Luminate

Privacy Policy & Cookie Notice

Privacy Policy

Luminate is a global philanthropic organisation focused on empowering people and institutions to work together to build just and fair societies. We support innovative and courageous organisations and entrepreneurs around the world, and we advocate for the policies and actions that will drive change across four impact areas: Civic Empowerment, Data & Digital Rights, Financial Transparency, and Independent Media. We work with our partners to ensure that everyone has the opportunity to participate in and to shape the issues affecting their societies, and to make those in positions of power more responsive and accountable. Luminate was established in 2018 by philanthropists Pierre and Pam Omidyar. The organisation was founded by The Omidyar Group. 

This notice provides information about the types of personal information we collect about you during the course of our work, including via our website www.luminategroup.com, our work with partners, and via our social media accounts. The notice also provides information about how we will use your personal information and your rights in relation to your personal information. 

This notice is about Luminate and our work. If we start a new project or activity, we may provide you with additional privacy notices with more information.  

  1. Who we are and how to get in touch 
  2. What is personal information? 
  3. Whose personal information do we use? 
  4. Where do we get your personal information? 
  5. What personal information do we collect? 
  6. What do we do with your personal information? 
  7. When will we get in touch? 
  8. What if you’re a job applicant?  
  9. Do we share your personal information?  
  10. Links to other websites and social media plug-ins  
  11. How we keep your information safe 
  12. Where your information is used 
  13. How long we keep your information 
  14. Your rights 
  15. Updates to this notice

We also collect personal information and anonymised information through the use of cookies and similar technologies. See our Cookies Notice at the end of this notice for more information.  

1. Who we are and how to get in touch?

Our organisation is made up of a group of companies in the UK and US, with an office in Nairobi. Our group includes the following legal entities: 

  • Luminate Foundation Inc 
  • Luminate Holdings LLC 
  • Luminate Fund LLC  
  • Luminate US Services LLC 
  • Luminate US Services Limited 
  • Luminate Projects Limited   

Even though we work around the world and through different legal entities, we operate as one organisation. The one exception is funding applicants to Reset, a project operated through Luminate Projects Limited. For more information about funding applications to Reset, please see their data use policy 

 Our contact details are below: 

  • London: 36-38 Hatton Garden, London EC1N 8EB  | +44 (0)207 729 9997  
  • Washington, DC: 1200 17th Street NW, Suite 501  Washington, DC 20036  
  • Nairobi: Lavington, 2nd Floor, 90 JGO, James Gichuru Road, P.O. Box 1093-00606, Nairobi 

If you want to know more about this notice and how we approach data protection and your privacy, email [email protected] 

2. What is personal information?

When we use the term personal information, we mean any information which identifies you or which could be used to identify you. At its simplest this could be your name and/or email address. Personal information also includes information about your expertise in a particular area as well as contributions you may make (for example, when we ask you to contribute to reports or we conduct surveys to evaluate our impact). 

We occasionally anonymise personal information, which means that we remove all ability to connect you to the information. For example, when we collect personal information for the purposes of research and evaluation, we will anonymise responses wherever possible. Where this is not possible, we will inform respondents accordingly.  

We try not to collect information from children, and if we find this information in a dataset, we will permanently delete this information.  

Certain types of personal information are sensitive and merit more protection. For example, information about your race or ethnic origins, political opinions, sex life or sexual orientation, religious beliefs, health information, biometric and genetic data. Criminal information (information about convictions or allegations about convictions) also merits additional protection and special consideration. Financial information (bank details, identity documents, etc) can also cause harm when misused, so we endeavour to treat these as sensitive, as well.  

3. Whose personal information do we use?

We collect and use personal information about people with whom we work, people interested in Luminate’s work, and people we believe could be helpful to our work. These include:  

  • Contacts at partners (and potential partners). By partners, we are referring to organisations that we fund.  
  • Experts in our Impact Areas and regions of focus 
  • Stakeholders (for example, public sector figures, contacts at other foundations, and potential co-investors) 
  • Contacts at co-funders and co-investors  
  • Advisors to Luminate (members of our Advisory Group and others) 
  • Attendees at our events  
  • Vendors with whom we work (and who are recommended to us) 
  • Visitors to our website (and people who engage with us on social media) 
  • Applicants for jobs at Luminate 

If you’re a staff member of Luminate, we have a separate Staff Privacy Notice (which can be requested through People Operations).  

