This Privacy Policy describes how we – Lumorus Corporation Plc. (together with its affiliates companies and brands – “Culture Diagnostic Index (CDI)”, “we”, “our” or “us”) collect, store, use and disclose personal data regarding individuals (“you”) who: (i) visit or otherwise interact with our website available at www.Lumorus.com or www.culturediagnosticindex.com or any other website, webpage (including broadcasted boards or forms generated through our Service), e-mail, text message or digital ad under our control (collectively – “Sites”); (ii) use our cloud-based visual work management platform, via the Sites, or the Lumorus desktop or mobile applications, integrations, add-ons or extensions (“Users”; and together with the Sites – the “Service”).
Specifically, this Privacy Policy describes our practices regarding –

1. Data Collection
2. Data Use
3. Data Location and Retention
4. Data Sharing
5. Cookies and Tracking Technologies
6. Communications
7. Data Security
8. Data Subject Rights
9. Data Controller/Processor
10. Additional Notices

Your privacy is important to us, and we are committed to making our practices regarding your personal data fair and transparent.
Please read this Privacy Policy carefully and make sure that you fully understand it. You are not legally required to provide us with any of your personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our service providers, please simply do not visit or interact with our Sites, nor use our Service. You may also choose not to provide us with “optional” personal data, but please keep in mind that without it we may not be able to provide you with the full range of our services or with the best user experience when using our Service.
This Privacy Policy pertains to Lumorus practices as a “data controller”, where we determine the means and purposes for processing personal data. Where we process data on our business customers’ (“Customers”) behalf, we act as their “data processor”, pursuant to our agreement with them (as further explained in Section ‎9 below). If you are a User of the Service on behalf of any of our Customers, we suggest that you contact your account administrator(s) (“Account Admin”) with any questions or requests which pertain to the personal data processed by us on such Customer’s behalf.
Any capitalised but undefined term in this Privacy Policy shall have the meaning given to it in our Terms of Service (“Terms”).

1. Data Collection
We collect technical data, profile data, content, and other data received from you, your organization and other third party sources.
We collect and control various types of personal data regarding our Users and visitors to our Sites. Such data is collected and generated through your interaction with us or with our Service, through automatic means, or directly from you, from other Users, from our Customers, or from other third parties (including our Service Providers, as defined below).Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, is deemed as “personal data”):
Data automatically collected or generated: When you visit, interact with, or use our Service, we collect, record or generate certain technical data about you. We do so either independently or with the help of third party Service Providers (as defined in Section ‎‎4 below), including through the use of “cookies” and other tracking technologies (as detailed in Section ‎5 below).
Such data consists of connectivity, technical and aggregated usage data, such as IP addresses and general locations, device and application data (like type, operating system, mobile device or app id, browser version, locale and language settings used), date and time stamps of usage, the relevant cookies and pixels installed on or interacted with via such device, and the recorded activity (sessions, clicks, use of features, logged activities and other interactions) of visitors and Users in connection with our Service. In addition, phone calls (e.g., with our customer service or product consultants) may be automatically recorded, tracked and analysed, for purposes including analytics, service-, operations-, and business quality control and improvements, training, and record-keeping purposes.
User Data received from you: When you contact us, sign up to the Service and create your individual profile (“User Profile”), or sign up to an event that we host, organise or sponsor, you provide us with personal data. This would typically include your name, workplace and position, contact details (such as e-mail, phone and address), account login details (e-mail address and passwords which are automatically hashed), as well as any other data you choose to provide when you use our Service, contact us, or interact with others via our Service. For example, you may connect your Google or LinkedIn account when you sign up or login to the Service, and thereby provide us with your name, e-mail address, image and other details available on your profile there. You may also provide us with your profile photo, location, time-zone, skills, device, general location, and activity logs and data; as well as your preferences, characteristics and objectives for using the Service (collectively, “User Data”).
