LUMON GROUP PRIVACY NOTICE
Updated September 22nd 2023
All Lumon Group companies are committed to protecting your privacy. The information which we collect is always used to help serve you in the best possible way. You can trust us to store and manage your data respectfully, safely, and with care.
Lumon Group processes your personal data in accordance with applicable data protection laws. This Privacy Notice provides you comprehensive information about personal data processing activities conducted by Lumon. The purpose of this notice is to give you information regarding how we process personal data in our customer relationship management, sales and marketing activities. Information may be supplemented by specific privacy notices and additional local documentation. Also note that your rights as a data subject may also vary from country to country depending on the applicable data protection laws. Our Privacy Notice presents the rights according to the EU’s general data protection regulation (“GDPR”). Any mandatory laws or regulations will take precedence in the event that it conflicts and has stricter requirements than our Privacy Notice.
1. Controllers and contact details
Lumon Invest Oy (established in Finland and being the parent company of Lumon Group) is the joint data controller
Lumon Invest Oy
Business ID: FI22544498
Kaitilankatu 11, 45130 Kouvola, Finland
tel.:+358 (0) 20 7403 200
email: [email protected]
together with other Lumon Group companies:
Lumon Oy, Lumon Suomi Oy, Suomen Visor Oy, Lumon International Oy, Lumon Cristales Espana S.A., Svenska Lumon AB, Lumon Norge AS, Lumon North America Inc., Lumon Deutschland GmbH, Lumon Schweiz AG, Lumon France SAS, Lumon Danmark Aps, AO Lumon, Lumon Fabrica S.L.
Contact details in privacy matters:
2. What kind of personal data do we collect?
We currently collect and process following information, whereby the Lumon customer register can include for example following information:
• Basic information: e.g., first name, last name, street address, postal code, city, country, phone number, mobile phone number
• Purchase history: e.g., place and date of purchase, purchased products with their prices, final sum of purchases, way of payment, delivery address, ID
• Customer relationship management information: e.g., preferred contact method, type of apartment, date of beginning of customer relationship, as well as Lumon product ownership, contracts, invoice details and similar information that are needed to manage the relationship
• Personal preferences: e.g., Lumon products that you are interested in and permissions or prohibition for direct email and SMS marketing
• Lumon website and other online tools use data like browsing data, location data and IP address.
From companies we also store data including e.g., company name, address, VAT number, delivery and invoicing addresses, company’s contacts’ name, email, phone number and title/position. We collect this information to be able to communicate and serve our potential and current customers better, as well as to improve the overall customer experience.
3. Where do we collect personal data from?
Personal data is collected by phone, through websites or other digital channels, in meetings or by other equivalent means. Data is also collected in connection with the conclusion of the customer agreement and otherwise obtained over the course of the customer relationship. Personal data may also originate from Lumon’s representatives based on their business interactions with individuals, or through data collected and updated from public and private registers.
We collect and process data when you, e.g.:
- submit a form to book a visit, to ask for more information, to get a quote, to download a guide, Ebook or similar document, or to subscribe to a newsletter on any of our websites
- place an order for our products or services available through any of our web shops
- send a message to Lumon personnel to get service through your preferred channel
- approve an agreement in an e-signature tool
- voluntarily complete a customer survey on Lumon website or sent via email
- provide feedback or have a conversation on any of our chat tools or via email
- voluntarily participate in any of our quizzes or lotteries
- voluntarily allow browser cookies
- login to our customer portal to review your order or to get other useful information
- call Lumon and give your contact details and other personal data
- visit a Lumon booth or exhibition stand at a trade show or fair, or in a shopping mall or parking lot, and give your contact information to a Lumon employee, or you fill in a digital or paper form
- give your contact information to a Lumon employee that visits your home and inserts the data to our systems.
- voluntarily provide information to participate in an event, where the event organizer can forward your information to the event’s exhibitors
4. What permits the use of your personal data and for what purpose is your personal data collected?
When performing sales, marketing, or customer relationship management activities we process personal data of our potential and current consumer and business customers (incl. e.g., newsletter subscribers, individuals who have requested a quote or submitted a contact request, participants of events and website visitors). The processing of personal data is based on an agreement, a legitimate interest of Lumon (e.g., customer relationship management, direct marketing, debt collection), on a customer relationship, or other appropriate connection or agreement between Lumon and the customer or potential customer upon consent (e.g. related to cookies).
The purposes of processing your personal data are:
• to process your order, manage your account, create invoice and warranty documents
• to communicate with you during the relationship between you and Lumon (incl. e.g., feedback and customer satisfaction surveys)
• to manage, develop, analyze, and retrieve statistics of the relationship between you and Lumon to process requests and act upon them accordingly
• to invite you to sales and marketing events
• to implement opinion and market surveys, and to organize prize competitions and draws
• to conduct direct marketing, online targetings, and advertising
• to email you regarding your open offer
• to email you with special offers on other products and services we think you might like
• to plan and develop business operations and services
• to manage receivables and collect debt
• to identify users and manage access rights
• to detect, prevent and investigate of misuse, fraud or other crimes
• to analyze and segment data and to retrieve statisticsfor the above mentioned purposes
On Lumon websites and web shops, cookies are used to collect information about user behavior on our websites, web shops, and portals users. This includes, for example, devices they use, pages they visit, and download information. We use this information to improve the usability of our web services in relation to our customers and potential customers.
