Privacy Policy

Who are we

When we refer to 'we’ (or 'our’ or 'us’), that means Ice Dragon Ltd, and our headquarters are based in the China.

Privacy notice overview

This Privacy Notice describes how and why we, as Data Controller, obtain, store and process personal data. 'Personal data’ means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. We commit to processing your personal data fairly, lawfully, and transparently. In the spirit of data privacy principles, we will only collect and use your personal data for the following purposes, to:

• Provide our services
• Improve our services
• Make our marketing more relevant
• Meet our legal responsibilities

Please do not hesitate to contact us if you have questions in addition to the information provided in this Privacy Notice.

Depending on the type and level of engagement you have with us, we may collect the following categories of personal data:

• Identifying and Demographic Information: such as your full name, date of birth, email address, and phone number (if provided)
• Billing Information: such as payment preferences, address, and bank account details (if provided)
• Communications: such as a record of our interactions with you using one or multiple of the following; direct messages, emails, posts, phone conversations
• User Feedback: while using our services, occasionally you may be asked to provide feedback. Providing this feedback is entirely optional.

When you visit our website, we collect technical data such as:

• Usage data: (if permitted) we collect certain information related to your device, such as your device’s IP address, what pages your device visited, and the time that your device visited our website (for more information please see 'Our Use of Analytics' section)
• Cookies: (if permitted) your IP Address and other information provided to us by cookies (for more information please see our Cookies Policy) While our services are designed for a general audience, we will not knowingly collect any data from children under the age of 16 or sell products to children. If you are under the age of 16, you are not permitted to use or submit your data to the website.

How we collect your data

We may collect your personal data in one of the following ways:

• When you create an account with us
• When you provide additional information directly into our products and services
• When you visit our website
• When you express an interest to use our services
• When you contact us for service-related queries
• When you engage with us on social media
• When you review our services
• When you interact with our website (see our Cookies Policy for more details)
• When you apply for an employment vacancy with us
• When you subscribe to our newsletter or blog
• When you contact us with queries using our website chatbot
• When you buy products/services using our online checkout

We may also receive data about you from various third parties, including:

• Technical data from analytics providers. Please see further information in the section entitled 'Our Use of Analytics'
• Technical data from our website and cookies providers. Please see further information in the section entitled 'Our Use of Cookies'
• Contact and/or transactional data from our trusted third-party providers. Please see further information in the section entitled 'How We Share Your Data'

How we use your personal data

We will only collect and process your personal data where we have a legal basis to do so. As a data controller, the legal basis for our collection and use of your personal data varies depending on the manner and purpose for which we collected it. We will only collect personal data from you when:

• We have your consent to do so, or
• We need your personal data to perform a contract with you, or
• We are pursuing our legitimate interests in a way that you might reasonably expect to be a part of running our business and that does not significantly impact your interests, rights, and freedoms. For example, communicating with you if we have sufficient legal ground based on the e-marketing laws in your country
• We have a legal obligation to collect or disclose personal data from you (for example, in suspected instances of fraud we may need to give personal data to relevant government bodies).

Why we process your personal data

We process your personal data in order to fulfil any of the activities below:

• Setting up an account with us
• Providing, operating and maintaining our services
• Providing communications to existing customers or subscribed users
• Processing and completing transactions, and sending related information, including transaction confirmations and invoices
• Managing our customers’ use of our services, responding to inquiries and comments, and providing customer service and support
• Sending customers technical alerts, updates, security notifications, and administrative communications
• Investigating and preventing fraudulent activities, unauthorised access to our services, and other illegal activities

How we share your data

We sometimes share your personal data with our trusted categories of third parties we use to conduct our business. Our trusted categories of third parties include:

• Website provider
• Cloud service (SaaS) providers
• Social media providers
• Professional services providers (e.g., our lawyers, accountants, and insurance providers)
• E-marketing providers
• Advertising providers
• Recruitment partners
• Payment providers

As part of fraud monitoring and prevention, we may be legally required to share your personal data with government bodies and law enforcement. Please note that these bodies may retain a record of the information that we provide to them for this purpose.

