Effective Date: January 6, 2025 | Version: 2.0
1. Definitions and Interpretation
In this Privacy Policy, unless the context otherwise requires:
- "Company," "we," "us," or "our" refers to Luminary Technologies Pty Ltd (ABN: [Company ABN]), a company incorporated in Australia.
- "Personal Information" means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
- "Services" refers to all technology solutions, visualisation services, software development, consulting, and related services provided by the Company.
- "Website" refers to luminarytech.com.au and all associated subdomains and pages.
- "User," "you," or "your" refers to any individual who accesses our Website or engages our Services.
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"Processing" means any operation performed on personal information, including collection, recording, organisation, storage, adaptation, alteration, retrieval,
consultation, use, disclosure, dissemination, or destruction.
3. How We Collect Information
3.1 Direct Collection
We collect information directly from you when you:
- Complete forms on our Website (contact forms, inquiry forms, newsletter subscriptions)
- Engage our services through formal agreements or contracts
- Communicate with us via email, phone, or other channels
- Attend meetings, consultations, or project discussions
- Participate in surveys, feedback sessions, or market research
- Register for events, webinars, or training sessions
- Submit project materials, specifications, or requirements
3.2 Automatic Collection
We automatically collect certain information through:
- Website analytics tools and tracking technologies
- Cookies and similar tracking mechanisms
- Server logs and access records
- Email tracking and engagement metrics
- Social media interactions and referrals
3.3 Third-Party Sources
We may collect information from legitimate third-party sources including:
- Professional networking platforms (LinkedIn, industry directories)
- Business partners and referral sources
- Public business registries and databases
- Industry publications and professional associations
- Marketing and lead generation services (with appropriate consent)
5. Legal Basis for Processing
We process your personal information based on the following legal grounds:
5.1 Contractual Necessity
Processing necessary for the performance of contracts for our services, including pre-contractual measures and project delivery.
5.2 Legitimate Interests
Processing necessary for our legitimate business interests, including:
- Business development and client relationship management
- Security monitoring and fraud prevention
- Internal administration and operational efficiency
- Professional networking and industry engagement
5.3 Legal Compliance
Processing necessary to comply with legal obligations, including tax requirements, regulatory compliance, and court orders.
5.4 Consent
Processing based on your explicit consent, particularly for marketing communications and optional services.
5.5 Vital Interests
Processing necessary to protect vital interests, including emergency situations and safety concerns.
7. Data Security and Protection
7.1 Security Framework
We implement comprehensive security measures aligned with industry best practices and standards, including:
- ISO 27001 Information Security Management: Our security practices are designed to meet international standards for information security management systems.
- Multi-layered Security Architecture: Defense-in-depth approach with multiple security controls and monitoring systems.
- Regular Security Assessments: Ongoing vulnerability assessments, penetration testing, and security audits.
- Incident Response Procedures: Comprehensive incident response and business continuity plans.
7.2 Technical Safeguards
- Advanced encryption for data in transit and at rest (AES-256, TLS 1.3)
- Secure cloud infrastructure with enterprise-grade security controls
- Multi-factor authentication and access control systems
- Regular security updates and patch management
- Network segmentation and firewall protection
- Intrusion detection and prevention systems
- Secure backup and disaster recovery procedures
7.3 Administrative Safeguards
- Comprehensive staff security training and awareness programs
- Background checks and security clearances for personnel
- Strict access controls and need-to-know principles
- Regular security policy reviews and updates
- Vendor security assessments and due diligence
- Confidentiality agreements and non-disclosure obligations
7.4 Physical Safeguards
- Secure office facilities with access controls and monitoring
- Locked storage for physical documents and media
- Secure disposal procedures for sensitive materials
- Environmental controls and monitoring systems
8. Data Retention
8.1 Retention Principles
We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, and protect our legitimate interests.
