Privacy Policy

Last updated: January 27, 2021

This Privacy Policy describes our policies and procedures on the collection, use and disclosure of your information when you use the Service and tells you about your privacy rights and how the law protects you.

This Privacy Policy constitutes integral part of the Terms and Conditions and the Cookie Policy, entered into with us when you messaging to us.  

We have worked out this Privacy Policy for you to get to know about:

  • what personal data are;
  • which of your personal data we collect;
  • how and why we use them;
  • how we protect your privacy of your personal data;
  • how to contact us ad whom to contact if you have questions about processing of your personal data.

References in this Privacy Policy to “Lumer”, “we”, “us”, “our” shall mean LUMER SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (company registered in Poland on 28 of May, 2020, KRS 0000843525, legal address: AL. GRUNWALDZKA, 56 street, aprt. 202, GDANSK, ZIP code 80-241, Poland).

Statement

We quite seriously regard the issue of protecting personal data of our visitors, therefore we strive to protect privacy of your personal data. Lumer undertakes to take all necessary measures to prevent improper use of your personal data which become known to us. We will process your personal data in strict compliance with the requirements set forth by the applicable legislation, and only if we have legal grounds for doing so.

We process your personal data only if the following terms stipulated by Article 6 of GDPR applies:

  • you have given consent to the processing of your personal data;
  • processing is necessary for entering into or the performance of services to you;
  • processing is necessary for compliance with the legislation of the states to/from where we operate.

Definitions

Personal data means any personal information allowing a third party to identify a natural person (data subject).

Special categories of personal data means “sensitive” personal data which might hurt the data subject at work, at educational institution, at the place he/she lives, or might cause discrimination against him/her. For instance, personal data containing information about racial origin, political opinions, religious beliefs, trade union membership, state of health, sex life, biometric or genetic data.

Personal data subject means a natural person to whom personal data are related, and who can be identified by means of such personal data, or who has been identified.

Personal data controller means a natural or legal person which determines the purposes and means of the processing of personal data, and bears the primary responsibility for their processing.

Personal data processor means a natural or legal person which based on the controller’s instructions (directives, orders) processes personal data for the controller.

Personal data processing means any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, alteration, adjustment, retrieval, use, dissemination or otherwise making available to third parties, including, staff of the personal data controller or processor, or destruction.

Law

Your personal data are processed in compliance with the requirements set forth by the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as “GDPR”). Furthermore, legislation of the states to where we provide our services may determine additional requirements.

Purposes

We need to have your personal data for the following purposes:

  • to provide our services;
  • to contact you;
  • to manage your request;
  • for other purposes, for instance, for business transfers (when we transfer our assets to another Party), for data analysis etc. 

We may share your personal information just in the following situations:

  • with our services providers, if your request needs additional knowledges or tools;
  • we can share or transfer your personal data as our asset in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company;
  • we can share information with our affiliates, business partners, if they have an appropriate data protection level

Please see the table below to find out which of your personal data we process to provide your services to you:

Name

We need your name for correct address you and give you some greetings, answers for your request etc.

E-mail Address

We need your e-mail address for the opportunity to response you on your request that you leave on our website

* These personal data are processed just via website.

In addition to the aforesaid, we can process any other personal data if you decide to provide them to us.

If storage of your personal data is not necessary for the provision of services to you, or is not required under applicable legislation, we will delete them.

 

Special Categories of Dana and Personal Data of Children

We do not collect special categories of data about our clients.

We recognize the importance of special protection of personal data of children. Lumer website is not intended and is not aimed directly at the use for children under the age of 13. Even though we do not intentionally collect and process personal data of persons under the abovementioned age.

Storage and Storage Time

We have not a lot of personal data, so to ensure their safety we use cloud services and our servers located in Poland.

We will not store your data longer than it is necessary to fulfill the purpose for which they are processed, or to comply with the legal requirements.

To determine the appropriate storage period, we identify the nature and category of personal data, the purposes for which we process them, and if we can achieve purpose through other means.

Data Protection

For safe storage of your personal data we have implemented various technical and organizational measures to protect personal data against unauthorized or unlawful processing and against accidental loss, destruction or damage.

Lumer observe the principle of personal data minimization. We process only the information we need to provide certain services, or the information you provide of your own free will beyond the required processing range. In addition, we have configured all the interfaces of our website and services application to comply with highest confidentiality requirements, which settings you can adjust at your own convenience.

Right of Personal Data Subject

The General Data Protection Regulation (GDPR) provides certain rights for individuals whose personal data is being used, processed or transferred. Under the GDPR, individuals can exercise:

  • the right to be informed
  • the right of access
  • the right to rectification
  • the right to erasure
  • the right to restrict processing
  • the right to data portability
  • the right to object to processing
  • the rights in relation to automated decision making and profiling

Right to be informed

You have the right to be informed about the collection and use of personal data.

In this Privacy Policy you can find information about the name and contact details of our organisation, the purposes of the processing, the lawful basis for the processing, the retention periods for the personal data, the rights available to individuals in respect of the processing, the right to lodge a complaint with a supervisory authority.

Right of access

If you ask us, we must give data subjects:

  • confirmation of whether we are processing your data
  • other supplementary information (including mandatory privacy information)
  • a copy of the personal data being processed

Please note that if we are unable to verify your identity by e-mail messages or at your application, or in the case of reasonable doubts concerning your identity, we may ask you to provide a proof of identity. This is the only way we can avoid disclosing your personal data to a person who can perpetrate your identity. Such information could be provided within 1 month.

Right of rectification

Under Article 16 of the UK GDPR you have the right to have inaccurate personal data rectified. You may also be able to have incomplete personal data completed – although this will depend on the purposes for the processing. This may involve providing a supplementary statement to the incomplete data.

Right to erasure (also known as right to be forgotten)

Under the GDPR, you have to right to ask us to delete your personal data if:

  • we have processed your data unlawfully
  • we no longer need the data for the original purpose (and we have no new lawful purpose)
  • we rely on consent for processing and they withdraw it (and there are no other legal grounds we can apply)
  • you exercise your right to object to processing, and we can't override your objection
  • erasure is necessary for compliance with other EU or national law

Right to restrict processing

You can ask us to restrict processing your personal data if, for example:

  • you believe your data is not accurate (we should stop processing until we verify the accuracy of the data)
  • the processing is unlawful but you don't want the data erased
  • we no longer need the data but you need it to exercise a legal claim
  • we are taking steps to verify overriding grounds in the context of an erasure request

If someone asks us to restrict processing, we will be allowed to store the data, but won't be able to carry out any processing.

Right to object to processing

If we rely on lawful bases of public interest or legitimate interests for processing, you may have a right to object to such processing. The objection has to be justified and can be made verbally or in writing. We may have to cease processing unless we can demonstrate that:

  • we have compelling legitimate grounds for processing which override the interests, rights and freedoms of you
  • the processing is necessary in connection with legal rights

Right to not be evaluated based on automated processing

Under the GDPR, you have the right not to be subject to a decision that is based solely on automated processing and which significantly affects them. Find out more about the privacy rights of individuals under the GDPR.

Contact information of the Controller and the Administrative Authority in Poland

Should you have any questions, remarks, complaints or comments relating to the protection and processing of your personal data, feel free to apply to us via e-mail: info@lumer.agency .

The administrative authority in charge of the personal data protection in Poland is the President of the Office for Personal Data Protection (Urzad Ochrony Danych Osobowych). You can find more information on link  https://uodo.gov.pl/.