For job applicants, see section 8 for more information. 

4. Where do we get your personal information?

We collect your information from three types of sources: 

  • Directly from youFor example, if you sign up for an event with us.  
  • Indirectly from another source: For example, if a potential partner provides information about its board of trustees as part of due diligence.  
  • When it is available publiclyFor example, if you write an article about an area in which we are interested or engage with us on social media.  

5. What personal information do we collect?

The information we collect depends upon your relationship with us, and so we have set out below the types of information we collect and from whom we collect it.  

  • Name (all) 
  • Contact details (all) 
  • Information you provide to us (all) 
  • Records of our communication with you (all) 
  • Role & associated organisations (partners*, experts, stakeholders, co-funders, co-investors, advisors, attendees, vendors) 
  • Records of our relationship with you - for example: reports, contracts, funding disbursements (partners, experts, stakeholders, co-funders, co-investors, advisors, vendors) 
  • References from other relevant people (partners, advisors, vendors) 
  • Information about staff and beneficiaries – for example: collected during due diligence and portfolio management (partners) 

*Note that where we refer to “partners”, we also mean “potential partners” who are undergoing the due diligence process.  

We do not usually collect sensitive personal information about you. We will only process these types of personal information about you if we have a valid reason for doing so and only if the law allows us to do so.  

There are two key exceptions:  

  • First, if you are a partner or potential partner, we may collect sensitive personal information as part of the due diligence process (for example, race or ethnic origins to understand the diversity of your organisation). We may also collect sensitive personal information during the course of our relationship with you (for example, health information if there’s a crisis which requires emergency support).  
  • Second, if you are a job applicant, we may collect sensitive personal information as part of the application process. See section 8 for more information.  

Please note that if you fail to provide us with the relevant details that we request, we will not be able to consider you for funding or appoint you to provide services. 

6. What do we do with your personal information?

We use your personal information to help Luminate operate. This includes: 

  • Promoting our work and values, for example through case studies in blogs and speaking engagements 
  • Assessing how and where we distribute our funding 
  • Further developing and refining our work  
  • Evaluating our impact and identifying areas for improvement 
  • Administering our funding (for example, receiving reports and making further disbursements) 
  • Amplifying our partners’ work through our website and social media 
  • Running and participating in events (for example, partner convenings and conferences) 
  • Handling any concerns or queries which arise within the course of our work 
  • Procuring services and advice from you (whether there’s a vendor and/or advisor relationship) 
  • Operating Luminate (for example, making financial payments or participating in annual audits) 
  • Ensuring the proper governance and stewardship of our funding  

We can only use your personal information if we have a valid reason. In Europe, this is known as a lawful basis of processing. Below we explain the lawful bases which we think apply to our use of personal information. 

Legitimate interests is a flexible lawful basis which allows us to use your personal information provided that: 

  • We have a good reason to do so. For example, to evaluate whether we should invest in a potential partner. 
  • You can reasonably expect that we would use your personal information in this way. In other words, our use of your personal information shouldn’t be a surprise. 
  • It fits with your rights and it doesn’t affect you unfairly. Your rights are explained in section 14.  

When we rely upon legitimate interests as a lawful basis, our use of your personal information must be fair and balanced, and we need to consider the points above.

Consent is when we ask for your permission to use your personal information for a specific purpose. For example, if we ask to use a quote from you to promote our work. You always have the right to withdraw your consent. Just send us an email or contact us using the details set out in section 1.  

We may also need to process your personal information to comply with a legal obligation on us. For example, to run checks on your identity prior to disbursing funding. 

We may also need to process personal information in order to perform our contract with you. For example, where you provide us with your bank details for payment.  

7. When will we get in touch?

We may contact you when you give us your contact details or when we believe that you may wish to hear from us. Some of these communications may be administrative (for example, to respond to a query or request from you) and some may be promotional (for example, a newsletter with updates about our work).   

We’ll only contact you when we’re allowed to do so. And you can request that we cease contacting you with promotional material at any time. Though please note that we may still send you administrative communications (for example, if you’re a contact at a partner, we will contact you above your funding).  

