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This website uses cookies Our organization and our partners collect and access information, such as unique cookie identifiers, to process personal data on your device. You have the option to accept or manage your preferences, including your right to object to processing based on legitimate interest, by clicking below, directly in your user settings or at any time on our privacy policy page. Your preferences will be communicated to our partners and will not affect browsing data. LUMAPPS PRIVACY POLICY This Privacy Policy sets out how LumApps uses and protects your personal data. It will help you understand what personal data we collect, why we collect it and what rights you have. This Privacy Policy applies to: your use of the LumApps website www.lumapps.com (“Website”); your use of a LumApps portal called the ‘Hive’: https://hive.lumapps.com/portal/ (“Portal”); when you register to receive a newsletter, to attend an event or where you share your personal data with us during a sales promotion, campaign or by completing any LumApps’ survey (for example to give us feedback); and the processing of your personal data by LumApps collected through a third party or public website in connection with: a job application or a LumApps job posting. legitimate purposes, including marketing and promotional activities. In such cases, you will be duly informed of the source of the data collection, and you will retain the right to object to the processing of your data in accordance with applicable data protection regulations. the processing of your personal data by LumApps to improve and develop our products and services. This Privacy Policy applies where LumApps processes your Personal Data as a ‘data controller’. This Privacy Policy does not apply where LumApps processes Personal Data in its capacity as a ‘data processor’. In this Privacy Policy, references to “we”, “us” or “LumApps” are references to LumApps SAS and its affiliates. See here a full list of the defined terms used in this Privacy Policy. Contents 1) WHERE WE GET THE PERSONAL DATA THAT WE PROCESS 2) HOW DO WE USE AND PROCESS YOUR PERSONAL DATA AND WHAT LEGAL BASIS DO WE HAVE TO PROCESS IT? 3) YOUR RIGHTS 4) HOW TO EXERCISE YOUR RIGHTS 5) HOW DO WE SHARE YOUR PERSONAL DATA? 6) CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES 7) INTERNATIONAL TRANSFER OF PERSONAL DATA 8) DATA STORAGE PERIOD 9) SECURITY 10) CALIFORNIA RIGHTS 11) CHILDREN’S POLICY 12) LINKS TO OTHER WEBSITES AND SERVICES 13) PRIVACY POLICY UPDATES 14) HOW TO CONTACT US 15) FAIR RESOLUTION COMMITMENT 16) DEFINITIONS 1) WHERE WE GET THE PERSONAL DATA THAT WE PROCESS The sources from which we obtain your personal data How we collect personal data. In most cases, the personal data that we process is provided to us by you directly. You provide us with personal data either in person at our events or via the contact form on our Website or Portal. External or public sources. We may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant individual at a client or other company. Partners, such with which we offer co-branded services or engage in joint marketing activities. Indirect sources. When we have not collected your personal data directly from you, we may obtain it from third-party professional providers/tools (such as Dropcontact, ZoomInfo, or similar services). This data typically consists of publicly available professional contact information. We use this data in accordance with our legitimate interests and applicable data protection laws. You can find more detailed information about these sources and related processing activities here. Automated technologies. When you visit our Website or the Portal, some data is created and generated during the use of our Website or Portal such as cookies, server logs and other similar technologies. Tracking pixels in emails. When we send you emails, we may use tracking pixels (small, invisible images) to manage our mailing lists and ensure good deliverability — for example to detect whether and on which day our emails are opened, adapt how often we contact you, and stop sending to inactive addresses. We may also use this tracking to measure campaign performance and optimize our communications. Accordingly, LumApps will not send you emails containing pixel tracking unless you have consented to it. You can object to the use of tracking pixels at any time and free of charge, via the privacy preferences settings available through the link provided in our emails and forms or by contacting [email protected]. 2) HOW DO WE USE AND PROCESS YOUR PERSONAL DATA AND WHAT LEGAL BASIS DO WE HAVE TO PROCESS IT? We have provided below a detailed table showing the categories of personal data that we process and the corresponding purpose and legal basis for processing that personal data. Where we rely on your consent to process personal data, you may withdraw it at any time by sending an email to [email protected]. PURPOSE CATEGORIES OF PERSONAL DATA PROCESSED LEGAL BASIS FOR PROCESSING 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. IP address Device and usage data (such as device information, IP address, and interaction data) Legitimate interest: providing a well-functioning website for the benefit of our website visitors, and providing online content to our customers and prospective customers regarding our service offering and related information. Contact request: Register to be in the LumApps contact list to receive a Demo, Analyst reports, Checklists, Guides, Webinars, White papers, or further information about products and services related information and managing event registrations and attendance. Name Job title Contact information (email address, postal address, and telephone number) Consent Your Testimonial: We may publish your testimonials and quotes on our Website or Portal. LumApps obtains consent from each customer and the featured individual, prior to posting their personal information and testimonial. Name Job title Video footage or photographs 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. Name Job title Contact information (email address, postal address, and telephone number) Legitimate Interest Prospecting: Direct marketing and contacting publicly sourced prospects. Name Job title Contact information (email address, postal address, and telephone number) Legitimate interest To protect our business: In order to administer and protect our business, prevention of fraud, deal with any misuse of our Website or Portal, comply with our security policies at our locations, to handle claims and legal processes. IP address Device and usage data Legitimate Interest and 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. Name Job title Contact information (email address, postal address, and telephone number) To perform a contract Use of our Portal: Tracking the use of the Portal and activities, keeping the Portal update and relevant, providing access