Effective Date: 06/10/2024

TL;DR: Your privacy is important to us at Integrate. We collect only the personal information necessary to provide and improve our Services. We do not sell your data to third parties. You can access, modify, or delete your data at any time. We are committed to complying with all applicable data protection laws, including the GDPR.

Privacy Policy

Luminum Solutions B.V. ("Integrate," "we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our services, including our website (integrate.fyi), mobile applications, browser extensions, plugins, and other related services (collectively, the "Services").

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Services.

1. Who We Are

Luminum Solutions B.V.

• Email: [email protected]
• KvK Number: 66904420

We are registered in the Netherlands and act as the data controller for the personal data we process.

2. What Data Do We Collect?

2.1 Personal Identification Information

We collect the following personal data directly from you:

• Account Information: Name, email address, and password when you register for an account.
• Profile Information: Any additional information you choose to add to your profile, such as a profile picture or bio.
• Contact Information: Information you provide when you contact us for support or with inquiries.

2.2 Content and Usage Data

• User-Generated Content: Notes, highlights, bookmarks, annotations, and any files you upload or create using our Services.
• Third-Party Integrations: Data from third-party services you connect to our Services (e.g., cloud storage providers, productivity tools), as authorized by you.
• Device and Usage Information: IP address, browser type, operating system, device identifiers, pages viewed, links clicked, in-app actions, and the date/time of your visits.

2.3 Cookies and Similar Technologies

We use cookies and similar technologies to enhance your experience. See our Cookie Policy for more details.

2.4 Marketing and Communications Data

• Preferences: Your preferences in receiving marketing communications from us.
• Survey Responses: Information you provide when participating in our surveys or promotions.

2.5 Information from Third Parties

We may receive personal data about you from various third parties:

• Service Providers: Analytics providers, payment processors, and marketing partners.
• Social Media Platforms: Information from your interactions with our profiles on social media platforms, in accordance with their privacy policies.

2.6 Specific Disclosures for Browser Extension Users The following section applies solely to users of the Integrate Chrome Extension.

To provide the functionality of the extension, we require specific browser permissions. We process the following data only when you explicitly interact with the extension:

• Page Content (Text & Media): We collect the specific text, images, or screenshots you select to save to your Integrate account. We do not passively scrape page content without your action.
• URLs and Page Titles: When you save a note or highlight, we collect the URL and Title of the web page to create a reference link for your saved content.
• Kindle & Goodreads Data: If you use our integration features, we collect book highlights and metadata from your Kindle Cloud Reader or Goodreads account to sync them with your Integrate profile.

Permissions Justification:

• activeTab / tabs: Used to access the URL and title of the page you are currently viewing to save your highlights.
• contextMenus: Used to allow you to right-click and save text directly to Integrate.
• storage: Used to save your user preferences and pending highlights locally on your device before syncing.

3. How Do We Collect Your Data?

3.1 Direct Interactions

You directly provide Integrate with most of the data we collect. We collect data when you:

• Register an Account: Provide personal details to create an account.
• Use Our Services: Interact with our applications and features.
• Communicate with Us: Send us emails, fill out forms, or participate in surveys.
• Participate in Promotions: Engage in contests, promotions, or events.
• Provide Feedback: Submit reviews or feedback about our Services.

3.2 Automated Technologies

As you interact with our Services, we automatically collect technical data about your equipment, browsing actions, and patterns. We collect this data using cookies, server logs, and similar technologies.

3.3 Third Parties or Publicly Available Sources

We may receive personal data about you from various third parties as set out below:

• Technical Data: From analytics providers such as Google Analytics, Posthog, Sentry, Auth0.
• Contact and Transaction Data: From providers of technical, payment, and delivery services such as Stripe.
• Social Media Data: From platforms when you interact with us through your social media account.

