PRIVACY POLICY

Version 2.1, last updated 30/05/2014

Lumina Learning ("we, us, our") is committed to protecting and respecting your privacy. For the purpose of this policy Lumina Learning means Lumina Learning LLP, a company registered in England (Company Number 06895465) whose registered office is at Alderwick James.

This policy together with our Terms of Use sets out the basis on which any personal data (“data, personal data, information, personal information”) we collect from you, or that you provide to us, through our website located at www.luminalearning.com ("Website") or by any other means will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

By submitting personal information to us, you are deemed to have agreed to the terms set out below regarding the use of your personal information and how we will process it. From time to time we may change this policy and we will post changes to our Website. You are therefore requested to regularly check for any updates as by continuing to provide us with your personal information or by continuing to use the Website you signify your agreement to any such changes.

1. OVERVIEW

If you fill in one of our questionnaires you will be termed an "Assessee" in this Privacy Policy, and we will analyse the data you submit in order to provide reports to our clients ("Assessment Service") for one of three reasons: the questionnaire is part of broader developmental process you are part of; the questionnaire is part of a recruitment/selection/promotion process you are part of; the questionnaire is part of a research project.

When you fill in one of our questionnaires, it will be under the instruction of one of our specially trained and qualified assessors ("Practitioner") or under the direct instruction of Lumina Learning. We will process the data and provide the Practitioner with the necessary information for the client to use as part of the Assessment Service. For the purposes of the Data Protection Act 1998 ("the Act"), the data controller is the Practitioner or Lumina Learning or both, dependent on whose instruction you complete a questionnaire under, and the data processor is Lumina Learning.

2. INFORMATION WE COLLECT

The information that you provide us with may vary depending upon whether you are an Assessee or a client.

We may collect and process the following data about you:

  • Information you provide us with when you complete a questionnaire as part of an Assessment Service, which may include sensitive personal data such as your name, gender, email address, contact telephone number, postal address, date of birth, job title, cultural background, qualifications, work history, your current employment status and responsibilities, your workplace performance, your opinions and interpretations of issues, your psychological preferences, skills, qualities, underlying motivations, competencies, capabilities, interests and responses to pressure and/or stress;
  • Information that you provide to us in the event that you wish to subscribe to our services (including an Online Practitioner Account) and/or buy products or materials from us which may include your name, gender, email address, contact telephone number, postal address and date of birth;
  • Information you provide if we ask you about a problem with our Website that you have reported;
  • Information provided to us by our clients about you, including but not limited to your name, job title and email address (typically this is provided so we can contact you regarding a questionnaire to fill in);
  • Details of your visits to our Website and the resources that you access;
  • Records of correspondence if you contact us;
  • Records of correspondence between you and our Practitioners which is processed by us through our website or by us through any other means;
  • Feedback on the delivery of our services and/or products if you provide feedback to us.

 

3. HOW WE WILL USE YOUR INFORMATION

We will use your personal information in an ethical manner for the following purposes:

  • To process your registration to our services;
  • To fulfil any orders you make for our products and/or services;
  • To provide you with customised questionnaires and applications;
  • To process questionnaires and create reports;
  • To provide Assessment Services to our clients, through research/analysis of your workplace performance, opinions and interpretations of issues, your psychological preferences, skills, qualities, underlying motivations, competencies, capabilities, interests and responses to pressure and/or stress;
  • To research and improve our Assessment Services;
  • To support our security, administration, testing our systems, billing processes, accounting, credit card checks, maintaining our systems, providing customer service, enforcing and/or defending our legal rights and developing our products;
  • To enable us and our clients (typically their human resources function, through the use of our Assessment Services) to engage in one of three purposes: the development of individuals; the recruitment/selection/promotion of individuals; general research in the field of Human Resources;
  • To carry out our obligations arising from any contracts entered into between you and us;
  • To allow you to participate in interactive features of our Website;
  • To administer the Website which may involve sharing information with our network provider;
  • To carry out customer and market research;
  • To provide you with any marketing materials you have consented to receive, including news, updates and offers, unless you subsequently inform us that you do not wish to receive such information;
  • To provide existing clients with information about our products and services where these are similar to previous purchases by the client or the client has previously been contacted about;
  • To deal with your requests and enquiries whether directed at us or our Practitioners;
  • To track activity on the Website;
  • To improve the quality of our products and services;
  • To comply with legal, statutory and/or regulatory obligations.

 

4. HOW LONG WE KEEP YOUR INFORMATION FOR

The information you provide and our processed versions of it will be kept for as long as is required for the specific purpose it was collected for.

Information will be deleted if we consider it is no longer appropriate to keep it.

If you (or the client that paid for the Assessment Services you are part of) request(s) your data is made anonymous we will comply with such a request as soon as reasonably possible.

5. COOKIES

We may use cookies on our Website. Cookies are software applications which are placed onto the hard drive of your computer by websites. The aim of a cookie is to track a user's navigation of the website and store the information onto the user's hard drive. This information should make your website visits more productive by storing and using information on your website preferences and habits. Whilst cookies do not identify users personally, they do identify each user's computer.

