Privacy Policy

 

Effective September 05, 2023

Thank you for choosing to be part of our community at Lumenci, 901 S MoPac Expressway, Building 1, Suite #300, Austin, TX 78746 USA (“Lumenci”, “we”, “us”, or “our”). We are sensitive to your concerns about how we use the personal information we collect from you through Lumenci’s website (the “Site”) and other plug-ins exchanging information with Lumenci (“Applications”). We are committed to protecting your personal information and your right to privacy. This Lumenci Policy (“Privacy Policy”) describes how Lumenci may collect, use, store, disclose, and process your personal information through your access to or use of Lumenci products and services, including those at https://www.lumenci.com/, related websites, mobile software applications, and other offerings (collectively, the “Services”).

We hope you take some time to read through this Privacy Policy carefully, as it is important. By using these Services, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Services. Lumenci may change this Privacy Policy from time to time by posting changes at this URL and may send notification emails. Your continued use of the Services following the posting of such changes will be deemed your acceptance of those changes.

If you have any questions or concerns about our policy or our practices with regards to your personal information, please contact us at legal@lumenci.com.

TABLE OF CONTENTS

  1. What information do we collect? 

  2. Methods of collecting personal information 

  3. How do we use your information? 

  4. Will your information be shared with anyone? 

  5. Analytics & advertising 

  6. How do we handle your social logins? 

  7. Data we process on behalf of our customers 

  8. How long do we keep your information? 

  9. What are your privacy rights? 

  10. How do we keep your information safe? 

  11. Data breach 

  12. Do California residents have specific privacy rights? 

  13. Do we collect information from minors? 

  14. Do we make updates to this policy? 

  15. How can you contact us about this policy? 

  16. How can you review, update, or delete the data we collect from you? 

WHAT INFORMATION DO WE COLLECT?

  • Publicly Available Personal Information: Lumenci requires each customer to provide us with personal information (collectively “Personally Identifiable Information”) to access and use Lumenci products and services. We collect email addresses, business emails, business phone numbers, first name, maiden name, last name, phone numbers, and other similar data. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.

  • Testimonials and Review: We may display personal testimonials of satisfied customers. We will ask for your specific consent as part of the survey. If you wish to update or delete your testimonial, you can contact us at legal@lumenci.com. We may also display customer reviews. If you provide a review that we display and wish to update or delete it, you can also contact us at legal@lumenci.com.

Information is automatically collected.

  • Traffic Data: Lumenci or its third-party service providers may collect a variety of visitor data such as IP addresses, browser settings, internet service provider (ISP) information, referring/exit pages, operating systems, date/time stamps, and clickstream data (collectively “Visitor Data”). The Lumenci internal servers and software automatically recognize Visitor Data. The Site may use Visitor Data to compile traffic data about the types of visitors who use the Site at specific intervals (collectively “Traffic Data”).

    We may use Traffic Data to analyze Site traffic. We may also use Traffic Data to diagnose problems with our server, administer our Site, or display content according to your preferences. Visitor Data and Traffic Data may also be disclosed to business partners, affiliates, or advertisers on an aggregated and anonymous basis.

  • Cookies: Lumenci may use the standard cookie feature of major browser applications and third-party providers, including Google Analytics features (Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting), or employ internally developed cookies, clear GIFs, pixel tags, tracking codes, and other technologies that allow Lumenci to store a small piece of data on a visitor’s computer, or any other device a visitor uses to access Online Services, about his or her visit to the Site or use of Applications. You can remove persistent cookies by following the directions provided in your Internet browser’s “help” directory. If you reject cookies, you may still use our site, but your ability to use some areas of our site will be limited.

  • Location Information: When you use the Online Services, we may collect general location information (such as general location inferred from an IP address).

  • Information from Other Sources: We may collect information about you from third parties, such as marketing partners and researchers. Our customers may give us information about you, such as your Contact Data, in order to facilitate contracting through our Online Services. We may combine this information with information we collect from you and use it as described in this Privacy Policy.

