Privacy policy

Last updated on June 15, 2026

 

This Privacy Policy for EmberWorks LLC ("we", "us", or "our") describes how and why we collect, store, use, and share your personal information when you use our services ("Services"), including when you:

  • Visit our website at http://www.ember-works.com or any website of ours that links to this Privacy Policy;
  • Download and use the Lumina Link mobile application, or any other application of ours that links to this Privacy Policy; or
  • Engage with us in other related ways, including any marketing or events.

Questions or concerns? If you do not agree with our policies and practices, please do not use our Services. If you have questions, please contact us at info@ember-works.com.



SUMMARY OF KEY POINTS

This summary highlights the key points from our Privacy Policy. You can find full details in the sections linked below.

  • What personal information do we process? We may process personal information depending on how you interact with our Services, the choices you make, and the products and features you use. See Section 1.
  • Do we process sensitive personal information? We may process sensitive information (such as financial data) when necessary with your consent or as permitted by law. See Section 1.
  • Do we collect information from third parties? We may collect information from public databases, marketing partners, and social media platforms. See Section 1.
  • How do we process your information? We process your information to provide and improve our Services, communicate with you, prevent fraud, and comply with law. See Section 2.
  • With whom do we share your information? We share information only in specific situations and with specific third parties. See Section 4.
  • How do we keep your information safe? We maintain organizational and technical measures to protect your information, though no system is 100% secure. See Section 9.
  • What are your rights? Depending on your location, you may have rights to access, correct, or delete your personal information. See Sections 11, 13, and 14.
  • How do you exercise your rights? Visit https://www.ember-works.com/pages/contact-us or contact us directly at info@ember-works.com.



TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?

2. HOW DO WE PROCESS YOUR INFORMATION?

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

8. HOW LONG DO WE KEEP YOUR INFORMATION?

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

10. DO WE COLLECT INFORMATION FROM MINORS?

11. WHAT ARE YOUR PRIVACY RIGHTS?

12. CONTROLS FOR DO-NOT-TRACK FEATURES

13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

15. DO WE MAKE UPDATES TO THIS POLICY?

16. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE YOUR DATA?



1. WHAT INFORMATION DO WE COLLECT?

Personal Information You Provide to Us

In Short: We collect personal information that you voluntarily provide to us.

We collect personal information when you register for an account, express interest in our products or Services, participate in activities on the Services, or contact us. Depending on your interactions, we may collect:

  • Names, usernames, and passwords
  • Phone numbers and email addresses
  • Mailing and billing addresses
  • Debit/credit card numbers and payment data
  • Contact or authentication data
  • Profile information, photos, and content you post through the Lumina Link app

 

Sensitive Information

Where necessary and with your consent or as otherwise permitted by law, we may process sensitive information including financial data. All payment data is handled and stored by Shopify and Stripe. You can review their privacy policies at https://www.shopify.com/ca/legal/privacy and https://stripe.com/en-ca/privacy.

 

Social Media Login Data

If you register or log in using a social media account (such as Facebook, Google, or Apple), we will collect certain profile information from that provider as described in Section 6.

 

Application Data (Lumina Link App)

When you use the Lumina Link app, we may collect the following if you grant permission:

  • Geolocation Information. We may request access to your device's location (continuously or while using the app) to provide location-based features such as proximity messaging and contact discovery. You can change location permissions at any time in your device settings. Disabling location access may limit certain app features
  • Bluetooth and Device Features. We may request access to your device's Bluetooth, camera, storage, and other hardware features to support app functionality, including the radio-frequency communication features of Lumina Link. You can adjust these permissions in your device settings.
  • Mobile Device Data. We automatically collect device identifiers, operating system and version, app identification numbers, browser type, hardware model, mobile carrier, and IP address. This information is primarily used for security, troubleshooting, and internal analytics.
  • Push Notifications. We may request permission to send you push notifications about your account, messages, and app features. You can opt out at any time through your device settings or in-app notification preferences.
  • Radio Frequency Usage Data. Because Lumina Link uses public radio frequency spectrum for certain communications, we may collect metadata associated with message transmission (such as signal quality, transmission timestamps, and delivery status) to operate and improve the service. Note that public spectrum communications may be observable by third parties; we do not guarantee the confidentiality of transmissions made over public frequencies.

 

Information Automatically Collected

In Short: Some information is collected automatically when you use our Services.

We automatically collect certain technical information when you visit, use, or navigate the Services. This includes:

  • Log and Usage Data. IP address, browser type, device information, pages and files viewed, date/time stamps, and app feature usage.
  • Device Data. Device identifiers, hardware model, operating system, internet service provider, and system configuration.
  • Location Data. Device location (precise or approximate), derived from GPS, IP address, or other technologies. You may opt out by disabling location settings on your device, though some features may not function without location access.