8.2 Retention Periods
- Client Project Data: 7 years after project completion or contract termination
- Financial and Tax Records: 7 years as required by Australian tax law
- Marketing Communications: Until consent is withdrawn or 3 years of inactivity
- Website Analytics: 26 months from collection date
- Employment Records: 7 years after employment termination
- Legal and Compliance Records: As required by applicable laws and regulations
8.3 Secure Deletion
When retention periods expire, we securely delete or anonymize personal information using industry-standard data destruction methods to prevent unauthorized recovery.
9. International Data Transfers
9.1 Transfer Safeguards
When we transfer personal information internationally, we ensure appropriate safeguards are in place:
- Standard Contractual Clauses (SCCs) approved by relevant authorities
- Adequacy decisions by competent privacy authorities
- Binding Corporate Rules for multinational organizations
- Certification schemes and codes of conduct
- Explicit consent for specific transfers where appropriate
9.2 Cloud Services
Our cloud service providers maintain data centers in multiple jurisdictions with appropriate security and privacy protections, including data residency controls where required.
10. Your Privacy Rights
10.1 Universal Rights
Regardless of your location, you have the following rights regarding your personal information:
- Right to Information: Clear information about how we process your personal information
- Right of Access: Request copies of your personal information we hold
- Right to Correction: Request correction of inaccurate or incomplete information
- Right to Deletion: Request deletion of your personal information in certain circumstances
- Right to Restrict Processing: Request limitation of how we process your information
- Right to Object: Object to processing based on legitimate interests or for marketing purposes
10.2 Additional Rights
Depending on your jurisdiction, you may have additional rights including:
- Data portability (receive your data in a structured, machine-readable format)
- Withdrawal of consent (where processing is based on consent)
- Complaint to supervisory authorities
- Compensation for damages resulting from privacy violations
10.3 Exercising Your Rights
To exercise your privacy rights:
- Contact us using the details provided in Section 20
- Provide sufficient information to verify your identity
- Specify the right you wish to exercise and relevant details
- We will respond within the timeframes required by applicable law (typically 30 days)
11. Cookies and Tracking Technologies
11.1 Types of Cookies
We use the following types of cookies and similar technologies:
Essential Cookies:
- Session management and user authentication
- Security and fraud prevention
- Website functionality and navigation
- Load balancing and performance optimisation
Analytics Cookies:
- Website usage statistics and performance metrics
- User behavior analysis and journey mapping
- A/B testing and optimisation insights
- Error tracking and debugging information
Marketing Cookies:
- Targeted advertising and remarketing
- Social media integration and sharing
- Campaign tracking and attribution
- Personalized content and recommendations
11.2 Cookie Management
You can control cookies through:
- Browser settings and preferences
- Our cookie consent management platform
- Third-party opt-out tools and services
- Industry self-regulatory programs
11.3 Third-Party Tracking
We use reputable third-party services for analytics and marketing, including Google Analytics, which may set their own cookies and tracking technologies subject to their respective
privacy policies.
12. Third-Party Services and Links
12.1 External Links
Our Website may contain links to third-party websites and services. We are not responsible for the privacy practices or content of these external sites. We encourage you to review their
privacy policies before providing any personal information.
12.2 Integrated Services
We integrate with various third-party services to enhance our offerings:
- Social media platforms (LinkedIn, Twitter, etc.)
- Professional networking and recruitment services
- Cloud storage and collaboration tools
- Payment processing and financial services
- Customer relationship management systems
12.3 Data Sharing Agreements
All third-party integrations are governed by comprehensive data sharing agreements that include privacy protection requirements, security standards, and compliance obligations.
13. Marketing Communications
13.1 Consent and Preferences
We only send marketing communications with your explicit consent or where permitted by law. You can:
- Opt-in to receive newsletters, updates, and promotional materials
- Manage your communication preferences and frequency
- Unsubscribe from marketing communications at any time
- Update your contact information and interests
13.2 Types of Communications
- Industry insights and thought leadership content
- Service updates and new offering announcements
- Event invitations and webinar notifications
- Case studies and success stories
- Technical resources and educational materials
13.3 Personalization
We may personalize marketing communications based on your interests, industry, and previous interactions with our services, always respecting your privacy preferences and applicable
laws.