Marketing preferences

We may send you marketing communications, product information, and promotional offers:

• If you have consented to receive such communications from us, or
• If you have recently created an account with us and not opted out of receiving such communications from us, or
• If you have bought a product or service from us and have not opted out of receiving communications from us, or
• If you are from a country where the laws permit us to send you such communications

You will always have full control of your marketing preferences. If you do not wish to continue receiving marketing information from us at any time:

• You can unsubscribe or 'opt-out’ by using the unsubscribe link included in the footer of any marketing message from us.

We will process all opt-out requests as soon as possible, but please note that due to the nature of our IT systems and servers, it may take a few days for any opt-out request to be implemented.

SMS and Email Marketing Communication Policy

Opting In for SMS or Email Marketing - by choosing to sign up for SMS (Short Message Service), or Email marketing messages from 'LUMI Therapy', you agree to receive periodic automated marketing and informational messages from us. These messages will be sent to the mobile phone number, and/or Email address you provide to us upon opting in.

Opt-in can occur through various means, including but not limited to:

• Texting a keyword to our designated number.
• Entering your phone number or email address in a signup form on our website or at our physical location.
• Opting in via an online purchase, or through one of our customer service representatives.

Consent to receive SMS messages and Email marketing is not a condition of purchase of any goods or services.

Personal Information Collected

When you sign up for our SMS or Email marketing messages, 'Ice Dragon' will collect personal information that may include your:

• Mobile phone number
• Email address
• Name
• Contact preferences
• Purchase history and preferences

This information is used to send personalized marketing messages and to provide offers that may be of interest to you. We may also use this information for the purposes of analytics, targeting, and campaign performance evaluation.

Frequency of SMS Messages

The frequency of SMS messages will vary depending on ongoing promotions, notifications, and personalized information relevant to your interests and engagement with 'Ice Dragon'. We typically send no more than 2 SMS messages per month.

SMS Cost

While 'Ice Dragon' does not charge you for sending or receiving text messages, message and data rates may apply from your mobile carrier.

Opting Out

You may opt-out of receiving SMS messages and/or Email marketing messages from 'Ice Dragon' at any time by either - contacting us directly and instructing us to remove you from our marketing list, by replying 'STOP' to any SMS message you receive from us, or using the 'Unsubscribe' link in an email marketing message. For SMS marketing, after sending 'STOP', you will receive one final message confirming that you have been unsubscribed. After this, you will no longer receive SMS messages from us.

Should you wish to opt back in, you can follow the initial opt-in process again.

Data Security

We take the privacy and security of your personal information seriously. 'Ice Dragon' employs industry-standard data protection measures to ensure that your personal information is not accessed by unauthorized persons and is used only for the purposes described in this policy.

Updates to this Policy

'Ice Dragon' reserves the right to modify this Marketing Communication Policy at any time. Any changes will be effective immediately upon the posting of the revised policy on our website. We encourage you to regularly review this policy to ensure you are aware of any changes.

If you have any questions regarding this policy or our Marketing Communications, please contact us.

By providing either your phone number or email address, and opting in to receive marketing messages from us, you are confirming that you have read, understood, and agreed to the terms of this Marketing Communication Policy.

Our use of cookies

Our website uses cookies. They help us to provide you with the very best experience when you browse our website and to make improvements to our website. You can accept or reject cookies by clicking on the cookie consent banner on our website.

Our use of analytics

We use analytics tools on our website and services. For example, we use tools such as Google Analytics to analyse and improve our suite of product features, website content, knowledge centre content, and marketing campaigns.

If you would like any further information about the data collected by these third parties or the way in which the data is used, please contact us via our contact us page.

Our use of targeted advertising

We use targeted advertising tools to advertise our services, including (but not limited to):

• Google Ads
• Facebook (including Instagram)
• TikTok

We use these tools to deliver relevant content to you in marketing communications (where applicable) and to measure the effectiveness of the advertising provided.

If you would like any further information about the data collected by these third parties or would like to opt out of targeted advertising, please contact us via our contact us page.

Links to other websites and third parties

Our website may include links to social media platforms and other websites. If you follow a link to any of these platforms or websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to their platforms or websites.

Securing your data

The communication between your browser and our website uses a secure encrypted connection wherever your personal data is involved.

