Privacy Policy

Last updated: January 6, 2021.

This website is the responsibility of Lumen Labs (HK) Ltd (“Lumen Labs”). Lumen Labs understands that using the internet, downloading files and making purchases online involves a great deal of trust on your part. We take that trust seriously, which is why we seek to ensure the security and confidentiality of your personal data.

With this privacy policy, Lumen Labs provides transparency on the personal data collected and processed on the basis of this website. It follows the principle of the European Union’s General Data Protection Regulation (GDPR) that any information and communication relating to the processing of personal data should be easily accessible and easy to understand as well as formulated in clear and plain language. If you still have questions that are not addressed here, please submit them to us by:

Sending an email to:

Calling to: +852 5927 0128

Writing to:
Lumen Labs (HK) Limited
21st Floor, CMA Building
64 Connaught Road
Hong Kong

Your privacy is very important to us. Please read below to see how Lumen Labs handles information. Before you get to the details, here are a few of our fundamental privacy principles:

  • We aggregate and de-identify certain information about our members to use for business purposes.
  • We give you several ways to control the privacy of your personal information and are continuously working to enhance privacy options available to you.

Lumen Labs respects your privacy and shares your concern about the security of information you may submit to Lumen Lab’s websites and the related mobile applications and services (collectively, the “Services”). Our privacy policy (the “Privacy Policy”) explains the information we collect, how we use and share it, how to manage your privacy settings and your rights in connection with the Services.

Lumen Labs is headquartered in Hong Kong. If you are a resident of the European Union (“EU”), Lumen Labs is the controller of your personal data for the purposes of EU data protection law.

This policy was written in English. To the extent a translated version conflicts with the English version, the English version controls. Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through the Services.

We Collect, Use, Share and Otherwise Process Information

Lumen Labs relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Privacy Policy, including:

  • Where you have consented to the processing, which you can revoke at any time.
  • Where necessary to comply with a legal obligation, a court order, or to exercise and defend legal claims;
  • To protect your vital interests, or those of others, such as in the case of emergencies;
  • Where you have made the information public;
  • Where necessary in the public interest; and
  • Where necessary for the purposes of Lumen Labs or a third party’s legitimate interests, such as those of visitors, members or partners.

Our Legitimate Interests

We process your information in furtherance of our legitimate interests, including:

  • Providing and improving the Services, including any personalized Services. We do so as it is necessary to pursue our legitimate interests of providing and developing innovative and tailored offerings to our members on a sustained basis; and
  • Keeping the Services safe and secure. We do so as it is necessary to pursue the legitimate interests of Lumen Labs and its members in ensuring the Services are secure, and to protect against fraud, spam and abuse, etc.

Information We Collect

Lumen Labs collects information about you, including information that directly or indirectly identifies you, if you or your other members choose to share it with us. We receive information in a few different ways, including when you track, complete or upload activities using the Services. We also collects information about how you use the Services. There are also several opportunities for you to share information about yourself and your activities with Lumos. For example:

  • We collect basic account information such as your name, email address, date of birth, gender, username and password that helps secure and provide you with access to our Services.
  • Profile and use information is collected about you when you choose to upload a picture, activity (including date, time and geo-location information as well as your speed and pace) or post, join a challenge, add your equipment usage, view others’ activities, or otherwise use the Services.
  • When you make a payment, you may provide payment information such as your payment card or other payment details. We use Stripe compliant third-party payment services and we do not store your credit card information.
  • We collect and process location information when you sign up for and use the Services. To record your ride and to provide you with your training statistics , it is necessary to collect and record the physical location of your device including, data such as speed and direction.
  • Lumen Labs allows you to sign up and log in to the Services using accounts you create with third-party products and services, such as Facebook or Google (collectively, “Third-Party Accounts”). If you access the Services with Third-Party Accounts we will collect information that you have agreed to make available such as your name, email address, profile information and preferences with the applicable Third-Party Account. This information is collected by the Third-Party Account provider and is provided to Lumen Labs under their privacy policies. You can generally control the information that we receive from these sources using the privacy settings in your Third-Party Account.
  • We collect information from your browser, computer, or mobile device, which provide us with technical information when you access or use the Services. This technical information includes device and network information, cookies, log files and analytics information.

