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Your GDPR Rights

Last updated: September 10, 2026

This page explains how Lumagate Inc (“Lumagate”, “we”, “us”) processes personal data under the EU General Data Protection Regulation and the UK GDPR, and how you can exercise your rights. It is the GDPR-specific companion to our Privacy Policy and product policies. If you want to make a request about your data, the fastest path is our support portal at https://support.lumagate.us.

1. Who is responsible for your data

Lumagate Inc is the data controller for the personal data described on this page. We are a company organized under the laws of Delaware, United States. You can reach us about privacy and GDPR matters at privacy@lumagate.us or through https://support.lumagate.us.

Related policies:

2. Whose data this covers

This notice applies when we process personal data of people in the European Economic Area, the United Kingdom, or Switzerland in connection with:

  • The lumagate.us marketing website, including the contact form
  • ATV Companion (iOS, Android, and the web companion)
  • Exam Prep Flashcards (web, iOS, and Android)
  • Exam Prep Quiz App (web, iOS, and Android)
  • Support requests submitted at support.lumagate.us

MovoSuite and MovoKey are deployed in the customer’s own cloud subscription. Identity and operational data in those products stay in the customer tenant unless the customer grants Lumagate access for support. See the MovoSuite and MovoKey privacy policies.

3. Personal data we process

We collect only what we need to run the website, deliver the exam-prep apps, take payment, keep the services secure, and answer support requests. We do not sell personal data and we do not use it for advertising.

ATV Companion

ATV Companion is usable without an account. Used that way your rides stay on the device and nothing about them reaches Lumagate. Map, trail, and weather requests still go to the providers named in section 5. If you do sign in, you use Google, Apple, or Microsoft, and we never receive your password.

The App processes precise location, which deserves particular care. Location is collected only while a ride or navigation session you started is running, and it is used to record your track, show your position, share your live position with a group ride you joined, and place waypoints or reports you create. In Google Firebase we store your profile, rides and their GPS tracks, routes, waypoints, and any social content you create. Some of that is deliberately visible to others — your rider profile, trail condition reports, emergency beacons, trip share links, and activities you mark public or unlisted — which the ATV Companion Privacy Policy sets out in full.

ATV Companion contains no advertising, no analytics SDK, and no third-party crash reporting. Map, trail, and weather requests reveal the area you are viewing to the provider serving it (Apple MapKit, Google Maps, the OpenStreetMap Overpass API, and Open-Meteo); we do not send your account identity with them.

Storage location: signed-in ATV Companion data is stored in Google Cloud’s United States multi-region. If you are in the EEA, the UK, or Switzerland and would prefer your ride data not to be transferred to the United States, use the App signed out — recording, offline maps, and navigation all work without an account, though sync, group rides, and social features necessarily do not.

Flashcards

You sign in with Google, Apple, or Microsoft. We never receive your password. From your chosen sign-in provider we receive your email address (or Apple’s private relay address), display name, profile photo URL, and a stable user identifier. In Google Firebase (Cloud Firestore) we store:

  • Your profile (display name, email, and photo URL)
  • Flashcard learning progress and study activity, including last-viewed cards per set
  • Cards you have flagged or bookmarked
  • Subscription status and the customer or subscription identifiers issued by Stripe, Apple, or Google Play — never your full card or bank details
  • A record of which in-app service notifications you have seen

Search queries are sent to Algolia so we can return matching flashcards. On iOS and Android, Firebase Crashlytics records crash diagnostics (device model, OS version, stack traces). Firebase App Check confirms that requests come from a genuine copy of the app. Web sign-in stores authentication tokens in the browser so you stay signed in; those tokens are cleared when you sign out. We do not use advertising cookies, tracking pixels, or a third-party analytics SDK in Flashcards.