We have put in place physical, electronic, and managerial security procedures for the storage and disclosure of your personal data to protect it against accidental loss, destruction, or damage. Nevertheless, any data transmission over the internet or by any other means can never be fully secure, such is the character of the internet, and the provision of personal data by you to us is at your own risk. We take all reasonable measures to protect your personal data by putting appropriate technical and operational security measures in place.

When we disclose your personal data to trusted third parties (for the purposes set out in this Privacy Notice and our list of Data Sub-Processors), we require all third parties to have appropriate technical and operational security measures in place to protect your personal data, and we work with them to ensure that your data privacy rights are respected. Where your personal data is shared with a third party, it must only be used for the purposes for which it was supplied.

In the unfortunate event of a personal data breach, we will notify you and any applicable data protection authority when we are legally required to do so.

Retaining your data

We will not keep your personal data for longer than is necessary and when we no longer need to keep it, we will securely destroy, delete or anonymise it in line with our Data Retention Policy.

Having obtained your consent (or other legal basis) to contact you, we will retain your personal data for marketing and analysis purposes until you withdraw your consent or unsubscribe. If you choose to withdraw your consent or unsubscribe from marketing, we will delete your personal data from our systems, unless we have another legal basis to retain it, which may include the performance of our contract with you or to maintain your contact details on an 'unsubscribed list' to ensure we do not send you further communications.

We may need to retain your personal data to satisfy our legal obligations, to deal with complaints and queries, in order to resolve, litigate or defend a dispute, and to prevent fraud and abuse.

Data transfers

Our servers are hosted outside the EEA. If you are using our services from another country, the laws governing our collection and use of information may be different from the laws of your country. By default, if you decide to use our services, or share your information with us, you are agreeing to be governed by the laws of the United Kingdom, and agree to the transfer of your information to the United Kingdom.

However, at Ice Dragon, we endeavour to take all steps necessary to ensure that there is an appropriate transfer mechanism in place to protect your personal data and comply with our data protection obligations. For EU and UK citizens. Please contact us if you want further information on the countries to which we may transfer personal data and the specific mechanism used by us when processing your personal data outside the EEA and UK.

Your rights and our commitment to you

You have rights under data privacy laws and Lumi Therapy is committed to you being able to freely exercise your Rights. Where possible, we have incorporated automated tools on our website that enable you to facilitate your rights in real time. You are not required to pay any charge for exercising your rights. Your rights include, under certain circumstances, the right to:

Be informed: you have the right to be informed if and how your personal data is being processed.

Access, rectification, or erasure: you have the right of access to personal data we hold about you in our records. You are also entitled to have your personal data corrected if it is inaccurate, or to have it erased if we do not have a legitimate reason for retaining your data.

To request data portability: for personal data which you have provided to a controller, where processing was based on your consent, or where processing is done by automated means, you have the right to obtain a digital copy of your personal data, request the transfer of your personal data to another company or request to move your data from one IT system to another in a safe and secure way.

To request the restriction of processing: you have the right to restrict the processing of your personal data where you are contesting the accuracy of that information, you have objected to the processing (as described below), or where the processing is unlawful. Where the processing is restricted, we are may need to retain sufficient information about you to ensure that the restriction is respected in the future.

To object to automated decision-making including profiling: you have the right not to be the subject of any automated decision-making or profiling by us.

To withdraw consent: in cases where we are relying on your consent for the processing of your personal data, you have the right to withdraw your consent at any time. In respect of the e-marketing we conduct, an unsubscribe option is included with every e-marketing communication we send.

To object to processing: where your personal data is being processed based on the legitimate interests of a data controller or third party, you have the right to object to that processing.

To complain to the relevant supervisory authority: should you have any concerns or complaints regarding the way in which we process your data, you also have the right to make a complaint to the relevant European Supervisory Authority. We would, however, appreciate the chance to deal with your concerns before you approach a Supervisory Authority, so please contact us via our contact us page. The contact details of European Supervisory Authorities can be found here: https://edpb.europa.eu/about-edpb/about-edpb/members_en-member-lv

Changes to this privacy notice

We may update this privacy notice from time to time and we will inform all our paying customers and users subscribed to receive communications from us of any changes.

How to contact us

We welcome feedback and are happy to answer any questions you may have about your data. You can contact us via our contact us page.