 

Information Collected from Other Sources

We may obtain additional information about you from public databases, marketing partners, affiliate programs, social media platforms, and other third parties. This may include mailing addresses, email addresses, phone numbers, and behavioral or interest data, used to improve our marketing and the relevance of our Services.

Note: Your Google API data will be used in accordance with the Google API Services User Data Policy, including the Limited Use requirements.

 

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, prevent fraud, and comply with law.

We process your personal information for the following purposes:

  • Account creation and authentication — to create and maintain your account.
  • Service delivery — to provide the Services and features you request, including Lumina Link communications.
  • Order fulfillment — to process payments, returns, and exchanges.
  • User-to-user communications — to enable messaging and social features within the app.
  • Customer support — to respond to your inquiries and resolve issues.
  • Administrative communications — to send notices about our products, services, and policy changes.
  • Marketing and promotional communications — to send marketing emails and offers, where permitted by your preferences. You may opt out at any time.
  • Security and fraud prevention — to monitor and protect the security of our Services.
  • Analytics and improvement — to understand usage trends, evaluate marketing effectiveness, and improve our Services and user experience.
  • Legal compliance — to meet our obligations under applicable law.

 

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we have a valid legal reason to do so.

 

For Users in the EU and UK (GDPR / UK GDPR)

We may rely on the following legal bases:

  • Consent — where you have given us permission for a specific purpose. You may withdraw consent at any time.
  • Contract Performance — where processing is necessary to fulfill our contractual obligations to you.
  • Legitimate Interests — where processing is reasonably necessary for our business interests and does not outweigh your rights, such as improving our Services, fraud prevention, and marketing analysis.
  • Legal Obligations — where processing is required to comply with applicable law.
  • Vital Interests — where processing is necessary to protect someone's life or safety.

 

For Users in Canada

We process your information based on your express or implied consent, which you may withdraw at any time. In limited circumstances permitted by law, we may process information without consent, such as for fraud prevention, legal compliance, or safety purposes.

 

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We share information only in specific situations and with specific third parties.

 

Service Providers

We share your data with third-party vendors and service providers who perform services on our behalf under written contracts that require them to protect your data. These include:

  • Cloud computing and infrastructure: Google Cloud Platform, Firebase, Mapbox, Apple iCloud. These providers may process and store information necessary to host, operate, secure, and maintain our Services.
  • User authentication: Firebase Authentication, Google Sign-In, Apple Sign-In. These providers process information necessary to authenticate users and facilitate account creation and login.
  • Messaging and notifications: Firebase Cloud Messaging. This provider may process device identifiers and notification-related information necessary to deliver push notifications and service communications.
  • Analytics and crash reporting: Firebase Crashlytics. This provider may process technical, device, diagnostic, and usage information to help us identify and resolve technical issues and improve the performance and stability of our Services.
  • Website hosting, e-commerce, payments, and AI-assisted chat: Shopify, Stripe. Shopify processes information necessary to operate our online store and e-commerce functionality. We also use Shopify to power AI-assisted chat on our online store. Shopify may process customer data, including chat communications, to generate responses and to improve the quality of the Inbox agent over time. Stripe processes payment and transaction information necessary to facilitate payment processing.
  • Loyalty rewards: BLOY Loyalty Rewards. This provider may process customer information, including email addresses and information related to participation in our loyalty program, to manage loyalty points, rewards, and related program features.
  • App testing: Google Play Console, TestFlight. These providers may process application and device information necessary to test, distribute, and manage our mobile applications.

Third parties process your data only as instructed by us and are required to maintain protections consistent with applicable data protection law, including the EU-US and Swiss-US Data Privacy Framework Principles.

 

Other Sharing Situations

  • Business Transfers. We may share your information in connection with any merger, acquisition, sale of assets, or financing.
  • Affiliates. We may share information with our affiliates, who are required to honor this Privacy Policy.
  • Business Partners. We may share information with business partners to offer certain products, services, or promotions.
  • Legal Obligations and Protection of Rights. We may disclose your information where necessary to comply with applicable law, legal process, or governmental requests; enforce our agreements; protect the rights, property, or safety of EmberWorks LLC, our users, or others; or investigate, prevent, or respond to fraud, security incidents, or other unlawful activity.
  • Other Users. When you use social or public features of the Lumina Link app, your profile information and activity may be visible to other users or publicly accessible. Please be mindful of what you share in these areas.

 

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We use cookies and similar technologies to collect and store information.