to content, and informing our marketing strategy. Name Job title Contact information (email address, postal address, and telephone number) To perform a contract To communicate with you: In order to let you know about upcoming changes or improvements to our services. To send you relevant marketing communications. Name Job title Contact information (email address, postal address, and telephone number) To perform a contract Legitimate interests: provide, maintain and improve services to meet the needs of our users, marketing to inform users about our services To collect your feedback and improve our services: In order to collect, organize, and analyze user feedback, usage information/interaction with our platform and feature requests in order to improve and develop our products and services. Name Contact information (email address, postal address, and/or telephone number) Device and usage data (such as device information, IP address, and interaction data) Legitimate interest in improving and developing our products and services Your consent To improve and develop our products and services. Device and usage data (such as device information, IP address, analytics and interaction data) Legitimate interest in improving and developing our products and services To create and display guided product demonstrations: In order to provide product/services demonstrations. Depending on your interactions with the demonstrations, we may collect and process personal data to help us analyze your engagement, improve our products and services, and provide a personalized experience to users. Contact information (e.g., name, email address, company, job title) when voluntarily submitted Technical and usage data (e.g., IP address, device/browser information, session and interaction data) Engagement data (e.g., clicks, page views, demonstration completion) Consent when users voluntarily submit personal data through forms or demonstrations Legitimate interest to analyze demonstration performance, improve products and services, and optimize user experience Tracking pixels in our emails: We use tracking pixels (small, invisible images) in the emails we send you to manage our mailing lists, ensure good deliverability and measure campaign performance and optimize our communications. Contact information (name, email address) Consent for measurement and optimization of campaign performance Legitimate interest to measure the opening rate of emails for deliverability purposes AI-assisted call recording and analysis: When you take part in a sales or business call with us, we may record, transcribe and analyze the call using an AI tool to generate notes and summaries, update our CRM, improve our sales process, and for internal coaching and training purposes. We inform you at the start of the call, and you may decline or ask us to stop recording at any time. Identity and contact details Audio recording of your voice; transcript and content of the conversation Call metadata (date, time, participants, duration). Consent (obtained at the start of the call; you may refuse or withdraw at any time without affecting the call itself). Where applicable, our legitimate interest in improving our sales process and training our teams. How Google Processes Personal Information For more details on how Google handles and protects personal information, please visit Google’s Business Data Responsibility page. The use of “raw data” or “derived data” received from Google Workspace APIs will adhere to the Google User Data Policy, including the Limited Use requirements. LumApps for Google Chat LumApps does not use Google Workspace APIs to develop, improve, or train generalized artificial intelligence and/or machine learning models. (Learn more) 3) YOUR RIGHTS You can execute and use any of your rights listed below, by contacting us by sending email at [email protected]. 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. Request information about how we process your Personal Data. 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. Please note there are situations where LumApps is unable to delete your data, for example when it’s still necessary to process the data for the purpose we collected it for, we have an overriding interest in continuing to process the data, for example where we need the data to protect our services from fraud, LumApps has a legal obligation to keep the data, or LumApps needs the data to establish, exercise or defend legal claims. 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. Withdraw your consent at any time: without affecting the lawfulness of the processing based on such consent before its withdrawal. Right to lodge a complaint: In compliance with the EU-US. DPF, the UK Extension to the EU-US. DPF, and the Swiss-US. DPF, we commit to refer unresolved complaints concerning our handling and processing of personal data received in reliance on the EU-US. DPF, the UK Extension to the EU-US. DPF, and the Swiss-US. DPF to the EU data protection authorities (DPA) with regard to unresolved complaints concerning personal data received in reliance on the EU-US DPF; the UK Information Commissioner’s Office (ICO) with regard to unresolved complaints concerning personal data received in reliance on the the UK Extension to the EU-US DPF, and to the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning personal data received in reliance on the Swiss-U.S. Data Privacy Framework. You have the possibility, under certain conditions, to invoke binding arbitration as per the EU-US DPF Principles Annex. If you are located in the EU, you also have the right to lodge a complaint to your DPA. 4) HOW TO EXERCISE YOUR RIGHTS To exercise your rights, you may contact us at: LumApps SAS 75 rue François Mermet, Tassin-la-Demi-Lune 69160 [email protected] No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. Your choices Account Information You may access, update, or modify your Personal Data by logging into the relevant LumApps platform or by contacting us at [email protected]. Please note that LumApps may retain certain Personal Data as needed to meet legal obligations or for legitimate business purposes, such as dispute resolution or enforcement of agreements. Advertising and Communications You may opt out of promotional emails from LumApps by following the unsubscribe instructions in those messages or by contacting [email protected]. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. 