Updated on April, 2021
1. WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU AND WHAT ARE THE SOURCES?
We collect your personal data when you use our Website or Portals, during sales promotion, or a campaign, when you register to our events or to receive Newsletters, to manage your account, when you download the Mobile App, or otherwise when you interact with us. Below are examples of the sources and categories of the personal 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, Portals, 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 our Website or the Portals, some data is created and generated during the use of our Website or Portals such as cookies, server logs and other similar technologies.
B. Personal data LumApps may collect 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; communication between you and LumApps; marketing opt-in’s / opt-out’s; publicly available information about you.
- Analytics Data: The logging systems on our Website and Portals automatically log certain Analytics Data when you visit our Website or Portals. We use Analytics Data to operate and improve our services and may also use it to provide you with personalized 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 our Website or Portals: IP address; geographical location; browser type; referral source; length of visits; pages viewed; heat mapping.
2. COOKIES POLICY
Our Cookies Policy can be found here.
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 data 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 legal basis for each purpose is as follow:
|Use of our Website: Tracking the use of our website and activities, keeping our website up to date and relevant, developing our business, and informing our marketing strategy.||Consent|
|Registration: Register to be in LumApps contact list directly in person (e.g. during an event) or on our Website or Portals, to receive a Demo, Analyst reports, Checklists, Guides, Webinars, White papers, or products and services related information.||Consent|
|Your Testimonial: We may publish your testimonials and quotes on our Website or Portals. LumApps obtains consent from each customer and the featured individual, prior to posting their personal information and testimonial.||Consent|
|Manage your account: Processing of your contact business information for managing and billing your account, to provide you with important real-time information about our products, training, 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.||Legitimate Interest|
|Prospecting: direct marketing and contacting publicly sourced prospects.||Legitimate interest (or consent if required by local laws)|
|To protect our business: In order to administer and protect our business, prevention of fraud, deal with any misuse of our Website or Portals, comply with our security policies at our locations, to handle claims and legal processes.||Legitimate Interest or Compliance with a Legal Obligation|
|Download the Mobile App: In order for you to download the Mobile App on your mobile device from an application store.||Consent|
|Use of our Portals: Tracking the use of the Portals and activities, keeping the Portals update and relevant, providing access to content, and informing our marketing strategy.||Consent|
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 applicable laws. Only authorized personnel within LumApps have access to the data.
We may disclose your personal data to third parties to carry out our usual business practices. Disclosures will only be so that we can process your personal data for the purposes set out above. LumApps may share your personal data to the following third parties:
- Our service providers;
- Our affiliates;
- Third Parties involved in a corporate transaction with us.
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 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 (EEA), specifically in the United States. If personal data is transferred outside the European Union (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), or (ii) 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 firstname.lastname@example.org. 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 the reasons we can’t comply.
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 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 Califonia 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 email@example.com. 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 outside the above circumstances, 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 firstname.lastname@example.org.
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 email@example.com.
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 firstname.lastname@example.org | LumApps SAS, 23 Rue Louis le Grand, 75002 Paris.
15. FAIR RESOLUTION COMMITMENT
We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, and you are located in the EEA, you have the right to lodge a complaint with the competent supervisory authority.