We use cookies, web beacons, pixels, and similar technologies to maintain security, remember your preferences, and support basic site functions. We also permit third parties to use these technologies for analytics and advertising purposes, including to display tailored advertisements and send abandoned cart reminders.

We use Meta Pixel, a tracking and advertising technology provided by Meta, to help us measure advertising effectiveness, understand how visitors interact with our website, and support targeted advertising and marketing activities. Meta may receive information about your interactions with our website and related events through the Pixel, subject to applicable privacy settings and consent requirements.

Where these technologies constitute a "sale" or "sharing" of personal information under applicable US state laws, you may opt out as described in Section 13. For more detail, see our Cookie Policy at https://www.ember-works.com/pages/cookie-policy.

 

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you log in via a social media account, we receive limited profile information from that provider.

When you register or log in using a social media account (such as Google, Apple, or Facebook), we receive profile information such as your name, email address, profile photo, and other information you have made public on that platform. We use this information only as described in this Privacy Policy. We do not control how your social media provider uses your information — please review their privacy policies for details.

 

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: Your information may be transferred to and processed in countries other than your own, including the United States.

Our servers and those of our service providers are located in the United States and other countries. If you are located in the EEA, UK, Switzerland, or Canada, your information may be transferred to and processed in countries that may not have data protection laws equivalent to your own. We take the following measures to protect such transfers:

  • Standard Contractual Clauses (SCCs). We use the European Commission's SCCs for transfers from the EEA and UK. Our Data Processing Agreements are available at https://www.shopify.com/ca/legal/dpa.
  • EU-US and Swiss-US Data Privacy Framework. We comply with these frameworks as set by the US Department of Commerce. Under the frameworks, EU and Swiss individuals may request access to, correction of, or deletion of their personal data by contacting info@ember-works.com. If your complaint cannot be resolved through us, you may contact the relevant EU data protection authority, the Swiss FDPIC, or invoke binding arbitration for residual claims.

We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) and may be required to disclose personal information to law enforcement or government authorities in limited circumstances.

 

8. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information as long as necessary to fulfill the purposes in this Policy unless law requires otherwise.

We retain your personal information for as long as you maintain an account with us, or as required to fulfill the purposes described in this Policy, including legal, tax, and accounting obligations. When we no longer have a legitimate need to process your information, we will delete or anonymize it. If deletion is not immediately possible (for example, due to backup storage), we will securely isolate the data until it can be deleted.

 

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We use technical and organizational measures to protect your information, but no system is 100% secure.

We have implemented reasonable technical and organizational security measures to protect your personal information. However, no electronic transmission or storage technology can be guaranteed to be fully secure. You should only access the Services in a secure environment, and you transmit information to us at your own risk.

Please also note that Lumina Link uses public radio frequency spectrum for certain communications. Transmissions over public frequencies may be observable by third parties and are not guaranteed to be private or secure. Do not transmit sensitive personal information through the app's radio-frequency features.

 

10. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from children under 13, and certain features require users to be 18 or older.

The Lumina Link app requires users to be at least 13 years of age. Users aged 13 to 17 may only use the app with the consent of a parent or legal guardian. Certain features of the app — including some social features, location services, and in-app purchases — may require users to be 18 or older under applicable law.

The broader Services (including our website and e-commerce store) are intended for users who are 18 years of age or older, or the equivalent minimum age in their jurisdiction.

We do not knowingly collect, solicit, or market to children under 13. If we learn that a user under 13 has provided us with personal information, we will deactivate the account and delete such data promptly. If you believe we have collected data from a child under 13, please contact us at info@ember-works.com.

 

11. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: Depending on your location, you may have rights to access, correct, or delete your personal information.

In the EEA, UK, Switzerland, and Canada, your rights under applicable data protection laws may include:

  • The right to access and obtain a copy of your personal information
  • The right to rectification or erasure of your personal information
  • The right to restrict or object to processing
  • The right to data portability
  • The right not to be subject to solely automated decision-making that produces significant effects

To exercise these rights, contact us at info@ember-works.com or visit https://www.ember-works.com/pages/contact-us. EEA/UK residents may also complain to their local data protection authority. Swiss residents may contact the Federal Data Protection and Information Commissioner.

 

Withdrawing Consent

Where we process your information based on consent, you may withdraw consent at any time by contacting us using the details in Section 16. Withdrawal does not affect the lawfulness of processing that occurred before withdrawal.

 

Opting Out of Marketing

You may unsubscribe from marketing communications at any time using the unsubscribe link in our emails or by contacting us. You will continue to receive service-related communications necessary for your account.

 

Managing Your Account

You may review, update, or delete your account information at any time by logging into your account settings or contacting us. Upon a deletion request, we will deactivate or delete your account from our active systems, though we may retain certain information as required for fraud prevention, legal compliance, or other legitimate purposes.

