Privacy Policy

 This Privacy Policy has been updated on December 17, 2020.

We welcome you to LUCIENT DATA SA, by informing you that we have transformed our old brand from the SOLIDQ GLOBAL SA and international regions owned by the brand, renewing our image to adapt it to the latest vanguard; always with the inspiration of being a virtuous company that contributes to Information Technology.

One of our fundamental pillars is truthful and transparent information to our Customers, building long-lasting relationships based on trust, which is why Personal Data Protection is of the utmost importance to us.

Lucient Data SA and its international offices will relate in this document as LUCIENT.

This Privacy Policy will allow you to better understand the data protection principles we apply at LUCIENT. We invite you to read it before providing your personal data.

This Privacy Policy may be updated by LUCIENT at any time. The date of the latest version will appear on this page, we suggest you refer to it regularly.

Please note that by using the https://lucient.com website, you authorize LUCIENT to Collect, Register, Organize, Store, Use and/or Transfer your personal data in accordance with this Privacy Policy

Likewise, we remind you that every time you use the Web, you provide us with, or it is necessary for us to access, any type of information that, due to its characteristics, allows us to identify you, such as your name and surname, e-mail address, billing address, telephone number, type of device or credit or debit card number, etc. (hereinafter, “Personal Data”), whether for browsing the same website, acquiring our services, training or functionalities, will be under the application of this Privacy Policy, together with the Terms of Use of the Website, and other referenced documents in force at any given time, and you should review these texts to verify that you agree with them.

In the field of distance training, it is mandatory to provide certain personal information, as this is necessary both to process the training and to prepare the invoicing, such personal information is strictly confidential; not providing such information would imply not being able to materialize the management of the training.

This Privacy Policy, our Cookie Policy and our Terms and Conditions may be modified at any time, and it is your responsibility to read them periodically, as those in force at the time of use of the Website will apply. If you have registered in our NEWSLETTER, we will notify you of the changes we make to our policies by e-mail, and it is your responsibility to read them.

OUR COMMITMENT TO PRIVACY

• We respect your privacy and your choices,
• We ensure that privacy and security are built into everything we do.
• We do not send you marketing communications unless you ask us to.
• We are committed to keeping your data safe and secure.
• Our goal is to be transparent about how we use your data
• We do not use your data in ways that we have not informed you of.
• We respect your rights and always try to act on your requests as soon as possible, in accordance with our legal and operational responsibilities.
• To learn more about our privacy practices, we set forth below what types of personal data we may collect or maintain, how we may use it, with whom we may share it, how we protect it, and how you can exercise your rights with respect to your data.
• When you share your Personal Data with us or when we collect personal data from you, we use it in accordance with this Privacy Policy (“Policy”). Please read this information carefully. If you have any questions or concerns about your Personal Information, please contact us dpo at lucient.com

1. Who are we?

LUCIENT, is a global service provider aimed at optimizing the management of business data. Its solutions are based on Microsoft’s Data Platform (SQL Server, Business Intelligence & Analytics, Azure, Power Platform, HDInsight, Machine Learning, …), as well as specialized services.

When we say “LUCIENT”, “we” or “our”, we mean LUCIENT DATA SA is the data controller for the purposes of the applicable data protection laws.

1. PERSONAL DATA

Personal Data refers to any information or data that may identify you directly (e.g. your name or surname) or indirectly (e.g. your national identity card or ID card). Personal Data includes information such as e-mail / home / mobile phone addresses, user names, profile pictures, personal preferences and purchasing habits, user-generated content, financial information and social assistance information, among others.

It may also include unique numeric identifiers such as your computer’s IP address or the address of your mobile device, as well as information we obtain through cookies.

This Policy covers all personal data collected and used by LUCIENT.

