Legal

Luminance Technologies Limited - Data Privacy Policy

Luminance Technologies Limited (“Luminance”) is committed to protecting and respecting your privacy. Luminance collects, uses and keeps information in compliance with the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”), the Privacy and Electronic Communications (EC Directive) Regulations 2003, the UK Data Protection Act 20188 and all relevant regulations. For the purpose of GDPR, the data controller is Luminance.

This policy and any other documents referred to set out the basis on which any personal data Luminance collects from you, or that you provide to us, will be processed by us. Please read the following privacy policy to understand how we collect and use your personal data, for example when you contact us, visit our website (Site), apply for a job, or use our products and services.

Whenever you give us personal data, you are consenting to its processing, collection and use in accordance with this privacy policy. You may withdraw your consent at any time by emailing [email protected] with your full name.

Information Luminance may collect from you

Luminance may collect and process the following data about you:

IP addresses

Luminance may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our business partners. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

Cookies

Cookies are small text files that websites save to your computer. These pieces of information are used to improve services for you through, for example: (i) remembering settings, so you don’t have to keep re-entering them whenever you visit a new page; (ii) remembering information you’ve given (e.g. your postcode) so you don’t need to keep entering it.

Session cookies allow us to track your actions during a single browser session, for example to remember the items returned from a search. They do not remain on your device beyond your session.

Persistent cookies remain on your device between sessions and allow us to authenticate you and to remember your preferences.

Session and persistent cookies can be either first or third-party cookies — a first-party cookie is set by the website being visited. A third-party cookie is issued by a different website to that being visited.

Our website may use a third-party cookie provided by Google Analytics to gather anonymized information for the benefit of all web users. Luminance do not use behavioural targeting cookies. All our cookies fall within the ICC classifications Strictly Necessary, Functionality and Performance and none within the classification Behavioural Targeting.

If at any time you wish to disable our cookies you may do so through the settings on your browser, but if you do so you will not be able to use certain important features of our service.

To learn more about cookies and how to manage them, visit AboutCookies.org.

Job Applicants

If you are making a job application or inquiry, you may provide us with a copy of your CV or other relevant information. We may use this information for the purpose of considering your application or inquiry. Except when you explicitly request otherwise, we may keep this information on file for future reference.

Providing products and services

If you purchase or use our products or services, we may use your personal data for purposes which include but are not limited to:

Certain products and services may include features that collect additional personal data for other purposes, as described in the applicable customer agreement. For detailed information, please also refer to the applicable product or service description.

Where your personal data is stored

Your personal data is securely stored by Luminance on the Luminance servers located in Cambridge, United Kingdom. Luminance has set up systems and processes to prevent unauthorized access or disclosure of your data.

Transferring personal data

As a global company, we have international sites and users all over the world. When you give us personal data, that data may be used, processed or stored anywhere in the world, including countries outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA, who work for us or for one of our suppliers. Luminance places substantial importance on protecting the confidentiality of personal information and seeks the cooperation of all its suppliers in furthering this goal. Luminance will only transfer personal information to a supplier where the supplier has provided assurances that they will provide at least the same level of privacy protection as is required by this Policy. Where Luminance has knowledge that a supplier is using or sharing personal information in a way that is contrary to this policy, Luminance will take reasonable steps to prevent or stop such processing.

Security

Luminance endeavours to hold all personal data securely in accordance with our internal security procedures and applicable law. We update and test our security on an ongoing basis. Luminance will do its best to protect your personal data, but Luminance cannot guarantee the security of your data transmitted to our site through the internet; any such transmission is at your own risk. Once Luminance has received your information, Luminance will maintain appropriate administrative, physical, technical and organizational measures to protect your personal data accessed or processed by Luminance against unauthorized or unlawful processing or accidental loss, destruction, damage or disclosure.

Uses of the information

In addition to the above, Luminance uses information held about you in the following ways:

If you are an existing customer, Luminance will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those that were the subject of a previous sale to you.

If you receive an email which claims to come from us but does not use our domain, or if you are suspicious that an email may not be approved by us, then please send a copy of the email to [email protected] so we can investigate. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box on the form on which Luminance collects your data. We will not sell or rent your data to third parties or share your data with third parties for marketing purposes. We may use third party software to send you information for marketing purposes but such third parties will not have access to or be able to read your personal information.

We will share your data if we are required to do so by law.

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that Luminance does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Disclosure of your information

Luminance may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

In the event that Luminance sells or buys any business or assets, Luminance may disclose your personal data to the prospective seller or buyer of such business or assets.

If Luminance or substantially all of its assets are acquired by a third party, personal data held by it about its subscribers and users will be one of the transferred assets.

Luminance may disclose your personal information if Luminance is under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of Luminance Limited, or others.

Your rights

You have the right to request by contacting [email protected]:

You can also:

Access to information

GDPR gives you the right to access information held about you. Your right of access can be exercised in accordance with GDPR

Changes to our Privacy & Data Protection Policy

Luminance reserves the right to amend this Data Privacy Policy at any time, for any reason, without notice to you. You should check our Site to see the current Data Privacy Policy that is in effect and any changes that may have been made to it.

This policy was last amended on 20 November 2018.

Data Privacy Officer

Luminance is headquartered in Cambridge, United Kingdom. Luminance has appointed an internal data protection officer for you to contact if you have any questions or concerns about Luminance’s Privacy Policy. The contact information for the Luminance data protection officer is as follows:

Andrew Kanter
Luminance Technologies Limited
Maurice Wilks Building, St John’s Innovation Park
Cowley Road, Cambridge
CB4 0DS UK
[email protected]

Luminance Technologies Limited — Anti-Slavery Policy Statement

Pursuant to s54 of the Modern Slavery Act 2015, this Policy Statement confirms the steps Luminance Technologies Limited (“We”) has taken and will continue to take to prevent modern slavery and human trafficking in any part of our business and supply chain.

Our Business & Risk

We have offices in the UK and the US and are a primarily a hosted technology company. In light of where we do business, where our suppliers are based and the industry in which we operate, we consider that there is a very low risk that modern slavery and human trafficking may affect our business.

Our Policies

We have adopted policies and procedures which are designed to:

Our Supply Chain

Our process for contracting with suppliers includes checks to remain vigilant to any risk of modern slavery and human trafficking. We require staff engaged in the process for the selection of suppliers to conduct reasonable checks and due diligence to ensure that modern slavery and human trafficking does not affect any supplier or partner. This due diligence may include (but is not limited to) raising enquiries with the supplier / partner, asking them to provide a copy of relevant policies and their employee handbook and, where necessary, verifying the physical working conditions for the supplier’s / partner’s staff and contractors.

We also include appropriate contractual commitments and protections in our agreements with our suppliers where necessary, requiring those suppliers to implement effective systems and controls to prevent slavery and human trafficking from affecting any part of their business and supply chain. We also require them to provide us with a summary of the steps they take from time to time to prevent modern slavery and human trafficking (including details of any relevant staff and supplier policies and details of due diligence conducted on their suppliers.

In respect of staff employed by the company, our Employee Handbook makes clear to employees the actions and behaviour expected of them when representing the organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating and managing our supply chain.

In addition, our HR team continues to ensure that we comply with all applicable laws in the territories in which we are based and we only use specified, reputable employment agencies to source labour. We are proud of the work environment we provide to our staff and the vibrant culture that permeates our business.

Training

Our staff are advised to take particular care for organisations that provide services from higher risk territories. Staff are also advised to notify the legal and HR teams immediately if they have any concerns so that we can then take appropriate action.