14. Children's Privacy
Our services are designed for business and professional use. We do not knowingly collect personal information from children under 16 years of age. If we become aware that we have
collected personal information from a child under 16, we will take immediate steps to delete such information and terminate any associated accounts.
Parents and guardians who believe their child has provided personal information to us should contact us immediately using the details provided in Section 20.
15. California Privacy Rights (CCPA)
15.1 California Consumer Rights
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):
- Right to Know: Request information about the categories and specific pieces of personal information we collect, use, disclose, and sell
- Right to Delete: Request deletion of personal information we have collected from you
- Right to Opt-Out: Opt-out of the sale of your personal information (we do not sell personal information)
- Right to Non-Discrimination: Not receive discriminatory treatment for exercising your CCPA rights
15.2 Categories of Information
In the past 12 months, we have collected the following categories of personal information:
- Identifiers (name, email, phone number, IP address)
- Commercial information (project requirements, service history)
- Internet or electronic network activity (website usage, email interactions)
- Professional or employment-related information
- Inferences drawn from personal information (preferences, characteristics)
16. GDPR Rights for EU Residents
16.1 Enhanced Rights
If you are located in the European Union, you have enhanced rights under the General Data Protection Regulation (GDPR):
- Right to Rectification: Correct inaccurate personal data without undue delay
- Right to Erasure: Request deletion of personal data in specific circumstances
- Right to Restrict Processing: Limit how we process your personal data
- Right to Data Portability: Receive your data in a structured, commonly used format
- Right to Object: Object to processing based on legitimate interests or direct marketing
- Rights Related to Automated Decision Making: Not be subject to decisions based solely on automated processing
16.2 Supervisory Authority
You have the right to lodge a complaint with your local data protection authority if you believe we have not complied with applicable data protection laws.
17. Data Breach Notification
17.1 Incident Response
In the event of a data breach that poses a risk to your rights and freedoms, we will:
- Notify relevant supervisory authorities within 72 hours where required by law
- Inform affected individuals without undue delay when the breach poses a high risk
- Provide clear information about the nature of the breach and recommended actions
- Implement immediate containment and remediation measures
- Conduct a thorough investigation and implement preventive measures
17.2 Notification Content
Breach notifications will include:
- Description of the nature of the breach
- Categories and approximate number of individuals affected
- Likely consequences of the breach
- Measures taken or proposed to address the breach
- Contact information for further inquiries
18. Automated Decision Making
18.1 Limited Automated Processing
We use limited automated processing for:
- Website analytics and performance optimisation
- Email marketing personalization and segmentation
- Security monitoring and fraud detection
- Lead scoring and qualification processes
18.2 Human Oversight
All significant decisions affecting individuals involve human review and oversight. You have the right to:
- Request human intervention in automated decision-making processes
- Express your point of view regarding automated decisions
- Contest decisions made through automated processing
- Request explanation of the logic involved in automated processing
19. Changes to This Privacy Policy
19.1 Policy Updates
We may update this Privacy Policy periodically to reflect:
- Changes in our business practices or services
- Legal or regulatory requirements
- Industry best practices and standards
- Technological developments and security enhancements
- Feedback from users and stakeholders
19.2 Notification of Changes
When we make material changes to this Privacy Policy, we will:
- Post the updated policy on our Website with a new effective date
- Notify you via email if you have provided your email address
- Provide prominent notice on our Website for significant changes
- Obtain additional consent where required by applicable law
19.3 Continued Use
Your continued use of our Website and services after the effective date of any changes constitutes acceptance of the updated Privacy Policy.
Last Updated: January 6, 2025
Version: 2.0
Next Review Date: January 6, 2026