5. Who do we share your personal data with, and may data be transferred outside the EEA?
Personal data is not regularly transferred outside Lumon Group and is not transferred outside the EEA. However, we use certain services like marketing automation tools and web analytics, where information may be transferred to other countries (e.g., UK, Canada, Switzerland, and the United States). The data of these services is stored on service providers servers mainly within the ETA and United States. Some of the data processing functions of the service providers are nonetheless performed outside the EEA area, e.g., in Canada. The transfers of data to Canada, the United Kingdom and Switzerland are carried out based on the adequacy decision issued by the EU Commission.
The level of data protection may be lower outside the EEA than in the EEA. Unless the country to which the data is transferred, such as the United States, has received the EU Commission’s adequacy decision, Lumon Group is to apply other appropriate protective measures to ensure the protection of personal data, for example by applying standard contract clauses in accordance with the European Commission’s decision on the transfer of personal data to third countries (https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en )
We use the services of external service providers, e.g., system and communication software providers, logistics and printing houses. According to the data protection agreements, each service provider processes personal data only to the extent that it is necessary to provide the service.
In certain countries or certain regions of a country Lumon operates via trusted resellers or dealers. Information with trusted resellers or dealers may be shared to ensure that you are being served in the best possible way. In addition, our service providers may have access to your personal data, as their services are needed to technically process certain requests and orders.
When Lumon processes your order, it may send your data to, and also use the resulting information from, credit reference agencies to prevent fraudulent purchases.
6. Do we use user profiling
We might use profiling and/or automated profiling to offer you the best possible customer service and offers which suit you best. Your profile can be based on, for example, your browsing and purchase history. The communications you receive from us are personalized based on that information.
7. What are our principles of personal data protection? How long do we retain information?
All your personal data is always protected with necessary technical and administrative methods. Lumon strives to ensure that data held by Lumon isn’t used incorrectly, deleted without reason, counterfeited or manipulated, and that data doesn’t end up to outsiders or get published without given permission. Our data system is protected and accessible only by Lumon employees with personal login credentials.
Accessing the system requires a username and password. The system is also protected by firewalls and other technical solutions.
• Data in the register is accessible only by authorized and specifically designated employees
• Use of the register is protected with personal login credentials and authorization
• The register is located in a computer which is stored in a data center where access is limited
• Data contained in the register is located in secure and protected premises
• Regular backups are taken of the register
Your personal data is stored in our customer register for as long as it is necessary to fulfill the purposes defined in this privacy notice. For example, your personal data is stored in our customer register for the lifetime of the glazing systems, which is approximately 20-30 years. If you purchase blinds, carpets, or other types of accessories, your data is stored in our systems for approximately 5-10 years. After that we will dispose of your data by deleting it completely from our servers. In case you don’t become our customer, we will remove your data from our systems after five years.
8. What are your rights related to data processing?
The requests related to the data subjects’ rights should be sent to the address mentioned in section 1. As a data subject, you have the following rights:
Right of access, rectification, and erasure
- You are entitled to obtain information regarding your personal data processing, including a right to inspect the personal data concerning yourself stored in the register. You are also entitled to require rectification and erasure of your data.
Right to prohibit direct marketing
- You have the right to prohibit the processing of your data for market and opinion surveys or related profiling. In addition, you can prohibit direct marketing (email, SMS) at any time by reporting the prohibition to the e-mail address mentioned in section 1 or cancel the direct marketing messages you subscribed to by using the link in the e-mail or SMS message.
Right to object and right to restrict processing
- You have the right to object or demand restriction of the processing or transmission of your data.
Right to lodge a complaint with a supervisory authority
- If you consider that the processing of personal data relating to you infringes the data protection regulation, you have the right to lodge a complaint with a supervisory authority. You may lodge your complaint in the EU Member State of your habitual residence, place of work or place of the alleged infringement.
9. What are cookies?
Cookies can be blocked in browsers via their own settings. In addition, Lumon websites and web shops use a cookie banner whichallows you to select what cookies can be installed. However, if you block all or some of the cookies, you may not be able to use all of our services fully.
- Keeping you signed in
- Showing you the right information
- Serving you with relevant content and prefilled forms
- Retrieving website usage statistics and understanding website usage patterns to help us improve customer experience
- Showing you the chat window to have conversation with Lumon representatives
We also use temporary session-cookies, which close after you close your browser, and permanent cookies, which are saved to computer’s hard drive. With cookies we can identify your browser and use this information for analytic purposes, such as counting visitors on our website. This information gives us the possibility to observe and follow our customers’ interests and therefore improve our websites.
Third party advertisers may also use some tech to analyse and measure the effect of ads. For this, they may use a tracer (e.g. 1 pixel sized GIF-file), which is located on our website to collect anonymous information. After receiving anonymous information about visits on our and other websites, advertisers may design ads about products and services, which possibly interest the user.
11. What type of cookies do we use?
We use five different types of cookies: 1) Strictly necessary, 2) functional, 3) performance, 4) targeting, and 5) social media cookies. For more information, please visit our Cookie settings section (link to One Trust cookie pop-up).
12. Updates to privacy notice
Lumon Group drives to develop continuously its business and data protection tools and reserves the right to amend this Privacy Notice. When required by applicable laws Lumon Group may contact you to provide information about updates or changes which may have an effect on you.