Cookies and Similar Technologies

When you visit the Services, a cookie will be stored on your computer. Generally, cookies and similar technologies work by assigning to your browser or device a unique number that has no meaning outside of Lumen Labs. We uses these technologies to personalize your experience and to assist in delivering content specific to your interests. Additionally, after you’ve entered your member ID and password during a session on the Services, Lumen Labs saves that information so you don’t have to re-enter it repeatedly during that session.

Most browsers automatically accept cookies. To manage the collection of information through cookies or other equivalent technology you can use the settings on your browser or mobile device. We are committed to providing you choices to manage your privacy and sharing. However, Lumen Labs does not recognize or respond to browser-initiated Do Not Track signals, as the internet industry has not fully developed Do Not Track standards, implementations and solutions. Not accepting cookies may make certain features of the Services unavailable to you.

Log Files

The Services use log files. Stored information includes IP addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. This information is used to analyze trends, administer, protect and secure the Services, track member movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc., may be linked to session IDs, athlete IDs and device identifiers.

How We Use Information

Lumen Labs uses the information we collect and receive to administer and operate the Services and as otherwise described in this Privacy Policy. Your information, including your profile, username and photos.

We also use your information to analyze, develop and improve the Services. To do this, we may use third party analytics providers to gain insights into how our Services are used and to help us improve the Services. We may also use your information to market the Services, credit or accept payments, provide support related to the Services, protect members, promote safety, and communicate with you. Additionally, your information may be shared with third parties, as set forth below.

Lumen Labs may de-identify or aggregate the content you make available in connection with the Services, in ways that do not personally identify you. Examples of such aggregated information or statistical data include information about, usage, demographics, routes and performance.

We use your information to communicate with you about the Services, send you marketing communications (where you have agreed to receive such messages), or let you know about new features or updates. We also use your information to respond to you when you contact us. Lumen Labs will use your information to communicate with you, for example by sending you notifications.

How Information is Shared

Service Providers

We may share your information with third parties who provide services to us such as supporting and improving the Services, promoting the Services, processing payments, or fulfilling orders. These service providers will only have access to the information necessary to perform these limited functions on our behalf and are required to protect and secure your information. We may also engage service providers to collect information about your use of the Services over time on our behalf so that we or they may promote Lumos or display information that may be relevant to your interests on the Services or other websites or services.

Third Party Business via API or Other Integrations

When you choose to use third party apps that integrate with the Services, they may receive your information and content, including your personal information, photos, and your activity data (including private activities). Information collected by these third parties is subject to their terms and policies. Lumen Labs is not responsible for the terms or policies of third parties

Who controls your personal data, for which purpose and on which legal basis?

We want that our visitors and customers can effectively exercise their rights as data subjects. You have a right to know who is in control of your data and to whom you can address requests in your country. We as the controller of your personal data are responsible for the processing of your personal data on our side.

We also deem it important that you know the purpose of collecting and processing your personal data as well as the legal basis.

Finally, Lumen Labs collaborates with other companies to provide you an outstanding customer experience. For that reason we share your data with third parties. Some of them are located in the US while others are located in your country. You have a right to know who those third parties are and how we safeguard your data privacy rights when transferring your personal data.

  1. Who is the controller of your personal data and who is the local representative?
    As the controller, Lumen Labs determines the purpose and means of the processing of your personal data.
  1. What is the purpose and legal basis for processing your personal data? Who are other recipients of your personal data and how do we safeguard your data privacy rights?

    When you visit our website
    Purpose: The server logs will be used for the detection of malfunctions and for security reasons (e.g. denial of service attack detection).
    Legal basis: The processing of the server logs is lawful as it is within legitimate interests of the data controller.

    When you use our web shop
    Purpose: The personal data we collect allows us to process your order in our web shop located on our website. Collecting this information is essential to allow you, as our client, to place orders and purchase products from us.
    Legal basis: Based on the relationship between you as our client and us, as a seller, processing is lawful as it is necessary to perform your order.

