Terms of Use

1. Acceptance of Terms

These Terms of Use (the “Terms”) form a legally binding agreement between you and PT Lumira Solusi Digital (“Lumira”, “we”, or “us”), governing your access to and use of the Lumira Health platform, including its web application, mobile interfaces, APIs, and all related features and services (collectively, the “Platform”).

By accessing or using the Platform — including by any sign-in method made available on the Platform — you represent that you have read, understood, and agreed to be bound by these Terms and our Privacy Policy. If you access the Platform on behalf of a healthcare facility or organisation (the “Clinic”), you represent that you have authority to bind that Clinic to these Terms.

If you do not agree to these Terms, you must not access or use the Platform.

2. Definitions

• “Platform” means the Lumira Health SaaS software application, including all features, APIs, and content provided by Lumira.
• “Clinic” means the healthcare facility, clinic, or individual healthcare practitioner that subscribes to and uses the Platform.
• “User” means any individual accessing or using the Platform, including clinic owners, administrators, practitioners, nurses, and staff.
• “Patient Data” means personal data and/or health data relating to patients entered, processed, or stored on the Platform by the Clinic, including but not limited to names, phone numbers, email addresses, NIK or passport numbers, and medical notes in SOAP (Subjective, Objective, Assessment, Plan) format.
• “Subscription” means the active plan used by a Clinic to access the Platform, whether free or paid.
• “Content” means data, text, files, documents, or other materials uploaded to or generated through the Platform.
• “Customer Data” means personal data relating to the Clinic or its Users collected at registration and through use of the Platform, including name, age, gender, phone number, and email address.

3. Eligibility and Registration

To use the Platform, you must:

• Be at least 18 years old
• Be a registered healthcare facility or licensed healthcare practitioner operating under Indonesian law, or authorised staff of such a facility
• Have a valid email address and, where required, a registered Google account for authentication
• Provide accurate, complete, and current information at registration and throughout your use of the Platform

You are responsible for keeping your login credentials confidential and for all activity that occurs under your account. You must promptly notify us at support@lumirahealth.co if you suspect any unauthorised access to your account.

Lumira may refuse registration or suspend any account at its sole discretion, in particular where information provided is inaccurate or incomplete, or there is reason to believe the account is being misused.

4. Subscription Plans and Access

4.1 Plan Tiers

Lumira offers subscription tiers, which may include a free plan with limited features and paid plans with broader access. The features available to you depend on your active Subscription. Lumira may modify features included in any plan with reasonable notice.

4.2 Free Plan

Where a free plan is offered, it is subject to patient or usage caps as specified on the Lumira website or in the Platform. Use beyond those limits requires upgrading to a paid Subscription.

4.3 Paid Subscriptions

Paid Subscriptions are billed in advance on a monthly or annual basis. All fees are stated in Indonesian Rupiah (IDR) unless otherwise specified. Fees are non-refundable except as expressly stated in these Terms or as required by applicable Indonesian law. Failure to pay may result in suspension or termination of access to the Platform.

4.4 Upgrades and Downgrades

You may upgrade or downgrade your Subscription at any time. Upgrades take effect immediately. Downgrades take effect at the start of the next billing cycle. Lumira is not responsible for data or feature loss arising from downgrades.

4.5 Support Services

Lumira product support is available by email and via a WhatsApp Business account on working days, 09:00–17:00 WIB, excluding public holidays. Messages received outside those hours will be addressed when support is next available.

5. Permitted Use

The Platform is provided exclusively for lawful healthcare management. You may use the Platform to:

• Manage patient appointments, medical records, invoices, and clinical documentation
• Record and store Electronic Medical Records (EMR) in accordance with Permenkes No. 24/2022
• Communicate with patients regarding their healthcare (e.g. appointment reminders, payment receipts)
• Invite and manage staff members and practitioners within your Clinic account
• Create and manage invoices and process payments via third-party payment gateways when enabled by the Clinic user

6. Prohibited Use

You must not use the Platform in any way that:

• Violates applicable Indonesian laws or regulations, including those governing healthcare services, data protection, and electronic systems
• Involves unauthorised collection, processing, or disclosure of Patient Data
• Constitutes medical advice, diagnosis, or treatment — Lumira is an administrative management and basic clinical documentation tool, not a clinical decision-support system or a full medical information system
• Involves uploading malicious code, viruses, or software designed to disrupt or damage the Platform
• Attempts unauthorised access to any part of the Platform or to other Clinics’ data
• Involves scraping, reverse engineering, decompilation, or any attempt to extract the Platform’s source code
• Resells, sublicenses, or commercialises access to the Platform without prior written consent from Lumira
• Misrepresents your identity or your affiliation with any individual or organisation
• Uses the Platform for any purpose other than lawful healthcare facility management

7. Patient Data and Data Responsibilities

7.1 The Clinic as Data Controller

The Clinic is the data controller for all Patient Data entered into the Platform. Lumira acts as a data processor on behalf of the Clinic. The Clinic is fully responsible for ensuring a lawful basis for the collection and processing of Patient Data. Because the Platform processes health data through SOAP-note features, the Clinic must obtain explicit consent from patients under Article 34 of the PDP Law No. 27/2022 before entering patient health data into the Platform. The Clinic is also responsible for complying with all applicable healthcare regulations concerning patient data collection and storage.