METHODS OF COLLECTING PERSONAL INFORMATION

  1. Contact Us page: We collect personal information through the Contact Us page and use it to get back to the user in response to his / her request.

  2. Use of the website: We collect personal information that users provide when they use the website to subscribe to the services offered by Lumenci.

  3. Careers page: When a user accesses the Careers page on our website, we collect personal information that the user voluntarily submits while applying for jobs, and we use it for recruitment-related activities and to further process the job application. We also use it to send relevant information about careers and opportunities with us and to analyze the effectiveness of our recruitment efforts and resources. More information about how we use user data during the recruitment process is provided in the Candidate Privacy Notice.

  4. Email communication: When a user sends us an email, we may collect personal information that he/she freely supplies to us. We may also collect personal information that users post publicly on our website.

  5. Information from other sources: We collect personal information when a user voluntarily uploads information, sends us emails, completes customer surveys, provides feedback, participates in competitions, or applies for a job opportunity at Lumenci.

  6. Marketing communications: If a user receives our marketing communications, we will track when (s)he receives, opens, or shares the link received from Lumenci. To unsubscribe from marketing communications, users should refer to Usage of personal information for marketing purposes.

  7. Other sources:

  • Depending upon the engagement or association with us, we may receive information about users from other sources, including but not limited to vendors, insurance providers, auditors, travel service providers, consulting firms, background check service providers, and social media.

  • Obtaining personal information from public sources such as free or paid databases, including public content on social media websites, to make initial contact with a relevant individual at a client or other company.

HOW DO WE USE YOUR INFORMATION?

We use information we collect from the Online Services to provide you with the Online Services; communicate with you; manage and remember your preferences and customize the Online Services; analyze and improve the Online Services or Online Services we provide; improve our advertising and marketing; verify your identity; comply with our legal obligations or as permitted by law; protect the safety and/or integrity of our users, employees, third parties, members of the public, and/or the Online Services; and prevent fraud and enforce our legal terms.

We use personal information collected via our Services for a variety of business purposes described below.

We use the information we collect or receive:

  • Facilitating the usage of and personalizing the user experience on the Lumenci website.

  • To send administrative information to you: We may use your personal information to send you product, service, and new feature information and/or information about changes to our terms, conditions, and policies.

  • Request Feedback: We may use your information to request feedback and to contact you about your use of our Services.

  • To enable user-to-user communications: We may use your information in order to enable user-to-user communications with each user's consent.

  • To enforce our terms, conditions, and policies for Business Purposes, Legal Reasons, and Contractual.

  • To respond to legal requests and prevent harm: If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

  • To manage user accounts: We may use your information for the purposes of managing our account and keeping it in working order.

  • To deliver services to the user: We may use your information to provide you with the requested service.

  • To respond to user inquiries/offer support to users: We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

  • For other Business Purposes: We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Services, products, marketing, and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

WILL YOUR INFORMATION BE SHARED WITH ANYONE?

We only share information with your consent to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share data based on the following legal basis:

  • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

  • Required by Law. We may also disclose your personal information: as required by law, such as in response to a subpoena or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a legal request.

  • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

  • Visitor Demographics: Contact Data and Traffic Data may be used to gather general statistics about our customers and visitors. We may use Demographic Data to generate collective information about our users, but not in a way that identifies any user specifically. For example, we may inform third parties about the number of registered users and unique visitors, and the page’s most frequently browsed.

  • Service Providers: We may disclose your Personally Identifiable Information to companies that provide support services to us (such as a printer or email service provider) or help us market our products and services. These companies may need information about you in order to perform their functions.

  • Other Transfers: We may disclose Personally Identifiable Information and other data to businesses controlling, controlled by, or under common control with Lumenci. If Lumenci is merged, acquired, or sold, or if some or all of our assets or equity are transferred, we may disclose or transfer Personally Identifiable Information and other data in connection with the associated transactions.

