LuminEdge Advisory Private Limited (“LuminEdge“, “we”, “us”, “our”) recognizes that your privacy is important to you and takes it seriously. This Privacy Notice explains how we collect, use, share and protect your personal data, that is, any information from which you can be identified.

This Notice applies to https://luminedgeadvisory.com/ and any other websites produced and managed by LuminEdge that link to it (the “Sites“). LuminEdge acts as data fiduciary (data controller) for the personal data you share with us through the Sites.

LuminEdge may update this Notice from time to time at its sole discretion. Please review the current version each time you visit the Sites.

1. INFORMATION WE COLLECT

We collect personal data when you request information from us or provide information through the Sites, for example when you:

• fill out a subscription form or a consulting or expertise enquiry;
• opt in to receive emails from us;
• agree to participate in surveys; or
• apply for a role at LuminEdge.

This may include your name, email address, contact details, title, occupation, company or university affiliation, industry, region or country, relationship to LuminEdge, reason for contacting us, topics of interest, background information provided with a job application, and any other information you choose to share. We may also collect information about how you use the Sites through cookies, as described in Section 4.

2. HOW WE USE YOUR INFORMATION

We use your personal data to:

• respond to your request and provide the information you have asked for;
• send you marketing communications, publications and information about events that may interest you;
• evaluate and process job applications (see Section 7); and
• analyze and improve our Sites, services, and recruitment and onboarding processes.

By browsing the Sites and submitting information to us, you consent to LuminEdge processing your personal data for these purposes and in the manner described in this Notice. Please do not send us any information you do not wish us to use. Where stated in this Notice, we may also rely on other legal grounds, such as legitimate uses permitted under applicable law.

We may share personal data with third-party service providers in aggregated form for marketing and promotional purposes. In such cases, we do not disclose any information that could personally identify you.

3. RETENTION

We keep your personal data for as long as needed to handle your request or for as long as we have a relationship with you. Personal data associated with a job application is kept for up to five years. Data of SaaS tool users is retained as set out in Section 8.

4. COOKIES AND DO NOT TRACK

We use cookies and similar technologies (“cookies“), which may collect personal data, to obtain certain information when you browse the Sites. Details of the data collected, how it is used and how to manage your cookie settings are set out in our Cookie Policy.

The Sites may track visitor behaviour in order to show advertising, products or services relevant to you. Some browsers offer a “Do Not Track” feature that signals to websites that you do not wish your browsing to be tracked. We are not currently able to respond to “Do Not Track” signals.

The Sites include Google Maps features and content, the use of which is subject to Google’s current Privacy Policy.

5. WHO WE SHARE YOUR PERSONAL DATA WITH

LuminEdge does not sell your personal data or share it with any third party for its own use. We may share your personal data with:

• our group companies and affiliates;
• carefully selected service providers who provide services to us, such as marketing service providers (if you have subscribed to our communications), IT system providers, background check providers, data cleansing providers and event organisers;
• recruitment service providers, including providers of AI-driven assessments;
• our professional advisors; and
• law enforcement authorities or other government bodies, where we are required to do so by law.

Third parties other than law enforcement and government bodies will process your personal data only on behalf of LuminEdge, in accordance with our instructions and for the purposes described in this Notice. They are bound by contractual obligations, including data protection and security standards, that are at least as protective as those in this Notice and consistent with applicable data protection laws.

6. PUBLIC FORUMS AND THIRD-PARTY WEBSITES

LuminEdge is not responsible for information you disclose publicly in chat rooms, message boards or similar forums on or linked to the Sites. Such information may be collected and used by people you do not know, and some forums may display your IP address alongside your name and message. LuminEdge bears no responsibility for the actions or policies of any third party who collects information disclosed in this way.

The Sites may contain links to third-party websites, including social networks, which are governed by their own terms of use and privacy policies. Please review these before browsing or submitting information to them. A link does not mean that LuminEdge endorses such a website, and LuminEdge accepts no liability for its content, its privacy practices or your use of it.

7. JOB APPLICANTS

If you apply for a job at LuminEdge, we will ask you to provide information such as your name, contact details, education and work history, and any other background information relevant to your application or that you choose to share. We may also process information gathered during interviews, other interactions with you and assessments. If you do not provide this information, we may be unable to process your application.

