LUMENE WEBSITE PRIVACY POLICY

 

Last updated 18th June 2018

Lumene Oy

Business I.D. 2377940-8

PL 27

02781, Esbo

(“Lumene”, “we”, “us” or “our”)

Lumene acts as a controller to the personal data that our website visitors and online store users, such as you, share with us or which we collect automatically when you use our website or online store (hereinafter referred to together as “Services”). As a controller, we carry the ultimate responsibility for the processing of personal data you provide to us. Privacy is about trust, and protecting your privacy and your personal data is of utmost importance to us. Therefore, we collect your personal data only to the extent we need them to offer you a first-class customer experience on our Services.

This Privacy Policy describes the means and purposes of processing your personal data when you use our Services, and applies to the processing of personal data obtained through your use of our Services. Please note that our Services may include links to contents of third-party service providers. Any such links to contents of other service providers does not constitute our affiliation with or control over such third parties and thus, to the extent permitted by applicable legislation, we are not responsible for such contents, their level of data protection nor the actions of such third parties.

 

CONTACTING IN MATTERS RELATED TO THE PROCESSING OF PERSONAL DATA

Lumene Oy

PL 27

02781 Espoo

lumene.info(at)lumene.com

 

WHY WE PROCESS YOUR PERSONAL DATA

We process personal data only to the extent it is necessary for us to provide you the Services you have requested. We process your personal data primarily in order to offer you the opportunity to use our Services, to deliver your order, and to fulfil any possible subsequent warranty measures. We also process your personal data to send you updates about your order and questionnaires to measure your satisfaction with our Services.

In addition to the foregoing, we process your personal data for the purposes of management, analysis and development of the contractual relationship between us, for example, to provide you customer service and to carry out customer communications. We also process your personal data for viewing you such content in our Services that is most relevant to you, for developing our Services, as well as for preventing and detecting possible misconduct. We may also process your personal data to alert you on new and interesting products, special offers and updates on our Services, within the limits of applicable legislation or based on your consent.

The legitimate grounds for processing your personal data are either compliance with the agreement entered into between us, compliance with legal obligations to which we are subject, our legitimate interest, or your consent as further described below.

Contractual and statutory obligations: Processing of your personal data to certain extent is necessary to enable us to fulfil the agreement we have concluded with you. For example, when you place an order in our online store, it is necessary for us to process your personal data so that we can carry our contractual obligations and deliver your order. Your placing of order also creates certain statutory obligations for us related to e.g. product safety, quality of our products and product returns.

Our legitimate interest: We process your personal data based on our legitimate interest in particular to offer you first-class customer experience in our Services and to provide you the most relevant online and newsletters content as well as for administrative purposes and to preventing and resolving possible misconduct.

Consent: Based on your consent, we can process your personal data to sending you direct electronic marketing.

The provision of your personal data as described in this Privacy Policy is partially a contractual requirement. For example, when you place orders on our online store, you are required to provide us with certain personal data for processing purposes specified in this Privacy Policy. Failure to provide us personal data may prevent us from performing our contractual obligations, which may lead to you being unable to use our online store.

 

THE CATEGORIES OF DATA WE PROCESS

When you create a user account to use our Services, you will be asked to provide certain personal data, including the following: name, contact information, date of birth, phone number, password, as well as billing and delivery details, such as billing and delivery address. You can also voluntarily provide us information about your interests, as well as your consent to receive direct marketing. Your user account information is constantly updated (for example by your purchase history).

When you place orders at our online store, we may process certain personal data and information relating to you, such as: user account details (or your name, delivery and billing address(es) and phone number), type and amount of products you ordered, purchase price, date of placing the order, status of your order, method of payment and specifics related to your payment, product returns and customer service requests.

We also collect metadata from your use of our Services, such as referral page, time of access, amount of data transferred, IP address, operating system and interface, your web browser type, version and language. If you visit our Services without creating a user account or placing orders, we will only process the abovementioned metadata.

 

TRANSFERS OR DISCLOSURES OF YOUR PERSONAL DATA

  1. Why we transfer or disclose your personal data

    We may to transfer or disclose your personal data to other companies within the worldwide Lumene group or to external service providers as follows.

