Privacy Policy

 This Privacy Policy has been updated on March 23, 2021.

We would like to introduce you to LUCIENT CORPORATE GROUP and inform you that we have transformed our former brand GRUPO SOLIDQ GLOBAL SA. This refinement of our image shows our dedication to the latest advances in information technology. We remain committed to always being an ethical company that contributes reliably and responsibly to the state of the art in information technology.

One of our fundamental pillars is about providing accurate and transparent information governance for our Clients, which allows us to build long-lasting relationships based on trust. Therefore, Personal Data Protection is of utmost importance to us.

This Privacy Policy will allow you to better understand the data protection principles that we apply at LUCIENT CORPORATE GROUP (hereinafter, 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 be shown on this page. We suggest that you refer to it regularly.

Please consider that when using the website https://lucient.com, you authorize LUCIENT to Gather, Record, Organise, Store, Use and/or Transfer your personal data in accordance with this Privacy Policy.

Equally, we remind you that every time you visit the website and 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, invoicing addresses, telephone number, type of device or debit or credit card number, etc. (hereinafter, “Personal Data”), whether it be to browse this website, acquire our services, training or functionalities, they will be subject to the application of this Privacy Policy along with the Terms of Use of the website and other referenced documents that are valid at any given time, and said texts must be reviewed to ensure that you are in agreement with them.

Within the context of distance training, certain personal information must be provided as it is necessary to process the training and prepare the invoice. This personal information is strictly confidential. Not providing this information would prevent the training from being successfully delivered.

This Privacy Policy, our Cookies Policy, and our Terms and Conditions may be modified at any time, with it being your responsibility to read them regularly as the conditions that are valid when visiting the website will be applicable. If you have subscribed to our NEWSLETTER, we will notify you about the modifications that we made to our Policies via email 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 an inherent part of everything that we do.
• We do not send marketing communications unless you request them.
• We are committed to keeping your data safe and protected.
• Our aim is to be transparent about how we use your data.
• We do not use your data in ways that we have not informed you about.
• We respect your rights and we always try to act on your requests as soon as possible and in accordance with our legal and operational responsibilities.
• To obtain further information about our privacy practices, we have set out which type of personal data we may gather or keep, how we use it, who we may share it with, how we protect it, and how you can exercise your rights regarding your data below.
• When you share your Personal Data with us or when we gather personal data about you, we use it in accordance with this Privacy Policy (hereinafter, the “Policy”). Please read this information carefully. If you have any questions or concerns about your personal data, please contact us at dpo at Lucient.com

I. Who are we?

LUCIENT is a global provider of services 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 specialist services.

When we say “LUCIENT”, “us” or “our”, we refer to LUCIENT as the data controller for the purposes of the applicable data protection laws.

II. Personal data

Personal Data makes reference to any information or data that could identify you directly (for example, your name or surname) or indirectly (for example, your ID document). The Personal Data includes information such as personal email/postal addresses or mobile numbers, usernames, profile images, personal preference and purchasing habits, the content generated by the user, financial information, and social assistance information, amongst others.

It could also include unique numerical identifiers such as the IP address on your computer or the MAC address on your mobile device, as well as the information that we obtain via Cookies.

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

III. Gathering personal data and processing purposes

Remember that before starting to use any of our services or functionalities, you must read this Policy, as well as the Terms and Conditions in the specific section concerning that service or functionality. In said section, you will be able to see if there are any particular usage conditions or if specific processing of your Personal Data is required. Not providing certain information marked as mandatory may mean that it is not possible to handle your user registration or the use of certain available functionalities or services via https://lucient.com.

The user (you) hereby guarantees that the Personal Data provided is correct and accurate and undertakes to notify of any changes or modifications to it. Any loss or damage caused to the Website, to the Data Controllers, or any other third party through the submission of erroneous, inaccurate, or incomplete information on the registration forms will be the user’s sole responsibility.

A. What data do we gather about you?

There are many ways in which you can share your personal data with us, and we could gather or receive your data via our websites, forms, or pages on our social media.

In some cases, you provide us with your Personal Data directly (for example, when you create an account, when you get in contact with us, when you make a purchase on our websites), in other cases we gather them ourselves (for example, using cookies to understand how you use our websites) or, on other occasions, we receive your data from other third parties, including other companies belonging to the LUCIENT Group.