  • Bankruptcy: In the event of an Lumenci bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control how your personal information is treated, transferred, or used. If such an event occurs, your Personally Identifiable Information may be treated like any other Lumenci asset and sold, transferred, or disclosed to third parties, or used in ways not contemplated or permitted under this Privacy Policy. In this case, you will be notified via email and/or a prominent notice on our site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

  • Consent:  In addition to the disclosures described in this Policy, we may disclose information about you whenever you consent to or direct such disclosure.

ANALYTICS & ADVERTISING

Analytics: We may use third-party web analytics services on the Online Services, such as those of Google Analytics. These service providers use the sort of technology described in the “Information We Collect Automatically” section above to help us analyze how users use the Online Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Service. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.

Advertising: Our partners and affiliates, including Google Analytics (Google Tag Manager, Search Console, Keyword Planner, Google Display Network, and Campaign Manager 360), may use cookies and web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. This means that these partners and affiliates may show our ads on sites across the Internet based upon your previous visits to our site. Together with our partners and affiliates, we may use these cookies and web beacons to report how you're on-page activity and interactions with these ad impressions, and ad services are related to your visits to our site. 

The use of tracking technologies by our service providers, technology partners, or other third-party assets (such as social media links) on the site is not covered by our Privacy Policy. We do not have access to or control over these technologies.

Opting Out of Marketing. We send promotional emails and newsletters from time to time to users who have registered on the site and to those who have opted in to receive such emails. You can opt out of promotional communications by following the unsubscribe instructions in any communication or by emailing us at legal@lumenci.com. Generally, you may not opt out of service-related or transactional communications which are not promotional. If you do not wish to receive service-related communications, however, you may terminate your account by contacting legal@lumenci.com. 

Do Not Track. Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.

DATA WE PROCESS ON BEHALF OF OUR CUSTOMERS

We receive information from and on behalf of our customers when they use our Services. Because of the nature of the services, this information may contain any type of personally identifiable information, including Contact Data, Financial Data, Demographic Data, and Legal Data (such as social security numbers, company information, trade secrets, inventions, and idea submissions and other sensitive information necessary to generate legal documents). We process such data only in accordance with our customer’s instructions. For such data, the customer is the "data controller" (for purposes of GDPR) or the “business” (for purposes of the CCPA) and is responsible for most aspects of the processing of personal information. If you have any questions or concerns about how your personal information is processed in these cases, including how to exercise your rights as a data subject, please contact the customer. If we receive any rights requests concerning instances where we act as data processors, we will forward your query to the relevant customer.

We may also collect the information of third-party individuals on behalf of our customers. For example, our customers may use our service to collect counterparty information to populate a contract. Lumenci primarily uses this information for the purpose of administering and improving its services for our customers. Where the third-party individual chooses to create a Lumenci account with us, however, we will process their information in accordance with this Privacy Policy.

HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this policy will require us to keep your personal information for longer than the period in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

WHAT ARE YOUR PRIVACY RIGHTS?

You may review, change, or terminate your account at any time. To the extent provided by the law of your jurisdiction, you (a) request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes, (b) request that we update or correct inaccuracies in that information, (c) object to our use of your personal information, and (d) request to download the information you have shared on the Services. You may make these requests and any other inquiries about this Privacy Policy by emailing us at legal@lumenci.com. Any such requests are subject to the protection of other individuals’ rights and applicable law.

You may choose not to provide Lumenci with Personally Identifiable Information, or you may turn off cookies in your browser by changing its settings. If you make these decisions, you may continue to use the Online Services and browse its pages. However, Lumenci cannot process orders without Personally Identifiable Information.

  • Deleting Your Information. If you no longer desire our services, or if you want to remove your Personally Identifiable Information from our Site, you may terminate your account by contacting legal@lumenci.com.

  • Opting Out of Marketing. We send promotional emails and newsletters from time to time to users who have registered on the site and to those who have opted in to receive such emails. You can opt out of promotional communications by following the unsubscribe instructions in any communication or by emailing us at legal@lumenci.com. Generally, you may not opt out of service-related or transactional communications which are not promotional. If you do not wish to receive service-related communications, please contact legal@lumenci.com.