4. How Will We Use Your Data?

Integrate uses your personal data for the following purposes:

4.1 Providing and Improving Services

• Operate and Maintain Services: Ensure the proper functioning of our Services.
• Personalization: We use your data to personalize content and recommendations through profiling and certain automated decision-making processes. We allow setting preferences over how our systems profile you to optimize your experience, so we ensure profiling is truly improving your experience.
• Development: Analyze data to improve and expand our Services.

4.2 Account Management

• Authentication: Verify your identity when you log in.
• Customer Support: Respond to your inquiries and provide assistance.

4.3 Communication

• Service Updates: Inform you about changes or updates to our Services.
• Security Alerts: Notify you about security issues or breaches.
• Administrative Messages: Send you information about your account.

4.4 Marketing

• Promotional Materials: Send you newsletters, offers, and promotions, subject to your consent where required.
• Event Information: Inform you about events or webinars that may interest you.

4.5 Legal Compliance and Protection

• Compliance: Fulfill our legal obligations.
• Enforcement: Enforce our Terms of Service and other agreements.
• Protection: Protect the rights, property, or safety of Integrate, our users, or others.

5. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to provide the Services you have requested.
• Consent: Where you have provided consent for specific purposes (e.g., receiving marketing communications).
• Legitimate Interests: For our legitimate interests in improving our Services, ensuring security, and conducting marketing activities, provided these do not override your rights.
• Legal Obligations: To comply with applicable laws, regulations, and legal processes.

6. How Do We Share Your Data?

6.1 Service Providers

6.1 Service Providers and Sub-Processors We share data with specific third-party infrastructure providers to operate the Service. These providers are strictly limited to using your data for the purposes outlined below:

• Auth0: Used for secure user authentication and identity management.
• Stripe: Used to process payments. We do not store your full credit card information on our servers.
• Sentry: Used for error tracking and debugging to ensure service stability.
• Posthog / Google Analytics: Used to analyze aggregated usage patterns to improve the product experience.
• Cloud Hosting (Google Cloud): Used to securely store your User-Generated Content (notes and highlights).

6.2 Legal Requirements

We may disclose your personal data if required to do so by law or in response to valid requests by public authorities, including:

• Compliance with Legal Obligations: Responding to subpoenas, court orders, or legal processes.
• Protecting Rights: Enforcing our agreements or protecting the rights and safety of Integrate, our users, or others.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets, your personal data may be transferred to the successor entity. We will notify you via email and/or a prominent notice on our Services before your personal data becomes subject to a different privacy policy.

6.4 With Your Consent

We may share your personal data with third parties when you provide explicit consent to do so.

7. International Data Transfers

Your personal data may be transferred to and processed in countries outside the European Economic Area (EEA). When we transfer data outside the EEA, we ensure an adequate level of protection by:

• Standard Contractual Clauses: Using contractual provisions approved by the European Commission.
• Adequacy Decisions: Transferring data to countries recognized by the European Commission as providing an adequate level of data protection.
• Privacy Shield Frameworks: Although invalidated for EU-U.S. transfers, similar frameworks may apply in other contexts.

8. How Do We Store and Secure Your Data?

8.1 Data Security

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction, including:

• Encryption: Protecting data in transit and at rest using encryption technologies.
• Access Controls: Limiting access to personal data to authorized personnel.
• Security Assessments: Regularly reviewing our security practices.

8.2 Data Retention

We retain your personal data only as long as necessary to fulfill the purposes for which it was collected, including:

• Account Information: Retained as long as your account is active. Upon deletion, we will remove your data within 30 days, unless required otherwise by law.
• User-Generated Content: Retained until you delete it or delete your account.
• Legal Obligations: Data required for legal compliance will be retained according to statutory requirements.

After the retention period expires, we will securely delete or anonymize your personal data.

9. Your Data Protection Rights

Integrate is committed to ensuring you can exercise your rights under applicable data protection laws. You have the following rights:

• Access: Request access to your personal data and receive a copy.
• Rectification: Request correction of inaccurate or incomplete data.
• Erasure ("Right to be Forgotten"): Request deletion of your personal data under certain conditions.
• Restriction: Request restriction of processing your personal data under certain conditions.
• Data Portability: Receive your personal data in a structured, commonly used format and have it transmitted to another controller.
• Objection: Object to processing of your personal data based on legitimate interests or for direct marketing purposes.
• Withdraw Consent: Withdraw your consent at any time where we rely on consent to process your personal data.