7.2 Data Accuracy

The Clinic and its Users are solely responsible for the accuracy, completeness, and legality of all Patient Data and other Content entered into the Platform. Lumira does not verify or validate clinical data and is not responsible for errors, omissions, or inaccuracies in Patient Data.

7.3 Data Security Obligations

You agree to use the Platform’s access controls appropriately, including assigning roles that reflect each staff member’s actual responsibilities. In particular, the Clinic is responsible for ensuring that access to SOAP medical records is limited to authorised clinical staff, and that administrative staff only have access to data needed for their function. You must promptly revoke access for staff who leave or change roles. Sharing of login credentials between users is prohibited.

7.4 Medical Record Storage

Electronic medical records created on the Platform, including SOAP notes, are subject to mandatory retention under Indonesian healthcare law: at least five (5) years from the patient’s last visit, in accordance with the rules applicable to clinics and independent practice. The Clinic is responsible for understanding and complying with this obligation. Lumira will retain medical records during the Clinic’s active Subscription and for a reasonable period thereafter, in accordance with these Terms.

7.5 Data Breach Notification

In the event of a data security breach affecting Patient Data, Lumira will notify the affected Clinic as soon as possible and no later than 3×24 (seventy-two) hours after Lumira becomes aware of the breach, in accordance with the PDP Law No. 27/2022. The Clinic is responsible for notifying affected patients and relevant authorities in accordance with its obligations as data controller.

7.6 Data Export and Access

Lumira provides a data export feature that lets you download your clinic’s data through the Platform interface. The following terms apply:

• Access during the Subscription. Access to all data within the Platform is available only during an active Subscription. Once the Subscription ends, is disabled, or is not renewed, access to the Platform and all data within it is disabled.
• Exporting data before the Subscription ends. We strongly recommend exporting your data at least 30 days before the Subscription ends to avoid losing access.
• After the Subscription ends. Lumira will retain your data for 90 days after the Subscription end date. During this period, you may request a data export by contacting support@lumirahealth.co. After 90 days, data will be permanently deleted or anonymised, unless retention is required by applicable law — including the obligation to retain electronic medical records for at least 25 years.
• Export format and mechanism. Data is exported in the formats available on the Platform. Lumira is not required to provide data in raw database formats (such as MySQL dumps) or in any format outside what the Platform provides.
• Security of exported data. Exported data is the User’s sole responsibility once downloaded. Users must keep the file secure from unauthorised access.
• Export limits. To preserve system performance, exports may be limited in volume or frequency. For large export requests, please contact the team in advance at support@lumirahealth.co.

8. Intellectual Property

8.1 Lumira’s Intellectual Property

All intellectual property rights in the Platform — including software, designs, user interfaces, trademarks, logos, and documentation — are owned by or licensed to PT Lumira Solusi Digital. These Terms do not transfer any intellectual property rights to you. You are granted a limited, non-exclusive, non-transferable licence to access and use the Platform solely for the purposes described in these Terms.

8.2 Your Content

You retain ownership of all Content and Patient Data you upload to the Platform. By using the Platform, you grant Lumira a limited, non-exclusive licence to process, store, and display your Content solely for the purpose of providing the Platform services to you. Lumira will not use your Content or Patient Data for any other purpose, including advertising or sale to third parties.

8.3 Feedback

If you provide Lumira with feedback, suggestions, or ideas regarding the Platform, you grant Lumira a perpetual, irrevocable, royalty-free licence to use that feedback for any purpose without compensation to you.

9. Third-Party Services

The Platform integrates with third-party services for authentication, payment processing, transactional email delivery, database infrastructure, and content delivery and security networks. A full list of third-party providers and the data processed is set out in our Privacy Policy. Use of these third-party services is subject to their respective terms and privacy policies. Lumira is not responsible for the practices, availability, or content of any third-party service.

The Platform may include links to third-party websites or resources. Such links are provided for convenience only and Lumira does not endorse or take responsibility for any third-party content or service.

