1.1 The (i) products of the Company include a wide range of consumer technology products, software solutions and digital services (“Products”); (ii) website domain https://circuithouse.tech and https://lumio.co.in (“Website”); and (iii) associated applications (“App”) (collectively referred to as “Platform”) is owned by CIRCUIT HOUSE TECHNOLOGIES PRIVATE LIMITED, a company incorporated under the Companies Act, 2013, and having its registered office address at Golden Corner No 1185, 11th Cross, 22nd Main HSR Layout, 1 Sector, Bangalore – 560102 (“Company” which expression shall, unless it be repugnant to the context thereof, be deemed to include its successors, affiliates, and permitted assigns).

1.2 The Company is committed to respecting your online privacy and recognizes your need for appropriate protection and management of any information you share with the Company on the Platform. This privacy Policy (“Privacy Policy”) explains how the Company will collect, use, share and process information in relation to the services provided on the Platform.

1.3 This Privacy Policy shall be deemed to be incorporated into the terms of use (“Terms”) and shall be read in addition to the Terms. In the event of any conflict between this Privacy Policy and the Terms, the interpretation placed by the Company shall be final and binding on you.

1.4 By accepting this Privacy Policy, through an affirmative action, you provide free, specific, informed, unconditional and unambiguous consent to the Company and understand and agree to the collection, use, sharing and processing of personal information as described herein. If you provide the Company with personal information about someone else, you confirm that: (a) such information is accurate and up-to-date; (b) such person is aware that you have provided their information; and (c) they consent to both, the disclosure and the use/processing of their information in accordance with this Privacy Policy. This Privacy Policy applies to all the current and former visitors, users and others who access the Platform.

2.1 This Privacy Policy is an electronic record in the form of an electronic contract formed under the Information Technology Act, 2000 and the rules made thereunder. This Privacy Policy does not require any physical, electronic, or digital signature.

2.2 By agreeing, accessing or using the Platform or giving the Company your information or otherwise clicking to accept this Privacy Policy, if and when prompted on the Platform, you undertake that you have the capacity to enter into a legally binding contract vide. this Privacy Policy, which constitutes a legally binding document between you and the Company under applicable law, in particular, the Indian Contract Act, 1872. The Company will collect and process your personal information and third-party data carefully, only for the purposes described in this Privacy Policy and only to the extent necessary as defined herein and within the scope of the applicable legal regulations. This Privacy Policy seeks to ensure that any personal information or third-party information handled by the Company is managed in a way that is ethical, compliant and adheres to best industry practices.

2.3 Please read the terms and conditions of this Privacy Policy carefully, before accepting the same and/or accessing or using the Platform. By accessing or using the Platform including its services or otherwise clicking to accept this Privacy Policy, if and when prompted on the Platform, you agree to the terms of this Privacy Policy. If you are accepting this Privacy Policy on behalf of another person or company or other legal entity, you represent and warrant that you have full authority to bind such person, company or legal entity to these terms. If you are accepting this Privacy Policy on behalf of a child or person with disability, you represent and warrant that you are a parent or legal guardian of such a child or person with disability, as the case may be.

2.4 This Privacy Policy describes the types of information the Company collects, why and how the Company uses the information, with whom the Company shares it, and the choices you can make about the Company’s use of the information.

2.5 This Privacy Policy also describes the measures the Company takes to protect the security of the information and how you can contact the Company about its privacy practices.

2.6 This Privacy Policy describes the Company’s current data protection policies and practices and may be amended/updated from time to time. The Company will notify you at least once in a year, or whenever there is a change in the Privacy Policy, by email or by posting a conspicuous notice on the Platform regarding its then applicable data protection policies. The Privacy Policy shall come to effect from the date of such update, change or modification. It is recommended that you regularly check this Privacy Policy to apprise yourself of any updates. Your acceptance or continued use of the Platform or provision of data or information thereafter will imply your unconditional acceptance of such updates to this Privacy Policy.

By performing the affirmative action, as deemed fit by the Company, you expressly, freely, unconditionally, and unambiguously consent to the Company’s use and disclosure of your Personal Information (as defined below) and third-party information in accordance with this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not accept this Privacy Policy or use the Platform.

4.1 Personal Information is defined as any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, is capable of identifying such person.