Your browser software can choose whether or not to accept cookies and most browser software is initially set up to accept them. You should read the information that came with your browser software to see how you can set up your browser to notify you when cookies are used. This will give you an opportunity to either accept or refuse the cookies. Further information on cookies and how you can refuse them is provided by the Interactive Advertising Bureau on its website located at www.allaboutcookies.org. Please note that you may not be able to use all the interactive features of the Website if cookies are disabled.

6. WEBSITE USAGE

Our Website tracks various aspects of data usage, such as the IP address any data request come from, the domain name, the date and time of the data requests, any referring website and any data contained within the URL. This information is logged and aggregated reports analysed to help us research how our Website is being used, which sections of the Website are most popular and to identify and potential fraudulent usage of the Website.

7. WHO WE DISCLOSE INFORMATION TO

We may disclose your personal information to third parties:

  • In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
  • If we or substantially all of our assets are acquired by a third party, in which case personal data held by it about its website users will be one of the transferred assets;
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Use or General Terms and Conditions of Business or other agreements; or to protect the rights, property, or safety of our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
  • When we provide Assessment Services for a client, we will disclose your personal data to the client. However, we do not control our clients' use of the data or any further distribution by our clients;
  • When we provide Assessment Services we may, from time to time, disclose your personal data to Lumina Learning's Practitioners and agents;
  • To improve our Assessment Services we may, from time to time, disclose your personal data in an anonymous form to Lumina Learning's clients, university research partners, Practitioners and agents. This helps us undertake research and monitor to ensure our questionnaires are fair with regard to gender, age and ethnic origin;
  • To deliver our Assessment Services we may, from time to time, appoint third parties to engage in data processing on our behalf.
  • When we are responsible for processing correspondence between you and a Practitioner through our website or by any other means. We will disclose only the personal information relevant to your correspondence to only the Practitioner to whom your enquiry is directed.

 

8. INFORMATION WE MAY RECEIVE ABOUT YOU FROM THIRD PARTIES

In addition to the information you provide us with, we may also receive information about you from our clients. This typically occurs when the client employs you, sub-contracts services to you or is considering employing or sub-contracting services to you.

Some of our Assessment Services may involve you providing details of other people, for example, when the assessment requires others to provide 360 feedback on performance at work or personality aspects. If you do provide details of other people to us, you should first inform them that you will be disclosing their information to us and ensure you have their informed consent to allow you to disclose their information to us.

In the event that we have contacted you as a result of a request to provide feedback as part of an Assessment Service, we can confirm that the data you provide will be used according to this Privacy Policy.

9. DATA PROTECTION

We will process any personal data that you may submit to us through our Website or other means in accordance with the Data Protection Act 1998 (as amended from time to time), and will ensure that any sub-contractor we may engage to provide the services requested by you acts in such manner. We will keep your personal data secure and will only retain your personal data for as long as reasonably necessary to provide the services requested.

We may from time to time process your personal data using third parties located in countries outside of the European Economic Area and some of these do not have strict data protection laws. When we do use third parties, these parties are bound by the terms of Lumina Learning's Privacy Policy. We are committed to ensuring the safety and security of your data and will use our best endeavours to ensure your data is handled according to this Privacy Policy.

10. SECURITY

We will endeavour to take all reasonable steps to protect your information. However, we cannot guarantee the security of any information you disclose online. You accept the inherent security risks of providing information and dealing online over the internet and you will not hold us responsible for any breach of security unless due to our negligence or wilful default.

You are not permitted to create a link to this Website without our prior written consent.

Once we receive your information, it will be stored on our secure servers where data is regularly backed-up and encrypted.

Our Website does contain links to third parties such as our Practitioners, clients, other websites/networks and external web services (such as Facebook and YouTube). If you go to these websites/networks or use these external services, please be aware that such usage will be governed by the third parties’ own privacy policies. We cannot prevent such third parties collecting information on you. We are not liable for any of these third parties’ activities.

11. HOW TO ACCESS PERSONAL INFORMATION

You may by law request a copy of any personal data that we may hold about you. In order to obtain a copy of your personal information please provide us with a written request for the release of your personal information to the address below and enclose a fee of 10.00 pounds sterling payable to Lumina Learning LLP to cover our administration costs.

12. TRANSLATIONS

The language of this Privacy Policy is English and even though there may be translations of this Privacy Policy into languages other than English, English shall be the definitive and binding version and the only language used in the interpretation of this Privacy Policy.

13. HOW TO CONTACT US

In the event that you do not want to receive any communications that we may from time to time send via email to our clients and people who have registered with us, you may inform us by emailing us at support@luminalearning.com.

If any of the information that you have provided to us changes or requires correction for any reason or you would like to change your registration preferences, please let us know by emailing us at support@luminalearning.com or writing to us at the following address: Lumina Learning LLP, Third Floor St George's House, Knoll Road, Camberley, GU15 3SY.