8. What if you’re a job applicant?

We handle personal information of those who apply to work with us slightly differently than we have discussed above, so we’ve included a dedicated section. 

 When you apply to work at Luminate, we will collect and use your information for the purposes of evaluating your application as part of our recruitment process.  

We will collect the following types of personal information: 

  • Information you provide on your CV or resumé and any associated covering letter or email. 
  • Information you provide during the course of the recruitment process (for example, during the interview phase). 
  • Information provided by third parties about you, including former employers and named references. 
  • Information recorded in our notes and records.  

We will use the personal information we collect about you to: 

  • Assess your skills, qualifications, and suitability for the role. 
  • Carry out background checks and reference checks (where applicable). 
  • Communicate with you about the recruitment process. 
  • Keep records about our recruitment process. 
  • Comply with other legal and regulatory requirements.  
  • If successful, enter into a contract of employment with you.  

It is in our legitimate interests to decide whether to appoint you to the role, since it would be beneficial to Luminate to appoint a qualified and appropriate person to the role.  

Please note that if you fail to provide us with the relevant details that we request, we will not be able to process your application. 

If you are successful in your application, we will transfer the personal information collected as part of your recruitment process to your employment record. We will also provide you with a staff specific privacy notice.  

If you are unsuccessful with your application we usually retain your personal information for two years after we communicated the decision to you, unless otherwise required to do so by law (for example, where immigration regulations require the retention of recruitment notes). 

9. Do we share your personal information?

As mentioned above, Luminate operates through several legal entities (listed above). These entities share systems, and so your personal information will be shared among these entities.  

We also use vendors to help us operate. For example, we have a database management provider and communications consultants. We have written agreements with our vendors that require them to help keep your personal information safe.  

There are other circumstances where we may need to share your personal information, for example: 

  • If we spin out our operation or part of our operation to another organisation; 
  • With co-funders and co-investors to help our portfolio grow; 
  • With our professional advisors such as lawyers or accountants; 
  • If we’re under any legal or regulatory obligation to do so; and  
  • In connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise, or defend our legal rights.  

If we share your information with any other third party, we will let you know in advance where possible.  

We will not sell your information.  

10. Links to other websites and social media plug-ins

Our website includes links to other websites. This notice only covers how Luminate uses personal information and does not cover these other websites. We encourage you to read the privacy notices on other websites you visit.  

The success of Luminate depends in part on people amplifying our messages, and we have provided social media plugins to allow you to easily share content from our website with your networks. In doing so your personal information will be disclosed to these social media platforms. When you share content using these buttons, a new page will pop up from the relevant social media platform. If you’re already logged into your account on that social media platform, then you will probably be automatically logged into this pop-up page.  

We have no control over how social media platforms use your personal information. We encourage you to read the privacy notices on the various social media platforms you use (and engage with their privacy tools).  

Find out more about how these social media platforms use your personal information:  

11. How we keep your information safe

It’s our job to keep your personal information safe and secure. We have security measures in place to protect your personal information, like encrypted messaging and secure systems.  

We also provide training to our staff on how to keep your information safe.  

12. Where your information is used

As we mentioned, Luminate is a global organisation. We have offices in Washington DC, London, and Nairobi. We also have staff and vendors working around the world in our key regions. This means we transfer your personal information to these various locations.  

Even as your information goes around the world, we are under an obligation to make sure that your information remains safe and secure. We vet our suppliers and have strict contracts in place covering the transfer of personal information to other countries.  

13. How long we keep your information

We keep your personal information for as long as we reasonably need to use it for the purposes set out in section 6 and section 8 (for job applicants). We have set out below a few examples of the periods of time we retain personal information. For full details contact us for a copy of our retention schedule.  