You may also send us a “Contact Us” or support requests, or provide us with feedback, reviews, or responses to our surveys or promotions, including by submitting an online form on our Service or social media channels, by posting on any of our online public forums or communities, by sending an e-mail to any of our designated addresses, or any other form of communication. Such data may include details on an issue you are experiencing, contact information and any other documentation, screen recording, screenshots or other information.
Our Customers may provide us with additional data such as their billing details, business needs and preferences. To the extent that such data concerns a non-human entity (e.g. the bank account of a company or business), it will not be regarded as “personal data” in most countries.
User Data received from our Customers and Users: Customers and Users may provide us with the contact details of potential Users, such as their employees, team members and colleagues, in order for us to contact, invite or subscribe them as Users to our Service (including by using Single sign-on tools). Such data typically includes these individuals’ names, phone numbers and work e-mails, however additional data may be provided at the discretion of those providing it. For the purposes of this Privacy Policy, this data is also regarded as User Data.
Data received from other third parties: We may receive personal data which relates to you from other sources. For example, if you participate in an event, webinar or promotion that we sponsor or participate in, we may receive your personal data from its organisers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our Partners (defined below), from our service providers, and through the use of tools and channels commonly used for connecting between companies and individual professionals in order to explore potential business and employment opportunities, such as LinkedIn.
Data obtained through Analytics Tools: We use analytics tools (e.g. Google Analytics) to collect data about the use of our Sites and Service. Analytics tools collect data such as how often Users and visitors visit or use the Sites or Service, which pages they visit and when, which website, ad or e-mail message brought them there, and how they interact with and use our Service and its various features.

2. Data Use
We use personal data as described in this section (e.g. to provide, improve and secure our Service; for analytics, marketing and sales purposes; to comply with applicable laws; and to support our legitimate interests).
We use personal data as necessary for the performance of our Service; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Service, e.g. in understanding how our Service are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Service to you and others; providing customer service and technical support; and protecting and securing our Users, Customers, visitors, ourselves and our Service. If you reside or are using the Service (i) in a territory governed by privacy laws which determine that “consent” is the only or most appropriate legal basis for processing personal data (in general, or specifically with respect to the types of personal data you choose to share via the Service), your acceptance of our Terms and of this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Privacy Policy, to the extent permitted under law in such territory. If you wish to revoke such consent, please contact us by email at info@lumorus.com

Specifically, we use personal data for the following purposes:

• To facilitate, operate, and provide our Service;
• To authenticate the identity of our Users, and to allow them to access our Service;
• To provide our visitors, Users and Customers with assistance and support;
• To gain a better understanding on how visitors and Users evaluate, use and interact with our Service, and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Service;
• To facilitate and optimiseour marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Service, and thereby to increase your engagement and overall satisfaction with our Service. This includes contextual, behavioural and interests-based advertising based on the visitor’s or User’s activity, preferences or other data available to us or to our Service Providers and business partners;
• To explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences, including through partnerships with local distributers, resellers, business partners and providers of professional services related to our Service (“Partners”, as further described in Section 4 below);
• To contact our visitors, Users and Customers (whether existing or prospective) with general or personalisedservice-related messages, as well as promotional messages that may be of specific interest to them (as further described in Section 6 below);
• To facilitate, sponsor and offer certain events, contests and promotions;
• To publish your feedback and submissions to our Sites, public forums and blogs;
• To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
• To create aggregated statistical data, inferred non-personal data or anonymisedor pseudonymised data (rendered non-personal), which we or others may use to provide and improve our respective services, or for any other business purpose; and
• To comply with applicable laws and regulations.
  In respect of personal data we obtain from Google OAuth API Scopes, used in our integration with certain Google services (“Integrated Google Services”), our use of such personal data and data aggregated, anonymised, or derived therefrom (“Restricted personal data”), is limited to the following:
  Facilitating, operating, supporting, providing and improving the Integrated Google Service;
  Troubleshooting or security purposes (such as investigating a bug or abuse);
  Compliance with applicable law and regulations;
  For our internal operations, provided that the Restricted personal data (including derivations thereof) have been aggregated and anonymised;
  Transfer of the Restricted personal data to third parties: (1) in accordance with this Privacy Policy, solely to the extent necessary to provide or improve the Integrated Google Services; (2) to comply with applicable laws and regulations; and (3) in connection with any change in control, including by means of merger, acquisition or purchase of substantially all of Lumorus’s assets; or
  In strict accordance with your affirmative agreement.