10. Disclaimer

THE PLATFORM IS PROVIDED “AS IS” AND “AS AVAILABLE” WITHOUT WARRANTIES OF ANY KIND, EXPRESS OR IMPLIED. TO THE EXTENT PERMITTED BY APPLICABLE LAW, LUMIRA DISCLAIMS ALL WARRANTIES, INCLUDING BUT NOT LIMITED TO:

• Warranties of merchantability, fitness for a particular purpose, and non-infringement
• That the Platform will operate uninterrupted, error-free, or free of viruses or harmful components
• That any errors or defects in the Platform will be corrected
• That the Platform is suitable for any specific clinical, regulatory, or compliance purpose

THE PLATFORM IS A CLINIC-MANAGEMENT TOOL ONLY. LUMIRA DOES NOT PROVIDE MEDICAL ADVICE, CLINICAL DECISION SUPPORT, OR DIAGNOSTIC SERVICES. ALL CLINICAL DECISIONS REMAIN THE FULL RESPONSIBILITY OF THE LICENSED HEALTHCARE PRACTITIONERS USING THE PLATFORM.

The SOAP-notes feature provided on the Platform is a clinical documentation tool. The templates and formats provided are not intended as clinical guidance, treatment recommendations, or a substitute for the professional judgement of a healthcare practitioner.

11. Limitation of Liability

To the extent permitted by applicable Indonesian law, PT Lumira Solusi Digital, its directors, employees, and agents are not liable for:

• Indirect, incidental, special, consequential, or punitive damages
• Loss of data, revenue, profits, or business opportunity
• Damages arising from your reliance on the Platform for clinical, regulatory, or compliance purposes
• Damages from unauthorised access to or alteration of your data

Where liability cannot be excluded under applicable law, Lumira’s total liability to you for any claim arising under or in connection with these Terms will not exceed the total Subscription fees you have paid to Lumira in the three (3) months preceding the event giving rise to the claim.

12. Indemnity

You agree to indemnify, defend, and hold harmless PT Lumira Solusi Digital and its officers, directors, employees, and agents from and against any claims, damages, losses, liabilities, costs, and expenses (including reasonable legal fees) arising from or relating to:

• Your use of the Platform in breach of these Terms
• Your breach of any applicable law or regulation, including those governing health data and patient privacy
• Patient Data or Content you upload to the Platform
• Claims by any third party, including patients, arising from your use of the Platform

13. Term and Termination

13.1 Term

These Terms remain in force for as long as you access or use the Platform or maintain an active Subscription, whichever is longer.

13.2 Termination by You

You may terminate your Subscription at any time by contacting us at support@lumirahealth.co or through the Platform account settings. Termination takes effect at the end of the current billing cycle. No refunds are issued for the unused portion of a paid Subscription period, except as required by applicable law.

13.3 Termination by Lumira

Lumira may suspend or terminate your access to the Platform immediately and without notice if:

• You breach any provision of these Terms
• You fail to pay fees when due
• We are required to do so by law or regulatory authority
• We reasonably believe your use of the Platform poses a risk to the Platform, other users, or third parties

13.4 Effect of Termination

Upon termination, your right to access and use the Platform ceases immediately. Lumira will retain your data for 90 days after termination, during which you may request an export of your data. After this period, your data will be deleted or anonymised, subject to mandatory legal retention obligations for medical records.

14. Changes to These Terms

Lumira may update these Terms from time to time. When we make material changes, we will notify you by email and/or in-platform notice at least 14 (fourteen) days before the changes take effect. Your continued use of the Platform after the effective date of the revised Terms constitutes acceptance of the changes.

The latest version of these Terms is always available in the Platform under Settings and on our website.

15. Governing Law and Dispute Resolution

These Terms are governed by and construed in accordance with the laws of the Republic of Indonesia, without regard to its conflict-of-laws rules.

Any dispute, controversy, or claim arising out of or in connection with these Terms, or their breach, termination, or invalidity, will first be attempted to be resolved through good-faith negotiation between the parties. If the dispute cannot be resolved within 30 (thirty) days of written notice, it will be submitted to the competent courts in Bali, Indonesia, unless the parties agree in writing to an alternative dispute resolution mechanism, or unless applicable law requires another jurisdiction.

16. General Provisions

• Entire agreement: These Terms, together with our Privacy Policy, constitute the entire agreement between you and Lumira regarding the Platform and supersede all prior agreements and understandings.
• Severability: If any provision of these Terms is held to be unenforceable, the remaining provisions remain in full force.
• Waiver: Lumira’s failure to enforce any right or provision of these Terms does not constitute a waiver of that right or provision.
• Assignment: You may not assign your rights or obligations under these Terms without prior written consent from Lumira. Lumira may assign its rights and obligations without restriction.
• Language: In the event of a conflict between the Bahasa Indonesia and English versions of these Terms, the Bahasa Indonesia version prevails for disputes subject to Indonesian jurisdiction.

17. Contact Us

If you have questions about these Terms, please contact:

PT Lumira Solusi Digital
Bali, Indonesia
WhatsApp Business: +62 822-2163-7132
Email: support@lumirahealth.co
Website: www.lumirahealth.co.id