  • Partner records: 10 years following the end of our funding 
  • Unsuccessful potential partners: 3 years from our decision not to fund 
  • Unsuccessful job applicants: 2 years from the communication of our decision 
  • Research and evaluation information: 5 years from the collection of the information

14. Your rights

You are in control of your personal information. When we use your personal information you have the right to: 

  • Ask for a copy of the personal information we hold about you. We may ask you for proof of your identity. We will give you a copy of your personal information unless we consider that an exemption applies. If we withhold any of your personal information, we’ll explain why.  
  • Ask that we erase the personal information we hold about you. We may not be able to erase your information (for example, we may be legally obliged to keep your personal information), but we will consider and respond to your request. 
  • Ask that we correct any personal information that we hold about you that you believe to be incorrect.  
  • Ask that we restrict the use of your personal information if you believe the information we hold is incorrect, or if we don’t have a valid reason for using your personal information.  
  • To change your mind and withdraw your consent.  
  • Ask us to stop using your personal information, if we are relying on legitimate interests as our lawful basis.  

Other rights may apply under various legal regimes, which will not obviously apply to the way in which we use your personal information. For example, European data protection law allows you to port (or transfer) your personal information to a third party in certain circumstances.  

If you have any concerns about the way we are handling your personal information, or if you’ve raised a question or a complaint that we haven’t dealt with, you can (in certain cases) contact your data protection regulator directly. For example, the Information Commissioner’s Office in the UK.  

15. Updates to this notice

We may update this notice from time to time. If we update this notice in a way that significantly changes how we use your personal information we will bring these changes to your attention where reasonably possible. Otherwise, you can access the latest version on our website.  

Dated: August 2021 

Cookie Notice

This notice explains how Luminate uses cookies and other tracking technologies through our website, www.luminategroup.com 

What are cookies?

Cookies are small files that are placed on your computer or mobile deice by a website when you visit it. They contain details of your browsing history on that website and distinguish you from other users. Cookies send data back to the originating website on each subsequent visit or allow another website to recognise that user’s device and, for instance, remember your preferences and generally improve your online user experience. Like most websites, our website uses cookies.  

Although this notice refers to the general term cookie, it also applies to similar tracking technologies that we use (such as web beacons, clear GIFs and pixel tags).  

You can find out more about cookies at www.allaboutcookies.org  

Why do we use cookies?

  1. To let you do things on the website. For example, to fill in application forms or view content.  
  2. To collect statistics. This enables us to improve the website through analysis of usage figures and patterns. For example, it’s useful to us to understand our most popular content, and the way in which users interact with our website.  
  3. To improve your experience with the website. For example, to ensure that users can find what they’re looking for quickly. 
  4. To keep our website secure. For example, we take steps to make sure that personal information you give us does not fall into the wrong hands.   

The table below provides more information about the cookies we use and why.  

Cookie Name
Source
Use
Duration
mtm_consent
Matomo

Used to determine whether Matomo analytics tracking has been accepted or not.

30 years
luminate_cookie_ok
Luminate
Used to track the user's cookie preference.
20 years
_pk_id
Matomo
Used by Matomo to store basic user data including the unique user ID
13 months 
luminate_session
Luminate

Used for communication between the front and backend of the site.  Disabling this cookie would prevent requests to the backend from working, such as Search and Newsletter form submission.


2 hours
MATOMO_SESSID
Matomo

Used by Matomo analytics to allow tracking at a session level.


Session
XSRF-TOKEN
Laravel

Used by Laravel to protect against unauthorised cross site requests to the backend.

2 hours
_pk_ses
Matomo

Short lived session cookie used by Matomo for the current visit


30 mins
__cfduid
Cloudflare

Set by Cloudflare to detect and mitigate the impact of malicious visits to the website. 


30 days

We also use some cookies which are strictly necessary for you to use our website.  

How do I change my cookies settings?

Most browsers also let you turn off either all or at least third-party cookies. What you can do depends upon which browser you are using. If you do not accept our use of cookies as described above, you can configure your browser to reject cookies. However, please be aware that this may impair or limit your ability to use the website. If you are attempting to reject cookies which are strictly necessary for the performance of the website. The ability to do this is usually found in the options, settings, or preferences menu of your browser or mobile device (and we include links for common browsers below).  

Click on the links below to find out how to change your cookies session in the relevant browsers:  

There is also software available which enables you to use settings that allow you to choose which cookies are set on your computer or mobile device, such as the Ghostery App.

Updates to this Notice

We may update this notice from time to time and so we recommend you check this notice regularly. We aim to notify you if there are any significant changes by a notice on this website or by contacting you directly.   

Dated: August 2021