Privacy Policy

Lumesse UK Limited (“Lumesse”, “we”) operates the website lumesse.com as well as the career platform careers.lumesse.com (together the “Site”), accessible at https://Lumesse.com and careers.lumesse.com. Through this privacy policy, we inform you on what personal data we collect when you visit our Site and how we process it. With this privacy policy we also fulfil our duty to inform you pursuant to Art. 13 GDPR.

1. Identity of the controller and contact details of our Data Protection Officer

The controller is the

Lumesse UK Limited

475 The Boulevard

Capability Green Luton LU1 3LU

United Kingdom

You can contact our Data Protection Officer at:

dpo@lumesse.com

2. When, how and why we process personal data

2.1   Personal data

Pursuant to the General Data Protection Regulation (“GDPR“), personal data means any information relating to an identified or identifiable natural person (‘data subject’). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

2.2   Which kind of data we process and how we collect it

2.2.1  General use of our Site

Insofar as you do not actively make personal data available to us, we do not store personal data while you use our Site except that our webserver(s) register all connections to the Site automatically and collect the following technical information about your visit:

  • Your IP address;
  • the name of the files accessed;
  • information about the transmission;
  • date and time of the connection;
  • the amount of data transmitted;
  • the requesting provider;
  • the referrer; and
  • the web browser/user agent.

We do not store your IP address after it is communicated to our webserver via your device. Hence, all information listed above is stored anonymously, and we cannot identify you through this information.

2.2.2   Contact

If you contact us by writing an email or using the respective form on the website, we collect your email address and all information that is included in the email.

2.2.3     Online application

If you apply for a position at Lumesse, we collect the following data either directly from you, or, if you gave us the permission, from a social network profile:

  • First Name
  • Last Name
  • Email Address
  • Alternative Email Address
  • Phone number
  • Links to your social media profiles
  • Street
  • City
  • County
  • Postcode
  • Country
  • CV
  • Resume
  • Attachments
  • How you learned about the vacancy

2.3     Why and on which legal basis do we do that

We process your IP address only to allow your device to establish a connection to our webserver over the Internet. This processing is based on Art. 6 par. 1 lit. f) GDPR.

If you contact us by email or by using a contact form, the processing is based on Art. 6 par. 1 lit. f) GDPR. The purpose as well as our legitimate interest is to answer your inquiry.

If you apply for a job position at Lumesse, we process your data for the purpose of the recruitment process. The legal basis for this is Art. 6 par. 1 lit. b) GDPR and Art. 88 GDPR in connection with a national law, if the relevant country adopted national laws for the protection of employee data. For example Germany has adopted such legislation in Sec. 26 par. 1 s. 1 BDSG (Federal Data Protection Act). If you gave us your consent, we process the data in order to consider you for and inform you about job positions at Lumesse in the future. The legal basis for such processing is Art. 6 par. 1 lit. a) GDPR.

3. Who receives personal data from us and when it is transferred to third countries

Internally, the relevant department processes your data. Externally, we use IT service providers. A transfer to third countries does not take place, unless otherwise stated below.

4. Period for which personal data will be stored

We delete your IP address immediately after you stop visiting our Site and do not store it. Our log files are stored for 28 days. Your E-Mails will be stored for the time needed to answer your inquiry and for 3 more years, if you refer to us again. If you apply for a job at Lumesse, we store your data for the duration of the recruitment process and for 6 more months after the recruitment process ended. If you gave us your consent to consider you for and inform you about new job positions at Lumesse, we store the date until you withdraw your consent. Additionally, we delete your data after 12 months of inactivity.

5. Your rights as a data subject

If the respective requirements are met, the GDPR grants you certain rights as a data subject.

-             Art. 15 GDPR – Right of access: You shall have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and certain information.

-             Art. 16 GDPR – Right to rectification: You shall have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

-             Art. 17 GDPR – Right to erasure: You shall have the right to obtain from us the erasure of personal data concerning you without undue delay.

-             Art. 18 GDPR – Right to restriction of processing: You shall have the right to obtain from us the restriction of processing.

-             Art. 20 GDPR – Right to data portability: You shall have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you shall have the right to transmit those data to another controller without hindrance from us. You shall also have the right to have the personal data transmitted directly from us to another controller, where technically feasible.

-             Art. 21 GDPR – Right to object: You shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, which is based on legitimate interests or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller

In such case, we shall no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing, which override your interests, rights and freedoms or where the processing is necessary for the establishment, exercise or defence of legal claims.

