Privacy Policy

Lumata Digital believes that the establishment of trust and privacy is instrumental to the continued growth of the Internet. We also believe that the efficient collection, use and transfer of information serve to enhance the development of the Internet and electronic commerce, provided that such information is handled in a fair and responsible manner.



In order to inform you of our policies and activities with respect to the collection, use and transfer of Personal Data on its websites, Lumata Digital is providing you with an electronic copy of this Privacy Policy (the “Policy”). This Policy applies to all websites that are owned and operated by Lumata Digital and/or companies that Lumata Digital controls, directly or indirectly (collectively, “Lumata Digital”), unless a particular website displays its own privacy policy.

Lumata Digital or one of companies that Lumata Digital controls, directly or indirectly, is the data controller with respect to Personal Data collected and processed via its respective website. When required by local law, the relevant Lumata Digital entity performs the formalities with the local data protection authorities with respect to the processing of personal data.

In this Policy, “Personal Data” means information which relates to an individual and which identifies that individual, either directly or indirectly (together with other information that is reasonably likely to come into Lumata Digital’s possession), such as your name, email address or telephone number.


Collection of personal data

Generally, you can visit Lumata Digital websites without providing any Personal Data about yourself. However, in order to access some parts of our websites, such as to download certain documents, or in connection with another specific purpose, we may need to collect Personal Data from you. Providing Personal Data to us in these events is voluntary. If you do not provide Personal Data to us, then you will not be able to benefit from the respective functionality offered by our websites, such as communication, downloading of documents or recruitment. The purposes, for which your Personal Data is collected, are described below, along with a brief description of how your Personal Data may be handled in each case.

  • Communicating with you.We will follow up on comments and other requests that you submit to us through our website, such as online queries, business related inquiries, or registering your attendance at a conference. This may include using your Personal Data to call you back by telephone or communicating with you via email.
  • Direct marketing and promotion.Direct marketing and/or promotional efforts by or on behalf of Lumata Digital may include providing you with specific information that you have requested online, providing more general information about other Lumata Digital offerings, or enabling you to participate to online contests or to register for any sponsored events. When we collect Personal Data for direct marketing or promotional purposes, however, we generally offer appropriate choices regarding the use of your Personal Data.
  • Recruitment. If you submit a resume or job application online, we will use your Personal Data for recruitment-related purposes, which may include contacting you via email, telephone or post. In some cases, you may be required to register on our website in order that you may track the progress of your application online. Except where you request otherwise, Lumata Digital may keep your Personal Data on file for an appropriate time in order to consider you for other employment opportunities with Lumata Digital in the future.
  • Discussion forums. If you choose to participate in Lumata Digital discussion forums or chat rooms then, in some cases, you may be required to register certain details, such as your name and email address. You should also be aware that your comments may be made broadly available to others, inside or outside Lumata Digital, depending on which particular discussion forum or chat room you are accessing.
  • Maintaining the website and conducting customer satisfaction surveys. We will use your Personal Data in order to maintain and improve our website.  We may also use your Personal Data in order to conduct customer satisfaction surveys.
  • Compiling aggregate statistics regarding the use of the website.

When providing Personal Data on this website, you acknowledge that you have the necessary authorisation and consent to disclose Personal Data to be used by Lumata Digital as described in this Policy.



Like many websites, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We may use cookies for two purposes. First, we may utilize persistent cookies to save your login information for future logins to the website. Second, we may utilize session ID cookies to enable certain features of the Website to better understand how you interact with the website and to monitor aggregate usage by users and web traffic routing on the website. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the website and then close your browser. Third party advertisers on the website may also place or read cookies on your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions of the website or all functionality of the website.

Other non-cookie technologies

Lumata Digital also enables the use of technologies that perform functions similar to cookies such as web beacons or other technologies that may be included in marketing e-mail messages or newsletters in order to determine whether messages have been opened and links clicked on. Web beacons do not place information on your device, but may work in conjunction with cookies to monitor website activity.

“Do-not-track” signals: 

Some web browsers may transmit “do-not-track” signals to the websites with which the browser communicates. As of the Effective Date of this Privacy Policy, an industry standard has not yet been established on how to respond to these signals. Therefore, our website does not currently recognise or respond to these signals, but Lumata Digital will reassess its response approach once a standard is established. However, at this time you can generally express your privacy preferences regarding the use of most cookies through your web browser.


Global organization

Lumata Digital is a global organisation. Whilst we have distinct legal entities (e.g., country subsidiaries) in many parts of the world, our internal processes and infrastructure are international in scope and nature and generally cross country borders. Accordingly, you should be aware that we may share your Personal Data inside Lumata Digital and transfer it to countries in the world where we have data centres or otherwise do business, including those located outside the European Union (EU). In these instances, Lumata Digital will process your Personal Data in the manner described by this Policy and in accordance with applicable law.


Third-party suppliers

Like many organisations, we use third-party suppliers to collect, use and otherwise process Personal Data on our behalf. Our practice is to require such third parties to handle Personal Data in accordance with Lumata’s Privacy Policy.


Business Reorganisations

Like many organisations, Lumata Digital may reorganise its business operations around the world from time to time, whether by buying new businesses or selling or merging existing businesses. This may involve us disclosing Personal Data to prospective or actual purchasers of parts of our business, or receiving personal data from potential sellers. It is our practice to seek appropriate confidentiality protection for Personal Data disclosed in these types of transactions.


Legal disclosures

Lumata Digital may disclose your Personal Data in order to enforce our website Terms of Use or in urgent circumstances to protect personal safety, the public or Lumata Digital’s websites. It is also possible that we may be required by law to disclose your Personal Data pursuant to judicial or other government subpoenas, warrants, or orders, potentially, in any country where we do business.


Sensitive personal data

As a general rule, Lumata Digital does not collect “Sensitive Personal Data” through its website. “Sensitive Personal Data” means Personal Data concerning racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, or concerning health or sex life. By volunteering unsolicited sensitive Personal Data to us (e.g., by submitting your resume or a job application online), you expressly consent to your Personal Data being used as described in this Policy.


Accessing, correcting, updating and deleting personal data

If you have any questions or concerns regarding this Policy, or would like to request a copy of your Personal Data, then please fill-in the contact form on the website. Also, if you consider your Personal Data to be incorrect or wish to have it deleted, then please either sign-in and update, correct or delete your profile on our website or fill-in the form previously mentioned so that Lumata Digital may make any necessary updates, corrections and/or deletions.


Data security and integrity

Lumata Digital uses various technological and procedural security measures in order to protect the Personal Data we collect, use or transfer from loss, misuse, alteration or destruction. However, you should be aware that, due to the open and unsecured character of the Internet, Lumata Digital cannot be responsible for the security of transmissions of the Personal Data over the Internet.


Third-party websites

Lumata Digital websites may provide links to third-party websites. Lumata Digital does not make any representations or warranties with respect to such third-party websites. You should be aware that the owners and operators of such third-party websites might collect, use or transfer personal data under different terms and conditions than Lumata Digital. Upon linking to a third-party website, you should inform yourself of the privacy policies of such third party websites.


Notification of changes to this policy

This Policy is effective in July 2016 (the “Effective Date”). In order to check updates to this Policy, please consult this page on a regular basis.