← Back to home

PRIVACY POLICY

About this Policy

This Privacy Policy (the "Policy") is issued by Lumina Strategy Solutions (SMC-Private) Limited (Company Registration No. 0337302), with registered offices at Techverx, 3-P 2nd Floor, Sir Syed Road, Block-P, Gulberg-II, Pakistan (referred to as "Lumina", the "Company", "we", "us", or "our").

This Policy explains what personal data we collect from individuals who visit or interact with our website (the "Website"), why we collect it, how it is used and protected, and the rights available to you under applicable data protection legislation.

Who does this Policy apply to?

This Policy applies to the following categories of individuals:

Visitors: persons who access the Website to view information about the Company and its services, without submitting personal data beyond what is generated automatically by their device or browser.

Applicants: persons who submit personal data through the Website in connection with an application to join the Company's team.

Personal Data We Collect

This Privacy Policy applies to personal data collected by the Company from any person who contacts, accesses, uses or interacts with the Company through the Website. The categories of personal data we collect depend on how you interact with our Website.

As a Visitor, we may collect limited information relating to your use of the Website, including webpage download information, site usage information, technical information, device information and similar data.

As an Applicant, we may collect personal data that you actively provide to us, including:

Identity and contact details including your first and last name, email address, and telephone number.

Professional and educational background such as employment history, qualifications, memberships, certifications, and related information.

Any additional information you choose to include in your application or communications with us.

Any further information we may request from you at a later stage of the application process.

Please refer to our separate Candidate Privacy Notice for a comprehensive description of the personal data processed in the context of recruitment.

We are committed to safeguarding the privacy of our Visitors and Applicants. We will not collect additional personal information from you unless such information is voluntarily provided by you or is otherwise necessary for the Purpose described in this Privacy Policy.

In accordance with applicable data protection laws, we are legally required to respect and safeguard personal information collected from you, and we shall comply with this obligation. Except as otherwise stated in this Privacy Policy, the Terms and Conditions of the Website, or where required by law, regulation, court order or competent authority, we take appropriate measures to prevent unauthorised access to personal information and do not disclose personal information obtained through the Website to unauthorised third parties.

All personal information communicated to the Company is retained within the Company's records in accordance with applicable laws and regulations.

1. 3. Why We Collect and Process Your Personal Data

We process personal data only to the extent necessary to achieve one or more of the following purposes:

Service information: to provide Visitors with information about the Company, its services, and its activities.

Recruitment and employment: to manage applications submitted through the Website and to carry out associated recruitment processes.

Website operation and security: to ensure the proper functioning, performance, and security of the Website, including the detection and prevention of technical issues or misuse.

Personal data will not be processed for purposes beyond those set out above without a lawful basis to do so.

1. 4. Data Retention

We retain personal data only for as long as is reasonably necessary to fulfil the purposes for which it was collected, and in any event for no longer than required under applicable law or regulation.

In determining appropriate retention periods, we take into account:

The nature and sensitivity of the personal data concerned.

The purpose for which it was collected and whether that purpose has been fulfilled.

Applicable local legal and regulatory requirements.

Any contractual obligations relevant to the data.

Upon expiry of the applicable retention period, personal data is securely deleted, destroyed, or anonymised.

1. 5. Your Rights

Subject to applicable data protection laws and any legal limitations, you may have certain rights in relation to your personal data, including the rights set out below.

Right of Access: You may request a copy of the personal data we hold about you and request confirmation that we are processing it lawfully. The Company reserves the right to charge a reasonable fee for providing such records, except where this is not permitted under applicable law.

Right to Correction: You may request that we correct or complete any inaccurate or incomplete personal data we hold about you. We may need to verify the accuracy of any new or corrected information you provide.

Right to Erasure: You may request that we erase or remove your personal data in certain circumstances, including where there is no longer a valid reason for us to continue processing it, where you have successfully exercised your right to object to processing, where you believe we may have processed your information unlawfully, or where erasure is required under applicable law. Please note that we may not always be able to comply with a request for erasure where there are specific legal, regulatory, contractual or legitimate reasons requiring us to retain the relevant personal data. Where applicable, we will notify you of such reasons at the time of your request.

Right to Object: Where we process your personal data on the basis of our legitimate interests, you may object to such processing in certain circumstances. You may exercise this right in advance or at any later stage, subject to applicable law.

Right to Restrict Processing: You may request that we restrict or suspend the processing of your personal data in certain circumstances, including where:

1. a. you want us to establish the accuracy of the data; b. our use of the data is unlawful, but you prefer restriction of processing instead of erasure; c. we no longer require the data, but you need us to retain it in order to establish, exercise or defend legal claims; or d. you have objected to our use of your data and we need to verify whether we have overriding legitimate grounds to continue using it.

Right to Data Portability: Upon your request, and where applicable, we may provide your personal data to you or to a third party chosen by you in a structured, commonly used and machine-readable format.

Right to Withdraw Consent: Where we rely on your consent to process your personal data, you may withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of any processing carried out before consent was withdrawn.

1. 6. Data Security

We have implemented appropriate technical and organisational measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. Access to personal data within the Company is restricted to personnel who require it in order to carry out their functions, and all such personnel are subject to obligations of confidentiality.

We maintain procedures to identify, investigate, and respond to potential data security incidents. In the event of a breach that is likely to result in a risk to your rights, we will notify you in accordance with applicable law.

1. 7. Amendments to this Policy

The Company reserves the right to amend this Policy at any time, at its sole discretion. Any amendments will take effect upon publication of the revised Policy on the Website. We encourage you to review this Policy periodically to stay informed of any changes.

1. 8. Acceptance

By using the Website, you acknowledge that you have read and understood this Policy and you consent to the processing of your data, including the transfer of any Confidential Information to the relevant Pakistan authority when required by law. You also warrant that all data and information you provide are accurate and current. Your use of the Website constitutes your acceptance of the terms and conditions outlined in this Privacy Policy, as well as other information available on the Website. Accordingly, you agree to waive any rights to hold the Company liable for claims arising from or related to the processing of your data as described herein, except in cases where such data has been processed fraudulently or negligently in violation of the provisions of this Privacy Policy. Should you have any questions regarding your Confidential Information held by us, please do not hesitate to contact us using the contact details provided on the Website.

1. 9. Contact Us:

Should you have any queries in relation to this Privacy Policy, your personal data held by us, or any other general questions in relation to the Company and its services, do not hesitate to contact us here.