We use this information to assess your candidacy, including evaluating your skills and experience against the requirements of the role and tracking feedback and interactions throughout the recruitment process. We may also use it to improve our recruitment processes, including identifying which recruitment sources to focus on, improving integration and training programmes for new hires, and enhancing our interview model and assessments. We may also contact you about LuminEdge events and send you publications that may interest you.

We process applicant data on the following legal grounds:

• Legitimate uses: assessing your application, managing our relationship with you and improving our recruitment processes, where not overridden by your rights;
• Contractual necessity: taking steps before entering into an employment contract with you;
• Legal obligation: for example, verifying your right to work; and
• Consent: for optional recruitment activities, or where the law requires explicit consent, particularly for sensitive data or automated decision-making.

Automated tools and decisions. We may use automated tools, including assessment platforms and tools using artificial intelligence (“AI“), to evaluate aspects of your application, such as cognitive and skill-based assessments. Given the high volume of applications, for certain consulting roles we may also use internally developed algorithms that apply predefined criteria (such as education, qualifications, skills, experience and assessment results) to decide whether your candidacy should progress. In some cases, an application that does not meet these criteria may be rejected automatically without human review. Where this occurs, you may request meaningful information about the logic involved, ask for human intervention, express your point of view and contest the decision.

Applicant data processed through these tools is stored and processed securely and in compliance with applicable data protection laws. We may share applicant data with recruitment service providers (including AI and other assessment platforms), background check providers and IT system providers. Application data is retained for up to five years.

8. USE OF SAAS TOOLS

We provide cloud-based Software-as-a-Service (“SaaS“) tools to our clients, who may upload or store personal data in them. We process such data on behalf of our clients, as a data processor, in accordance with their instructions and applicable data protection laws. This processing is governed by the data processing terms agreed between LuminEdge and the relevant client, not by this Notice.

Where our clients’ employees access our SaaS tools directly, we may also collect user data such as login details, IP addresses and system activity, to ensure proper functioning, improve service quality and maintain security. LuminEdge acts as data fiduciary (data controller) for this data and processes it on the following legal grounds:

• Contractual necessity: where processing is required to provide and deliver SaaS functionality to our clients; and
• Legitimate uses: to maintain, secure and improve our SaaS services and the user experience.

All personal data processed through our SaaS tools is protected by industry-standard security measures, including encryption in transit and at rest. Any transfer to third-party service providers is subject to contractual obligations ensuring compliance with applicable data protection laws. We retain SaaS user data only for as long as necessary to provide the services; on termination of the service, it is securely deleted or anonymized.

9. SECURITY OF YOUR PERSONAL DATA

LuminEdge has implemented appropriate technical and organizational security measures to protect your personal data against loss, misuse, alteration or destruction, including anonymizing or pseudonymizing data where possible. Our personnel and the third parties described above have access to your personal data only to the extent required for their role or services. Despite these precautions, LuminEdge cannot guarantee that unauthorized persons will never gain access to your information.

10. YOUR RIGHTS

Subject to applicable law, including the Digital Personal Data Protection Act, 2023, you may have the right to:

• access your personal data, obtain a copy of it and information about how we use it;
• request correction of inaccurate, incomplete or out-of-date data;
• request erasure of your personal data;
• object to, or ask us to restrict or stop, processing of your personal data;
• withdraw your consent at any time, without affecting processing carried out before withdrawal; and
• nominate another person to exercise your rights in the event of your death or incapacity.

To exercise any of these rights, contact us using the details in Section 12. You can unsubscribe from marketing communications at any time through the “preferences” link in any marketing email from LuminEdge, or by contacting us. We will take reasonable steps to verify your identity before acting on a request.

If you believe we are handling your personal data unlawfully, please contact us first. You may also have the right to lodge a complaint with the Data Protection Board of India or the supervisory authority in your country.

11. CHILDREN

The Sites are not directed at persons under the age of 18. LuminEdge does not knowingly collect personal data of anyone under 18 and requests that no such information be submitted to us.

12. CONTACT US

If you have any questions about this Notice, wish to exercise your rights or have a complaint about how LuminEdge handles your personal data, please contact our Grievance Officer at info@luminedgeadvisory.com