-             Art. 77 GDPR – Right to lodge a complaint with a supervisory authority: Without prejudice to any other administrative or judicial remedy, you shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR.

Where the processing is based on your informed consent, you shall have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. Therefore, you may send us a message to dpo@lumesse.com.

6. Your obligation to provide us with personal data

You have no statutory or contractual obligation to provide us with any personal data. However, we may not be able to provide you with our services if you decide not to do so.

7. Existence of automated decision-making, including profiling

We do not use automated decision-making, including profiling, which produces legal effects concerning you or similarly significantly affects you.

8. Internet specific processing or use of personal data

8.1    Cookies

For providing you the services of the Site we may use cookies. Cookies are small text files, which are transferred from the Site and stored on your device. Cookies cannot execute programs or infect your device with computer viruses.

If you wish to prevent us from storing cookies on your device, your web browser or device may provide you with certain settings to do so. Most web browsers accept cookies by default. However, you may change these default settings in order to prevent any kind of storage or only allow storage after an explicit request. You may find an instruction on how to change your settings in the help section of your browser or device. The respective settings only apply to the device you are currently using. If you use another device, change your web browser or reinstall your browser you may have to change the respective settings again. Please, be aware that not accepting cookies may lead to you not being able to fully use the Site. Our usage of cookies finds its legal basis in Art. 6 par. 1 lit. f) GDPR. The aforementioned purposes constitute also the legitimate interests we pursue with it.

8.2    Google Analytics

We use Google Analytics, operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google“) to collect information about how users use our Site. The information generated by the cookie about your use of the Site will be transmitted to and stored by Google on servers in the United States. As IP-anonymization is activated, your IP address will be anonymized as soon as technically feasible at the earliest possible stage of the collection network. In addition, it will only be partially used within the European Union or just in the European Economic Area if it is used by other parties. Only in exceptional cases, the full IP address will be transferred to a Google server in the United States, and then shortened so it is only partially used there.

Google will use this information on our behalf for the purpose of analyzing your use of the Site, compiling reports on the website activity and providing other services relating to activity on the Site and internet usage. The IP address that your browser conveys within the scope of Google Analytics will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser; please note, however, that if you do this you may not be able to use our service comprehensively. You can also opt-out from being tracked by Google Analytics in the future by downloading and installing ‘Google Analytics Opt-out Browser Add-on’ for your current web browser: http://tools.google.com/dlpage/gaoptout?hl=en. Our processing is based on Art. 6 par. 1 lit. f) GDPR. The aforementioned purposes constitute also the legitimate interests we pursue with it. The collected data is stored for 50 months. Further information on how Google processes personal data is available at: https://policies.google.com/?hl=en.

8.3    Facebook Connect

Facebook Connect is a service of the Facebook Ireland Limited, 5-7 Hanover Quay, Dublin 2, Ireland. If you wish to register with a Facebook Account, you will be forwarded to Facebook and Facebook will require you to either register with Facebook or log into your Facebook account. Your log in data will not be disclosed to us. Only the data you mark as publicly available or that you actively give access to will be disclosed to us. This may contain your name, profile picture, gender, user name, Facebook URL, user number or more. The processing is based on Art. 6 par. 1 lit. f) GDPR. The aforementioned purposes constitute also the legitimate interests we pursue with it.

8.4   Hotjar

We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link:

Our processing is based on Art. 6 par. 1 lit. f) GDPR. The aforementioned purposes constitute also the legitimate interests we pursue with it. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link https://www.hotjar.com/legal/compliance/opt-out.

 8.5   Twitter Analytics

We use Twitter Analytics, operated by Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA (“Twitter”) to collect information about how our tweets are viewed and reacted to. The information generated by the cookie about your use of the Site will be transmitted to and stored by Twitter on servers in the United States. Twitter will analyze your use of our tweets, compiling reports on your activity and providing other services relating to activity on our twitter profile and its usage. You can find more information by clicking on this link: https://twitter.com/de/privacy.

Our processing is based on Art. 6 par. 1 lit. f) GDPR. The aforementioned purposes constitute also the legitimate interests we pursue with it. Further information on how Twitter processes personal data is available at: https://twitter.com/de/privacy.

8.6   BingAds

We use Bing Ads Universal Event Tracking, a conversion tracking service of the Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA (“Microsoft”). The service enables us to track your activities, if you accessed our site by clicking on a bing advertisement. For this purpose, Microsoft stores a cookie on your device. By using this cookie, Microsoft and we can see the total number of users that clicked on the ad. This data is stored by Microsoft for 180 days. We have no access to any personal information about you.

