Lumel Data Privacy Notice for Employees, External Staff, Candidates and Guests

Overview

Your privacy is important to Lumel (“we”, “us”, “our” or “Lumel”). We respect the privacy rights of all individuals and we are committed to handling personal data responsibly and in accordance with applicable laws and Employee Privacy Principles. This privacy notice, together with the Addenda and other notices provided at the time of data collection, explain what personal data Lumel collects about you, how we use this personal data, and your rights to this personal data.

Please note that this privacy notice applies to the handling of your personal data as an employee, former employee, candidate, guest, or as external staff. (“External staff” are workers who are not employed by Lumel and who have access to Lumel’s facilities and/or Lumel’s corporate network. This could include agency temporary workers, outsourced staff, contractors, and business guests.) Lumel has additional governance and privacy requirements concerning the collection and uses of personal data.

This notice does not cover your use of Lumel consumer products as a consumer, or outside of your employment or assignment with Lumel. Lumel consumer products may include services, websites, apps, software, servers, and devices. To learn more about Lumel’s data collection practices that cover your use of Lumel products as a consumer, please read our Lumel Privacy Policy.

This notice is not intended and shall not be read to create any express or implied promise or contract for employment, for any benefit, or for specific treatment in specific situations. Nothing in this notice should be construed to interfere with Lumel’s ability to process employee data for purposes of complying with our legal obligations, or for investigating alleged misconduct or violations of company policy or law, subject to compliance with local legal requirements.

Lumel's processing of personal data is in all cases subject to the requirements of applicable local law, internal policy, and where applicable or appropriate, any consultation requirements with worker representatives. To the extent this notice conflicts with local law in your jurisdictions, local law controls.

Personal Data that We Process (this may include data that you provide to us, that we collect about you, or that we assign to you.)

We collect, use, and store (collectively “process”) different types of personal data about you in in the operation of our business. If you are an employee, we process personal data about you (and your dependents, beneficiaries and other individuals associated with your employment) primarily for managing our employment relationship with you and managing your interactions with workplace facilities/information systems. If you are a former employee, we process personal data about you primarily for legal compliance. If you are external staff, the type of personal data we process is limited to what we need to manage your engagement with Lumel and access to Lumel facilities and information systems. If you are a candidate, the type of personal data we process is generally limited to what we need to engage with you about Lumel career opportunities, consideration of your application for employment to specific roles at Lumel, including candidate screening, interview scheduling and management, lawful background screening, and to on-board you at Lumel if you receive and accept an offer of employment with us.

The personal data we process can include, but is not limited to, the following:

Name and contact data. Your first and last name, employee identification number, email address, mailing address, phone number, photo, beneficiary and emergency contact details, and other similar contact data. Additionally, you may opt to provide Lumel with additional contact information such as personal email address(es) and/or cell phone number(s).

Demographic data. Your date of birth and gender as well as more sensitive personal data (also known as special category data) including information relating to information about your health, disabilities, gender identity, and transgender status.

We process this personal data for a variety of reasons, and this will vary in our different jurisdictions. Our reasons for processing this data include:

1. Where it is necessary to comply with local requirements and applicable law. For example, we may use this information to comply with anti-discrimination laws and government reporting obligations;
2. To monitor and ensure diversity and equal treatment and opportunity;
3. To provide work related accommodations or adjustments, to provide health and insurance benefits to you and to your dependents, and to manage absences from work.

Where the processing of this personal data is not required by law, we will seek your consent to process your data and, in the consent mechanism, we will explain the purposes for which we will use your data. This will be voluntary, and you may decide whether or not to give consent.

National identifiers. Your national ID/passport, citizenship status, residency and work permit status, social security number, Aadhaar, PAN, or other taxpayer/government identification number.

Employment details. Your job title/position, office location, employment contract, offer letter, hire date, termination date, performance history and disciplinary records, training records, leave of absence, sick time, and vacation/holiday records.

Spouse’s/partner’s and dependents’ information. Your spouse and dependents’ first and last names, dates of birth, and contact details.

Background information. Your academic and professional qualifications, education, CV/Resume, credit history and criminal records data (utilized for background screening and vetting purposes where permissible and in accordance with applicable law and consultation requirements).

Video, voice and image. We may collect and use your video, voice and image data, subject to the requirements of local law, internal policy, and any consultation requirements with worker representatives (where appropriate).

Financial information. Your bank account details, tax information, salary, retirement account information, company allowances and other information necessary to administer payroll, taxes and benefits.

