Privacy Policy

1. Introduction

2. Data Responsibility

5. Use and Sharing of Data

6. Your Rights

7. Data Retention & Security

8. International Data Transfers

Lumintix committed to safeguarding your privacy. This Policy explains how we collect,use, and protect your personal data when you visit our Website. It also outlines yourrights and how to contact us with questions.

By using our Website, submitting inquiries, or applying for job opportunities, you agreeto the collection and use of your personal information as described in this Policy. Pleasereview this Policy carefully before interacting with our Website. Our services are notintended for individuals under the age of 18, and we do not knowingly collect personaldata from anyone in this age group.

This Policy forms part of our Terms of Use and may be updated from time to time. Werecommend checking it periodically for changes.

For any questions, reach out to us at support@lumintixsolutions.com

Under the UK General Data Protection Regulation (UK GDPR) and, where applicable,the EU General Data Protection Regulation (EU GDPR), Lumintux acts as both a datacontroller and processor. We determine how personal data is collected and used andensure compliance with all applicable data protection laws.

If you apply for a job through our Website, your personal information may also beprocessed by our third-party recruitment partner, Workable. In such cases, SPARQLEYNETWORK LIMITED remains the data controller, and Workable acts as the dataprocessor. We take measures to ensure your data is handled securely and in line withthis Policy.

Data You Provide

We collect personal data you provide to us when:

• Contacting us via forms or email (e.g. name, email, phone number, message)

• Applying for a job (e.g. CV, contact details, location, supporting documents)

• Being referred or sourced via recruitment platforms

• Representing a client, partner, or vendor (e.g. professional and business contactdetails)

Data Collected Automatically

We collect technical and usage data such as:

• Device and browser information (hardware, OS, browser type)

• Website usage data (IP address, location, navigation paths)

• Cookies and tracking technologies (see Section 7)

• Log files (used to ensure website security and performance)

Communication (Legitimate Interest – UK GDPR Article 6(1)(f))

• Responding to enquiries

• Arranging meetings or calls

• Keeping communication records

• Providing support and updates

Marketing & Analytics (Consent – UK GDPR Article 6(1)(a))

• Conducting market analysis

• Analysing website interactions

• Sending newsletters or promotions (if subscribed)

• Personalising your website experience

• Measuring ad performance

Recruitment

• Processing job applications (Consent – UK GDPR Article 6(1)(a))

• Sharing CVs with clients (Legitimate Interest – UK GDPR Article 6(1)(f))

• Background checks if required

• Evaluating candidates for future roles

• Managing our talent database

• Supporting relocation or visa processes

Business Operations (Legitimate Interest – UK GDPR Article 6(1)(f))

• Managing vendor, client, and partner relationships

• Contract management and compliance

• Anti-fraud and anti-corruption screening

• Internal auditing and business reviews

• Financial and operational reporting

Corporate & Investor Relations (Legal Obligation – UK GDPR Article 6(1)(c))

• Organising corporate events

• Meeting legal reporting duties

• Managing bank accounts and filings

• Supporting investor communication

• Complying with regulatory inspections

• Adhering to anti-money laundering obligations

Security (Legitimate Interest – UK GDPR Article 6(1)(f))

• Securing our Website and infrastructure

• Preventing fraud and misuse

• Monitoring physical office access

• Implementing cybersecurity controls

• Conducting risk assessments

• Controlling system and data access

We process personal data through structured storage, retrieval, and deletion. Data may
be shared within Lumintix's group entities, and with regulators, auditors, service
providers, or clients as necessary.

• Access, update, or delete your personal data

• Object to certain processing

• Restrict or request data portability

• Withdraw your consent

To exercise these rights, contact support@lumintixsolutions.com. We may require
proof of identity. We typically respond within one month.


If you are dissatisfied with how we process your data, you can contact the Information
Commissioner's Office (ICO).

We take appropriate security measures, including encryption, access controls, and
audits. Data is stored on secure servers, including trusted cloud providers.

We retain data based on its purpose:

• Contact information: while communication is ongoing and for a reasonable time
afterward

• Recruitment data: up to 3 years after the last interaction (unless required longer)

• Business data: for contract performance and financial compliance

• Security logs: up to 3 years for risk monitoring

Data may be retained longer for legal or compliance purposes. Once no longer
required, data is securely deleted.

If we transfer personal data outside the UK, we implement appropriate safeguards such
as:

• UK-approved Standard Contractual Clauses (SCCs)

• Transfers to countries with UK adequacy decisions

We ensure all transfers are lawful and your data remains protected.