    We may disclose personal information to our partners within the limits permitted by law, e.g. for purposes of carrying out deliveries, billing or marketing. For example, to execute your orders, we use services of our partners (such as payment services offered by banks or credit card companies or shipping and delivery services offered by dispatching companies). We will only provide these partners the information they need to deliver the services agreed, and we require that these parties agree to process personal data based on our instructions and in compliance with this Privacy Policy.

    In addition, we may disclose your personal information without notice only if we are required to do so by law or if we in in good faith believe that such action is necessary to conform to the provisions of the law or comply with legal process served on Lumene; to protect and defend the rights or property of Lumene; or to act in urgent circumstances to protect safety of the public.

    In case we sell our business or part of it or otherwise reorganize our business, personal data processed by us as a controller may be disclosed to buyers and their advisors in accordance with applicable legislation.
     
  2. International transfers of personal data

    We use partners in business activities requiring the processing of personal data, and in this context, we or our partners may, in accordance with applicable legislation, process personal data anywhere in the world and thus transfer the personal data also outside EU or EEA area. In regard to transfers of personal data to countries where the local data protection legislation does not provide adequate level of data protection, the transfers are based on appropriate safeguards, such as standard contractual clauses approved by the European Commission or a competent supervisory authority.

    To learn more about the appropriate safeguards we use, please send us an email at lumene.info(at)lumene.com.

 

HOW DO WE SECURE YOUR PERSONAL DATA?

We have taken appropriate technical and organizational measures to protect the security of your personal data and to ensure that your choices for its intended use are honored. We protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction by appropriate technical measures such as firewalls.

We do not share your personal data outside Lumene, its subsidiaries, affiliates or other partners, except under conditions and for purposes explained in this Privacy Policy, or unless otherwise required under mandatory applicable law. Within Lumene, its subsidiaries, affiliates and other partners, personal data is stored in password-controlled servers with limited access granted only to such persons whose work requires the processing or personal data.

 

HOW LONG WILL WE KEEP YOUR PERSONAL DATA?

The retention time of the collected personal data is subject to the legal basis and processing purpose for which the data were collected. We will retain your personal data for as long as they are necessary for carrying out the processing purposes specified in the Privacy Policy, such as the fulfilment of our contractual obligations (e.g. return and limited warranty periods), or for providing other customer service. When we no longer need the collected personal data, the data will be safely destroyed or irrevocably anonymized.

Where the personal data is processed on the basis of an obligation based on applicable law, the retention period may also be subject to explicit statutory requirement.

We may also retain certain personal data after the termination of the initial processing purpose, should such retention of personal data be necessary to comply with other applicable laws or should we need the personal data to establish, exercise or defend a legal claim, on a need to know basis only.

 

WHAT RIGHTS DO YOU HAVE?

“The data subject” refers to natural persons whose personal data is processed by us, i.e. the users of our Services.

The data subjects have the right to access the data processed by Lumene as a controller and to get incorrect personal data related to them rectified. If you wish to use your right of access or rectification, please proceed as follows.

Your request on the right of access or rectification must be in written or in electronic form and be signed, and addressed to the contact person mentioned in this Privacy Policy. The request shall contain the basic information needed for finding the requested data. After receiving and processing the request, we will send you a copy of the personal data by mail or electronically. We reserve the right not to complete your request if the request is manifestly unfounded or vexatious. Should you request for multiple copies or should you wish to submit more than one request per year, we may charge you a reasonable fee based on administrative costs for the execution of your request.

You as a data subject also have the right at any time to request us to erase personal data concerning you and processed by us and we are obliged to erase the data if there is no longer a legal ground for processing the data. Please note that certain data processed by us are subject to statutory retention requirements, and regardless of a request of erasure, such data we cannot erase until the end of the statutory retention period.

You as a data subject also have the right to object the processing of your personal data if the data has been processed on the basis of our legitimate interest, and we are obliged to stop processing such personal data unless we can demonstrate compelling legitimate grounds for further processing of such personal data.

In addition, you as a data subject have the right to file a complaint with the competent supervisory authority regarding our processing of personal data.

 

IN CONCLUSION

We reserve the right to update and modify this privacy policy. Unless otherwise provided by mandatory applicable legislation, we may not personally post changes to this Privacy Policy to the data subjects in person, and therefore we prompt you to check this policy from time to time for possible changes.

