1Who we are and our role
LUMEN provides a quote-recovery service to Australian trade and service businesses (“Business customers”). We connect to the job-management software a Business already uses — such as ServiceM8 and Xero — identify quotes that were sent to that Business’s own customers and never resolved, and send follow-up messages on behalf of and in the name of the Business.
There are three parties, and it matters which is which:
- The Business customer is our client and is responsible for its own customers’ personal information.
- The Business’s customer (the “homeowner”) requested a quote from the Business and receives a follow-up message.
- LUMEN handles the homeowner’s personal information only on the Business’s behalf and on its instructions, as part of delivering the service.
For personal information about a homeowner, the Business is the entity responsible for that information, and LUMEN acts as its service provider. LUMEN also determines the timing and content of messages, and to that extent handles that information in its own right; this policy covers both roles.
2The information we handle
About Business customers and their staff: name, business name, email address, phone number, role, and account and billing details.
About homeowners, on behalf of the Business: name, mobile number, email address, site or job address, job or quote description, quote value and status, and the content of SMS conversations arising from a follow-up.
We do not intentionally collect sensitive information, and we do not collect information from anyone we believe to be a child.
3How we collect it
- From Business customers directly, when they sign up and communicate with us.
- From the Business’s connected software (for example ServiceM8 or Xero), via authorised, permissioned access granted by the Business, which draws through quote, job, customer and job-material records the Business already holds.
- From replies homeowners send to a follow-up message.
We do not purchase personal information, and we do not collect homeowner information from any source other than the Business’s own systems.
4Why we handle it
- To identify unresolved quotes and send follow-up messages in the name of the Business.
- To route replies to the Business and record outcomes.
- To verify when a quote converts to booked work, for outcome reporting to the Business.
- To produce reporting for the Business.
- To operate, secure, support and improve the service, and to meet legal obligations.
5Messaging, consent and opting out
Follow-up messages are sent as the Business, under the Business’s existing relationship with the homeowner, who had previously requested a quote from that Business. We do not send messages where no quote was ever provided.
Every message includes a working unsubscribe. When someone opts out, we honour it across every Business on the LUMEN platform — not just the sender — within the timeframes required by the Spam Act 2003 (Cth). We apply send-time restrictions based on the recipient’s location.
6Where it is stored
All personal information is stored in Australia (Sydney region). We do not transfer personal information overseas for storage. Where a third-party service provider is involved in delivering the service (see section 7), we take reasonable steps to ensure personal information is handled consistently with this policy and the Australian Privacy Principles.
7Who we share it with
We do not sell personal information. We disclose it only:
- To the relevant Business customer — its own customers’ replies and outcomes.
- To service providers who help us run the platform, under contract and only as needed to deliver the service. Our hosting and database infrastructure stores data in Australia; other providers are engaged only as required to deliver a specific feature and are contractually bound to handle personal information consistently with this policy.
- Where required or authorised by law, or to protect our legal rights.
8Security
We hold personal information in access-controlled systems with tenant isolation, encryption in transit, and an append-only, tamper-evident record of message and outcome events. Access is limited to those who need it to deliver or support the service. No system is perfectly secure, but we take reasonable steps to protect information from misuse, interference, loss, and unauthorised access, modification or disclosure.
9Retention, access, correction and deletion
We keep personal information only as long as needed for the purposes above or as required by law, and we provide export and deletion on termination of a Business’s account. Because our event record is append-only for integrity and dispute-defence reasons, some records may be retained for a limited period after a deletion request; where that applies we will explain it and honour deletion to the fullest extent consistent with our legal obligations.
If you are a homeowner and want to access, correct or delete your information, the fastest route is usually the Business you dealt with, as they are responsible for that information. You may also contact us and we will assist, working with the relevant Business.
10Data breaches
We maintain a data breach response plan. If an eligible data breach occurs, we will act in line with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth), including notifying the OAIC and affected individuals where required, and we will support any affected Business customer in meeting its own obligations.
11Contact and complaints
Questions, requests or complaints about privacy can be sent to us. We will acknowledge and respond within a reasonable time. If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au.
GET LUMEN PTY LTD — Privacy
12Changes to this policy
We may update this policy from time to time. The current version is always available here, with the effective date shown at the top.