Coulomb Inc. (d/b/a Lumin), a Delaware corporation (referred to in this Privacy Policy as “Lumin”, “we”, “us”, or “our”) respects your privacy and we are committed to protecting it through compliance with this Lumin Privacy Policy (this “Privacy Policy”). This Privacy Policy is part of the Lumin Service User Agreement, located at https://luminsmart.com/legal/useragreement (the “User Agreement”). Except as otherwise defined herein, all terms used in this Privacy Policy have the meanings set forth in the User Agreement.

1. Introduction. This Privacy Policy describes the types of information we may collect through your use of the Lumin Service and our practices for collecting, using, maintaining, protecting, and sharing that information. This Privacy Policy applies to all information that we collect through the Lumin Service, whether you access or use the Lumin Service from a computer via the Internet or through a software application provided by Lumin for accessing the Lumin Service from a mobile device. This Privacy Policy does not apply to information that you provide to third parties or that we may collect from you or about you in other ways, including through e-mails you may send to us or through third parties.
2. Updates to Privacy Policy. As technology changes and as our business grows and develops, we may modify this Privacy Policy from time to time. Changes to this Privacy Policy will be made and will become effective as described in the User Agreement.
3. Children Under Age 18. We are committed to protecting the privacy of children under the age of eighteen (18) years (each a “Child” and collectively, “Children”). Use of the Lumin Service by Children is prohibited by the User Agreement. The Lumin Service is not designed for or marketed to Children, and we do not knowingly collect Personal Information (as defined below) from Children. If we learn we have collected or received Personal Information from a Child, we will delete that information. If you believe we might have any information from or about a Child, please contact us at: [email protected].
4. Definitions.As used in this Privacy Policy:
   1. “Personal Information” means personally-identifiable information (information relating to an individual that can be used to identify, locate, or contact that individual, alone or when combined with other personal or identifying information), such as: name, home or physical address, e-mail address, phone number, or personal characteristics, Sensitive Information (as defined below), or any other information about an individual that we collect through the Lumin Service and maintain in personally identifiable form in combination with other personally- identifiable information.
   2. “Sensitive Information” means Social Security numbers, passport numbers, driver’s license numbers, bank account numbers, credit or debit card numbers, insurance policy numbers, login or authentication credentials (such as passwords), or other similar information.
   3. “Non-Personal Information” means information or content other than Personal Information, including, for example, aggregated, anonymized, or de-identified information about our users and other information that does not identify any individual. Non-Personal Information may include the location from which you are accessing or using the Lumin Service.
5. Types of Information Collected.
   1. Visitor Information. We may automatically collect information about you when you use the Lumin Service, such as the materials you access, the amount of data transferred, the links you click, the amount of time you spend interacting with content, the location from which you are accessing or using the Lumin Service, and other information about your interactions with the Lumin Service, as well as certain standard information that your browser sends to every website that you visit, including your Internet Protocol (IP) address, operating environment (such as browser type and version, browser plugins installed, operating system version, regional and language settings, screen size and/or resolution, windows size, and page size), access dates and times, and referring websites. The Lumin Service may use cookies, flash cookies, web beacons, and other technologies for a variety of purposes, such as saving and retrieving information about you and your visit. We may use such technologies to share non-Personal Information with third parties or to retrieve Non-Personal Information from third parties. At this time, the Lumin Service does not respond to “Do Not Track” signals sent to us by your browser.
   2. Google Analytics. We may, from time to time, use a tool called “Google Analytics” (including Google Analytics Demographics and Interest Reporting features) to collect information about your use of the Lumin Service, which helps us provide content that is relevant to you and optimized for the devices that you use (such as smartphones and tablets). We respect and value your privacy, and we never combine the information collected through the use of Google Analytics with Personal Information. We use the information we receive from Google Analytics only to improve the Lumin Service and our content and marketing. Google’s use and sharing of information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using Google’s Ad Settings tool. As an added privacy measure, you can use the Google Analytics Opt-out Browser Add-on.
   3. Information You Provide. In order to use certain features of the Lumin Service, you must create a Lumin Account. When you create or use a Lumin Account, you may provide us with a variety of information, such as your name, postal address, physical address, e-mail address, phone number, and other types of information. We will store and use such information only in accordance with the User Agreement and this Privacy Policy.
6. Cookie Policy.We may use cookies and other similar technologies, such as HTML5 local storage, to provide the Lumin Service.
   1. Cookies and Local Storage. Cookies are small text files placed onto your device when you visit and interact with the Lumin Website. Local storage is a technology that allows a website or application to store information locally on your device. These technologies enable us to provide and enhance your experience using the Lumin Service.
   2. How We Uses Cookies and Local Storage. We use these technologies to provide the Lumin Service to you and to analyze and improve the Lumin Service. Our uses generally fall into one of the following categories:
   3. Essential Processes and Security: To enable essential functions of the Lumin Service, such as to facilitate logging you in to the Lumin Service, protecting your security, and helping us fight spam, abuse, and violations of the User Agreement.
   4. Preferences: To remember information about your browser and your preferences.
   5. Performance, Analytics, and Research: To help us understand and measure how you use the Lumin Service and to improve the Lumin Service.
   6. Blocking and Removing Cookies. We are committed to protecting your privacy, as described in this Privacy Policy. Most browsers allow you to modify your settings to accept or deny all cookies or to request your permission each time a website attempts to place a cookie on your device, and most browsers allow you to delete cookies that have already been placed on your device. However, the Lumin Service will not function properly if you prevent it from placing cookies on your device.