  • If you are a resident of the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

HOW DO WE KEEP YOUR INFORMATION SAFE?

We strive to make certain that our servers and connections incorporate the latest encryption and security devices. We have implemented electronic and managerial procedures to safeguard and secure the information we collect. personal information is transmitted by secure servers (SSL). In the event that we mail you documents, documents are delivered to you via UPS or similar overnight delivery services, the United States Postal Service, or email. Unfortunately, no data transmission is guaranteed to be 100% secure, and we, therefore, cannot guarantee the security of information you transmit to or from the Site, Applications, or through the use of our services, and you provide this information at your own risk. ACCORDINGLY, WE DISCLAIM LIABILITY FOR THE THEFT, LOSS, OR INTERCEPTION OF, OR UNAUTHORIZED ACCESS OR DAMAGE TO, YOUR DATA OR COMMUNICATIONS BY USING THE SITE, APPLICATIONS, AND OUR SERVICES. YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND ASSUME THESE RISKS.

DATA BREACH

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure, or disposal of personal information. You will be notified about data breaches when Lumenci believes you are likely to be at risk of serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that Lumenci becomes aware of a security breach that has resulted or may result in unauthorized access, use, or disclosure of personal information, Lumenci will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED THROUGH THE USE OF OUR WEBSITE, APPLICATIONS, OR OTHER SERVICES, PLEASE CONTACT US IMMEDIATELY AT legal@lumenci.com.

DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Supplemental Privacy Notice for California Residents

This Supplemental Privacy Notice supplements the information in our Privacy Policy above, and except as provided herein, applies solely to California residents. It applies to personal information we collect on or through the Online Services and through other means (such as information collected offline, in person, and over the telephone). It does not apply to personal information we collect from our employees and job applicants in their capacity as employees and job applicants. It also does not apply to personal information we process as a service provider.

Summary of Information We Collect

If you are a California resident, California law requires us to provide you with some additional information regarding how we collect, use, and disclose your “personal information” and "sensitive personal information" (as defined in the California Consumer Privacy Act (“CCPA”)).

Throughout our Privacy Policy, we describe the specific pieces of personal information and sensitive personal information we collect, the sources of that information, and how we disclose it. Under the CCPA, we also have to provide you with the "categories" of personal information we collect and disclose for “business purposes” (as those terms are defined by applicable law). Those categories are identifiers (such as name, address, email address, phone number, other account information, and cookies); internet or other network or device activity (such as IP address or service usage); geolocation information (general location); inference data about you; professional or employment-related data; education data; insurance (including health insurance) information; medical information; physical characteristics or description; legally protected classifications (such as gender); other information that identifies or can be reasonably associated with you.

We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Online Services; (3) affiliates; and (4) third parties such as social networks and other Lumenci users.

We or our service providers may collect and disclose the above categories of information for the purposes described in our Privacy Policy. This includes the following business or commercial purposes (as those terms are defined in applicable law):

  • Our or our service provider’s operational purposes.

  • Auditing consumer interactions on our site.

  • Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity.

  • Bug detection and error reporting.

  • Customizing content that we or our service providers display on the Online Services.

  • Providing Online Services (e.g., fulfillment, customer service, advertising and marketing, analytics, and communication about the Online Services).

  • Improving the Online Services and developing new services (e.g., by conducting research to develop new products or features).

  • Other uses about which we notify you.

We may also use the above categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.

We describe our information disclosure practices in our Privacy Policy. We may disclose certain categories of personal information with third parties (as defined by the CCPA) for the business purposes described above. For example, we may disclose identifiers and other information that identifies or can reasonably be associated with you with counterparties to your agreements. We may disclose identifiers with our marketing partners, and we may also disclose any of the categories described above with our subsidiaries and affiliates. If you connect your account with social media services or interact with social media plugins or links on the Online Service, we may disclose identifiers, commercial information, internet or other network or device activity, or general location with those social media services.

