Our Privacy Policy

About this policy

Blocks Global Pty Ltd and Lumin NZ Limited (together, we, us, our and Lumin) are committed to protecting the privacy of personal information that we hold.

We collect and hold a range of personal information in carrying out our business and functions as a provider of tablets for seniors (Lumin CareHub) and related communications, entertainment, wellness, smart-home and emergency services (Lumin Service). This Privacy Policy explains how we collect, use, disclose and hold personal information and how to contact us if you have any queries about personal information that we hold about you.

In this policy, a Customer refers to our end user customer of the Lumin CareHub and services. Where we refer to a Supporter, this is a friend or family member of a Customer, as nominated by the Customer. We refer to Village to mean the retirement village or other aged care facility of which the Customer is a resident.

This policy applies to any personal information we collect through the use of the Lumin CareHub, the Lumin Service, and any of our other products and services. It also applies to personal information we collect through other means, such as the Lumin website (mylumin.org), attendance at events or through marketing and promotional activities, and from third parties.

If you are a Customer, or a Supporter, when you register for an account with us we will also provide you with a Privacy Collection Notice, which confirms the facts and circumstances of the collection of personal information and sets out more specific information about how we handle such personal information.

What is personal information?

'Personal information' is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. Examples include an individual's name, address, contact number and email address.

'Sensitive information' is a special category of personal information. Sensitive information includes health information and information or an opinion about an individual's race or ethnic origin, political opinions, religious or philosophical beliefs, membership of a professional or trade association, or trade union, criminal record, sexual orientation or practices, genetic information and certain biometric information.

Personal information we collect and hold

The kinds of personal information we collect and hold about you will depend upon the nature of our relationship with you and the circumstances of a collection, including whether we collect the information from you as a Customer, a Supporter or a contact person at a Village.

Information we collect about you as a Customer includes:

• your name, date of birth, address, telephone number and email address
• profile picture and any other information that you provide for your user profile, including the radio stations and podcasts you like to listen to
• name and contact details for your Supporters
• payment details you provide to us for the Lumin Service
• calendar inputs, photographs if you upload photographs to the photo application, and other information that you decide to input into the Lumin CareHub
• health information where you input medication reminders into your Lumin calendar and if you enable the emergency services and/or health monitoring features on the Lumin
• information about your interests and how you use and interact with the Lumin CareHub, for example, what applications are used and which content is watched or listened to, and whether the screen is not touched for a period of time (as part of our 24/7 remote monitoring)
• the device ID, make, model and operating version of the Lumin CareHub, and also the location of where the Lumin CareHub is installed
• personal information you provide to us when you contact us, or interact with us, such as for customer service or technical support, or where you provide us with feedback or make a complaint

Information we collect about you as a Supporter:

• your name, telephone number and email address (as supplied by the Customer, or added by you through the Supporters mobile application (Supporters App))
• details about the smartphone or tablet you use to access the Supporters App and the Lumin Service of a Customer, and the country of origin
• personal information you provide to us when you contact us or interact with us, such as for customer support or technical support, including the chatbot service we operate for the Supporters App

If you are the contact person or administrator at a Village, we may collect your name, position title, employer and contact details, and any personal information you provide to us when you contact us or interact with us.

If you apply for a job with us, we collect your name, contact details and any personal information you provide in connection with your application.

If you provide us with personal information about another person, please make sure that you tell them about this Privacy Policy.

Sensitive information we collect and hold

We may also hold personal information about our Customers that is considered health information under applicable privacy laws:

• Medication and other health-related appointments and reminders: If you are a Customer and you (or your Supporter) inputs medication reminders, or telehealth appointments, into your Lumin calendar, we collect this information so that it can be displayed in the calendar and reminders. By using this feature, you consent to us collecting and handling your health information for this purpose. We do not otherwise use or disclose this information.
• Emergency alerts: If you or your Supporter activates the duress-alarm or "Supporter Alert" feature on the Lumin, this will generate information in Lumin that you are in duress and require assistance (which is sent to the emergency services provider and your Supporters). It may also be sent to your Village, if they provide this service to you.
• Health and wellbeing monitoring: We offer health monitoring with the Lumin CareHub and peripherals. For example, monitoring if you have not interacted with the Lumin CareHub during the day. This will collect health information about you and share it with your Supporters (if any), and if you enable this service, our 24/7 call centre service providers.

Before you enable the emergency alerts or health monitoring services, we will ask for your consent to collect, use, disclose and handle your health information (through a separate form we ask you to sign).

How we collect personal information

If you are a Customer, most of the personal information we hold about you will be collected directly from you, through your interactions with us and from your use of the Lumin CareHub and the Lumin Service. But we may also collect personal information about you indirectly from your Supporters, your Village and anyone else authorised to act on your behalf.

