LATD, Inc. d/b/a Latitude (hereinafter referred to as "Latitude," "us," "we," "our," or "Company") created this Privacy Policy to apply to information collected through this website (https://lumiere.is/) and all digital assets contained or offered therein ("Site"), and through any offline activities (collectively, our "Services"), except as described below. This Privacy Policy describes, among other things, the types of information we collect from users when you use our Services, how we use it, and how you can access your information.
This Privacy Policy is integrated into our Terms & Conditions of Use ("Terms & Conditions").
By using the Services and providing us with your Information (defined below), you acknowledge and agree to the practices described in this Privacy Policy and Terms & Conditions referenced above and to the updates to these policies posted here from time to time.
This Privacy Policy does not apply to information collected by or provided in connection with an individual's application for employment, current or former employment, or independent contractor arrangement with Latitude.
If you are coming to our Services from the European Union (EU), European Economic Area (EEA) or United Kingdom, or certain U.S. States, you may be entitled to certain individual rights under the applicable Data Protection Laws. Please see the Notice to Certain Residents of Data Subject Rights .
We may collect the following categories of information about you which are described in more detail below: (A) information you provide to us, (B) information we may automatically collect, and (D) information we may receive from third parties. To the extent that this information includes, "Personal Information" or "Personal Data" as defined under the appliable law, this information is referred to collectively as "Information". Specifically, Information includes any information relating to an identified or identifiable natural person, who could be identified either directly or indirectly by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
In using our Services, you may provide us with Information, including, without limitation:
Washington My Health My Data Notice. You may provide us with Information that constitutes "Consumer Health Information" under the Washington State My Health My Data Act ("MHMDA"). Consumer Health Information includes personal information that is linked or reasonably linkable to a consumer and that identifies the consumer's past, present, or future physical or mental health status. We will only process this Consumer Health Information with your consent and in compliance with this Privacy Policy. To learn more, please visit our Consumer Health Information Privacy Notice .
Our Services may automatically collect the following categories of usage and technical Information about you. This Information is used by Latitude for the operation of the Services, to maintain quality of the Services, and to provide general statistics regarding use of the Services. This Information may include:
We and/or certain service providers operating on our behalf may collect information about your activity, or activity on devices associated with you over time, on our sites and applications, and across non-affiliated websites or online applications. We may collect this Information by using certain technologies, such as cookies, local storage, web beacons, and other similar technologies. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons.
Our use of online tracking technologies may be considered a "sale" or "sharing" under certain laws. To the extent that disclosing information to these online tracking technologies is deemed to be a "sale" or "sharing" under certain laws, you can opt out of these online tracking technologies by submitting a request via [INSERT LINK] or by broadcasting an opt-out preference signal. Please note that some features of our website may not be available to you as a result of these choices.
We may collect additional Information about you from third-party websites, social media platforms, such as, but not limited to, Medium, LinkedIn, X (formerly Twitter), and Instagram ("Social Media Platforms"), and/or sources providing publicly available information (e.g., from the U.S. postal service) to help us provide services to you, help prevent fraud, and for marketing and advertising purposes.
Information we may access about you, with your consent, may include, but is not limited to, your basic Social Media Platform information, your location data, your list of contacts, friends or followers and certain information about your activities on the Social Media Platform. Please keep in mind that when you provide Information to us on a third-party website or Social Media Platform, the Information you provide may be separately collected by the third-party website or the Social Media Platform.
This Privacy Policy only applies to Information collected by our Services. We are not responsible for the privacy and security practices of those other websites or Social Media Platforms or the Information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.
We use and process your Information for things that may include, but are not limited to, the following:
We may also use Information that has been de-identified and/or aggregated for purposes not otherwise listed above.
We may disclose your Information as set forth in the Privacy Policy and in the following circumstances:
For purposes of this Privacy Policy, "sell," "sold," or "sale" means the disclosure of Information for monetary or other valuable consideration but does not include, for example, the transfer of Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business. "Sharing" means disclosing or making available Information to a third-party for purposes of cross-context behavioral or targeted advertising. While we do not disclose information to third parties in exchange for monetary compensation, we disclose identifiers and Internet and network activity information to third-party advertising networks and analytics providers for purposes of marketing and advertising, and to improve and measure our ad campaigns. Such disclosures may be considered "sales" or "sharing" of Information under applicable laws. We do not sell or share sensitive Information, nor do we sell or share Information about individuals we know are under age sixteen (16).