Consumer Rights

If you are a California resident, you may have certain rights. California law may permit you to request that we:

  • Provide you the categories of personal information we have collected or disclosed about you; the categories of sources of such information; the business or commercial purpose for "collecting," "selling," or "sharing" your personal information; the categories of third parties to whom we disclose or "sell," or with whom we "share," personal information; and the categories of personal information we "sell."

  • Provide access to and/or a copy of certain information we hold about you.

  • Delete certain information we have about you.

  • Correct inaccurate personal information that we maintain about you.

You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide the Online Services to you. If you ask us to delete it, you may no longer be able to access or use the Online Services.

In instances where we process personal information on behalf of our customer, rights requests should be directed to the relevant customer. Any request sent directly to us that pertains to information collected on behalf of a customer will be forwarded to that customer.

If you would like to exercise any of these rights, you can submit a request at legal@lumenci.com or submit the Customer Rights Request Form. You will be required to verify your identity before we fulfill your request. To do so, you will need to provide information to match with our existing records to verify your identity, depending on the nature of the request and the sensitivity of the information sought. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

“Sale” of Personal Information

California residents may opt out of the "sale" of their personal information. The CCPA broadly defines "sale" in a way that may include allowing third parties to receive certain information, such as cookie identifiers, IP addresses, and/or browsing behavior, to add to a profile about your device, browser, or you. Such profiles may enable the delivery of interest-based advertising by such third parties within their platform or on other sites.

Depending on how you use the Service, we may disclose the following categories of information for such interest-based advertising, which may be considered a “sale” as defined by the CCPA: identifiers (such as IP address, device identifiers, and cookies) and internet and device activity. To opt out of such "sales," please submit a request to legal@lumenci.com or submit the Customer Rights Request Form.

"Sharing" of Personal Information

California residents may opt out of the "sharing" of their personal information. The CCPA defines "sharing" as the targeting of advertising to a consumer based on that consumer's personal information obtained from the consumer's activity across websites. We "share" information for these purposes to provide more relevant and tailored advertising to you regarding our Services. As part of this advertising, we may "share" identifiers (such as IP address, device identifiers, and cookies) and internet and device activity with advertising platforms and advertising networks. To opt out of such "sharing," please submit a request to legal@lumenci.com or submit the Customer Rights Request Form.

Please note that we also respond to and abide by opt-out preference signals sent through Global Privacy Control. Any opt-out preferences you have exercised through these methods will only apply to the specific device/browser on which you made them. For more information on how to use Global Privacy Control, see www.globalprivacycontrol.org.

Children Under 16

We do not knowingly "sell" or "share" the personal information of children under 16.

Sensitive Personal Information

The CCPA also allows you to limit the use or disclosure of your "sensitive personal information" (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for purposes for which you cannot opt-out under the CCPA.

Retention of Your Personal Information

Please see the " HOW LONG DO WE KEEP YOUR INFORMATION " section above.

California Shine the Light

We do not disclose personal information to third parties for their direct marketing purposes.

DO WE COLLECT INFORMATION FROM MINORS?

The Online Services are not directed to children under the age of 13. We do not knowingly collect personal information (as that term is defined in the Children’s Online Privacy Protection Act (COPPA)) from children under 13. If we discover that an individual under 13 has provided us with personal information, we will delete the personal information to the extent required by COPPA.

We do not knowingly process data of EU residents under the age of 16 without parental consent. If we become aware that we have collected data from an EU resident under the age of 16 without parental consent, we will take reasonable steps to delete it as soon as possible.

DO WE MAKE UPDATES TO THIS POLICY?

We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date, and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.

HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Support, by email at legal@lumenci.com, or by post to:

Lumenci, 901 South Mopac Expressway, Building 1, Suite 300, Austin, TX 78746, USA

HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the laws of some countries, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please submit a request form by emailing us at legal@lumenci.com. We will respond to your request within 30 days.