Cookies

You may control cookies through your browser settings. Disabling cookies may affect certain features of our Services. See our Cookie Policy at https://www.ember-works.com/pages/cookie-policy.

 

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems include a Do-Not-Track ("DNT") setting. No uniform standard for recognizing or implementing DNT signals currently exists, and we do not respond to DNT signals at this time. If an industry or legal standard is adopted in the future, we will update this Policy accordingly. California law requires us to disclose this practice.

 

13. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Residents of certain US states have additional rights regarding their personal information.

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to access, correct, delete, or obtain a copy of your personal information, and to opt out of certain processing. These rights may be limited by applicable law.

 

Categories of Personal Information Collected (Past 12 Months)

The table below summarizes the categories of personal information we may have collected. See Section 1 for a full inventory.

 Category Examples Collected

A. Identifiers

Name, alias, postal address, phone number, unique personal identifier, IP address, email address, account name

YES

B. Personal information (California Customer Records statute)

Name, contact information, financial information

YES

C. Protected classifications

Gender, age, date of birth, race, ethnicity, marital status

NO

D. Commercial information

Transaction history, purchase and payment information

YES

E. Biometric information

Fingerprints and voiceprints 

NO

F. Internet/network activity

Browsing history, app usage, interactions with our Services and ads

YES

G. Geolocation data 

Device location 

YES

H. Audio/electronic/sensory

Images, audio, or video recordings in connection with our business

NO

I. Professional/employment information

Business contact details, job title, work history (job applicants only)

NO

J. Education information

Student records or directory information

NO

K. Inferences

Profiles based on collected data reflecting preferences and characteristics

YES

L. Sensitive personal Information

Account login credentials, debit/credit card numbers and financial account details

YES

 

We retain collected personal information for the duration of your account with us, or as otherwise required by law.

We have not sold personal information to third parties in the preceding 12 months. We have disclosed Categories A, B, D, F, G, K, and L to third parties for business purposes. See Section 4 for details on those third parties.

 

How We Collect and Share Personal Information

We collect personal information through targeting and marketing cookies, web beacons, pixels/tags, and Shopify Checkout tracking. See our Cookie Policy for more detail.

 

Your US State Privacy Rights

Depending on the state where you live, your rights may include:

  • Right to know whether we are processing your personal data
  • Right to access your personal data
  • Right to correct inaccuracies in your personal data
  • Right to request deletion of your personal data
  • Right to obtain a copy of personal data you previously shared with us
  • Right to non-discrimination for exercising your rights
  • Right to opt out of targeted advertising, sale of personal data, or profiling with significant legal effects

Additional rights may apply based on your state, including rights related to sensitive data, profiling disclosures, and third-party lists. Contact us to learn what applies in your state.

 

Exercising Your Rights

To exercise your rights, visit https://www.ember-works.com/pages/contact-us or email info@ember-works.com. You may designate an authorized agent to submit requests on your behalf with written, signed authorization. We will verify your identity before processing requests.

 

Appeals

If we decline your request, you may appeal by emailing info@ember-works.com. If your appeal is denied, you may submit a complaint to your state attorney general.

 

California "Shine The Light" Law

California residents may request, once per year and free of charge, information about any personal information we disclosed to third parties for direct marketing purposes in the preceding calendar year. Submit your request in writing to the contact details in Section 16.



14. DO OTHER REGIONS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: You may have additional rights based on the country where you reside.

Republic of South Africa

You have the right to request access to or correction of your personal information at any time. If you are unsatisfied with how we handle a complaint about our processing of your personal information, you may contact the Information Regulator:

  • General enquiries: enquiries@inforegulator.org.za
  • POPIA complaints: PAIAComplaints@inforegulator.org.za and POPIAComplaints@inforegulator.org.za



15. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes, we update this Policy as needed to stay compliant with applicable laws.

We may update this Privacy Policy from time to time. The updated version will be reflected by a new "Last updated" date at the top of this Policy. If we make material changes, we will notify you by posting a prominent notice or by sending you a direct notification (including via in-app notification where applicable). We encourage you to review this Policy periodically.

 

16. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this Policy, please contact us:

  • By email: info@ember-works.com
  • By post: EmberWorks LLC, 345 California St, Suite 600, San Francisco, CA 94104, United States

 

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE YOUR DATA?

Based on applicable law, you may have the right to request access to the personal information we hold about you, correct inaccuracies, or request deletion. You may also withdraw consent to our processing. To submit a request, visit https://www.ember-works.com/pages/contact-us or email info@ember-works.com. These rights may be limited in certain circumstances by applicable law.