4.2 Personal Information: Personal Information means any information that may be used to identify an individual, including, but not limited to, the first and last names, telephone number, e-mail address, or any other contact information (as the case may be). The Company limits the collection of Personal Information to that which is necessary for its intended purpose.

4.3 Non-Personal Information: Non-personal information means information that does not specifically identify an individual, but includes information from you, such as your browser type, the URL of the previous websites you visited, your Internet Service Provider (ISP), operating system and your Internet Protocol (IP) address. The Company may gather any non-personal information regarding how many people visit the Platform, the pages they visit, their IP address, browser types and versions, time zone settings and locations, operating systems, device, connection information, screen resolution, usage statistics, default communication applications and other technology on the devices you use to access the Platform (hereinafter referred to as “Non-Personal Information”). The Company may also collect Non-Personal Information that you voluntarily provide, such as information included in response to a questionnaire, or a survey conducted by the Company

4.4 Usage Information: Usage Information includes without limitation all data and information collected automatically through the Platform (or through the third party analytics service providers), by use and access of the Platform in the nature of system administrative data, statistical and demographical data, and operational information and data generated by or characterizing use of the Platform including without limitation Non-Personal Information, cookies, Platform traffic, time spent on the Platform, number of visits to the Platform and other similar information and behaviour indicating the mode and manner of use of the Platform (hereinafter referred to as the “Usage Information”).

4.5 Personal Information, Non-Personal Information and Usage Information hereinafter shall be referred to as “Information”.

5.1 The Company may collect Information from you when you (a) sign up to make an account on the Platform; (b) voluntarily schedule calls for repair or maintenance with customer care; (c) voluntarily complete a survey or provide feedback in relation to the services provided by the Company; and/or (d) avail any other services provided by the Company on the Platform.

5.2 You hereby acknowledge and agree that all Information is provided by you to the Company voluntarily and the Information provided by you is not subject to any undue influence.

5.3 The Company may use cookies to monitor the Platform usage in accordance with paragraph 13 of this Privacy Policy including, without limitation, to provide useful features to simplify your experience when you use the Platform.

5.4 The Company may also collect Non-Personal Information based on your browsing activity and in relation to your use or access to the Platform like your Internet Protocol (IP) address, your operating system, your prior search results, etc.

5.5 Information collected by the Company from a particular browser or device may be used with another computer or device that is linked to the browser or device on which such information was collected

6.1 The Company uses the Information you provide to (a) fulfil your requests for the services offered by the Company; (b) respond to your Applications made on the Platform; (c) provide you with information about services available on the Platform and offer you other services that the Company believes may be of interest to you; (d) resolve any glitches on the Platform including addressing any technical problems; (e) improve the services and content on the Platform and your experience of navigating through the Platform and carrying out transactions on the Platform; and (f) manage the Company’ relationship with you.

6.2 The Company may use the Information to monitor your use of the Platform and may review and analyse the Information provided by you to provide you with customized services.

6.3 The Company may use your Non-Personal Information or Usage Information for internal business purposes, such as data analysis, research, developing new services and/or features, enhancing and improving existing services and identifying usage trends.

6.4 Subject to and in accordance with applicable laws, the Company has the right to use your Information for the purpose of conducting promotional/marketing related activities on the Platform, including but not limited to, using your Personal Information for making posters/banners to promote the Company’ services.

6.5 When you send an email message or otherwise contact the Company through the Platform, the Company may use the Information provided by you to respond to your communication by way of messages on the Platform, Short Message Service (SMS), WhatsApp messages, voice calls, email or through any other communication channels that the Company may deem fit. The Company may also archive such Information and/or use it for future communications with you to inform you regarding updates, newsletters, offers, new services and promotions.

7.1 The Company maintains your Information in electronic form on its servers. The Information is made accessible to employees, agents or partners and third-parties only on a need-to-know basis.

7.2 The Company does not rent, sell, or share Information with other people or with other non-affiliated entities, except with your consent or to provide services you have requested for or under the following circumstances:

(a) The Company may share Information with the Company’s employees to contact you via email, phone, or otherwise for the provision of services being availed by you.

(b) The Company may engage third party vendors and/or contractors, to perform certain support services, who may have limited access to Information.

(c) The Company may share Information with government authorities in response to subpoenas, court orders, or other legal processes; to establish or exercise legal rights; to defend against legal claims; or as otherwise required by law. This may be done in response to a law enforcement agency's request.