If for some reason you believe that we have not adhered to the foregoing, please notify us by email at lumene.info (at) lumene.com, and we will do our best to determine and correct the problem promptly.

 

 

USE OF COOKIES ON LUMENE WEBSITE

 

What are Cookies

To facilitate the use of our website at www.lumene.com (“website”), we are using cookies and other similar technologies (“cookies”). Cookies are small units of data stored on the hard drive of your computer or other terminal device by your browser that include an identifier (such as a randomly created set of numbers), which allow us to collect information from your use of our website and to "remember" your actions or preferences over time. Cookies do not harm your computer or other terminal device and do not contain viruses or other malware.

Cookies are specific to the server that created them and cannot be accessed by other servers, which means that the cookies cannot be used to track your actions around the web. Alt-hough the cookies do identify a user's terminal device, we cannot personally identify the users of our website through cookies without the use of certain additional information.

As further specified below, some of the cookies we use are necessary for proper functioning of our website or online store, some are necessary to improve the website performance or the user experience, and some are used for purposes of targeting marketing viewed to you around the web.

The cookies on our website may be placed on your terminal device by us or by a third party service provider, such as Google.

 

What Information Do We Collect Through Cookies?

We and third parties collect in particular the following information though cookies:

  • IP address
  • Time of visit
  • Referral page
  • Pages viewed
  • Type of the user’s browser (such as Internet Explorer, Firefox)
  • Geographical location of the user

 

Why Do We Use Cookies?

We use cookies, and allow third parties to use cookies to better understand how our website is used and to allow improved navigation. Cookies help us to determine, for example, whether a page on our website has already been viewed by you. Cookies may also tell us whether you have visited our website before or whether you are a new visitor, as further specified below:

  • Necessary cookies: Necessary cookies are required for the operation of our web-site and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website, or to use a shopping cart.
     
  • Functionality cookies: We use functionality cookies to recognize you when you re-turn to our website. This enables us, subject to your choices and preferences, to personalize our website’s content for you, greet you by name and remember your preferences (for example, your choice of language or region).
     
  • Analytical/performance cookies: These cookies allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us for our legitimate purposes to improve the way our web-site works, for example, by ensuring that users are finding what they are looking for easily.

    Analytical/performance cookies are placed on your terminal device by third parties that use cookies to collect e.g. the following information for us: the number of visi-tors on our website, how and from where the visitors came to the website, what content they viewed and for how long their visit lasted. We use the statistics com-piled from this information to improve the functionalities and the contents of our website.
     
  • Targeting cookies: These cookies record your visit to our website, the pages and content you have viewed, as well as the links you have followed. We will use this information subject to your choices and preferences to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

    Targeting cookies are placed on your terminal device by third parties that collect information through these cookies, for example, information on the contents viewed by you. Based on this information, these third-party service providers can create target groups of visitors to whom they or their partners can view such marketing regarding our products that is likely of your interest. By targeting advertising, we aim at providing such marketing to you that is meaningful and timely.

 

How To Disable Cookies?

Where you have given your consent for placing third-party cookies on your device and you want to revoke your consent, you can prevent them from being used [link to where the user can manage cookie consents].

Most web browsers automatically accept cookies, but if you do not wish to receive cookies, please configure your Internet browser to erase all cookies from your computer's hard drive, block all cookies or to receive a warning before a cookie is stored.

Refer to your browser’s user guide to find out how to control cookies by adjusting your browser’s preferences.

You should note that disabling the use of all cookies may affect the functioning of our web-site, and therefore some of the functionalities of our website may not be available to you af-ter you have disabled cookies. If you disable only third-party cookies, you can still use our website, such as make purchases on our website. If you disable all cookies, you will be una-ble to complete a purchase on our website.

 

In Conclusion

We reserve the right to update and modify this Cookie Policy. Unless otherwise provided by mandatory applicable legislation, we may not personally post changes to this Cookie Policy to the users of our website in person, and therefore we prompt you to check this policy from time to time for possible changes. You can tell when changes have been made to the Privacy Notice by referring to the “Last Updated” legend on top of this page. If for some reason you believe that we have not adhered to what is stated in this Cookie Policy, please notify us by email at lumene.info(at)lumene.com, and we will do our best to de-termine and correct the problem promptly.