Lumenia Consulting and its subsidiaries is committed to ensuring that your privacy is protected. This privacy notice (together with our general Terms and Conditions) sets out the basis on which any personal data we collect from and about you, or that you provide to us, will be processed by us.
Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. This privacy notice is being provided to you in line with our obligations from 25 May 2018 under the General Data Protection Regulation (GDPR).
Under the General Data Protection Regulation (GDPR), personal data is defined as: “any information relating to an identified or identifiable natural person (data subject)”. This definition provides for a wide range of personal identifiers to constitute personal data, including name, address and also electronic, manual and image data which may be held on computer or on manual files.
Identity and contact details of the controller
The Data Controller is:
Lumenia Consulting Limited,
Parkmore Business Park West,
Galway, H91 PTT8,
Contact details of the Data Protection Champion
Data protection queries relating to personal data held by Lumenia should be directed to the Data Protection Champion for Lumenia, contact details as follows:
Address: Lumenia Consulting Limited, Parkmore Business Park West, Galway, H91 PTT8, Ireland
Data we collect and process
We only process the minimum amount of personal data necessary for the purpose for which it is collected. In running and operating this website we may collect and process certain data and information relating to you and your use of this site in the following ways:
Information you give us
This is information about you that you give us by corresponding with us by phone, e-mail, website forms, attending our events or otherwise. The information you give us may include, but is not limited to, your name, address, e-mail address, phone number, financial, or other identification documents.
Information we collect about you
Depending on the circumstances, we might also obtain personal data about you from other sources such as public registers, business partners and service providers such as Linkedin.
Lumenia may also acquire your professional contact details, such as your name, your role, organisation name, postal address, phone number and email from the Oliver Searle Partnership Limited (“Oliver Searle Partnership”) with whom you agree to receive correspondence from us.
Why we process your data
We process your data in order to comply with legal obligations to which we are subject or to perform the services you have requested of us. We do this because you have consented to our processing of your data or for the purposes of our legitimate interests, such as to inform you of changes to our services or to provide you with information about other services we offer.
How we use your data
We gather and use your information to:
- Allow us to provide you with the services you request from us;
- Notify you of changes to our services or events;
- Allow you to participate in events organised by us;
- Provide you with information about other services we offer that are similar to those you have already requested of us or enquired about;
- Contact you to provide you with information about our services that we feel you would benefit from and have an interest in. We rely on your consent provided to us or to the Oliver Searle Partnership to enable us to contact you in this regard; or
- Comply with legal obligations to which we may be subject.
Contractual obligation to provide personal data and consequences for failing to do so
To allow Lumenia to provide services to you, it is necessary for you to provide Lumenia with your personal data. If you do not provide Lumenia with your personal data required to download a report, you will not be able to view Lumenia’s publications. When you download a report from the Lumenia website, an account is created for you on our website so that you can download additional publications. If you wish to have your account deleted, please email firstname.lastname@example.org. If you do not provide Lumenia with your personal data required on the website forms, we will not be able to contact you.
Who we share your data with
Your personal data may be disclosed internally when passed from one department to another in accordance with the data protection principles and this Notice. Personal data is not passed to any internal department or any individual that does not reasonably require access to that personal data with respect to the purpose(s) for which it was collected and is being processed.
We will not sell, rent or otherwise disclose your personal information to any third-party without your consent except in the following circumstances:
- Trusted third-party providers: Where we use or partner with trusted third-party providers to provide services for us, including, for example, the delivery and processing of any necessary marketing materials and other IT and operational services. These companies will have access to only the personal data needed to perform their specific functions and not for any other purposes. They are bound by data processing agreements as well as their own privacy policies.
- Legal advisors: We may disclose or share our data with our legal advisors in order to enforce or apply our general Terms and Conditions or where same is necessary for the defence of legal claims.
Lumenia may provide information, in response to properly made requests, for the purpose of the prevention and detection of crime, and the apprehension or prosecution of offenders. It may also provide information for the purpose of safeguarding national security. In the case of any such disclosure, we will do so only in accordance with the Legislation.
Lumenia may also provide information when required to do so by law, for example under a court order.
Whenever Lumenia discloses information to third parties, Lumenia will only disclose that amount of personal data that is necessary. Third parties that receive Personal Data from Lumenia must satisfy Lumenia as to the measures taken to protect and keep it secure.