We understand that “Personal Information” constitutes any information that may directly or indirectly identify you. We might ultimately gather the following personal information:

• Information about your identity and, particularly, name, surname, address, email address.
• Information about your payment method and, particularly, your credit card number and expiry date; payment data is fully safe thanks to an encryption procedure (SSL mode). Payment data is never saved, and it is passed on in a completely safe way to our PFS Web payment platform.
• Information about your commercial relationship and, particularly, your request via NEWSLETTERS, your preferences or interests, your activity on the website, or information about one of our services.
• Information about our services’ content.
• Information about your accounts on social media (usernames, captions, location, etc.), content, and post uploads (publications) when you share content or use hashtags.
• Technical information and, particularly, your IP address or information about how your device browses our website using Cookies (Cookies Policy).
• Other information that you provide when you get in contact with us or that we could obtain from external providers.

B. What purposes and legal basis can we use your Personal Data for?

The personal information that is gathered will be processed mainly in order to comply with the following purposes:

• Website administration and improvement to the quality of the service. This processing is necessary for the purposes of the legitimate interest mentioned previously.
• Processing its services (services, invoices, post-sales, etc.). This processing is necessary for the performance of the contract that you are party to.
• Client and/or user relationship management (CRM) and, particularly, to help us to get to know you better and to give you personalized offers for our products and services (specifically via email). To that effect, we may perform segmentation operations based on your preferences, interests, usage behavior, analyze your browser and requests on our website or perform any other action to improve our database.
• When applicable, preventing and detecting fraud, crime, and managing and tracking payment defaults or infractions observed during sales or disputes. This processing is necessary for the purposes of legitimate interest that were made reference to previously.
• Managing your request (claims, right to access, rectification, objection, and revocation, etc.). This processing is necessary to process your request and it carried out with your consent or it is necessary for the purposes of legitimate interest that were made reference to previously.
• In any other way that is admissible by the law and/or as we may notify you at any time.

IV. Who can access your personal data?

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

LUCIENT is an international corporate merger that operates in multiple countries. The personal information that we compile will be used by LUCIENT and it may be communicated to other companies within the LUCIENT Group if necessary, and more specifically, to our subsidiaries in Germany, Austria, Bosnia, Canada, Colombia, Costa Rica, Denmark, Slovakia, Slovenia, the United States (USA), Italy, Mexico, Norway, Panama, the United Kingdom (UK), Serbia, Sweden, and Switzerland.

Equally, we ensure that all the subsidiaries of the LUCIENT Group are compliant with the GDPR and follow our GROUP BCRs as well as internal legislative regulations in each of the countries where we are present; we are also concerned for the security of the information and we apply the most protective regulations including the California Consumer Privacy Act (CCPA).

The data may be sent to service providers chosen due to their experience and reliability acting in our name and under our orders (processing and secure payment, service management, maintenance operations, and technical development, managing the opinions/scores of our products and services, content personalization, etc.).

We authorize these service providers to use your personal information to the extent it is necessary to provide the services in our name or to comply with legal requirements and we strive to ensure that your personal information is always protected.

These third-party companies could be located inside or outside of the European Economic Area (EEA), including in countries that do not offer the same level of protection as your home country. In that case, and to the extent required by the applicable law, we ensure that we either:

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

Lastly, we may send your personal information to the local authorities if required to do so by law as part of an investigation and in accordance with the applicable legislation.

V. How long do we keep your personal data?

We only keep your Personal Data for the time necessary to fulfill the purpose we are processing your Personal Data for, to satisfy your needs, or to fulfill our legal obligations.

To determine the data retention period of the 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 query; Personal Data for the time needed to attend to your query.
• Personal Data obtained when providing your consent to receive commercial communications: until your subscription is canceled, you demand that we delete it or after a period of inactivity (without active interaction with the brands) of three years.
• Cookies are installed on your computer. We keep them for the time necessary to achieve their purposes (for example, during a session for session identification cookies) and for a maximum of 365 days.
• We may retain some personal data in order to fulfill our legal or regulatory obligations, as well as to govern our rights (for example, to assert our claims before the courts) or for historical or statistical purposes.
• When we no longer need to use your personal data, it will be removed from our systems, not being able to identify you via any retained data.