  We do not sell your personal information for any intents and/or purposes.
  3. Data Location & Retention
  We store your data in multiple locations around the world, for as long as necessary in accordance with our reasonable business needs (as necessary for the performance of our Service or for supporting and exercising our legitimate interests); and in accordance with our legal obligations.
  Data Location: We and our authorised Service Providers (defined below) maintain, store and process personal data in the United States, Europe, the United Kingdom and other locations as reasonably necessary for the proper performance and delivery of our Service, or as may be required by applicable law.
  Lumorus Ltd. is headquartered in the United Kingdom, a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for personal data of EU Member State residents. We transfer data from the EEA and Switzerland to the U.K on this basis.
  While privacy laws vary between jurisdictions, Lumorus, its affiliates and Service Providers are each committed to protect personal data in accordance with this Privacy Policy, customary and reasonable industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred. For data transfers from the EU or UK to countries which are not considered to be offering an adequate level of data protection, we and the relevant data exporters and importers have entered into Standard Contractual Clauses as approved by the European Commission. You can obtain a copy by contacting us as indicated in Section 10 below.
  Notwithstanding the foregoing, where Lumorus processes personal data on behalf of a Customer, such personal data may only be processed in such locations as permitted in any Data Processing Addendum and other commercial agreements with such Customer (as further described in Section 9 below).
  Data Retention: We may retain your personal data for as long as it is reasonably needed in order to maintain and expand our relationship and provide you with our Service and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy and at our reasonable discretion. If you have any questions about our data retention policy, please contact us by e-mail at info@lumorus.com
  4. Data Sharing
  We share your data with our Service Providers; your organization (our Customer); within our group; in accordance with legal compliance requirements; and amongst Users on your shared platforms.
  Research: Lumorus is engaged in an ongoing research/study of how people react to others and theworld around them, not limited to, but particularly our Cultural Diagnostic Index. We may engagewith research partners and service providers in these studies. The data we collect fromadministering our services is retained for these research purposes and to provide the comparativeanalyses that employers and others might request. After each survey deployment engagement andthe associated assessment commences, we delete the directly identifiable information that wasused to extend the participation invitation to you. We strip any direct identifiers from eachindividual dataset that represents your responses. We aggregate and retain the responses ofparticipants as part of our Research Data. We do not possess the direct identifiers necessary todirectly identify an individual’s dataset from the Research Data. Our policies and jurisdictionregulations forbid our employees and third parties (such as our Research Partners) from engagingin or employing means to attempt re-identification. We retain the data that we collect until wehave fulfilled the purposes that we describe in this Privacy Policy. If you have any questions aboutour research and how we retain and use data, please contact us by e-mail at info@lumorus.com
  Legal Compliance: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our products and services.
  Service Providers: We engage selected third party companies and individuals to perform services complementary to our own. Such service providers include providers of Third Party Services, hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection, investigation and prevention services, web and mobile analytics, e-mail and communication distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimisation and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, compliance and financial advisors and auditors (collectively, “Service Providers”).
  These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Service, and may only use it for such limited purposes as determined in our agreements with them.
  These are the information related to the 3rd party services providers we currently use
  Name Address
  Microsoft Office 365, 2 Kingdom St, London W2 6BD, United Kingdom
  Monday.com, 179 Great Portland St London, W1W 5PL United Kingdom
  Qualtrics, 10 York Rd, London SE1 7ND, United Kingdom
  Partnerships: We engage selected business and channel partners, resellers, distributors and providers of professional services related to our Service, which allow us to explore and pursue growth opportunities by facilitating a stronger local presence and tailored experiences for our prospective and existing Customers and Users. In such instances, we may share relevant contact, business and usage details with the respective Partner, to allow them to engage with those Customers and Users for such purposes. If you directly engage with any of our Partners, please note that any aspect of that engagement which is not directly related to the Service and directed by Lumorus is beyond the scope of Lumorus’s Terms and Privacy Policy, and may therefore be governed by the Partner’s terms and privacy policy.