    When you create an account on our website
    Purpose: The personal data we collect allows us to create and operating an account for you on our website. It makes using our web shop and purchasing goods with us more convenient for you.
    Legal basis: As we require your consent prior to creating an account, the processing of your personal data, in the course of creating and operating an account for you, takes place on the basis your consent given to us when creating an account (i.e. registration). You can delete your account at any time.

    When you subscribe to our newsletter
    Purpose: The personal data we collect allows us to send you newsletters and keep you updated on our products and services.
    Legal basis: As we require your consent prior to sending you a newsletter, the processing of your personal data, in the course of serving you with our newsletter, takes place on the basis of your consent given to us when subscribing to our newsletter. This service can be unsubscribed at any time.

    Note: We do not intend to further process your personal data for purposes other as the ones stated above.
  1. Our partners, other recipients of your personal data (third parties)

    To provide you with a smooth and first-rate purchasing experience we collaborate with trusted third parties which are recipients of your personal data. We and our partners take confidentiality and integrity of your personal data very serious. Lumen Labs will transfer personal data only if this is necessary for the performance of your order (e.g. to payment or logistic providers). Apart from this, personal data will only be transferred to third parties on basis of written contractual agreements and to the extent permitted by law respectively if we are obliged to transfer data by statutory provisions, a court order or an enforceable administrative order.
  1. Place of data processing and your data privacy rights

    The Lumen Labs website is hosted on servers located within the United States of America. When you visit our website, when you use our web shop, when you create an account on our website or subscribe to our newsletter, your data is therefore collected and processed within the United States. This takes place within a legal framework provided by the EU-US Privacy Shield. It protects the fundamental rights of anyone in the EU whose personal data is transferred to the United States. The Privacy Shield includes strong data protection obligations on companies receiving personal data, from the EU and provides effective protection and redress for you.

How long do we store your personal data? What are your rights and how can you exercise them?

Lumen Labs believes in fair and transparent processing of personal data. We deem it important to inform you on how long we store your personal data as well as on your rights and on how to exercise them.

How We Protect Information

We take several measures to safeguard the collection, transmission and storage of the data we collect. Although we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we do not guarantee or warrant the security of the information you share with us and we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content. No system is 100% secure. The Services uses industry standard Secure Sockets Layer (SSL) technology to allow for the encryption of personal information and credit card numbers. Lumen Labs engages a company that is an industry leader in online security and Services verification to strengthen the security of our Services. The Services are registered with site identification authorities so that your browser can confirm Lumen Labs identity before any personally identifiable information is sent. In addition, our secure servers protect this information using advanced firewall technology.

To help ensure that these measures are effective in preventing unauthorized access to your private information, you should be aware of the security features available to you through your browser. You should use a security-enabled browser to submit your credit card information and other personal information at the Services. Please note that if you do not use a SSL-capable browser, you are at risk for having data intercepted.

Most browsers have the ability to notify you if you change between secure and insecure communications, receive invalid services identification information for the Services you are communicating with, or send information over an unsecured connection. We recommends that you enable these browser functions to help ensure that your communications are secure. You can also monitor the URL of the services you are visiting (secure URLs begin with https:// rather than http://), along with the security symbol of your browser to help identify when you are communicating with a secure server. You can also view the details of the security certificate of the services to which you are connected. Please check the validity of any Services you connect to using secure communications.


While we continue to work hard to protect your personal information, no data transmission over the Internet can be guaranteed to be absolutely secure, and we cannot ensure or warrant the security of any information you transmit to us. Transmitting personal information is done at your own risk.

Managing Your Settings

Adjust Notification and Email Preferences

Lumen Labs offers various ways to manage the notifications you receive. You can choose to stop receiving certain emails and notifications by indicating your preference. You may also unsubscribe by following the instructions contained at the bottom of each type of email. Any administrative or service-related emails generally do not offer an option to unsubscribe as they are necessary to provide the Services you requested.

Updating Account Information

You may correct, amend or update profile or account information that is inaccurate at any time by adjusting that information in your account settings. If you need further assistance, please contact us at We will generally respond to your request within 7-10 business days.