We do not collect, use, or disclose sensitive Information beyond the purposes authorized by the applicable law. Accordingly, we only use and disclose sensitive Information as reasonably necessary and proportionate: (i) to perform our services requested by you; (ii) to help ensure security and integrity, including to prevent, detect, and investigate security incidents; (iii) to detect, prevent and respond to malicious, fraudulent, deceptive, or illegal conduct; (iv) to verify or maintain the quality and safety of our services; (v) for compliance with our legal obligations; (vi) with our service providers who perform services on our behalf; and (vii) for purposes other than inferring characteristics about you.
Our Services may contain links to other websites or services that are not owned or controlled by us, including links to Social Media Platforms, or may redirect you off our website away from our Services. We do not have control over the operation of these third-party websites, which have separate and independent privacy notices. We therefore have no responsibility or liability for the content and activities of these linked sites.
In addition, from our Services, you may be able to interact with third-party websites, for example, by "following" us on LinkedIn or by liking a post on X (formerly Twitter). If you choose to click on a link to these sites, your activities are not governed by this Privacy Policy and will be governed by the privacy policy on that third-party website. Please review their privacy policies and terms of service before disclosing any Information there.
This Privacy Policy only applies to Information collected by our Services. We are not responsible for the privacy and security practices of those other websites or Social Media Platforms or the Information they may collect (which may include IP address). You should contact such third parties directly to determine their respective privacy policies. Links to any other websites or content do not constitute or imply an endorsement or recommendation by us of the linked website, Social Media Platform, and/or content.
We use commercially reasonable and appropriate administrative, physical, and technical security measures to provide our Services and safeguard your information. However, no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, we do not promise or guarantee, and you should not expect, that your Information or private communications will always remain private or secure. We do not guarantee that your Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Information.
If you believe that your Information has been accessed or acquired by an unauthorized person, you should promptly Contact Us so that necessary measures can quickly be taken.
We will retain your Information for as long as needed to provide you Services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. We will retain and use your Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. In accordance with our routine record keeping, we may delete certain records that contain Information you have submitted to us. We are under no obligation to store such Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Information.
If you do not want to receive marketing and promotional emails from us, you may click on the "unsubscribe" link in the email to unsubscribe and opt-out of marketing email communications or see the Contact Us section below for more information.
To exercise choices regarding the marketing information you receive, you may also review the following links:
Residents of certain U.S. states may have rights and choices regarding their Information. To the extent any data protection law applies to our collection of your Information, this supplemental section of our Privacy Policy outlines the individual rights you may be entitled to and how to exercise those rights.
Depending on where you live and subject to certain exceptions, you may have some or all of the following rights.
To learn more about whether you are guaranteed certain rights, or to submit a request to exercise your rights, please contact us using any of the methods in the Contact Us section.
This section applies only to individuals coming to our Services from within the European Union (EU), the European Economic Area (EEA), and the United Kingdom ("UK"), and only if we collect through the Services any Information from you that is considered "Personal Data," as defined in the General Data Protection Regulation (GDPR) and the UK Data Protection Act 2018.
Unless otherwise stated, we are the Data Controller for the Information we process.
To the extent the GDPR and Data Protection Act 2018 apply, and we hold your Information in our capacity as a Data Controller as defined under those laws, you may request that we:
You may also revoke your consent for processing of your Information. If you wish to object to the use and processing of your Information or withdraw consent to this Privacy Policy, you can contact us using the information in the Contact Us section.
The requests above will be considered and responded to in the time-period stated by applicable law. Note, certain Information may be exempt from such requests. We may require additional Information from you to confirm your identity in responding to such requests.
You have the right to lodge a complaint with the supervisory authorities applicable to you and your situation, although we invite you to contact us with any concern as we would be happy to try and resolve it directly. Please contact us using the information in the Contact Us section.