  Application Providers and Event Sponsors: if so instructed or permitted by you or your Account Admin, we may share your personal data (such as your User Profile and contact details, as well as relevant usage data) with the provider(s) of any 3rd party applications or integrations added to your Account. Similarly, if you register to any event that we host, organise or sponsor, then with your permission we may share your registration details with others, including the hosts, organisers, speakers, service providers and sponsors of that event, so that they may contact you with relevant information and offers, or to fulfill any promotions related to the event.
  Feedback or Recommendations: If you submit a public review or feedback, note that we may (at our discretion) store and present your review to other visitors and Users of our Sites and Service (including other Customers). If you wish to remove your public review, please contact us at info@lumorus.com. If you choose to send others an e-mail or message inviting them to use the Service, we may use the contact information you provide us to automatically send such invitation e-mail or message on your behalf. Your name and e-mail address may be included in the invitation e-mail or message.
  Community Forum: Our Sites include public blogs, forums and podcast, such as Lumorus Forum and Leadership Melting Pot. We also manage and participate in various social channels and communities in other platforms. Any information you submit on these forums, blogs and communities – including profile information associated with the User Profile you use to post the information – may be read, collected, and used by others who access these Sites. Due to the nature of such public forums, your posts and certain profile information may remain visible to all even after you terminate your User Profile. To request removal of your information from publicly accessible Sites operated by us, please contact us as provided in Section 10 below and note the Sites from which you would like your information to be removed. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.
  Protecting Rights and Safety: We may share your personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Lumorus, any of our Users or Customers, or any members of the general public.
  Lumorus Subsidiaries and Affiliated Companies: We share personal data internally within our group of companies, for the purposes described in this Privacy Policy. In addition, should Lumorus or any of its group of companies undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal data may be shared with the parties involved in such an event. If we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Service.
  For the avoidance of doubt, Lumorus may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous.
  5. Cookies and Tracking Technologies
  We and our Service Providers use cookies and other technologies for performance, tracking, analytics and personalisation purposes.
  Our Sites and Service (including some of our Service Providers) utilise “cookies”, anonymous identifiers, pixels, container tags and other technologies in order for us to provide our Service and ensure that it performs properly, to analyse our performance and marketing activities, and to personalise your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall personal data, such as an IP address, previously indicated by a User. To learn more about our practices concerning cookies and tracking, please see our Cookie Policy. You may also use the “Cookie settings” feature available in our Service depending on your location and activity on our Service, as applicable.
  Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, however, most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or to block or remove cookies altogether.
  6. Communications
  We engage in service and promotional communications, through e-mail, phone, SMS and notifications.
  Service Communications: We may contact you with important information regarding our Service. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Service, billing issues, service changes, log-in attempts or password reset notices, etc. Our Customers, and other Users on the same Account, may also send you notifications, messages and other updates regarding their or your use of the Service. You can control your communications and notifications settings from your User Profile settings. However, please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like password resets or billing notices).
  Promotional Communications: We may also notify you about new features, additional offerings, events and special opportunities or any other information we think our Users will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Service, or through our marketing campaigns on any other sites or platforms. If you do not wish to receive such promotional communications, you may notify Lumorus at any time by sending an e-mail to info@lumorus.com, changing your communications preferences in your User Profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
  7. Data Security
  We secure your personal data using industry-standard physical, procedural and technical measures.In order to protect your personal data held with us, we use industry-standard physical, procedural and technical security measures, including encryption as appropriate. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties as described in Section 4 above.
  Data Subject Rights
  Individuals have rights concerning their personal data. For all such personal data that we process as a Data Controller (listed in Section 1), you may exercise your rights by contacting us as stated below.
