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Data Protection Policy

Effective Date: 8 May 2025

Lumenara is committed to safeguarding the personal information of our clients, employees, and partners. This Data Protection Policy outlines our approach to handling personal data in compliance with the Privacy Act 1988 (Cth), the General Data Protection Regulation (GDPR), and the California Consumer Privacy Act (CCPA).

1. Purpose

This policy ensures that Lumenara manages personal information in an open and transparent manner, adhering to legal obligations and best practices for data protection.

2. Scope

This policy applies to all personal information collected, held, used, and disclosed by Lumenara, including information from clients, employees, contractors, and other individuals, regardless of location.

3. Definitions

  • Personal Information: Information or an opinion about an identified individual, or an individual who is reasonably identifiable.
  • Sensitive Information: A subset of personal information, including health information, racial or ethnic origin, political opinions, religious beliefs, and more.
  • Processing: Any operation performed on personal data, such as collection, storage, use, disclosure, or destruction.

4. Collection of Personal Information

Lumenara collects personal information that is necessary for our functions and activities. We collect information by lawful and fair means, and where appropriate, directly from the individual.

5. Use and Disclosure

We use personal information for the primary purpose for which it was collected, and for related secondary purposes that an individual would reasonably expect. We do not disclose personal information to third parties without consent, unless required or authorised by law.

6. Data Quality

Lumenara takes reasonable steps to ensure that the personal information we collect, use, and disclose is accurate, complete, and up-to-date.

7. Data Security

We protect personal information from misuse, interference, loss, unauthorised access, modification, or disclosure through various security measures, including secure storage and restricted access.

8. Access and Correction

Individuals have the right to access their personal information held by Lumenara and to request corrections. Requests can be made by contacting us using the details provided below.

9. Cross-Border Disclosure

Before disclosing personal information overseas, Lumenara takes reasonable steps to ensure that the recipient does not breach applicable data protection laws in relation to the information.

10. Data Retention

We retain personal information only as long as necessary for the purposes outlined in this policy, unless a longer retention period is required or permitted by law. Upon request, we will delete or anonymise personal data, subject to legal obligations.

11. Data Protection by Design and Default

In accordance with GDPR Article 25, Lumenara implements appropriate technical and organisational measures to ensure that, by default, only personal data necessary for each specific purpose is processed.

12. Data Subject Rights

Under GDPR and CCPA, individuals have rights regarding their personal data, including:

  • Right to access personal data.
  • Right to rectification of inaccurate data.
  • Right to erasure ("right to be forgotten").
  • Right to restrict processing.
  • Right to data portability.
  • Right to object to processing.
  • Right not to be subject to automated decision-making.
  • Right to opt-out of the sale of personal information (CCPA).

To exercise these rights, please contact us using the details provided below.

13. Children's Privacy

Our services are not directed to individuals under the age of 16. We do not knowingly collect personal data from children without parental consent.

14. Complaints

If you believe that we have breached applicable data protection laws, you may lodge a complaint by contacting us. We will respond to complaints promptly and in accordance with our complaints handling procedures.

15. Contact Us

For any questions or concerns about this Data Protection Policy, please contact:
Email: privacy@lumenara.io
Address: 11 Wilson St, South Yarra, Melbourne, VIC, Australia