1. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU AND WHAT ARE THE SOURCES?
We collect your personal data when you use our Website, during sales promotion, or a campaign, when you register to our events or to receive Newsletters, or otherwise interact with us. Below are examples of the categories of the data we collect on you.
A. The sources from which we obtain your personal data
- Information you provide to us. The personal data we collect and use is mainly provided by you, either in person (at our locations or otherwise), via our Website, application or by telephone. This could include personal data which you provide when you: register for an event; subscribe to our communications; request information on our products or services; complete a survey from us or give us feedback; etc.
- External or public sources. With respect to potential customers, and potential candidates for employment with LumApps, we also receive personal data from external third party or public sources, as we constantly search for new customers and employees. If you did not provide us your personal information directly, we will inform you of the source when we first contact you.
- Automated technologies. When you visit the Website some data is created and generated during the use of our Website such as cookies, server logs and other similar technologies.
B. Personal data LumApps collects about you
- We may process the following contact information relating to you: name; title and name of the company represented; contact information (such as email address, postal address and phone number); technology used; communications between you and LumApps; marketing opt-in’s / opt-out’s; publicly available information about you.
- Analytics Data: The logging systems on our Website automatically log certain Analytics Data when you visit the Website. We use Analytics Data to operate and improve our services and may also use it to provide you with personalised information about LumApps. Although we do not normally use Analytics Data to identify you as an individual, you can sometimes be recognized from it, either alone or when combined or linked with your company and your contact information. In such situations, Analytics Data can also be considered personal data under applicable laws and we will treat such data as personal data. We may automatically collect the following Analytics Data when you visit or interact with the Website: IP address; geographical location; browser type; referral source; length of visits; pages viewed; heat mapping.
2. COOKIES POLICY
Our Cookies Policy can be found www.lumapps.com/cookies-policy
3. HOW DO WE USE AND PROCESS YOUR PERSONAL DATA AND WHAT LEGAL BASIS DO WE HAVE?
We will always use and process your personal information in accordance with the applicable laws.
For certain purposes it is appropriate for us to obtain your prior consent. Where we rely on consent, you may at any time withdraw the specific consent by contacting us at email@example.com.
Where we are relying on a basis other than consent, we process your personal data mainly to pursue our legitimate interest to: (i) maintain and develop business relationships and to run and develop our business; (ii) to comply with our contractual obligations; and (iii) to comply with our legal obligations.
The main purposes are:
- For business purposes: such as direct marketing and contacting prospects. You can, however, prohibit direct marketing by sending email to firstname.lastname@example.org. We do not sell or rent personal data to third parties for marketing purposes.
- To manage our relationship with you: to provide you with important real-time information about our products or services, to send you the information you have requested, to deal with your inquiries, and to ask you to leave a review or feedback on us. We may publish customer testimonials and quotes on the Website. LumApps obtains consent from each customer and the featured individual prior to posting their personal information and testimonial.
- To protect our business. In order to administer and protect our business, prevention of fraud, deal with any misuse of our Website, to comply with our security policies at our locations, to handle claims and legal processes.
- For our legal obligations. This includes data processed for complying with our legal obligations and providing information to relevant authorities.
- For Website usage. We may process information regarding your use of our Website for use data analytics, to identify usage trends, determine and measure the effectiveness of promotional campaigns and advertising, and to improve our Website, products/services, marketing, customer relationships, and experiences. This processing is necessary to define the types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy.
LumApps will not sell your personal data.
4. HOW DO WE SHARE YOUR PERSONAL DATA?
We will keep your personal data confidential except where disclosure is required or permitted by law. Only authorized personnel within LumApps have access to the data.
We may disclose your personal data to our affiliates or third party data processors who may process data on our behalf to enable us to carry out our usual business practices. Disclosure will only be so that we can process your personal data for the purposes set out above. LumApps seeks to conclude data processing agreements with its service providers to ensure that your personal data is used, stored and transferred securely and in accordance with the applicable laws.
We may also disclose or transfer personal data to fulfill legal obligations or when a legal authority requires a disclosure. We may also disclose personal data if we are a party of a business sale, such as a merger or an acquisition.