5) 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 where such transfer is reasonably necessary to fulfil the purpose specified above. LumApps may share your personal data to the following third parties: Service providers. LumApps may transfer your personal data to our service providers pursuant to a data processing agreement for several reasons including but not limited to third-party service providers for hosting services, authentication services, cybersecurity, anti-fraud services, advertising or any other third parties which may require us to share your Personal Data. Third Parties involved in a corporate transaction with us. Commercial and technology partners. Professional advisers. For legal reasons. In limited circumstances, LumApps may disclose your information when required or permitted by law, regulation, or legal process (such as a subpoena or court order) to public or regulatory bodies in response to lawful requests, including to meet national security or law enforcement requirements. We may also share your Personal Data as necessary to enforce our rights under this Privacy Policy or any agreement with you, or to protect the rights, property, or safety of LumApps or others. We may also disclose or transfer Personal Data to fulfill legal obligations and when a legal authority requires us to do so. Affiliates. LumApps may share your personal information with its affiliated companies — including current and future parent entities, subsidiaries, and other companies under common ownership or control — for any of the purposes described in this Privacy Policy. 6) CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES 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. 7) INTERNATIONAL TRANSFER OF 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. For your information, LumApps US entity (“LumApps Inc.”) complies with the EU-US. Data Privacy Framework (EU-US. DPF), the UK Extension to the EU-US. DPF, and the Swiss-US. Data Privacy Framework (Swiss-US. DPF) as set forth by the US. Department of Commerce. LumApps Inc. has certified to the US. Department of Commerce that it adheres to (i) the EU-US. Data Privacy Framework Principles (“EU-US. DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-US. DPF (ii) the UK Extension to the EU-US. DPF with regard to the processing of personal data received from the United Kingdom (and Gibraltar) and (iii) the Swiss-US Data Privacy Framework Principles (Swiss-US. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-US DPF. If there is any conflict between the terms in this privacy policy and the EU-US. DPF Principles and/or the Swiss-US. DPF Principles, the Principles of the DPF shall govern. To learn more about the Data Privacy Framework (DPF) programme, and to view our certification, please visit https://www.dataprivacyframework.gov/. Also, please note that we are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC) in compliance with the EU-US. Data Privacy Framework (EU-US. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-US. Data Privacy Framework (Swiss-US. DPF). In the context of onward transfers, LumApps is responsible for the processing of Personal Data it receives under the EU-US. DPF Principles and subsequently transfers to a third party acting as its agent. LumApps remains liable under the EU-US. DPF Principles if its agent processes Personal Data in a manner inconsistent with the EU-US. DPF Principles, unless LumApps can demonstrate that it is not responsible for the event that caused the damage. 8) DATA STORAGE PERIOD We will not store personal data for a longer period than is necessary for the purpose described in this Privacy Policy, any contractual terms, or as required by law. The length of time that we hold your personal data may vary based on its purpose and will be reviewed regularly. For example, the personal data of potential clients is retained for a period not exceeding three (3) years from the last contact with the concerned person. After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data. 9) SECURITY 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. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. 10) CALIFORNIA RIGHTS This Section provides details about the personal information we collect about California Residents. This Section fully incorporates all of the above stated Privacy Policy as if fully set forth below and your rights under the California Consumer Privacy Act (or “CCPA“) are intended to supplement the rights set forth therein. Right to Opt-Out or unsubscribe. “Do Not Sell My Personal Information” and/or “opt-out” from “selling” of your Personal Information, are rights that you can exercise. You also have the right to opt-out from the subsequent “selling” of your Personal Information by a third party that received personal information after an initial “selling”. LumApps shares your information with service providers and other authorized third-parties as set forth in this Privacy Policy. To the extent that any such third party is not considered a service provider under the CCPA or the CCPA is interpreted in a way that any action of LumApps is a “sale”, is “selling”, or otherwise deriving an economic benefit from the sharing of your personal information as described in this Privacy Policy and to the extent that you wish us not to share such information, please submit your request using the methods listed below. You understand that the opt-out can only stop the “selling” of Personal Information, and it does not impact other uses of their information. Right to not be discriminated against: LumApps will not discriminate against you for exercising any of the consumer’s rights under this Privacy Policy. 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 identifyyou and to ask for additional information in order to be able to fulfill your request. You can make your request at [email protected]. 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 [email protected]. 12) LINKS TO OTHER WEBSITES AND SERVICES Our Website or Portal may include links to third-party websites and services that are not operated by us. When you click these links, you will be directed away from our Website or Portal. A link to a third-party website or service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a third-party website or service, you are subject to its privacy practices and policies, not ours. This Privacy Policy does not apply to any personal information that you provide to these other websites and services. 13) PRIVACY POLICY UPDATES We may update this Privacy Policy from time to time as it may deem necessary. If we make any substantial changes to this Privacy Policy and the way in which we use your personal data we will post these changes on this page. Therefore, please visit this page and read this Privacy Policy from time to time. 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 protected]. If you need to contact us in connection with our use or processing of your personal data, or gain access to it our contact details are: LumApps SAS 75 rue François Mermet, Tassin-la-Demi-Lune 69160 [email protected] 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. 16) DEFINITIONS “Data Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law; “Data Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller; “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; and “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. 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