To exercise any of these rights, please contact us at:

• Email: [email protected]
• Address: Schoterstraat 007, 2021HH, Haarlem

We will respond to your request within one month. We may need to verify your identity before fulfilling your request.

10. Marketing Communications

10.1 Opt-In

You will receive marketing communications from us if you have:

• Requested information from us.
• Registered for an account and have not opted out of receiving marketing communications.

10.2 Opt-Out

You can opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email.
• Contacting us at [email protected].

Please note that even if you opt out of marketing messages, we may still send you non-promotional communications, such as service updates or security alerts.

11. Cookies and Similar Technologies

Please refer to our cookie policy at https://integrate.fyi/cookies

12. Third-Party Links

Our Services may include links to third-party websites, plug-ins, and applications. Clicking on those links may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy practices. We encourage you to read the privacy policies of every website you visit.

13. Children's Privacy

Our Services are not intended for individuals under the age of 16. We do not knowingly collect personal data from children under 16. If you believe we have collected data from a child under 16, please contact us to request deletion.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by:

• Posting the updated Privacy Policy on this page.
• Updating the "Effective Date" at the top of this policy.
• Sending you an email notification if you have an active account.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.

15. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us:

• Email: [email protected]

16. Supervisory Authority

If you are located in the European Economic Area and believe we have not complied with applicable data protection laws, you have the right to lodge a complaint with your local supervisory authority or the Dutch Data Protection Authority (Autoriteit Persoonsgegevens): Autoriteit Persoonsgegevens

17. Data Protection Officer

At this stage, we have not appointed a Data Protection Officer as we are not required to under GDPR Article 37. If you have any data protection concerns, please contact us at [email protected].

18. Automated Decision-Making and Profiling

18.1 Use of Automated Decision-Making and Profiling

We use automated decision-making processes, including profiling, to analyze your content and behavior. This enables us to provide personalized services and tailor content to enhance your learning journey. By evaluating certain personal aspects, we aim to predict your preferences, interests, and needs to deliver a more customized experience.

18.2 How It Works

• Content Analysis: We assess the content you interact with, such as notes, highlights, and annotations, as well as your usage patterns within the Services.
• Behavioral Analysis: We analyze how you use our Services, including the features you utilize and the frequency of your interactions.
• Personalization Algorithms: Our systems use this information to recommend content, features, or services that are relevant to you.

18.3 Significance and Consequences

• Enhanced User Experience: The profiling allows us to provide you with more relevant content and resources, making your learning experience more efficient and enjoyable.
• Necessary for Service Provision: This automated processing is essential for delivering our Services as described in our Terms of Service.
• No Legal or Significant Impact: The automated decision-making does not produce legal effects or similarly significant impacts on you. It is solely used to improve service personalization.

18.4 Your Rights Regarding Automated Decision-Making

As the profiling and automated decision-making are necessary for the performance of the contract between you and us, and do not produce legal or similarly significant effects, certain rights to object may not apply.

If you have concerns about our use of automated decision-making and profiling, you may:

• Contact Us for Clarification: We are happy to explain how we use your data to enhance your experience.
• Discontinue Use of Services: If you do not agree with this processing, you have the option to discontinue using our Services by cancelling your account.

To discuss any concerns, please contact us at:

• Email: [email protected]

19. Provision of Personal Data

Providing your personal data is not a statutory requirement. However, certain data is necessary to provide you with our Services. Failure to provide such data may result in limited functionality or inability to access certain features.

20. Updates and Notifications

We will communicate any changes to this Privacy Policy via:

• Email Notifications: If you have provided your email address.
• Website Updates: Posting the updated policy on our website.