This privacy policy applies to the processing of personal data by Lumio Leadership, Australiëlaan 51, 6199AA, Maastricht-Airport, Kvk 61279749, as ‘controller’, hereinafter referred to as Lumio Leadership or ‘we/our’. If you visit our website or purchase our products or services, we process your personal data. We do this to help you as best we can and to achieve our goals. In this statement, we explain what we use your personal data for and how you can exercise control over it.

Lumio Leadership is a specialized talent consultancy organization operating regionally, nationally, and internationally from Maastricht-Airport. With our unique Succession Planning methodology, we ensure that every company is able to manage talent for now and the future. We offer the services Succession Planning, Executive Search, Assessment Center, and the product Nesto®. Lumio Leadership collects personal data for the purpose of sending newsletters, providing our above-mentioned services, contacting leads, and answering (inquiries) via the contact form on the website.

Personal data are all data that provide information about you as an identifiable person, they tell something about who you are. We ‘process’ these data when we store, view, share, send, and delete them, etc. When you enter into an agreement with Lumio Leadership and/or register yourself for e-mailings or requesting quotes or other information via the website or perhaps by phone, we ask you to fill in company and/or contact information. In addition to information that you enter yourself on our website or give us over the phone, we can also combine this with data that we have previously obtained and with data that we automatically collect using cookies and other technical means, provided you have given your consent. This way, we can trace your IP address, actions performed on the website, the operating system you use, or what you download on the site. For cookies, we have a separate cookie statement. So, it actually concerns all data that we can associate with you, also indirectly.

The specific personal data that we process are:

Name, address, place of residence
Telephone number [optional]
E-mail address, opt-in for e-mailings
Gender, education level [Assessment Center & Executive Search]
Curriculum Vitae [Executive Search]
Company & function
Contact history
If you receive e-mails from us, we register your interactions (open and click behavior)
Invoice and payment data

We do not process special personal data such as your religious beliefs, race, political or sexual orientation, criminal records, religion, trade union membership, or biometric/genetic or medical background without your explicit consent.

Our goal is to provide you with products and/or services, so in the first place we use your personal data to communicate and identify you. This means that we use these data to execute the agreement that you enter into with us, such as processing financial data if you pay for a product, creating and maintaining an account, or in the event that you have a question about the service we provide and we have to call you back.

The legal basis for this is article 6 paragraph 1 sub b of the General Data Protection Regulation ‘GDPR’.

In addition, we will also use your personal data for marketing purposes if we think this may be relevant to you as our customer. Think of offers and advertisements based on the interests we know about you or to participate in surveys and questionnaires. Think also of sending newsletters and social media. The legal basis for this is article 6 paragraph 1 sub f GDPR.

Finally, it is possible that we may need to process personal data in the context of our legal obligations because the law requires us to do so. For example, we will always process financial data for our own accounting obligations. The legal basis for this is article 6 paragraph 1 sub c GDPR.

We may send you newsletters by email about the products and services you already purchase. In the event that we want to contact you about other products or services, we ask you to give your consent first. This consent can always be withdrawn by choosing an ‘opt-out’ at the bottom of the newsletter. Your email address will then be placed on a separate list so that we know that you do not want to be contacted via email.

When we ask you for personal data, we will always indicate per situation whether the provision of the data is necessary or mandatory and what the (possible) consequences are if the data is not provided. The starting point is that Lumio Leadership will not process more personal data than is necessary for the aforementioned purposes.

We will never sell, rent, or lease your personal data to third parties, unless we are legally required to provide data or when you have given your consent. For the execution of our services, we use service providers. These are not “third recipients” but “processors”. These processors do not use the data for their own purposes and process the personal data exclusively in accordance with the instructions of Lumio Leadership

The processors we use are:

NAAM OMSCHRIJVING VERWERKING
Mailchimp Email marketing software where personal data is stored and personal emailings are sent.
Simplicate CRM system used to record customer and contact information.
Online Succes Lead marketing software that can be used to supplement website visits with company data based on an IP address.
TMA Assessment software that contains personality and cognitive ability tests and from which results are generated.
HROrganizer Assessment software that contains personality and cognitive ability tests and from which results are generated.
Twinfield Online accounting software used for administration and invoicing.
Nesto® Test platform that provides insights into the talents and capabilities of individuals. For this, test results are linked to personal data.
Office 365 Office 365 is a subscription service that uses cloud storage and includes all commonly used productivity software (Word, Excel, Outlook, PowerPoint, etc.)

Your personal data may be processed by us, or by the service providers we work with, outside the EEA. This is currently happening in the following countries: United States (Mailchimp). We have agreed on separate security measures for these countries so that we can be sure that the personal data is also safe there.

Lumio Leadership does not use automated decision-making and/or profiling.

We will not store your personal data for longer than is necessary for one of the purposes we have described. The retention periods may vary under the law, but you can assume that we will erase all personal data that we no longer need to process after 2 years after the last contact between you and Lumio Leadership We may choose to anonymize instead of erasing if this is necessary for example for our statistics.

Lumio Leadership has taken appropriate technical and organizational measures to protect personal data from loss or any other form of unlawful processing, including:

Our website and software has an SSL certificate that gives visitors and users the guarantee that (personal) data is sent via browsers via HTTPS, making information encrypted and secure. SSL (Secure Sockets Layer) is also used for online transactions (with credit cards).
Lumio Leadership has taken extensive measures to cover what the procedure is in the event of a data breach. But more importantly, there are various technical and organizational measures taken to prevent data breaches. We use reliable systems that comply with privacy regulations to send email. We have also entered into processor agreements with our suppliers. The CRM system in which we store personal data of our customers also complies with privacy regulations and we do not store more information than necessary. Our website is managed by a reliable hosting company that takes care of the regular updating of the CMS system we use. We also monitor and block IP addresses that are considered unsafe to protect ourselves from hacker attempts.

If we process personal data about you, you have the right to exercise control over it as part of your privacy. For example, you can request access to the personal data we have stored about you and we can correct it for you if you notice an error. We can even grant your request to object or forget when it appears that the processing is no longer or not justified in the way we do it.

No matter what your request is, contact us and we will help you free of charge. You can contact us using the contact information below. Please note that we may sometimes not be able to grant your request because the processing of personal data by us is necessary. For example, if we have not yet completed the agreement, or if we are required by national law to keep financial data. If this is the case, the burden of proof lies with Lumio Leadership and we will explain this to you. In the case of withdrawal of consent or objection to direct marketing, we always grant this request. Finally, you also have the right to data portability if this is technically feasible and we do not have to incur disproportionate costs to provide it.

We want to make it clear to you that as a so-called ‘controller’ we have the obligation to identify the person making a request and we may therefore ask for further information. In any case, we will respond to any request within 4 weeks.

Lumio Leadership reserves the right to modify this statement from time to time. Any changes will be made on this page. The most recent changes were made on 17-05-2018. These changes will be announced on our website. Lumio Leadership may process your personal data for new purposes that have not yet been disclosed to you. In that case, we will contact you before using your personal data for these new purposes, to inform you of the changes to the personal data protection and to give you the opportunity to refuse.

If you have any questions about this privacy statement or our privacy policy, or if you wish to exercise any of your legal rights, you can contact us using the following details:

Lumio Leadership
Australiëlaan 51
6199AA, Maastricht-Airport, Nederland.
Tel: +31 (0)85 273 7904
E-mail: hello@lumioleadership.com