We also collect personal information in a variety of other ways, including:

• from you directly (such as when you interact with us in writing, over the phone, by email, using online forms or through our website, mobile applications or social media channels)
• if you are a Supporter, indirectly from a Customer or a Village if they add you to a Customer's Lumin CareHub profile
• when you communicate with us through our website or social media channels

The purposes for which we collect, hold, use and disclose personal information

We collect, hold, use and disclose personal information for a range of purposes including:

• to provide the Lumin device and our services to Customers so you can engage with the Lumin CareHub and features
• to supply our other products and services you have requested
• if the emergency services feature is enabled, to notify emergency services and/or Supporters when the duress-alarm or "Supporter Alert" feature has been activated
• if the health monitoring service has been enabled, to monitor health and wellbeing, and notify Supporters, the Village and (if chosen) the 24/7 call centre
• to process any payments for additional subscribed services
• to monitor usage trends, and perform usage and data analysis, for the purpose of evaluating and improving our products and services
• for our administrative purposes and record keeping
• to provide you with customer service or technical support
• to maintain and improve customer services and seek your feedback
• to conduct marketing and promotional activities
• to comply with our legal and regulatory obligations
• to manage and resolve any legal or commercial complaints and issues
• to investigate fraud and to carry out loss prevention activities

Disclosure of personal information to third parties

In conducting our business and providing our products and services to you, we may disclose personal information to third parties for the purposes outlined above. Where we disclose personal information to a third party, we take reasonable steps to require those third parties to comply with applicable privacy laws.

For our Customers, we have set out below the third parties, or types of third parties, to which we may disclose personal information as part of the Lumin Service:

• Emergency Services Provider: If you have enabled the emergency services feature on Lumin, when you press the duress alarm or the "Supporter Alert" feature, an automatic notification is sent to the third party emergency services provider and your nominated Supporters.
• 24/7 Call Centre: If you have enabled the health and wellbeing monitoring feature and elect to connect to the 24/7 call centre, automatic notifications can be sent when a health and wellbeing issue is detected.
• Supporters: With your authorisation, Supporters may be invited to connect with your Lumin by downloading the Supporters App, enabling them to remotely share content with your Lumin.
• Village: If your Village provides an administrative function for registered Lumin CareHub users, we may disclose personal information about you to the Village.
• Payment and delivery fulfilment providers: We disclose customer details to our third party service providers to process payments and to arrange provisioning and ongoing support.

We may also disclose personal information to other third parties where required or authorised by law, including to our employees, contracted service providers, business partners, professional advisers, and law enforcement agencies.

Sale of personal information

We do not sell personal information to any third party for money. We also do not sell personal information to third parties for their own marketing purposes.

We may share de-identified and aggregated data and insights about our users with third parties for market research and health research purposes. We take precautions to ensure that this data cannot be re-identified.

Overseas disclosures of personal information

We host the Lumin Service in Australia and store Customer data in a secure data centre in Australia. However, we do use third party service providers as part of our ordinary business operations, which may include service providers located in the US.

Linking to third party services

If you are a Customer, you may access third party content and services using the Lumin CareHub. Before you use the third party's service or provide any personal information to the third party, please make sure you check the third party's website, any terms of service and privacy policy, carefully. We do not have control over the privacy practices of these third parties.

How we hold personal information

We generally hold personal information in computer systems, including computer systems operated for us by our service providers. We store minimal personal information on our servers required to deliver the Lumin Service. The Lumin Service and customer data is hosted in Australia in a secure third party data centre.

We take reasonable steps to protect personal information from misuse, interference, loss, and unauthorised access, modification or disclosure. When we no longer need personal information, we take reasonable steps to destroy or de-identify the information, unless we are required by law to retain it.

Direct marketing

We may use your personal information so we can contact you with information about our products and services, special offers, promotions and events that may be of interest to you. We may contact you by email, or through targeted online advertising on social media. You can let us know at any time if you no longer wish to receive these communications by contacting us or using the opt-out/unsubscribe facility in our email communications.

Our website

We generally do not collect personal information about you when you visit our website, unless you complete an online form or make an enquiry through the website. We use cookies on certain web pages to help improve the content and functionality of our website. The information collected about your visit using cookies is not personal information, because we cannot identify you from it.

Bot and spam protection on our forms

To protect our online forms from automated abuse, spam and fraudulent submissions, we use Cloudflare Turnstile, a bot-detection service provided by Cloudflare, Inc. When you interact with a form on our website, Turnstile collects a limited amount of technical information about your browser and device (such as your IP address, user agent, screen size, request headers and basic interaction signals) to determine whether you are a human or an automated bot. Turnstile does not set advertising cookies, does not track you across other websites, and this data is not used for advertising purposes.

We rely on our legitimate interest in keeping our website and services secure to use this service. For more information about how Cloudflare handles this data, please see the Cloudflare Turnstile Privacy Policy.

Access to and correction of your personal information

You have a right to request access to personal information that we hold about you and request its correction if it is inaccurate, out of date, incomplete, irrelevant or misleading. You may do so by contacting our support team. We will respond to all requests within a reasonable period (usually 30 days).

Privacy complaints

Please contact us if you have any concerns or complaints about the manner in which we have collected or handled your personal information. We will inquire into your complaint and respond within a reasonable period of time (usually 30 days).

If you are not satisfied with our response, you can lodge a complaint with the Office of the Australian Information Commissioner at oaic.gov.au, or writing to GPO Box 5288, Sydney NSW 2001.

For New Zealand based customers, if you are not satisfied with how we have dealt with the complaint, you may contact the Privacy Commissioner at Level 13, WHK Tower, 51 - 53 Shortland Street, Auckland 1140, New Zealand. Telephone 0800 803 909, email enquiries@privacy.org.nz.

Contact details

If you would like more information about the way we manage personal information, would like to request access to or correction of personal information that we hold about you, or wish to make a complaint, please contact our support team:

Changes to our privacy policy

From time to time it may be necessary for us to review and revise our Privacy Policy. We may notify you about changes to this Privacy Policy by posting an updated version on our website.

Our Privacy Policy was last updated in August 2023.