Summit Privacy Policy

Effective date: 2026-01-14
Controller / Company: 14954106 Canada Inc.
Contact: support@lumincs.com (email only)

Short summary

• Data collected: precise & background location, account (name, email), photos/media (uploads), device identifiers, usage & diagnostics.
• Purpose: mandatory workforce tracking, attendance & route auditing, job documentation, operational reporting, and fraud prevention.
• Retention: location data is retained indefinitely by the employer (controller).
• Shared with: employer administrators/managers and service providers (cloud/storage). No advertising.

1) Overview

Summit is a workforce data-collection app used by enterprise customers to monitor technician activity and jobs. 14954106 Canada Inc. is the Data Controller for personal data collected by the Summit app. Summit collects and stores employee data required by employers for job auditing and operational purposes. Enabling location services while on site is mandatory to use the app.

2) Data we collect

• Location data: precise GPS coordinates (in-use and background) recorded while the employee is on site. Location records are associated with job/ticket logs and employee identifiers.
• Account & contact info: employee name, email, phone (if provided).
• Photos & media: photos and files taken/selected to document jobs and receipts (uploaded to employer storage).
• Device & identifiers: device type, OS version, IP address, app instance identifiers, auth tokens.
• Usage & diagnostics: app activity logs, crash diagnostics, and offline sync queues.

3) Purpose & lawful basis

Purpose: Provide mandatory workforce tracking, attendance verification, travel distance calculation, route logs, job documentation, operational reporting, and fraud prevention.

GDPR legal basis: Processing is performed under performance of an employment contract or as otherwise authorized by the employer.

4) Mandatory location collection (on-site)

Location tracking is required while an employee is working on site. If location services are disabled, the app cannot perform core functions and access may be restricted.

5) Controller, access & employee requests

Controller: 14954106 Canada Inc.

Employer access: Employer administrators and managers can access raw location histories, audit logs, and reporting data for their employees.

Employee requests: Employees should direct requests for access, correction, or deletion to their employer. We will cooperate with the employer and act on lawful instructions.

6) Retention & deletion

Location data: retained indefinitely by the employer for operational, compliance, and audit reasons.

Other data: photos, logs, and account data are retained according to employer instructions or until deletion by the employer.

7) Sharing & subprocessors

We share data with the employer and with subprocessors (service providers) necessary to operate the service. Subprocessors operate under contractual obligations.

8) Security

We implement reasonable technical and organizational measures to protect personal data (TLS for data in transit, access controls, authentication, logging, and incident response processes).

9) International transfers

Data may be processed and stored in multiple jurisdictions. Transfers are subject to appropriate safeguards and contractual measures where required by law.

10) Children & age limits

The app is intended for employees only, not for children.

11) Changes & contact

We may update this policy; material changes will be posted with a new effective date.
Contact: support@lumincs.com (email only)

This document is a template and not legal advice. Please have counsel review this policy prior to publication.