If you do not want to be tracked, you can opt-out under the following link: https://go.microsoft.com/fwlink/?LinkID=286759. Our processing is based on Art. 6 par. 1 lit. f) GDPR. The aforementioned purposes constitute also the legitimate interests we pursue with it. For further information, please click here: https://privacy.microsoft.com/en-us/privacystatement/.

8.7   Google AdWords

We use Google Adwords, a service of the Google LLC, 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, USA. Google Adwords enables us to advertise in the Google search as well as in the Google advertising network. We use the remarketing function. This allows us to present you with targeted advertising. In order to achieve that, Google stores a cookie on your device, which makes your device recognizable to Google. If you visit a website within the Google advertising network, you will be presented targeted ads. No personal data is disclosed to us.

Our processing is based on Art. 6 par. 1 lit. f) GDPR. The aforementioned purposes constitute also the legitimate interests we pursue with it. You can deactivate the retargeting feature by changing your preference on the following site: http://www.google.com/settings/ads. You can find further information by clicking on this link:  https://www.google.de/intl/de/policies/privacy/.

 8.8   Lead Forensics

 For the purpose of marketing and optimization, we use services of LeadForensics (http://www.leadforensics.com), Communication House 26 York Street, London, W1U 6PZ Großbritannien. Lead Forensics analysis how you accessed and used our site. IP addresses are anonymized immediately and not stored by LeadForensics.

Our processing is based on Art. 6 par. 1 lit. f) GDPR. The aforementioned purposes constitute also the legitimate interests we pursue with it. For more information on how LeadForensics processes your data, please refer to: https://www.leadforensics.com/privacy-policy/. Send request for deletion to data-compliance@leadforensics.com or by writing to: Data Compliance, Lead Forensics, Building 3000, Lakeside, North Harbour, Portsmouth, PO6 3EN.

 8.9   LinkedIn Ads

We use LinkedIn Ads, a service of the LinkedIn Ireland Unlimited Company. This function enables LinkedIn to show you our advertising within the LinkedIn network. For this purpose, LinkedIn will establish a direct connection between you and its servers and collect data about your use of our website. LinkedIn may relate this data to your user account. We have neither knowledge of nor a possibility to influence the data processing by Facebook. You can find more information on how Facebook processes your data in its privacy policy under: https://www.linkedin.com/legal/privacy-policy.

Our processing is based on Art. 6 par. 1 lit. f) GDPR. The aforementioned purposes constitute also the legitimate interests we pursue with it. If you want to opt-out, please change the respective settings in your user profile on LinkedIn: https://www.linkedin.com/psettings/advertising.

 8.10   Facebook Custom Audience

We use Facebook Custom Audience, a service of the Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Irland. This function enables Facebook to show you our advertising within the Facebook network. For this purpose, Facebook will establish a direct connection between you and its servers and collect data about your use of our website. Facebook may relate this data to your user account. We have neither knowledge of nor a possibility to influence the data processing by Facebook. You can find more information on how Facebook processes your data in its privacy policy under: https://www.facebook.com/policy.php.

Our processing is based on Art. 6 par. 1 lit. f) GDPR. The aforementioned purposes constitute also the legitimate interests we pursue with it. If you want to opt-out, please change the respective settings in your user profile on the following site: https://www.facebook.com/ads/website_custom_audiences/.

 8.11   Twitter Conversion Tracking and Twitter ads

 We use Twitter Ads, a service of Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA (“Twitter”). Twitter enables us to to use targeted advertising, retargeting and conversion measurements for online advertising. By using Twitter’s remarketing function, we can advertise our services to a certain target group, chosen by different factors. In order to present you the right advertising, Twitter analyses your usage  of our website by using tags. If you visit a website that has a tag implemented, Twitter stores a cookie on your device including an ID. Twitter uses the ID to show you relevant ads on its social network. Moreover, Twitter enables us to do conversion tracking. As soon as you click on a relevant ad on Twitter, Twitter stores a cookie on your device. Twitter reports to us, which ads were presented to you and on which ads you clicked. These reports only include aggregated data and no personal information about you.

Our processing is based on Art. 6 par. 1 lit. f) GDPR. The aforementioned purposes constitute also the legitimate interests we pursue with it. You can deactivate these functions on the following site: https://support.twitter.com/articles/20171528. For further information please refer to: https://business.twitter.com/de/help/troubleshooting/how-twitter-ads-work.html

Luton, May 2018

Contact

If you should have any concerns or queries in relation to our Privacy Policy please contact us. You find our contact details here www.lumesselearning.com/contact.