  If you wish to exercise your privacy rights under applicable law (including the EU or UK GDPR), such as the right to request access to, rectification or erasure of your personal data held with Lumorus, or to restrict or object to such personal data’s processing, or to obtain a copy or port such personal data (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at info@lumorus.com.
  Please note that once you contact us, we may instruct you on how to fulfill your request independently through your User Profile settings; may refer you to your Account Admin; or may require additional information and documents, including certain personal data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.
  9. Data Controller/Processor
  Lumorus is the Controller of our visitors’ and Customers’ personal data, and of certain types of User Data; we are the Processor of any personal data submitted to our Service (e.g. Culture Diagnostic index), and of User Data processed on behalf of our Customer.
  Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing personal data: the “Data Controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, “service provider”), who processes such data on behalf of the Data Controller (or business). Below we explain how these roles apply to our Service, to the extent that such laws and regulations apply.
  Our role as a Data Controller: Lumorus is the “Data Controller” of its visitors’ and Customers’ personal data, as well as User Data consisting of profile and contact details, usage, preferences, engagement and analytics data, and such data detailed in Section 1 above. With respect to this data, Lumorus assumes the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy.
  Our role as a Data Processor: If any of our Users upload or submit content to our Service which includes personal data (e.g. registration to take the CDI Assessment ), such data will be processed by Lumorus solely on behalf of our Customer, which is the owner of the respective Account or Product, along with all other User Data processed on such Customer’s behalf.
  In such instances, our Customer shall be deemed the “Data Controller” of such data, and Lumorus will process such data on the Customer’s behalf, as its “Data Processor”, in accordance with its reasonable instructions, subject to our Terms and other commercial agreements with such Customer. Where Lumorus is the “Data Processor” of the Customer’s personal data, Lumorus’s Service Providers who process such data are deemed as its sub-processors. The Customer will be responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing, providing data subjects with sufficient information about their personal data, and responding to Data Subject Rights requests concerning the personal data they control).
  If you would like to make any requests or queries regarding personal data we process as a Data Processor on our Customer’s behalf, including accessing, correcting or deleting your data, please contact us info@lumorus.com directly.
  10. Additional Notices
  We may update this policy from time to time; we are not responsible for other websites’ or services’ privacy practices; we have appointed a Data Protection Officer. Don’t hesitate to contact our DPO with any questions regarding privacy and data protection!
  Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Service. The amended version will be effective as of the date it is published. When we make material changes to this Privacy Policy, we’ll provide Users with notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Service or by sending an email. Your continued use of the Service after the changes have been implemented will constitute your acceptance of the changes.
  Third Party Websites and Services: Our Service includes links to third party websites or services, and integrations with Third Party Services. Such websites, services and Third Party Services, and any information you process, submit, transmit or otherwise use with or to such websites, services and Third Party Services, are governed by such third party’s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such website, services and Third Party Services.
  Our Service is not directed to children under the age of 16: We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Service, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at info@lumorus.com.
  DPO: Lumorus has appointed Oniel Croal as our Data Protection Officer, for monitoring and advising on Lumorus’s ongoing privacy compliance and serving as a point of contact on privacy matters for data subjects and supervisory authorities. If you have any comments or questions regarding our Privacy Policy, if you have any concerns regarding your privacy, or if you wish to make a complaint about how your personal data is being processed by Lumorus, you can contact info@lumorus.com.
  Questions, concerns or complaints: If you have any comments or questions regarding our Privacy Policy, or if you have any concerns regarding your personal data held with us, please contact Lumorus’s support at info@lumorus.com.
  If you are a GDPR-protected individual, you also have the right to lodge a complaint EU or UK supervisory authority, as appropriate.
  The ICO’s address:
  Information Commissioner’s Office
  Wycliffe House
  Water Lane
  Wilmslow
  Cheshire
  SK9 5AF
  Helpline number: 0303 123 1113
  ICO website: https://www.ico.org.uk
  This privacy notice is regularly reviewed to ensure it is accurate and up to date. It was last updated in September 2021.