Workplace, Device, Usage, and Content data. Application data (such as data from Office 365, Teams, Outlook, or internal business processes) including emails sent and received, calendar entries, to-do items, instant messages, building and information system access, Lumel devices, system and application usage (including telemetry) when accessing and using Lumel corporate buildings and assets. We may also collect personal data about you from third parties or public sources as needed to support the employment relationship or to engage with you concerning job opportunities at Lumel. For example, before and during your employment or assignment with Lumel, we may collect information from public professional networking sources, such as your LinkedIn profile, for recruitment purposes. We also may conduct lawful background screenings, to the extent permitted by law, through a third-party vendor for information about your past education, employment, credit and/or criminal history. In the event of a natural disaster or other life/safety emergency, we may rely on public social media posts or other public sources to account for employees if otherwise unable to contact them. Additionally, if there is an investigation of an incident involving employees, we may obtain information relevant to the incident from external sources including private parties, law enforcement or news sources and public social media posts.

Why We Process Personal Data

We collect your personal data for the purposes set out below. Failure to provide your personal data when requested may prevent us from being able to carry out these tasks and/or comply with our legal obligations.

1. To administer your employment contract, offer letter or other commitments we have made to you.

We collect and use your personal data primarily for the purposes of managing our employment or working relationship with you, and to fulfill our obligations under your employment contract, or applicable Lumel policies, including on-boarding, payroll, benefits administration, pension and retirement administration, managing vacation and other types of leave, tax reporting, and the like. A few examples include: your employment contract, your offer letter (e.g., so we can on-board you), promotion history and performance reviews (e.g., so we can manage our employment relationship with you), and your bank account and salary details (e.g., so we can pay you or provide HR benefits).

2. Other overriding and legitimate business purposes

We also may collect and use your personal data when it is necessary for other legitimate purposes, such as general HR administration, maintaining our global directory of employees and external staff, general business management and operations, disclosures for auditing and reporting purposes, measuring employee sentiment, internal investigations, management of network and information systems security, business operations, security, life safety and building management, provision and improvement of employee services and facilities, physical security and cybersecurity, data protection, for global diversity and inclusion initiatives, to protect the life and safety of employees and others and in connection with the sale, assignment or other transfer of all or part of our business. We also use business data and other workplace usage, device and content data for organizational and individual analytics and data insight purposes to improve Lumel business operations, manager capability, and the employee experience. We may also use special applications and systems that record employee performance metrics, such as sales related or code databases for business operations purposes as well as for the purposes of reviewing, rewarding and coaching employees on their performance and for administration and assessment of training. We may also process your personal data to investigate potential violations of law or violations of our internal policies.

Additionally, we may process your personal data to conduct scientific research, without your additional consent, when viewed as in the public interest and/or where there is a clear attempt for contributions to generalizable knowledge. In these cases, we will ensure appropriate technical and organizational controls are in place to protect your personal data, such as anonymizing and aggregating data to help protect your identity, ensuring use of your personal data is subject to our privacy standards and conducting ethics and compliance reviews prior to using your personal data.

3. Legally required purposes

We may also use your personal data when necessary to comply with laws and regulations, including collecting and disclosing personal data as required by law (e.g., for minimum wage, working time, tax, health and safety, anti-discrimination laws, global migration, and data subject rights), under judicial authorization, or to exercise or defend Lumel’s legal rights.

4. Other uses of your data (where permissible and in accordance with applicable laws and consultation requirements)

We also may collect your internal usage data of Lumel products, services and internal applications and tools, including business data created by employees and external staff, to measure and improve these products and for product research including human and machine review of data to train AI models and improve machine learning for Lumel products and services. Where required by law, we will seek your consent for such usage; and where your consent is sought, we will ensure your consent is informed, voluntary, and that you suffer no adverse consequence from any decision to withhold or revoke your consent.

For eligible employees (i.e., part or full-time employees, interns, apprentices, or contractors) who enroll in Lumel CSR, with your consent, we collect and use your personal data to enable voluntary personal donations of money, Lumel products, or volunteer hours to eligible organizations (i.e., certain non-profits or non-governmental organizations). Lumel CSR is a voluntary benefit program from which participants can opt-out and revoke their consent at any time; however, opt-outs and revocations do not affect previous processing of personal data.

Change of Purpose

We will use your personal data only for the purposes for which it was collected, unless we reasonably need it for another compatible purpose and there is a legal basis for further processing. For example, relying upon our legitimate interest in recruiting candidates for roles at Lumel, we may process the personal data you provided s while researching job openings. However, once you apply for and are successful in obtaining a role, we may process your personal data for the purpose of entering into an employment relationship with you.

