Privacy Policy | Lüm Mobile

Our Promise to Members

When you use our service, you're trusting us with your information. We understand this is a big responsibility and work to protect your information. This policy applies to all personal information you provide to Lüm Mobile. This privacy policy explains how we collect, share, and use personal information, and how you can exercise your privacy rights.

In addition to our existing procedures and our adherence to the Freedom of Information and Protection of Privacy Act (FOIP), which governs our approach to handling personal information, we've adopted the following privacy principles from the Canadian Standards Association's Model Code for the Protection of Personal Information:

Principle 1 - Accountability

Lüm Mobile is responsible for the personal information under our control and we've designated a Chief Privacy Officer (CPO) to be accountable for our compliance with the privacy principles.

Principle 2 - Identifying purposes for the collection of personal information

We'll identify the purpose for collecting personal information at or before the time the information is collected.

Principle 3 - Obtaining consent for the collection, use, and disclosure of personal information

We require the knowledge and consent of the customer for the collection, use, or disclosure of personal information except where it is impractical or inappropriate to do so, such as in emergency situations.

Principle 4 - Limiting collection of personal information

We'll limit the collection of personal information to what is necessary for the purposes identified by the company. We will collect personal information by fair and lawful means.

Principle 5 - Limiting use, disclosure, and retention of personal information

We won't use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. We retain personal information only as long as necessary for the fulfillment of those purposes.

Principle 6 - Accuracy of personal information

Personal information will be as accurate, complete, and up tot date as is necessary for the purposes for which it is to be used.

Principle 7 - Security safeguards

We'll protect personal information by security safeguards appropriate to the sensitivity of the information.

Principle 8 - Openness

We'll make readily available, to customers and employees, specific information about its policies and procedures relating to the management of personal information.

Principle 9 - Customer and employee access to personal information

Upon request, customers and employees shall be informed of the existence, use, and disclsure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Principle 10 - Challenging compliance

A customer may address a challenge concerning compliance with the above principles to the Chief Privacy Officer.

How Information is Collected

When we collect it

We collect information from you when you provide your information through the use one of our digital channels such as our website, mobile applications, or when you interact with us using other digital channels such as social media platforms, online chat applications, on our Member Forum, or any other contact you may have with us in writing or verbally. When you sign up for service you are consenting to the collection of this information. We may also collect information about you from third parties that have the right to disclose such information to us.

What we collect

We may collect the following personal information:

Account/Contact Information such as your name, mailing address, phone number, account number, date of birth, email address, nickname, user ID, and password
Demographic Information such as gender, nationality, household makeup, and previous phone provider if you choose to provide us with this information.
Financial Information such as debit or credit card information to process your purchases.
Location Information such as your phone’s physical location may be used to provide you with enhanced services, identify your location for 911 calls, or to help ensure the security of your account.
Transactional Information about your purchases and use of our products and services.
Phone Information such as model, manufacturer, software version, IMEI, and IP address. This information allows us to identify and communicate with your phone, fix bugs, and guide our decisions about how we can improve your experience and make our applications more useful to you in the future.
Biometric Data for the use of convenience login features such as Face ID, Touch ID, or Remember Me is stored in and controlled by your phone settings. Our apps may utilize these features to authenticate you, but we never have access to the biometric data.
Website Use Information such as browsing behavior on our site and links, content you have downloaded, your IP address, as well as other data gathered from the use of web tools (for example, pixels, tags and cookies) to better understand your interests and needs so that we can serve you better. Our website uses Mouseflow, a third-party analytics tool, to track page content and click/touch, movement, scroll, and keystroke activity. You can opt out with Mouseflow here. This information is collected on an aggregated basis and no personal information is associated with these statistics. If you would like more information about our use of cookies and identifiers for your mobile devices, visit How Google uses data when you use our partners'
Social Network Data such as aggregated statistics may be shared with Lüm Mobile by third party social media platforms when interacting with our brand through those platforms.
Online chat sessions to or from our service representatives may be monitored and/or recorded. Your telephone number, email address, and chat discussions with our representatives (including automated chat assistants) are retained for our mutual protection, to enhance customer service, improve interactions with our representatives, and to confirm our discussions with you.
Other information such as any feedback you may provide to us, information shared in the Member Forum, or information on web forms that you may choose to fill in. Feedback or information you provide to us may be used to better understand our customers, website visitors, and mobile app users.

From time to time, we may obtain any of the above information from 3rd party companies and combine it with information we have about you.