The lawful basis for our processing of your Personal Data will depend on the purposes of the processing. For most Personal Data processing activities covered by this Privacy Policy, the lawful basis is that the processing is necessary for our legitimate business interests. Where we process Personal Data in relation to a contract, or a potential contract, with you, the lawful basis is that the processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. If we are required to share Personal Data with law enforcement agencies or other governmental bodies, we do so on the basis that we are under a legal obligation to do so. We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law, for example, before we collect precise location data from your mobile device.
Depending on what Personal Data we collect from you and how we collect it, we may also rely on various grounds for processing your Personal Data, including the following reasons:
If the processing of your Personal Data is based on your consent, the GDPR and Data Protection Act 2018 also allow users the right to access, revoke, or modify your consent at any time. Please contact us using the information in the Contact Us section, below, to review or modify your consents.
We are operated in the United States, and we may use service providers based in the United States to operate our business and our relationship with you. Please be aware that Information, including your Personal Data, that we collect will be transferred to, stored, and processed in the United States, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen. We maintain measures to address the transfer of your Personal Data between our group companies and between us and our third-party providers in accordance with applicable data protection laws and regulations.
We will retain your Information for as long as needed for the purposes described in this Privacy Policy. More specifically, the time we maintain your Information depends on the following factors:
Regardless of our reason for retaining your information, we delete all Information in accordance with our routine record keeping policies.
To exercise any of the rights described above, please submit a verifiable request to us via the methods described below. The verifiable request must:
To help protect your privacy and maintain security, if you request access to or deletion of your Information, we will take steps and may require you to provide certain information to verify your identity before granting you access to your Information or complying with your request. In addition, if you ask us to provide you with specific pieces of Information, we may require you to sign a declaration under penalty of perjury that you are the consumer whose Information is the subject of the request.
If permitted by the applicable data protection law, you may use an authorized agent to submit requests on your behalf provided that the authorized agent is a natural person or a business entity that you have authorized to act on your behalf. If you use an authorized agent, we will require: (1) proof of written permission for the authorized agent to make requests on your behalf, and identity verification from you; or (2) proof of power of attorney pursuant under applicable law. Only you or your authorized agent may make a verifiable consumer request related to your Information. We may deny a request from an authorized agent that does not submit proper verification proof. You may also make a verifiable consumer request on behalf of your minor child.
Email us: privacy@latd.com
Write us: 16 Broadway, Beverly, MA 01915
Our Services are targeted to individuals located inside and outside the United States, and we maintain significant operations in the United States. As such, the Services collect Information and process and store that Information in databases located in the United States. If you are visiting the Services from a country outside the United States, you should be aware that you may transfer personally identifiable Information about yourself to the United States, and that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting the Services and submitting any personally identifiable Information you consent to the transfer of such personally identifiable Information to the United States.
The Services are intended only for users over the age of thirteen (13). If we become aware that a user is under thirteen (13) (or a higher age threshold where applicable) and has provided us with Information, we will take steps to comply with any applicable legal requirement to remove such Information. Contact us if you believe that we have mistakenly or unintentionally collected Information from a child under the age of thirteen (13).
Individuals with disabilities who are unable to usefully access our Privacy Policy online may contact us to inquire how they can obtain a copy of our policy in another, more easily readable format.
We do not support "Do Not Track." Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable "Do Not Track" by visiting the "Preferences" or "Settings" page of your web browser. Do Not Track is different from Global Privacy Controls ("GPC"), which may notify websites of consumers' privacy preferences regarding the sale or sharing of Information, or the use of sensitive personal Information.
We reserve the right to change, modify or amend this Privacy Policy at any time to reflect changes in our products and service offerings, accommodate new technologies, regulatory requirements, or other purposes. If we modify our Privacy Policy, we will update the "Effective Date" and such changes will be effective upon posting. It is your obligation to check our current Privacy Policy for any changes.
If you have any questions about this Privacy Policy or the Information we have collected about you, please contact us at the following:
Email us: privacy@latd.com
Write us: 16 Broadway, Beverly, MA 01915
Effective Date: September 18, 2024