Deleting Information and Accounts

You may request that your account is deleted.Once deleted, your data, including your account, activities and place on leaderboards cannot be reinstated.

Note that content you have shared with others or that others have copied may also remain visible after you have deleted your account or deleted the information from your own profile.

EU Members’ Rights

If you are habitually located in the European Union, you have the right to access, rectify, download or erase your information, as well as the right to restrict and object to certain processing of your information. While some of these rights apply generally, certain rights apply only in certain limited circumstances. We describe these rights below:

Access and Porting

  • You can access much of your information by logging into your account. If you require additional access or if you are not a Lumos member, contact us at

Rectify, Restrict, Limit, Delete

  • You can also rectify, restrict, limit or delete much of your information by logging into your account. If you are unable to do this, please contact us at We will generally respond to your request within 10-14 business days.


  • Where we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons.

Revoke consent

  • Where you have previously provided your consent, such as to permit us to process health-related data about you, you have the right to withdraw your consent to the processing of your information at any time. For example, you can withdraw your consent. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.


  • Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority.

Retention of Information

We retain information as long as it is necessary to provide the Services to you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until you ask us to delete it or your account is deleted whichever comes first. Additionally, we may retain information from deleted accounts to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

Information about you that is no longer necessary and relevant to provide our Services may be de-identified and aggregated with other non-personal data to provide insights which are commercially valuable to us, such as statistics of the use of the Services.

Other Sites

Lumen Labs maintains certain websites that can be accessed outside of, such as, (the “Other Sites”). The Other Sites maintain the look and feel of the Services, but are hosted by outside service providers with their own terms and privacy policies. If you interact with the Other Sites, your information may be stored, processed, or shared outside of the Services. If you interact with the Other Sites, you acknowledge that you may be subject to the terms and conditions and policies applicable to such Other Site. Please be aware that any personal information you submit to the Other Sites may be read, collected, or used by other users of these forums indefinitely, and could be used to send you unsolicited messages. Lumen Labs is not responsible for the personal information you choose to submit via the Other Sites.

Privacy Policy Information

Lumen Labs reserves the right to modify this Privacy Policy at any time. Please review it occasionally. If Lumen Labs makes changes to this Privacy Policy, the updated Privacy Policy will be posted on the Services in a timely manner and, if we make material changes, we will provide a prominent notice. If you object to any of the changes to this Privacy Policy, you should stop using the Services and delete your account.

Our Analytics Partners

Our Analytics Partners help us improve the quality of our site, and improve the relevance and frequency of advertisements you receive. We have carefully selected each of our Analytics Partners, and are confident they take your privacy as seriously as we do.

Our Analytics Partners use a variety of techniques to collect de-identified, non-personal information about your visit to our website. These techniques are discussed in the “Does Lumos Use Cookies?” section of our privacy policy, and may include session and persistent cookies, web-beacons, and other tracking technologies.

In order to make sure you understand how our Analytics Partners handle your information and how they interact with our site, app, or services, we’ve listed each of our Analytics Partners below, explained what they do, and shared hyperlinks to their Terms of Use. You should visit these pages, as Lumen Labs has no ability to control or monitor our Analytics Partners’ data collection or data use practices.

Google Analytics — Lumen Labs partners with Google Analytics to provide insight into our site, and to improve the relevance of advertisements you receive. Google Analytics’ terms are available here:

Facebook — We work with Facebook as a digital marketing and advertising platform to connect with potential users and customers. Facebook’s terms are available here:

Optimizely — We work with Optimizely to provide insight into our site and improve on our site structure and experience. Optimizely’s terms are available here:

SumoMe — We work with SumoMe to provide insight into our site and improve on our site structure and experience. SumoMe’s terms are available here:

MixPanel — We work with Mixpanel to improve our insight into your use of our site. Mixpanel’s terms are available here:

Rakuten — We work with Rakuten to provide insight into how you engage with our site or ads, and for other commercial purposes. Rakuten's terms about the collection, use and sale of your personal data and your rights, please see the Services Privacy Policy and their Services Privacy Rights Request Form.

For information on how to opt-out of the services our Analytics Partners provide, you can visit the Digital Advertising Alliance’s Consumer Choice website at:

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