8.1 The Company may engage third party vendors and/or contractors to perform certain support services, including, without limitation, fulfilment of your service requests, software maintenance services, advertising and marketing services, web hosting services and such other related services which are required by the Company to provide its services efficiently. These third parties may have limited access to Information. If they do, this limited access is provided so that they may perform these tasks for the Company and they are not authorized by the Company to otherwise use or disclose Information, except to the extent required by law. The Company does not make any representations concerning the privacy practices or policies or terms of use of such websites/apps, nor does it control or guarantee the accuracy, integrity, or quality of the information, data, text, software, music, sound, photographs, graphics, videos, messages or other materials available on such websites/apps. The inclusion or exclusion does not imply any endorsement by the Company of the website/app, the website/app's provider, or the information on such website/app.

8.2 The Platform may contain links and interactive functionality interacting with the websites of third parties. the Company is not responsible for and has no liability for the functionality, actions, inactions, privacy settings, privacy policies, terms, or content of any such websites. Before enabling any sharing functions to communicate with any such websites or otherwise visiting any such websites, the Company strongly recommends that you review and understand the terms and conditions, privacy policies, settings, and information-sharing functions of each such third-party websites.

The Company may disclose and/or transfer Information to an investor, acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the Company’s equity, business or assets.

10.1 You have the right to withdraw your consent at any point, provided such withdrawal of the consent is intimated to the Company in writing through an email at support@lumio.co.in requesting the same. If you at any time wish to rectify your Personal Information, you may write to the Company as per paragraph 11 of this Privacy Policy.

10.2 Once you withdraw your consent to share the Personal Information collected by the Company, the Company shall have the option not to fulfil the purposes for which the said Personal Information was sought and the Company may restrict you from using the services on the Platform and/or the Platform itself.

11.1 You shall have the right to review your Personal Information submitted by you on the Platform and to modify, correct, erase or delete any Personal Information provided by you directly on the Platform. You hereby understand that any such modification, correction, erasure or deletion may affect your ability to use the Platform. Further, it may affect the Company’ ability to provide its services to you.

11.2 The Company reserves the right to verify and authenticate your identity in order to ensure accurate delivery of services. Access to or correction, erasure, updation or deletion of your Personal Information may be denied or limited by the Company if it would violate another person’s rights and/or is not otherwise permitted by applicable law.

11.3 If you need to update, erase or correct your Personal Information that the Company may have collected to offer you services including, personalized services and offers, you may send updates, request for erasure and corrections to the Company at support@lumio.co.in citing the reason for such rectification or erasure of Personal Information. the Company will take all reasonable efforts to incorporate the changes within a reasonable period of time and such corrections shall be subject to validations, necessary documents, etc., as per requirement.

12.1 The Company shall store your Personal Information at least for such period as may be required and permitted by law or for a period necessary to satisfy the purpose for which the Personal Information has been collected. These periods vary depending on the nature of the information and your interactions with the Company.

12.2 You agree that you will not submit any false information or any illegal or damaging content to the Platform.

12.3 The Company reserves the right to terminate access to or the ability to interact with the Platform in response to any concerns the Company may have about false, illegal, or damaging content, or for any other reason, in its sole discretion.

13.1 The Company uses cookies and/or other tracking technologies to distinguish you from other users of the services and to remember your preferences on the Platform. This helps the Company to provide you with a good experience when you use the services on the Platform and also allows the Company to improve such services. Cookies are text files the Company places in your mobile phone, tablet or other devices to store your preferences. Cookies, by themselves, do not tell the Company your e-mail address or other personally identifiable information unless you choose to provide this information to the Company. They are designed to hold a marginal amount of data specific to a particular user. However, once you choose to furnish the Platform with personally identifiable information, this information may be linked to the data stored in the cookie. the Company uses cookies to understand Platform usage and to improve the content and offerings on the Platform. the Company may also use cookies to offer you programs or services. Cookies may be placed on the Platform by third-parties as well, the use of which the Company does not control.

13.2 Session cookies are automatically deleted from your hard drive once a session ends, and most cookies are session cookies. You may decline the cookies, however, if you decline the cookies, you may be unable to use certain features on the Platform and you may be required to re-enter your password frequently. You may opt to leave the cookie turned on.

14.1 The Company has taken adequate measures to protect the security of Information and to ensure that your choices for its intended use are honoured. the Company takes robust precautions to protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction.