5. YOUR DUTIES AS CONTROLLER AND AS DATA SUBJECT
Personal data must be accurate and current and we take all reasonable precautions to ensure that this is the case but we do not undertake to check or verify the accuracy of personal data provided by you. Please keep us informed if your personal data changes during your relationship with us by contacting us. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete personal data that you provide to us.
6. LOCATION OF YOUR PERSONAL DATA
It is possible that personal data we collect from you may be transferred, stored and/or processed outside the European Economic Area, specifically in the United States. If personal data is transferred outside the EU, we make sure that (i) the transferee is located in a country with adequate safeguards (as decided by the EU commission from time to time), the (ii) transferee is Privacy Shield certified (if a US-based company) or (iii) the transfer occurs by using model clauses published by the EU commission.
7. DATA STORAGE PERIOD
LumApps collects and stores personal data in accordance with general industry standards and practices and has implemented appropriate technical and organizational measures taking into account the nature of the data processing. LumApps uses Google Cloud infrastructure, Google Infrastructure Security Design, and Google Cloud Platform. Access to personal data is also protected with user-specific logins, passwords, and user rights. Our premises are also safe and secure.
9. YOUR RIGHTS
You can execute and use any of your rights listed below, by contacting us by sending email at email@example.com. In such a case, we ask you to provide us your name, contact details, as well as something that we can use to reasonably verify your identity. Once you have contacted us about this right, we will either comply with your request or explain why we can’t.
You have the following rights:
- Access to your personal data: upon your request, we can confirm whether we are processing your personal data and what data we have about you.
- Rectify your personal data: you can ask us to correct or amend any inaccurate or incomplete personal data that we hold.
- Erasure of your personal data: you have a right to ask us to remove your personal data from our database and the database of third parties. Notwithstanding any overriding exceptions, the right to erasure applies where: (i) your personal data is no longer necessary for the purposes it was originally collected or processed; (ii) the lawful basis of processing your data is consent and you withdraw your consent; (iii) you object to the processing and there are no reasons (overriding legitimate grounds) for continuing processing; (iv) your personal data has been unlawfully processed; (v) your personal data has to be erased to comply with a legal obligation.
- Restriction of processing of your personal data: you can ask us to restrict (suppress) or “block” processing of your personal data for example when your data erasure, rectification or objection requests are pending and/or when we do not have legitimate grounds to process your data. This may, however, lead to fewer possibilities to use our services.
- Data portability: if we process your personal data based on your consent, you have the right to require the transfer of the data you have provided to us.
- Object to processing your personal data: If we process your personal data based on public interest or our legitimate interest, you have the right to object to the processing of your data. Unless certain exemptions apply (such as there are compelling legitimate grounds, or the processing relates to a legal claim and we tell you about this) we will stop processing your personal data.
10. CALIFORNIA RIGHTS
- Authorized Agent: You have the right to designate an authorized agent to make any CCPA request on your behalf. LumApps reserves the right to ask for proof that such agent is in fact authorized by you.
For the exercise of the rights granted to California Residents, please note that LumApps may need to identify you and to ask for additional information in order to be able to fulfill your request. You can make your request at firstname.lastname@example.org. In both instances, you may be required to provide your email address on file with us among other information. Upon verification of your identity, we will fulfill your request. However, we will not provide any information that we reasonably believe may be subject to fraudulent action.
11. CHILDREN’S POLICY
We do not collect data from children under 13. If we learn we have collected personal data of a child under 13, or equivalent minimum age of jurisdiction, we will take the proper steps to remove this data. If you believe, at any time, that we have collected data from a child under 13, or if a parent or guardian needs to access, correct, or delete their child’s personal data, please reach out to email@example.com.
12. LINKS TO OTHER WEBSITES AND SERVICES
14. HOW TO CONTACT US
If you wish to correct your personal data held by us or to opt-out at any time from receiving marketing correspondence from us or to alter your marketing preferences, please contact firstname.lastname@example.org.
If you need to contact us in connection with our use or processing of your personal data, or gain access to it then our contact details are email@example.com | LumApps SAS, 23 Rue Louis le Grand, 75002 Paris.