For purposes of this Agreement, “Site” refers to the Company’s website, which can be accessed at www.LumenVA.com.
“Service” refers to the Company’s services accessed via the Site, in which users can view information about the company, send a message via a contact form or book an appointment for a discovery call via the Calendly scheduling tool and hire the site owner to support their business needs.
The terms “we,” “us,” and “our” refer to the Company.
“You” refers to you, as a user of our Site or our Service.
INFORMATION WE COLLECT
LumenVA collects “Non-Personal Information” and “Personal Information” in the categories described below.
LumenVA will process information about your use of our website and services (“usage data”). The usage data may include
(1) the browser types and versions used
(2) the operating system used by the accessing system
(3) the website from which an accessing system reaches our website (so-called referrers)
(4) the sub-websites
(5) the date and time (so-called timestamp) of access to the Internet site
(6) an Internet protocol address (IP address)
(7) the Internet service provider (ISP) of the accessing system
(8) the geographical location of the user
(9) the page views and site navigation paths
(10) the pattern of the users’ use of the service with regards to timing and frequency
(11) any other similar data and information that may be used in the event of attacks on our information technology systems.
The source of the usage data is Google Analytics. The usage data collected is needed to
(1) deliver the content of our website correctly
(2) optimise the content of our website as well as any advertisement
(3) ensure the long-term viability of our information technology systems and website technology
(4) provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack.
In order to process this information, we have obtained the user’s consent AND our legitimate interests in monitoring and improving our website and services.
LumenVA may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). Our newsletter may only be received by the user if
(1) the user has a valid email address and
(2) the user registers for the newsletter shipping.
A confirmation email will be sent to the email address registered by a user for the first time for newsletter shipping, for legal reasons, in a double opt-in procedure. The confirmation email is used to prove whether the owner of the email address as the user is authorised to receive the newsletter.
When the user registers for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the user at the time of the registration, as well as the date and time of the registration. The purpose of the collection of this data is to legally protect LumenVA by ensuring understanding of the possible misuse of the email address of a user at a later date. The personal information collected as part of a registration for the newsletter will only be used to send our newsletter.
The subscription to the newsletter may be terminated by the user at any time. The consent to the storage of personal data, which the user has given prior to the shipping of the newsletter, may be revoked at any time. For the purpose of revoking consent, a corresponding link for unsubscribing is found in each newsletter.
Enquiry data, correspondence data and customer relationship data
LumenVA may process information contained in any enquiry you submit to us regarding our services and products (“enquiry data”). If a user contacts us via email or via a contact form, or via the third party scheduling Calendly app, the personal information transmitted by the user is automatically stored.
The personal information may include:
(1) the user’s contact information
(2) the user’s name
(3) the name of the user’s employer
(4) the user’s job title or role
(5) the metadata associated with the communication
(6) and information contained in communications between the user and LumenVA
Such personal data transmitted on a voluntary basis by a user to LumenVA are stored for the purpose of processing or contacting the user, managing our relationships with customers, keeping records of communication with the user, and promoting our products and services to customers.
LumenVA may process information that the users post for publication on our website or through our services (“publication data”). On our website the users can post information in the following ways:
a user may post a comment on a blog post.
LumenVA may process information that relates to transactions, including purchases of goods and services, that the user enters into with us and/or through our website (“transaction data”). The transaction data may include:
(1) the user’s contact details
(2) the user’s bank card details
(3) the transaction details with regards to the purchase
In order to process the transactions on our website we use the following third party payment services provider: Stripe. The details of how the user’s data is processed by Stripe can be found here, https://stripe.com/ie/privacy.
We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding your payments and dealing with queries relating to your payments and refunds.
In order to further process the transactions we use the following third party accounting services provider: Wave Apps. The details of how the user’s data is processed by Wave can be found here, https://my.waveapps.com/privacy/.
We will share transaction data with our accounting services providers only to the extent necessary for the purposes of processing your payments, refunding your payments and dealing with queries relating to your payments and refunds.
HOW WE USE AND SHARE INFORMATION
In general, the Personal Information you provide to us is used to help us communicate with you. For example, we use Personal Information to contact users in response to questions, solicit feedback from users, provide technical support, and inform users about promotional offers.
Legal purpose of the processing of personal data
RETAINING AND DELETING YOUR PERSONAL INFORMATION
The personal information that we process for any purpose or purposes will not be kept for longer than is necessary for the expressed purpose. We will retain your personal data as follows:
- IP addresses will be retained for a minimum period of 30 days and for a maximum period of 14 months.
- Email addresses will be retained until such time as you request to be removed from mailing lists.
In some instances, it is not possible for us to specify in advance the periods for which your personal information will be stored by us. In such cases, we will determine the period of retention based on the following criteria:
- the period of retention of names and contact information will be determined based on the relationship duration should you become a client of LumenVA.
YOUR DATA PROTECTION RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)
If you are a resident of the EEA, you have the following data protection rights:
- If you wish to access, correct, update, or request deletion of your personal information, you can do so at any time by emailing hello@LumenVA.com.
- In addition, you can object to the processing of your personal information, ask us to restrict the processing of your personal information or request portability of your personal information.
- You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you. To opt-out of other forms of marketing, please contact us by emailing hello@LumenVA.com.
- Similarly, if we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority
about our collection and use of your personal information. For more
information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
LINKS TO OTHER WEBSITES
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of significant changes to this policy by email or by placing a prominent notice on our site. Significant changes will go into effect 30 days following such notification. Non-material changes or clarifications will take effect immediately. You should periodically check the Site and this privacy page for updates.
This website is owned and operated by LumenVA. We are registered in Ireland under sole trader status.
Our data protection officer’s contact details are: Nicola Devereux, nicola@LumenVA.com.