14.2 The Company considers the confidentiality and security of your information to be of utmost importance. It therefore uses industry standards, and physical, technical and administrative security measures to keep Information confidential and secure and the Company will not share your Information with third parties, except as otherwise provided in this Privacy Policy. Please be advised that, however, while the Company strives to protect Information and privacy, the Company cannot guarantee or warranty its absolute security when Information is transmitted over the internet into the Platform. The Company will periodically evaluate this necessity considering your privacy and our relation while keeping the applicable legislation in mind.

14.3 For any loss or theft of Information, due to unauthorized access to your device through which you use the Platform or other reasons solely attributable to you, the Company shall not be held liable or responsible under any circumstance whatsoever. Further, the Company shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the Company’s reasonable control including but not limited to acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of internet service or telephone service of the user, etc.

The Company does not intend to attract anyone under the relevant age of consent or person with disability to enter into binding legal contracts under the laws of their respective jurisdictions. the Company does not intentionally or knowingly collect Personal Information through the Platform from anyone under that age person with disability. The Company encourages parents and guardians to be involved in the online activities of minor and person with disability to ensure that no Personal Information is collected from a minor and person with disability without their prior consent. If you are using the Platform on behalf of someone else, including but not limited to, on behalf of your minor child/children/employer or person with disability, you represent and warrant that you are authorised by such person to accept this Privacy Policy on their behalf and to consent on behalf of such person to the Company’s use of such person’s Personal Information as described in this Privacy Policy. If you are accepting this Privacy Policy on behalf of a child or person with disability, you represent and warrant that you are a parent or legal guardian of such a child or person with disability, as the case may be.

16.1 The Company shall not be liable to you for any loss of profit, production, anticipated savings, goodwill or business opportunities or any type of direct or indirect, incidental, economic, compensatory, punitive, exemplary or consequential losses arising out of performance or non-performance of its obligations under this Privacy Policy.

16.2 The Company is not responsible for any actions or inactions of any third parties that receive your Information.

16.3 Notwithstanding anything contained in this Privacy Policy or elsewhere, the Company shall not be held responsible for any loss, damage or misuse of your Information, if such loss, damage or misuse is attributable to a Force Majeure Event. The term “Force Majeure Event” shall mean any event that is beyond the Company’s reasonable control and shall include, without limitation, sabotage, fire, flood, explosion, acts of God, civil commotion, strikes, lockouts or industrial action of any kind, riots, insurrection, war, acts of government, computer hacking, civil disturbances, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, pandemic or national/state lockdown due to any reason and any other similar events not within the Company’ control and which the Company is not able to overcome.

Once you use or access the Platform, you may receive communications, including but not limited to emails, Short Message Service (SMS), phone calls, e-mails and other digital communications. You have the option to 'opt-out' of all newsletters and other general promotional communications from the Company by way of links provided at the bottom of the mailers or by contacting the customer service team. It is hereby clarified that in the event of such opt-out, communications pertaining to transactions and services shall continue. The Company respects your privacy and in the event that you choose to not receive such mailers, the Company shall take all adequate steps to remove you from such lists. However, you will not be able to opt-out of receiving administrative messages, customer service responses or other transactional communications.

This Privacy Policy shall be governed by and interpreted and construed in accordance with the laws of India. The place of jurisdiction shall exclusively be in Bangalore. In the event of any dispute arising out of this Privacy Policy the same shall be settled by a binding arbitration conducted by a sole arbitrator, appointed jointly by both parties and governed by the Arbitration and Conciliation Act, 1996, as amended from time to time. The venue and seat of arbitration shall be Bangalore.

For registering your concerns, complaint or grievances, please write to the below mentioned designated officer of the Company at the below-mentioned email address in relation to any violation of this Privacy Policy or the applicable laws. The designated officer shall redress the concerns, complaint or grievances in accordance with the applicable laws.
Name: Parameswaran
Address: 2nd Floor, Golden Corner,1185,22nd B Main Road, 1st Sector, HSR Layout, Bengaluru, Karnataka -560102.
Mobile No: +91 9980599231
Email: grievance@lumio.co.in

If you have questions or concerns about this Privacy Policy, please contact the Company on the below mentioned:
Email: compliance@lumio.co.in
Phone: +91 080 31194589