PRIVACY POLICY

In an effort to communicate our commitment to actively protect the privacy and personal information of all visitors to stemcity.com, ondemand.mopi16.com, and enuggetlearning.com, Luma, Inc. ("We") makes the following statement in regard to the information that may be collected on our website(s) ("website"). Amendments to this statement will be posted on our website and will be effective when posted. Your continued use of this website following the posting of any amendment, modification, or change constitutes your acceptance thereof.

I. INFORMATION COLLECTED

We collect non-personally identifiable information about you in a number of ways, including tracking your activities through your IP address, computer settings or most-recently visited URL. We may also ask you to provide certain non-personally identifiable information about yourself, such as your age, gender, city, etc. We do not collect any personally identifiable information about you unless you voluntarily submit such information to us, by, for example, filling out a survey or registration form. The types of information that may be requested include your name, address, e-mail address, telephone number, and payment information.

We may also collect personal information that you voluntarily share with us through the Luma platform. For example, we collect information from you when you fill out an online form in Luma. Examples of information collected may include contact information, information your employer needs to complete your personnel or driver qualification file, images of your licenses, or images of you to prove your identity. The information collected through forms is encrypted in our databases.

We also collect information about your device in order to better serve content to you. This information includes browser and device information and IP addresses.

II. USE OF INFORMATION

We do not and will never sell personal information to third parties.

We do not market to our end users, nor do we share any personal information for the purpose of marketing to end users.

In general, we will only use the information you provide to us for the purpose for which such information was provided. We may also use this information to effectively administer our website.  Your information may also be used to contact you when necessary regarding your usage and experience with the website.

Non-personal demographic and profile data is used to enhance your experience at our site. This information may also be shared with advertisers on an aggregate non-personal basis.

The following are some of the ways we share your information:

· In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

· We may also disclose your personal information as required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

· We may share personal information with your employer for the purposes of maintaining compliance of your employment obligations.

· We may disclose your personal information at the direction of, and on behalf of, your Employer. Please contact the Employer with questions about the Employer’s sharing of your personal information.

· We may share your personal information with third-party service providers under contract with Luma to help us provide services to you. For example, we may share information that you provided through Luma's online form tool with your employer's other services in order to keep your driver qualification file current.

· We may share aggregated data with third-parties when the data has been de-identified or otherwise anonymized in such a manner that the information would not be able to identify you.

· We reserve the right to disclose and transfer your information, including your personal information:

· To a subsequent owner, co-owner, or operator of Luma or successor database.

· In connection with a corporate merger, consolidation, the sale of substantially all of our membership interests and/or assets or other corporate change, including to any prospective purchasers.

· To our attorneys as may needed to protect our legal rights.

III. USE OF IP ADDRESSES

We use your IP Address to verify your performance in Luma, to help diagnose problems with our server, administer our website, and to collect aggregated metrics on site usage.

IV. USE OF COOKIES

When you view our website we might store some information on your computer. This information will be in the form of a "cookie" or similar file. Cookies are small pieces of information stored on your hard drive, not on our site. Cookies do not spy on you or otherwise invade your privacy, and they cannot invade your hard drive and steal information. Rather, they help you navigate a website as easily as possible. We use cookies to deliver content specific to your interests and to prevent you from reentering all your registration data at each connection.

Some clients may use an outside advertisement server company to display ads on our site. These ads may contain cookies. The advertisement server company may collect cookies received with outside banner ads. We do not have access to information that would confirm the use of cookies by any advertisement server company.

V. SECURITY

Our site has industry standard security measures in place to protect the loss, misuse and alteration of the information under our control. While there is no such thing as "perfect security" on the Internet, we will take all reasonable steps to insure the safety of your personal information.

VI. OTHER WEBSITES; LINKS

Our website may contain links to other websites. We are not responsible for the privacy practices or the content of such websites.

VII. CORRECT; UPDATE

Our website allows its users the option to change or modify information previously provided. This may be done through the following methods:

(1) Login to your account at www.stemcity.com or enuggetlearning.com

(2) E-mail the information to info@learnwithluma.com

(3) Submit a help ticket to Luma at support.learnwithluma.com

Unfortunately, to the extent that such information is also stored in other databases, we cannot always ensure that such corrections or deletions will reach the other databases. We will use all reasonable efforts to ensure that your information is removed from or corrected in our records.

Contacting us:

If you have any questions about this privacy statement, the practices of this site, or your dealings with this website, you can contact us at:

Luma, Inc.

PO Box 2588

Mount Pleasant SC 29465

574-807-8148

info@learnwithluma.com

learnwithluma.com