Quiz App

You sign in with Google, Apple, or Microsoft, or you may use the app anonymously. We never receive your password. For a signed-in account we receive your email address, display name, and a stable user identifier. In Firebase we store:

  • Your profile (email, display name, theme preference, preferred exam)
  • Study activity such as streaks, last study date, and questions answered
  • Per-exam progress: scores, accuracy, readiness, flagged or missed questions, and any exam date you choose to save
  • Question attempts (selected answer, correctness, time spent, confidence) and study-session summaries
  • Question of the day attempts
  • Subscription status and the identifiers issued by Stripe, Apple, or Google Play — never your full card or bank details
  • In-app notification read status

Quiz App also uses Firebase Analytics for product usage (including a device identifier and coarse location derived from IP) and Firebase Crashlytics for crash diagnostics, both linked to your account so we can diagnose problems and improve the product. Anonymous use still creates a Firebase user identifier so progress can be saved on that device; it is not tied to your name or email until you sign in with a provider.

Website, contact form, and support

  • Contact form submissions: first name, last name, work email, and any job title, phone number, product interest, or message you provide
  • Marketing email records, if you choose to subscribe
  • Support tickets at support.lumagate.us: the account or contact details you use and the content of your request
  • Standard server logs (IP address, browser type, timestamps, referring pages) on lumagate.us and our hosting providers

4. Why we process it, and on what legal basis

GDPR requires a lawful basis for each use of personal data. We rely on the following:

  • Contract (Article 6(1)(b)). Creating and maintaining your account, saving and syncing study progress, providing search, processing subscriptions, and answering support requests that are part of delivering the service you asked for.
  • Legitimate interests (Article 6(1)(f)). Keeping the services secure (App Check, access logs, abuse prevention), diagnosing crashes, understanding aggregate product usage in Quiz App, and responding to website contact-form inquiries. Those interests are to run a reliable, secure service and to reply to people who contact us. They do not override your rights.
  • Consent (Article 6(1)(a)). Marketing emails, where we send them, and any non-essential analytics cookies on lumagate.us. You can withdraw consent at any time without affecting processing that already took place.
  • Legal obligation (Article 6(1)(c)). Retaining limited payment and transaction records that tax, accounting, or dispute-resolution rules require us or our payment processors to keep.

ATV Companion is different: an account is optional there, and recording, offline maps, and navigation work entirely without one. Signing in enables sync, group rides, and social features.

Providing an account is required if you want to use the signed-in features of Flashcards or Quiz App. You can browse lumagate.us without a contact-form submission. We do not process special-category data (Article 9) and we do not make automated decisions that produce legal or similarly significant effects (Article 22). Readiness scores and similar study metrics are study tools, not decisions about you with legal effect.

5. Who we share data with

We share personal data only with the processors and platforms needed to operate the services, each under its own terms:

  • Google Firebase — authentication, database, hosting, crash reporting, App Check, and (Quiz App) analytics
  • Stripe — web payments
  • Apple — Sign in with Apple and iOS In-App Purchase
  • Google Play — Android billing
  • Microsoft — sign-in when you choose Microsoft as your identity provider
  • Apple MapKit and Google Maps — base map rendering in ATV Companion; a map request reveals the area being viewed to the provider serving it
  • OpenStreetMap (Overpass API) and Open-Meteo — public trail geometry and weather for the area being viewed in ATV Companion; no account identity is sent with these requests
  • Algolia — Flashcards search
  • Cloudflare — hosting for lumagate.us and the support portal

Payment card numbers are handled by Stripe, Apple, or Google Play. We never receive or store full payment credentials. We do not use advertising networks or sell personal data. We may disclose information if required by law or to protect the security of the services or other people.

6. International transfers

Lumagate is based in the United States, and our processors listed above are located primarily in the United States. When we transfer personal data from the EEA, UK, or Switzerland to the United States, those transfers are covered by the EU-US Data Privacy Framework where the processor participates, by Standard Contractual Clauses, or by equivalent safeguards the processor provides. You can ask us for more detail about the safeguard that applies to a given transfer by contacting privacy@lumagate.us.