• COLLECTION OF PERSONAL DATA AND PURPOSES OF PROCESSING

Please remember that before you begin using any of our services or features, you should read this Policy, as well as the Terms and Conditions of the specific section to be viewed on that service or feature. In that section you will be able to see if there are any particular conditions for its use, or if a specific treatment of your Personal Data is required. Failure to provide certain information marked as mandatory may mean that it is not possible to manage your registration as a user or the use of certain functionalities or services available through  https://lucient.com

The user (you) hereby guarantees that the Personal Data provided are true and accurate and undertakes to notify any changes or modifications thereto. Any loss or damage caused to the Website, to the Persons Responsible for Processing or to any third party through the communication of erroneous, inaccurate or incomplete information in the registration forms shall be the sole responsibility of the user.

1. What data do we collect from you?

Because there are many ways in which you can share your personal data with us, and we may collect it, or receive your data through our websites, forms, or social networking pages.

In some cases, you provide us with your Personal Data directly (for example, when you create an account, when you contact us, when you buy from our websites), in other cases we collect it ourselves (for example, by using cookies to understand how you use our websites) or, on other occasions, we receive your data from other third parties, including other entities of the LUCIENT.

We understand that “Personal Information” is any information that can identify you, directly or indirectly. We may collect primarily the following personal information:

• Information on your identity, and in particular your name, surname, address and e-mail address
• Information on your method of payment, and in particular your credit card number and expiry date; data relating to payment are absolutely secure thanks to an encryption procedure (SSL mode). The payment data is never saved and is transmitted absolutely securely to our PFS Web payment platform.
• Information about your business relationship and, in particular, your request through the NEWSLETTERS, your preferences and interests, your activity on the website or information about one of our services;
• Information on contents;
• Information about your social network accounts (username, legend, location, etc.), content uploads and posts (publications) when you share content or use hashtags;
• Technical information and in particular your IP address or information on how your device navigates our website, by means of Cookies (Cookie Policy)
• Other information that you provide when you contact us or that we may obtain from external suppliers

1. For what purposes and on what legal basis can we use your Personal Data?

The personal information collected will be processed for the following purposes in particular:

• Web site management and service quality improvement. This processing is necessary for the purposes of the above-mentioned legitimate interest;
• Processing of your services (services, invoices, after-sales service, etc.). This treatment is necessary for the execution of the contract to which you are a party;
• Customer and/or user relationship management (CRM) and, in particular, to help us get to know you better and to provide you with personalized offers on our products and services (in particular, by e-mail). To this end, we may carry out segmentation operations based on your preferences, interests, usage behavior, analyze your browser and requests on our website or take any other action to better qualify our database.
• Where appropriate, prevention and detection of fraud, delinquency and management and follow-up of non-payment or infringements found at the time of sale or of litigation. This processing is necessary for the purposes of the legitimate interest referred to above;
• Manage your request (complaints, right of access, rectification, opposition and cancellation, etc.) This processing is necessary to process your request and is carried out with your consent or is necessary for the purposes of legitimate interest referred to above;
• As otherwise permitted by law and/or as we may notify you at any time.

1. WHO CAN ACCESS YOUR PERSONAL DATA?

We never sell or lease your personal information to other companies for marketing purposes.

LUCIENT is an international corporate union operating in many countries. The personal information we collect will be used by LUCIENT and may be communicated to other companies in the LUCIENT, if necessary and in particular to our subsidiaries in Austria, Bosnia, Canada, Colombia, Costa Rica, Denmark, Germany, Italy, Mexico, Norway, Panama, Serbia, Slovakia, Slovenia, Sweden, Switzerland, the United Kingdom and the United States.

They may be passed on to service providers chosen for their experience and reliability and who act on our behalf and under our orders (secure processing and payment, service management, maintenance operations and technical development, management of opinions/scores of our products and services, content customization, etc.).

We authorize these service providers to use your personal information only as necessary to provide the services on our behalf or to comply with legal requirements and we strive to ensure that your personal information is always protected.