VI. LUCIENT’s Information Security Policy (ISMS- ISO27001)

At LUCIENT we implement suitable technical and organizational measures regarding the nature of the data and the risks that processing it involves in order to preserve the security, confidentiality, integrity, authenticity, and availability of your personal information and, particularly, to prevent it from being altered, damaged or passed on to unauthorized third parties.

We work under an Information Security Management System whose scope not only affects the use of assets but is also extended to all the people and third parties in the knowledge and fulfillment of these structured guidelines in accordance with the ISO/IEC 27001:2013 standards. Both the Policy and the Information Security Guidelines are in line with GDPR 2016/679 on Personal Data Protection and the current legislation ensuring compliance with it.

These security guidelines regulate the following areas of the organization:

• Access to the facilities Where the access rules are governed with a special emphasis on access to secure areas and access regulation for people from outside of the organization.
• Access to the corporate network The corporate resources are protected with all necessary technical security measures to ensure that the information is protected, whether it be at the facilities or externally. Access to and use of the information is governed by legislation that focuses on protection with special attention given to sensitive or confidential information.
• Use of assets LUCIENT’s personnel undertakes to protect and maintain the systems provided by the organization in order to perform their duties and tasks and to use them appropriately. In this sense there are policies of action and configurations are applied that are aimed at protecting the information contained on those devices.
• Use of the internet Special attention is paid to the regulation of the use of the internet, email, and cloud storage for professional uses with the aim of minimizing the risks that could be caused by the unregulated use of said tools.
• Incident management The involvement of LUCIENT’s personnel in security matters helps to detect any potential problems that could endanger the confidentiality, integrity, and availability of the services or assets that they sustain.
• Business continuity All the measures implemented for the availability and continuity of the business online with the requirements of the ISO certified standards in the organization.

Any premeditated or negligent breach of the security policies and standards that may involve potential damage, whether it be carried out by LUCIENT or not, will be sanctioned in accordance with the mechanisms established in the collective agreement and the current corporate, legal, and contractual legislation.

VII. Your rights and options

At LUCIENT we respect your right to privacy. It is important that you are in control of your personal data. In this sense, you have the following rights:

1. Right of Information. You have the right to obtain clear, transparent, and understandable information about the way in which we use your personal data and about your rights. We provide said information in this Policy.
2. Right of access. You have the right to access your personal data kept by us (with certain limits). We will be able to charge a reasonable sum to cover the administrative costs incurred by providing the information. Clearly baseless, excessive, or repetitive requests may not be dealt with. To exercise this right, get in contact with us using any of the means stated below.
3. Right to rectification. You have the right to rectify your personal data when it is inaccurate or no longer valid or have it completed when it is incomplete. To exercise this right, get in contact with us using any of the means stated below. If you have an account, it may be easier if you correct it yourself by modifying your user information.
4. Right to erasure/right to be forgotten. In some cases, you have the right to have your data deleted or erased. It must be highlighted that this is not an absolute right given that we may have legal or legitimate reasons to keep it. If you wish to have your personal data erased, get in contact with us using any of the means stated below.
5. Right to withdraw consent at any time when the data processing is based on consent. You can withdraw your consent to the processing of your personal data when the processing is based on your consent. The withdrawal of consent will not affect the legality of the processing based on the consent prior to its withdrawal. For further information regarding the cases in which processing is based on consent, please see the section “What data do we gather about you?”, and particularly “What are the purpose and legal basis for processing your Personal Data?”.If you wish to withdraw your consent, get in contact with us using any of the means stated below.
6. Right to object to processing based on the satisfaction of legitimate interests. You can object to your data being processed at any time when the processing is based on the satisfaction of legitimate interests. For further information regarding the cases in which processing is based on legitimate interests, please see the section “What data do we gather about you?”, and particularly “What are the purpose and legal basis for processing your Personal Data?”.If you wish to exercise this right, get in contact with us using any of the means stated below.
7. Right to submit a claim before a supervisory authority. You have the right to make a claim before the Spanish Data Protection Agency regarding LUCIENT’s privacy and data protection practices. Do not hesitate to get in contact with us using any of the means stated below before submitting a claim to the competent data protection authority.
8. Right to data transfer.
   1. You have the right to move, copy or transfer data from our database to another one. This right may only be exercised regarding data that you have provided when the processing is based on the performance of a contract or on your consent and the processing is done automatically. For further information regarding the cases in which processing is based on a contract or on consent, please see the section “What data do we gather about you?”, and particularly “What are the purpose and legal basis for processing your Personal Data?”.For further information, get in contact with us using any of the means stated below.
      • where the interested party contests the accuracy of the personal data during the term allocated for the controller to verify its accuracy.
      • where the processing is illegal and the interested party objects to the erasure of the personal data and requests it is limited instead.
      • where the controller no longer requires the personal data for processing purposes, but the interested party requires it to formulate, pursue or defend claims.
      • where the interested party has objected to the processing by virtue of Article 21, section 1, whilst is it verified whether the controller’s legitimate reasons prevail over those of the interested party.