7. How long we keep it

  • ATV Companion account data — rides, GPS tracks, routes, and waypoints — is kept for as long as the account exists. Trail condition reports and emergency beacons stay published until you delete them or delete your account, because a hazard remains useful to other riders until it is reported cleared. Deleting the account removes them along with your profile and social content
  • Flashcards and Quiz App account data, including study progress, is kept for as long as the account exists. Deleting the account from in-app Settings removes the Firebase Authentication record and the Firestore data described above.
  • Payment processors may retain transaction records independently for tax, accounting, and dispute-resolution periods.
  • Contact-form submissions and marketing records are kept for as long as needed to respond, or until you unsubscribe or ask us to delete them.
  • Support tickets are kept as long as needed to resolve the request and for a reasonable period afterward for service quality and security.
  • Server logs are kept for a limited period for security and troubleshooting, then deleted or anonymized.
  • Crash reports, App Check signals, and (Quiz App) analytics events follow each processor’s retention schedule.

8. Your rights

If the GDPR or UK GDPR applies to you, you have the right to:

  • Access — obtain a copy of the personal data we hold about you
  • Rectification — have inaccurate or incomplete data corrected
  • Erasure — ask us to delete your data, including by deleting your in-app account
  • Restriction — ask us to limit how we use your data in certain circumstances
  • Portability — receive data you provided to us in a structured, commonly used format
  • Objection — object to processing based on legitimate interests, including profiling of that kind
  • Withdraw consent — where processing is based on consent, withdraw it at any time
  • Lodge a complaint — contact your local data protection authority (see section 11)

These rights are not absolute. We may need to refuse or limit a request where another lawful ground still applies — for example, retaining a payment record we are legally required to keep.

9. How to exercise your rights

Submit a request through our support portal. That is the channel we use to log, verify, and fulfill GDPR requests:

https://support.lumagate.us

You can also email privacy@lumagate.us. Please say which product the request is about (Flashcards, Quiz App, lumagate.us, or support) and which right you want to exercise. We will ask for enough information to confirm you are the person the data relates to before we act on the request.

You can delete a Flashcards or Quiz App account yourself at any time from Settings in the app. That is the fastest way to exercise erasure for app data.

We will respond without undue delay and within one month of receiving a verified request. If the request is complex or you have made several requests, we may extend that by up to two further months and we will tell you why.

10. Cookies and similar technologies

lumagate.us uses essential cookies required for the site to work. It may use analytics cookies to understand aggregate site usage. You can block cookies in your browser; doing so may affect parts of the site. The Flashcards and Quiz App web clients store authentication tokens in local storage or IndexedDB so you stay signed in. Those are essential to the service. We do not use advertising or cross-site tracking cookies.

11. Complaints

You have the right to lodge a complaint with a supervisory authority in the EEA country where you live, work, or where you believe a GDPR infringement occurred, or with the UK Information Commissioner’s Office if you are in the United Kingdom. We would rather fix the problem directly — please contact us first at privacy@lumagate.us or https://support.lumagate.us.

A directory of EEA authorities is published by the European Data Protection Board at edpb.europa.eu. The UK ICO is at ico.org.uk.

12. Children

ATV Companion is not directed to children, and we do not knowingly collect personal data from children. Where local law sets a minimum age for consenting to online services on their own, that age applies; a parent or guardian must consent below it. See the ATV Companion Privacy Policy for the product's own statement.

Flashcards and Quiz App are exam-prep products intended for adults. You must be at least 18 to use those services under our Terms of Service. We do not knowingly collect personal data from children. If you believe we have, contact privacy@lumagate.us and we will delete it promptly.

13. Changes

We may update this page from time to time. Changes will be posted here with a revised “Last updated” date. Material changes will be communicated through the relevant service where appropriate.

14. Contact

For GDPR requests, open a ticket at https://support.lumagate.us. For other privacy questions, email privacy@lumagate.us or use our Contact page.