyzing and reporting advertising performance.
Controlling which and how many ads are displayed to a user. Our clients collect data via Lumen technology for their own purposes (subject to an Lumen audit of the validity of those purposes and the sensitivity of the data collected).
Analyzing and reporting on traffic to our corporate site
What data is stored?
Mappings between a Lumen tag and other IDs which allow clients and partners to use their own data with the platform.
Segmentations of your LAMP ID; in other words, putting your ID into a group based web-behavior. This is data is processed by Lumen, but owned by our clients. We continuously audit the way our clients are using this functionality to make sure it’s consistent with your rights and follows privacy best-practices.
Third-Party Data Segmentations; data integrated into LAMP by a third-party. Again, this isn’t our data, but as a processor of the data we subject it to an audit to validate the purposes and sensitivity of the segmentation.
What data isn’t ever stored?
Any segmentations or data points that individually or in combination could allow you to be identified in the “real world”. E.g. full name, email address, physical address, etc.
Any sensitive segmentations – e.g. racial origin, health data, sexual orientation, etc.
How is it collected?
How is it shared?
It’s not. Ever. Lumen’s cookie IDs are never stored anywhere, except on your browser. Only anonymized and/or aggregated data is shared to our clients and partners.
How is it stored?
The LAMP tag is never stored in any log-file or database. We store a ‘hash’ of the ID which allows the data to be stored anonymously. When we aren’t in contact with your browser – the data goes back to being anonymous.
Data Collected On Our Platform and from Partners
Lumen collects data whenever Lumen is used by our clients to advertise or track users. Put simply, if our Service is used to show you an advertisement, or if you’re visiting a website or app we work with we may collect some data about those interactions. This data, may (and usually does) include anonymous identifiers such as cookies, does not identify you personally (as a person-in-the-real-world), but it does allow us to identify you on the internet if we see you again and serve you ads that get your attention.
Links to Third-Party Websites and Third-Party Content
Data Collection On Behalf Of Third Parties
We may, on behalf of our clients and partners, collect information from end users. This may occur, for example, if someone submits information in response to an ad that we provide on behalf of an advertising client. Such information may consist of personal data. In such situations, we collect the information and provide it to our client, and it will be subject to that client’s privacy practices.
From time to time cookies may be used to carry out the Research and to make the experience better. A cookie is a piece of information which is transferred to the cookie file of the browser on a participant’s computer. The browser saves the information and sends it back to a website server whenever the browser returns to the website. Cookies may be deposited through visits to particular websites or may be deposited directly by Lumen’s eye-tracking app. The purpose of any cookies deposited will be (i) to identify the state of the browsing device e.g., whether or not the eye tracking device is connected and currently in operation and (ii) to enable specific test content to be served to participants during the browsing session.
What is a cookie?
A cookie is a piece of information which a website transfers to the cookie file of the browser on a participant’s device. The browser saves the information and sends it back to the website server whenever the browser returns to the website. A cookie will typically contain the name of the domain (internet location) from which the cookie has come, the “lifetime” of the cookie (i.e. when does it expire), and a value, usually a randomly generated unique number. Cookies may be deposited through visits to particular websites or may be deposited directly by Lumen software. We use the following four types of cookies:
Session cookies which are temporary cookies that remain in the cookie file of a browser until the participant leaves the site. We use session cookies to:
Enable participants to securely login and connect to our services
Persistent cookies which remain in the cookie file of the browser for much longer (though how long will depend on the lifetime of the specific cookie). We use persistent cookies to:
Enable participants to securely login and connect to our services – using the “Remember me” option
First and third-party advertising cookies which are used to help us and other sites serve advertising to participants on this and other sites that are likely to be of interest or relevant to a specific task requested of participants during the browsing session with the Lumen app
First and third-party analytics cookies which are used to analyze usage of browsing the internet
Opt out of third-party advertising cookies by visiting: http://www.youronlinechoices.com/uk/opt-out-help
The GDPR (“General Data Protection Regulation”) is the EU’s safeguard for the rights of an individual to control their data. This regulation grants users a set of powerful rights with which to protect their data.
The right to be informed
Anytime your personal data is collected you have the right to know about it.
The right of access
You have the right to access the data stored about you for free on 30 days notice.
The right to rectification
You have the right to edit/correct the data stored about you (in most circumstance).
The right to erasure
You have the right to erase the data stored about you.
The right to restrict processing
In some cases you can restrict the processing uses your data is put to.
The right to data portability
You have the right to take your data in a form which makes it easy to port into another system.
The right to object
You have a right to object to any processing of your personal data, and this right is absolute when it comes to direct marketing.
Rights in relation to automated decision making and profiling.
In cases where you’ve been subject to “automated decision making” which has a significant effect on you, you can demand that the decision is reviewed by a real person.
When Lumen collects personal data or data that could be deanonymized and turned into personal data it does so on one of two legal bases.
If the data is going to be used for positive targeting (serving an ad because of the data) we do so only on the basis of the user’s consent. Currently, the only case in which we do this is when targeting users that have visited our site (“Lumen.io”).
For the data we collect to track advertisements delivered via our service we rely on a set of legitimate interests. (1) Uncovering ad fraud (e.g. a bot pretending to be a human), (2) to track the performance of our advertising (how many ads delivered, how many users delivered to, how many ads per user, which users clicks, which users went on to purchase…etc.), and (3) to restrict delivery of advertising (e.g. don’t show any users the same ad more the 3 times per week…etc.).
Here are the partners we currently sync with:
Bidswitch – http://www.bidswitch.com/privacy-policy/
AppNexus – https://www.appnexus.com/platform-privacy-policy
Data Management Platforms:
Adobe – https://www.adobe.com/uk/privacy/policy.html
Liveramp – https://liveramp.com/privacy/
Oracle (Bluekai) – https://www.oracle.com/uk/legal/privacy/marketing-cloud-data-cloud-privacy-policy.html
Lotame – https://www.lotame.com/about-lotame/privacy/
Nielsen (eXelate) – http://www.nielsen.com/eu/en/privacy-statement.html
Salesforce (Krux) – https://www.salesforce.com/products/marketing-cloud/sfmc/salesforce-dmp-privacy/
Amobee (Turn) – https://www.amobee.com/trust/privacy-guidelines
If you believe your child has provided Lumen with personal information, such as by registering at one of Lumen’s websites, and you would like to have the data removed, please contact us using the contact information below.
Lumen takes steps to protect the security of information that we collect. To that end, we have designed and deployed hardware, software, and networking solutions in an effort to reasonably secure and protect access to our systems and data.
We may need to disclose information, including PII, when in our good-faith judgement we are required to do so by law, or when such action is necessary to comply with a current judicial proceeding, a court order or legal process. We may also transfer all or some of the data discussed in this policy, in connection with a corporate merger, acquisition, sale of assets, bankruptcy, or other corporate change.
If you have any questions or concerns about our privacy practices, you may contact us at
firstname.lastname@example.org.Internet-Based Advertising Opt-Out
If you would like to opt out of the use of data for interest-based advertising by Lumen, please click here.