Appropriate measures will be taken to ensure that all such disclosures or transfers of personal data to third parties will be completed in a secure manner and pursuant to contractual safeguards.
Data transfers outside the European Economic Area (“EEA”)
Countries in the European Economic Area (EEA) are required to have a similar standard of protection of personal data. This is not always the case outside that area. Apart from the UK, we do not transfer data outside the EEA, but in the event that we do, before doing so, we will take steps to ensure that there is adequate protection, as required by the Legislation. Data transfers to the UK are made subject to Article FINPROV.10A: Interim provision for transmission of personal data to the United Kingdom of the Trade and Co-operation Agreement between the EU and UK. This allows for the free flow of data from the EU to the UK, pending the implementation of adequacy decisions in relation to the UK to be adopted by the EU under Article 36(3) of Directive (EU) 2016/680 and under Article 45(3) of Regulation (EU) 2016/679.
We take our data security responsibilities seriously, employing the most appropriate technical and organisational measures so as to avoid the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
Unfortunately, the transmission of information by means of the internet, including through e-mail, is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to or from us by means of e-mail and any such transmission is at your own risk.
It is our aim to only hold your data for as long as is necessary for the purposes for which it was gathered. In certain circumstances there may be legal requirements to keep data for a minimum period of time. We may store it for a longer period if so required for example, by applicable laws, regulators, payment protection, law enforcement or for secure archiving. In any case of longer storage by us, the terms of this privacy notice will continue to apply. Unless specific legal requirements dictate otherwise, Lumenia will retain information no longer than is necessary for the purposes for which the personal data was collected or for which they are further processed.
Marketing and opting out
We may contact you by mail, email and telephone about our services and other events involving or relating to Lumenia which may be of interest to you. You have the right to ask us to stop processing your personal data for direct marketing purposes. If you wish to do so, please send an email to email@example.com with a header that says “Unsubscribe” or you can directly “opt-out” from any of our email communications. Where we process your data solely on the basis of your consent, you are entitled to withdraw your consent at any time. This will not affect the lawfulness of our processing before the withdrawal.
We may acquire your professional contact details, such as your name, your role, organisation, postal address, phone number and email from our data partners, The Oliver Searle Partnership and TechTarget, with whom you agree to receive correspondence from us. We take care to ensure that we communicate with you solely on subjects and issues that are specifically relevant to your professional role based upon information provided to us by The Oliver Searle Partnership Ltd. If you would like to change your permission status with The Oliver Searle Partnership Ltd, you can do so by emailing them at firstname.lastname@example.org
Our website contains hyperlinks to other websites owned and operated by independent third parties. Please note that we are not responsible for the privacy practices of such other third-party websites and advise you to read the privacy statements of each website you visit which collects your personal information. Your use of such third-party websites is at your own risk.
A cookie is a small piece of information placed on your computer by a website.
You may have the following rights in relation to your personal data:
- Your right to be advised whether we process your personal data and your right to request access to said personal data;
- Your right to have any inaccurate data we might have about you rectified without undue delay;
- Your right to have your personal data erased (where appropriate);
- Your right to the restriction of processing of your personal data or your right to object to such processing;
- Your right to data portability regarding certain automated personal data.
- Your rights with respect to automated decision-making and profiling;
- Your right to withdraw consent, where consent is relied upon for a legal basis for processing.
Vindication of your rights shall not affect any rights which we may have under the Legislation. If you want to exercise any right, you can do so by making your specific request in writing to the contact details outlined below in the contact section. Your request will be confirmed within 21 days of receipt and processed within 30 days of receipt. If the information held about you is inaccurate, you are requested to advise Lumenia promptly so that the necessary amendments can be made and same can be confirmed as being made within 30 days of receipt of your request. The exercise of your rights might be subject to certain conditions prescribed by law and we might require further information from you before we can respond to your request.
You also have the right to lodge a complaint with the Data Protection Commissioner at any time.
Changes to policy
We may update this privacy statement from time to time and will publish such updated version on our website lumeniaconsulting.com as appropriate.
Last updated 22.01.2021.
If you would like to contact us with any queries or comments in relation to your personal data, please contact us at:
Parkmore Business Park West,
Galway, H91 PTT8,
Tel: 00 353 (0) 91 746940