How and Why We Share Personal Data

Lumel will only share your personal data with those who have a legitimate business need for it. Whenever we permit a third party to access your personal data, we will ensure the personal data is used in a manner consistent with this privacy notice (and any applicable internal data handling guidelines consistent with the sensitivity and classification of the personal data). Your personal data may be shared with our subsidiaries and affiliates and other third parties, including service providers, for the following legitimate purposes:

1. In order to carry out the purposes of our personal data processing as described above (see section titled: “Why We Process Personal Data”);
2. To enable third parties to provide services on behalf of Lumel. Third party data recipients include financial investment service providers, insurance providers, pension administrators and other benefits providers, childcare providers, payroll support services, relocation, tax and travel management services, health and safety experts, facility management, legal service providers, and security services;
3. To comply with our legal obligations, regulations, government clearances, or contracts, or to respond to data subject rights, a court order, administrative or judicial process, such as a subpoena, government audit or search warrant. Categories of recipients would include counter-parties to contracts, judicial and governmental bodies;
4. In response to lawful requests by public authorities (such as regulatory bodies, law enforcement authorities, and national security organizations);
5. To seek legal advice from external lawyers and advice from other professionals such as accountants, management consultants, etc.;
6. As necessary to establish, exercise or defend against potential, threatened or actual litigation;
7. Where necessary to protect Lumel, your vital interests, such as safety and security, or the vital interests of other persons;
8. In connection with the sale, assignment or other transfer of all or part of our business (such as a potential purchaser and its legal/professional advisers); or
9. Otherwise in accordance with your consent.

Please note that where legal requirements limit the sharing of your personal data, Lumel will respect such requirements.

Use of Cookies and Web Beacons

Site pages may use cookies (small text files placed on your device). Cookies and similar technologies allow us to store and honor your preferences and settings; enable you to sign-in; combat fraud; and analyze how our websites and online services are performing.

We also use “web beacons” to help deliver cookies and gather usage and performance data. Our websites may include web beacons, and cookies, or similar technologies from third-party service providers.

You have a variety of tools to control the data collected by cookies, web beacons and similar technologies. For example, you can use controls in your internet browser to limit how the websites you visit are able to use cookies and to withdraw your consent by clearing or blocking cookies.

Workplace Security and Monitoring

Lumel monitors its IT and communications systems through automated tools such as network authentication and wireless connectivity hardware and software, anti-malware software, website filtering and spam filtering software, security software for cloud-based applications, access and transaction logging, and mobile device management solutions. The primary purpose of this monitoring is Lumel’s legitimate interests in protecting its employees, customers, and business partners. For example:

1. For systems, applications, and network security, including in particular the security of Lumel’s IT systems and assets, and the safety and security of its employees, external staff and other third parties;
2. For network and device management and support;
3. For proof of business transactions and record-keeping;
4. For the protection of confidential information and company assets;
5. For investigating wrongful acts or potential violations of company policy; and
6. For other legitimate business purposes as permitted under applicable law.

We also monitor our offices, and other workplace facilities, through video monitoring such as closed-circuit television (“CCTV”), bio-metrics, and badge scans for security, life safety and building management purposes. CCTV is primarily used at office entrance and exit points, elevator lobbies, rooms where there may be valuable equipment, such as server rooms, and in other select areas with a high risk for theft or with highly sensitive assets. CCTV is not used in private spaces such as restrooms, new mothers’ rooms or locker rooms. Nor is it used to monitor employee workstations for performance reasons.

You should be aware that any message, files, data, document, facsimile, audio/video, social media post or instant message communications, or any other types of information transmitted to, through or from, received or printed from, or created, stored or recorded on our IT and communications systems and assets (included via the use of personal devices accessing corporate IT systems), are presumed to be business-related and may be monitored or accessed by us in accordance with applicable law and workplace agreements (such as works council agreements), and subject to Lumel’s own policies on access to and uses of such data.

Security of Your Personal Data

Lumel is committed to protecting the security of your personal data. We use a variety of security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. For example, we store the personal data you provide on limited access computer servers that are located in controlled facilities, and we protect certain highly confidential or sensitive personal data through encryption in transfer and at rest.

Where We Store and Process Personal Data

Lumel operates globally and therefore personal data may need to be transferred to countries outside of where the personal data was originally collected. For example, because we are headquartered in the United States, personal data collected in other countries is routinely transferred to the United States for processing. When we transfer your personal data to a different country, we will ensure that this transfer complies with applicable laws and legislation.

Please contact us if you would like us to direct you to your data protection authority contacts. Binding arbitration is available to address residual complaints not resolved by other means. Lumel is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

Our Retention of Personal Data

We will store personal data in accordance with applicable laws or regulatory requirements and retain data for as long as necessary to fulfill the purposes for which the personal data was collected, as documented in our corporate data retention schedule.

Changes to this Privacy Notice

We may occasionally update this privacy notice. When we do, we will revise the "last updated" date at the top of the privacy notice. If there are material changes to this privacy notice or in how Lumel will use your personal data, we will use reasonable efforts to notify you either by prominently posting a notice of such changes before they take effect on our websites or by directly sending you a notification. We encourage you to periodically review this privacy notice to learn how Lumel protects your personal data.

How to Contact Us

For copies of additional privacy documents mentioned in this privacy notice, or if you have a privacy concern or question related to this privacy notice, please contact it@lumel.com.

Our address is:

Lumel Technologies Inc.

5920 Windhaven Pkwy, Ste 130,

Plano TX 75093 USA

Telephone: +1 (469)-609-0039