   If you wish to exercise this right, get in contact with us using any of the means stated below.

9. Right to deactivate Cookies. You have the right to deactivate Cookies. Internet browser settings are usually programmed to accept Cookies by defect, but they can be easily deactivated by changing the browser settings. Many cookies are used to improve website usability or functionality; therefore, deactivating them may prevent you from using certain sections of our websites as stated in the Cookies Policy. If you wish to limit or block all the Cookies established by our websites (which could prevent you from using certain sections of the websites) or any other websites, you can do so via your browser settings.

VIII. GDPR Consent – Marketing Communications

• Marketing emails (Newsletters). Should you subscribe to our email marketing communications, you will receive Lucient’s latest news, training courses, events, webinars, and special offers, along with useful content and tools to boost your industry knowledge and professional skills.  You are able to customize/update your profile/preferences at any time to receive only relevant information as you see fit.
• Transactional emails. If you registered for an event (online or offline) or class or requested information about our services, you are giving us consent to send you direct emails regarding what you registered for or enquired about. By no means will we send you any marketing communications unless you specifically subscribe to them. Please be advised that should you withdraw your consent to receive direct emails, you also agree to stop receiving transactional emails from Lucient. However, this may entail that you could miss important information, such as URLs for our events or relevant information related to our training offerings. 
• Direct mail (postal). Should you subscribe to our direct mail communications, you will receive Lucient’s postcards, along with special occasion letters that may be of your interest. 
• Phone . We will only use your phone number to contact you in the following cases: 
  • To inform you about changes on the event/training for which you have registered 
  • To inform you about an inquiry you made on our website (or similar)
  • If you have previously indicated that you would like to be kept informed, we will call to let you know about upcoming events or offers you expressed interest in.  

       YOU MAY WITHDRAW OR MODIFY YOUR CONSENT TO ANY OF THESE AT ANY POINT. 

We point out that according to Art 6 GDPR in some cases, data processing is possible without explicit consent. http://www.privacy-regulation.eu/en/article-6-lawfulness-of-processing-GDPR.htm

“1. Processing shall be lawful only if and to the extent that at least one of the following applies…”

1. f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.”

Recital 47: http://www.privacy-regulation.eu/en/r47.htm
“(47) The legitimate interests of a controller, including those of a controller to which the personal data may be disclosed, or of a third party, may provide a legal basis for processing, provided that the interests or the fundamental rights and freedoms of the data subject are not overriding, taking into consideration the reasonable expectations of data subjects based on their relationship with the controller.

Such legitimate interest could exist for example where there is a relevant and appropriate relationship between the data subject and the controller in situations such as where the data subject is a client or in the service of the controller.

At any rate, the existence of a legitimate interest would need careful assessment including whether a data subject can reasonably expect at the time and in the context of the collection of the personal data that processing for that purpose may take place.

The interests and fundamental rights of the data subject could in particular override the interest of the data controller where personal data are processed in circumstances where data subjects do not reasonably expect further processing.

Given that it is for the legislator to provide by law for the legal basis for public authorities to process personal data, that legal basis should not apply to the processing by public authorities in the performance of their tasks.

The processing of personal data strictly necessary for the purposes of preventing fraud also constitutes a legitimate interest of the data controller concerned.

The processing of personal data for direct marketing purposes may be regarded as carried out for a legitimate interest.”

IX. CONTACT

If you have any doubts or concerns regarding the way in which we process and/or use your personal data or would like to exercise any of the aforementioned rights, get in contact with LUCIENT or right to us at the following address dpo at lucient.com directly contacting our Data Protection Officer and we will resolve any doubts or incidents concerning the protection of your personal data.