These third companies may be located inside or outside the European Economic Area (EEA), even in countries that do not offer the same level of data protection as in their country of residence. In that case, and to the extent required by applicable law, we will ensure:

• Obtain your express and unambiguous consent to share your personal information with these third companies.
• Sign appropriate data transfer contracts in accordance with the Standard Model Clauses established by the European Commission,
• Comply with the Binding Corporate Rules (BCR) approved by the competent authorities;
• Ensure that such third-party companies comply with the Privacy Protection Framework between US Privacy Shield and the EU and are registered as such with the US administration and comply with the Privacy Protection Principles relating to the collection, use and storage of personal information transferred from the European Union to the United States.

Finally, we may transfer your personal information to local authorities if required by law or as part of an investigation and in accordance with applicable regulations.

1. HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We only keep your Personal Data for as long as we need it for the purpose for which we process your Personal Data, to meet your needs or to comply with our legal obligations.

To determine the data retention period of your Personal Data, we use the following criteria:

• Personal Data obtained when purchasing services: for the duration of our contractual relationship;
• Personal Data obtained when contacting us for a consultation: Personal Data during the time necessary to attend your consultation;
• Personal Data obtained when you give your consent to send commercial communications: until you cancel your subscription, require us to delete it or after a period of inactivity (no active interaction with the brands) of three years;
• Cookies that are installed on your computer: we store them for as long as necessary to achieve your purposes (for example, during a session for session ID cookies) and for a maximum of 365 days.
• We may retain some personal data to fulfil our legal or regulatory obligations, to administer our rights (e.g. to enforce our claims in court) or for statistical or historical purposes.
• When we no longer need to use your personal data, it will be deleted from our systems and records or made anonymous so that we can no longer identify it.

1. HOW DO WE PROTECT YOUR PERSONAL DATA (ISO)?

At LUCIENT we implement appropriate technical and organizational measures, in relation to the nature of the data and the risks involved in its processing, to preserve the security, confidentiality, integrity, authenticity and availability of your personal information and, in particular, to prevent it from being altered, damaged or transmitted to unauthorized third parties,

We work under an Information Security Management System, whose scope not only affects the use of assets, but extends to all persons and third parties in the knowledge and compliance with these Guidelines structured according to ISO/IEC 27001:2013 standards. Both the Policy and the Guidelines on Information Security are in line with the GDPR 2016/679 on Personal Data Protection and current regulations, which ensure compliance.

This security regulation affects the following areas of the organization:

• Access to the facilities. In which access rules are regulated, with special mention of access to secure areas and regulation of access by persons outside the organization.
• Access to the corporate network. Corporate resources are protected with the necessary technical security means to ensure the protection of information, either from the premises or externally. Access to and use of information is regulated by rules focused on protection with special attention to sensitive or confidential information.
• Use of assets. The people at LUCIENT are committed to making rational use and ensuring the care of the equipment provided by the organization for the performance of their functions and tasks. To this end, rules of conduct are described and configurations are applied to protect the information contained in these devices.
• Use of the Internet. Special attention is paid to regulating the use of the Internet, e-mail and cloud storage for professional purposes in order to minimize the risks that may arise from the unregulated use of these tools.
• Incident management. The involvement of LUCIENT people in security matters helps to detect possible problems that may jeopardize the confidentiality, integrity and availability of the services or assets they support.
• Business continuity. All the means implemented for the availability and continuity of the business in line with the requirements of the ISO schemes certified in the organization.

Any premeditated or negligent violation of the security policies and regulations and which involves potential damage, consummated or not to LUCIENT, will be sanctioned according to the mechanisms enabled in the Company agreement and in the legal, contractual and corporate regulations in force.