7. Use of Non-Personal Information. We may use Non-Personal Information (including, for example, aggregated information about our users or information that does not identify any individual) for any purposes whatsoever (including without limitation, advertising, marketing, enhancing, designing, or developing products and/or services, and research), and we may share Non-Personal Information with others, including our partners, affiliates, and our service providers.
8. Use of Personal Information.
   1. We will only store and use your Personal Information as is reasonably necessary or appropriate in connection with the use of the Lumin Service, including: (a) to contact you in connection with your use of the Lumin Service, including to respond to your inquiries; (b) for authentication and identification purposes; (c) to enable us to provide the Lumin Service and the features of the Lumin Service; (d) to provide you with notices about your Lumin Account; (e) to fulfill any other purpose for which you provide such information to us; (f) in any other way we may describe when you provide the information; (g) to carry out our obligations and enforce our rights; (h) to ensure your compliance with the User Agreement or to investigate any potential breach of the User Agreement; and (i) to protect our networks, data, software, or business interests. You understand and agree that we may transfer, process, maintain, and store your Personal Information, your Account Information, and other information in any country (or in multiple countries), including countries other than your country of residence or the country or countries where you use the Lumin Service.
   2. We are committed to protecting your privacy and we will not sell, lease, or disclose your Personal Information to any third party except as described in this Privacy Policy.
   3. In addition to using and disclosing your Personal Information in the manner described above and elsewhere in this Privacy Policy, we may disclose your Personal Information:
      1. to any person, entity, or organization which you consent for us to disclose your Personal Information to;
      2. to electric utility companies and cooperatives if you have authorized us to share your Personal Information with such electric companies or cooperatives or if you have separately agreed with an electric company or utility that it can access and use your Personal Information in connection with your use of the Lumin Service.
      3. to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about our users is among the assets transferred;
      4. to our business partners, service providers, vendors, and agents who provide hosting services, technical support services, order processing services, payment processing services, and as is necessary or appropriate in connection with the processing and fulfillment of your orders or the operation, maintenance, and support of the Lumin Service;
      5. to any person, entity, or organization in order to facilitate the provision of the Lumin Service or the processing or fulfillment of subscription requests, such as providing your name, contact information, subscription details, and payment information to our third party order and payment processor(s) if you order a Lumin Smart Panel;
      6. to comply with any legal requirements, subpoenas, discovery requests, or court orders, to defend any legal or administrative proceedings, or as we believe in good faith is necessary to comply with any laws or legal requirements;
      7. as we believe is necessary or appropriate in an emergency situation, including without limitation, to prevent criminal activity, personal injury, or property damage;
      8. to law enforcement, financial institutions, or other appropriate authorities in connection with any investigation of suspected criminal or fraudulent activity by any person or entity; and
      9. if we believe it is necessary or appropriate to protect the rights, property, or safety of the Lumin Parties, our users, customers, or other third parties (including, without limitation, to facilitate the enforcement of our rights under the User Agreement).
9. Advertising; Opt-In Sharing Features. We may allow third parties to advertise on or using the Lumin Service, promoting products and/or services that we believe may be of interest to users of the Lumin Service. However, Lumin is not responsible for the products or services provided by third parties who advertise on or using the Lumin Service. Some third-party advertisements may enable you to click on a link to obtain additional information regarding the products or services being advertised or to provide contact information to receive such information. If you click on any such link, you will be redirected to a third-party website or location which is not controlled by Lumin. Any Personal Information or other information that you provide to an advertiser (whether using the Lumin Service or at the website of such advertiser) is not subject to this Privacy Policy and Lumin cannot control how a third-party advertiser may use information that you voluntarily disclose to such advertiser. You should carefully review the privacy policy of such third party before providing any Personal Information to a third party which advertises on or using the Lumin Service. We will not knowingly disclose your Personal Information to a third party if we know or have reason to believe that the third party will use your Personal Information for direct marketing purposes without your prior consent.
10. Security. We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure, including the use of TLS to encrypt information you send through the Lumin Service. The safety and security of your information also depends on you, and you are responsible for safeguarding your Login Credentials and notifying us of any unauthorized access to or use of your Lumin Account. Unfortunately, the transmission of information via the Internet is not completely secure. Despite our measures to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to or through the Lumin Service. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures of the Lumin Service or of our service providers, agents, or other third parties.
11. Third Party Sites. The Lumin Service may contain links to other websites that are operated by third parties. Once you have clicked on a link connecting you to such third-party website, you will leave the Lumin Service and be taken to a website that we do not control. This Privacy Policy does not apply to any Personal Information (or other information) collected on a third- party site. We suggest you read the privacy policy of the third-party site before providing any Personal Information on such third party site. We are not responsible for any use by any person or entity of any information that you may provide while accessing or using any websites or services provided by a third party.
12. Access to and Change of Personal Information. You may contact us at any time to: (a) request the removal of the Personal Information you provided to us from our databases; and (b) update your Personal Information. However, certain information associated with your Lumin Account and with orders you place for Lumin Smart Panels may be retained permanently for legal, tax, and business reasons. In addition, because certain Personal Information may be necessary to provide the Lumin Service to you, you understand that the removal of that Personal Information may require us to delete your Lumin Account. When your Personal Information or your Account Information is updated or deleted, copies of such information may remain in our backups.
13. Contacting Us. If you have any questions about this Privacy Policy, you may contact us by e-mailing us at [email protected] or by writing to us at Lumin, 501 Locust Ave, Floor 1, Suite 102 Charlottesville, Virginia 22902.