Protecting the Privacy of Children

The privacy of children is important to us. We do not use our website or app to intentionally collect or use a child’s personal data. We encourage parents to review our Privacy Policy, Terms of Service, and other Legal Notices. We ask that children do not submit any personal information to us. Our services are intended for individuals who can form legally binding contracts.

Services and devices to access our services may be purchased for family use and therefore used by children without our knowledge. When this happens, information collected may appear to us to be associated with the adult customer who subscribes to our services and will be treated as the adult’s information under this policy.

How Information is Used

Why we collect it

To establish and maintain a responsible relationship with you and to provide you with ongoing service.
To develop, enhance, market, or provide products and services to you. These may not be products and services we sell, but instead, those we think you might be interested in, for example, devices or applications.
To manage your account and understand your needs and preferences.
To detect and prevent potential fraud or illegal or inappropriate use of our services.
To manage and develop our business, including personnel and employment matters. For example, we analyze the usage of our networks to plan for future growth. Your use of our services creates personal information, such as usage information.
To meet legal and regulatory requirements. For example, we may collect information to respond to a court order.

When we share it

Personal information is not sold or rented to any parties. It will be shared within our organization, which includes SaskTel. We also share this information with the companies we select as our business partners and who supply services to us. However, we require them, by contract, to honor our privacy principles in the handling of personal information they obtain from us.

The information provided to our business partners is used only for that purpose and any disclosure outside of Lüm Mobile is made on a confidential basis. Should we sell a part of our business, merge, or amalgamate part or all of our business with another entity, we may need to disclose customer information as part of the transaction. This is a normal business practice in any such transaction. Any such disclosure would be subject to appropriate privacy and security safeguards.

In certain circumstances in which it is necessary to do so, or where permitted by law, we may disclose your personal information without your consent to the following parties:

you, or an agent who, in the reasonable judgement of Lüm Mobile, is seeking information on your behalf,
another telephone company and then only if the information is required for the efficient and cost effective delivery of telephone services, disclosure is made on a confidential basis, and the telephone company agrees to use the information only for that purpose,
a company involved in supplying the customer with telecommunications or directory-related services, only if the information is required by that company for that purpose, disclosure is made on a confidential basis, and that company agrees to use the information only for that purpose,
a party used by Lüm Mobile to evaluate the customer's creditworthiness or collect the customer's account, only if the information is required by that party for that purpose, disclosure is made on a confidential basis, and that party agrees to use the information only for that purpose,
a public authority or agent of a public authority, if in the reasonable judgement of Lüm Mobile it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information,
law enforcement or other government agencies if we are required to do so to meet legal and regulatory requirements; for exampe, if Lüm Mobile is required to provide records to law enforcement in response to a valid court order.

How Information is Retained

Your Rights

We'd like to have your consent to continue to collect, use, and disclose your personal information for the purposes that we have outlined.

However, you do have choices.

You can have your name removed from our marketing lists. By doing so, you may not be made aware of certain products, services, and promotions we offer. However, you'll continue to be contacted as necessary to service your account. If at any time you wish to reverse your decision, you may update your preferences in your myLüm account.

You may refuse to provide personal information to us. You may also withdraw your consent at any time, subject to legal, contractual, or practical restrictions and reasonable notice. However, in either case, this may limit our ability to serve you. When you contact us, we will confirm that you are the registered customer. Please know that withdrawing your consent may prevent us from providing you with service and products in certain circumstances.

Accountability

Our personnel are required to complete mandatory privacy training courses, and general staff education and training, to enhance awareness of responsibilities and commitments towards the proper handling of customer's personal information in accordance with our policies and procedures.

We may update this statement from time to time as reflected in the effective date of this document, so please review it periodically. You're also encouraged to review Lüm Mobile Terms of Service, Member Forum Terms of Service and Website Terms and Conditions provided on this website. They, too, are provided for your information and protection.

We welcome your comments about this Privacy Policy. Please contact us if you have questions about privacy and usage that weren't answered here. You may address these concerns, in writing, to:

Chief Privacy Officer
Lüm Mobile
13th Floor - 2121 Saskatchewan Drive
Regina, SK
S4P 3Y2
Email: privacyconcerns@lum.ca

If we are unable to resolve your concern to your satisfaction, you may contact the Saskatchewan Information and Privacy Commissioner by writing to:

Saskatchewan Information and Privacy Commissioner
503 – 1801 Hamilton Street
Regina, SK
S4P 4B4
Telephone: 306-787-8350
Toll Free Telephone (within Saskatchewan): 1-877-748-2298
Fax: 306-798-1603
Email: @email
Twitter: @SaskIPC

Last modified: December 3, 2021