• YOUR RIGHTS AND OPTIONS

At LUCIENT we respect your right to privacy: it is important that you have control over your personal data. In this respect, you have the following rights:

1. Right of Information.  You have the right to clear, transparent and easily understandable information about how we use your personal data and about your rights. We provide you with such information in this Policy. In order to process your application, we may ask you to provide proof of your identity, by means of a documentation
2. Right of access. You have the right to access your personal data that we hold (with certain limits). We may charge a reasonable fee to cover our administrative costs in providing the information. Manifestly unfounded, excessive or repetitive requests may not be granted. To exercise this right, please contact us by any of the means indicated below.
3. Right of rectification. You have the right to have your personal data corrected when it is inaccurate or no longer valid or to have it completed when it is incomplete. To exercise this right, please contact us by any of the means indicated below. If you have an account, it may be easier for you to correct them yourself by modifying your user.
4. Right of withdrawal/right to forget. In certain cases, you have the right to have your personal data deleted or erased. It should be noted that this is not an absolute right, as we may have legal or legitimate reasons for keeping it. If you wish us to delete your personal data, please contact us by any of the means indicated below.
5. Right to withdraw consent at any time when data processing is based on consent. You can withdraw your consent to the processing of your personal data, when this is based on data you previously consented to share with us. Withdrawal of consent shall not affect the lawfulness of processing based on consent prior to its withdrawal. To find out about cases in which processing is based on consent, we refer you to the section “What data of yours do we collect”, in particular “What is the purpose and legal basis for processing your Personal Data”. If you wish to withdraw your consent, please contact us by any of the means indicated below.
6. Right to object to processing based on the satisfaction of legitimate interests. You may object at any time to our processing your data when the processing is based on the satisfaction of legitimate interests. To inform you of the cases in which the processing is based on legitimate interests, we refer you to the section “What data of yours do we collect”, in particular “What is the purpose and legal basis for processing your  Personal Data”.
7. Right to lodge a complaint with a supervisory authority. You have the right to complain to the Spanish Data Protection Agency about LUCIENT’s privacy and data protection practices. Please do not hesitate to contact us by any of the means listed below before filing a complaint with the competent data protection authority. If you wish to exercise this right, please contact us by any of the means indicated below.
8. Right to data portability. You have the right to move, copy or transfer data from our database to a different one. It is only possible to exercise this right with respect to data you have provided, where the processing is based on the execution of a contract or on your consent and the processing is carried out by automated means. To inform you of the cases in which the processing is based on contract or consent, we refer you to the section “What data of yours do we collect”, in particular “What is the purpose and legal basis for processing your Personal Data”. For more information, please contact us by any of the means listed below.
9. Right to limit processing. You have the right to request a limitation on the processing of your data. If you exercise this right, the processing of your data will be subject to limitations, so we may store it, but we may not continue to use or process it. This right may only be exercised in certain circumstances defined by the General Data Protection Regulations, as follows:
   • that the person concerned contests the accuracy of the personal data, for as long as it allows the person responsible to verify the accuracy of the data;
   • that the processing is unlawful and the data subject opposes the deletion of the personal data and requests instead the limitation of their use;
   • that the controller no longer needs the personal data for the purposes of the processing, but that the data subject needs them for the formulation, exercise or defence of complaints;
   • that the data subject has opposed the processing by virtue of Article 21(1), while verifying whether the legitimate interests of the controller prevail over those of the data subject.

   If you wish to exercise this right, please contact us by any of the means indicated below.

10. Right to deactivate Cookies. You have the right to disable Cookies. The settings of Internet browsers are usually set by default to accept Cookies, but they can easily be disabled by changing the browser settings. Many cookies are used to improve the usability or functionality of the websites; therefore, their deactivation may prevent you from using certain parts of our websites as indicated in the Cookie Policy. If you wish to limit or block all cookies set by our websites (which may prevent you from using certain parts of the website) or by any other websites, you will be explicitly able to select which cookies you allow us to use when you visit the website for the first time.

• CONTACT

If you have any questions or concerns about the way we treat and/or use your personal data or wish to exercise any of your rights as described above, please contact LUCIENT or write to us at the following address dpo at lucient.com contacting our Data Protection Officer directly, so that we can resolve your doubts or incidents regarding the protection of your personal data.