Effective date of this Privacy Statement May 23, 2018
Lumileds Holding B.V. (“Lumileds”) is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose your personal data. This Privacy Statement (“Statement”) describes our practices in connection with personal data that we collect through:
- www.lumileds.com, and any other website operated by us from which you are accessing this Statement (“Websites”);
- The software applications made available by us for use on or through computers and mobile devices (“Apps”);
- Our social media pages that we control from which you are accessing this Statement (“Social Media Sites”); and
- HTML-formatted email messages that we send to you that link to this Statement.
Websites, Apps and Social Media Sites are hereafter collectively referred to as the “Services”.
By providing personal data to us, you agree to this Statement. This privacy statement is also respecting the requirements of the EU General Data Protection Regulation (“GDPR”). This is why you will sometimes see some legal language as required by the GDPR.
Types of Personal Data we Collect
When you interact with Lumileds through our Services, we may collect various personal data, such as:
- Your first and last name;
- Your email address;
- Your country;
- Your telephone number;
- Your Lumileds username and password;
- Your IP address;
- Your usage of and activities on our Services;
- Your interests; and
- Other information related to your online behavior.
If you submit any personal data relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so, and you permit us to use the data in accordance with this Statement.
How We Collect Personal Data
We and our service providers may collect personal data in a variety of ways, including:
- Through the Services: We collect personal data through the Services, e.g., when you sign up for a newsletter, sign up for a marketing activities, contact our support centers or make an account.
- Offline: We collect personal data from you offline, such as when you visit stores to purchase our products, attend one of our trade shows, place an order over the phone or contact customer service.
- From Other Sources: We receive your personal data from other sources, such as public databases, joint marketing partners, social media platforms such as Facebook, LinkedIn, Twitter, and Youtube (including from people with whom you are friends or otherwise connected) and from other third parties. In addition, if you elect to connect your social media account to your Website account, certain personal data from your social media account will be shared with us, which may include personal data that are part of your profile or your friends’ profiles.
For Which Purposes We Use Your Personal Data
We use your personal data for the following purposes:
- Providing the functionality of the Services and fulfilling your requests.
- To respond to your inquiries and fulfill your requests.
- To send administrative information to you, for example, information regarding the Services, product tests, surveys and changes to our terms, conditions and policies. We will engage in these activities to manage our contractual relationship with you and/or to comply with a legal obligation.
- Providing you with our newsletter and/or other marketing materials and facilitating social sharing. We will engage in this activity with your consent or where we have a legitimate interest.
- To send you marketing communications that we believe may be of interest to you.
- To facilitate social sharing functionality.
- Analysis of personal data for providing personalized services. We will provide personalized services either with your consent or because we have a legitimate interest.
- To personalize your experience on the Services, based on the information you choose to provide when registering an account with the Services, by presenting products and offers tailored to you.
- Allowing you to participate in sweepstakes, contests or other promotions. We use this information to manage our contractual relationship with you.
- To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities.
- Some of these activities have additional rules, which could contain additional information about how we use and disclose your Personal data. We suggest that you read any such rules carefully.
- Accomplishing our business purposes.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
- For data analysis, for example to improve the efficiency of our Services;
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
- For fraud monitoring and prevention and security monitoring, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For developing new products, enhancing, improving or modifying our Services;
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
Sharing your Personal Data with others
We share your personal data with:
- Lumileds affiliates for the purposes described in this Statement.
- Lumileds Holding B.V. is the party responsible for the management of the jointly-used personal data.
- To our third party service providers who provide services, such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
- To third parties (such as Pardot), to permit them to send you marketing communications, consistent with your choices.
- To third-party sponsors of sweepstakes, contests and similar promotions.
- To identify you to anyone to whom you send messages through the Services.
- By you, on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including, without limitation, our Social Media Sites). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public. We urge you to be very careful when deciding to disclose any information on the Services.
- To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
- We also use and disclose your personal data as we believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (d) to enforce our terms and conditions; and (e) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
Cookies and Similar Technologies
If you would like to request to review, correct, update, suppress, restrict or delete personal data that we process, object to the processing of personal data, or if you would like to request to receive an electronic copy of the personal data you provided to us (to the extent this right to data portability is provided to you by applicable law), you can log into your “profile” with us at www.lumileds.com/register and make the desired changes or you may contact us by: [email protected]. We will respond to your request consistent with applicable law.
In your request, please make clear what personal data you would like to have changed, whether you would like to have your personal data suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal data. For your protection, we may only implement requests with respect to the personal data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any case within the time limits set by applicable law. Please note that we may need to retain certain information for recordkeeping purposes. There may also be residual information that will remain within our databases and other records, which will not be removed.
If Lumileds’ collection and use of your personal data is based on your consent, you have the right to withdraw that consent at any time. Your withdrawal will not affect the lawfulness of Lumileds’ use of your personal data based on consent before the withdrawal.
Additional information regarding the EEA: You may also contact our Global Privacy Officer responsible via [email protected] or Lumileds Group, attention Global Privacy Officer, The Base (Tower B5), Evert van de Beekstraat 1, 1118 CL Schiphol, the Netherlands.
Alternatively, you may lodge a complaint with the data protection authority competent for your country or region or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
We want to know you better so that we can serve you better while at the same time respecting your choices about how we use your personal data.
If you do not want us to send you personalized offers or information, you can let us know by ticking the appropriate box on the registration form or reply card, or by selecting “opt-out” on emails you receive.
Where local law requires it, we will ask you to “opt-in” or affirmatively consent to the processing of your personal data. For example, where local law so requires, we will only send you newsletters if you have subscribed to them. Similarly, where local law so requires, we will ask you to “opt-in” before using sophisticated profiling techniques.
We will try to comply with your choice as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
We use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the Services and other websites or online services, based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. To do so, these companies may place or recognize a unique cookie on your browser (including through the use of pixel tags). They may also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as a mobile phone and a laptop. If you would like more information about this practice, and to learn how to opt out of it in desktop and mobile browsers on the particular device on which you are accessing this Statement, please visit http://www.networkadvertising.org/managing/opt_out.asp and http://www.aboutads.info/. You may also download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps. You may also download the AppChoices app at www.aboutads.info/appchoices to opt out in mobile apps.
When you participate in various social media forums, like Facebook, Twitter, Yammer, Pinterest, Instagram, etc., you should be familiar with and understand the tools provided by those sites that allow you to make choices about how you share the personal data in your social media profile(s).
Also, depending on the choices you have made regarding your settings on various social media sites (and/or in combination with your settings on the webpages), certain personal data may be shared with Lumileds about your online activities and social media profiles, e.g. interests, marital status, gender, user name, photos, comments and content you have posted/shared, etc.
Linking to Other Websites
During your online journey across our Websites, you may encounter links to other websites for your convenience and information. These websites may operate independently from Lumileds, and may have their own privacy notices, statements or policies. We strongly suggest that you review them to understand how your personal data may be processed in connection with those sites, as we are not responsible for the content of non-Lumileds-owned or managed sites, or the use or privacy practices of those sites.
How We Protect Your Personal Data
We recognize and take seriously our responsibility to protect personal data you entrust to Lumileds from loss, misuse or unauthorized access. Lumileds uses a variety of security technologies and organizational procedures to protect your personal data. For example, we implement access controls, use firewalls and secure servers, and we encrypt certain types of data. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please notify us immediately in accordance with the “How to Contact Us” section below.
Special Information for Parents
The Services are not directed to minors under the age of sixteen (16), and we request that they not provide personal data through the Services.
The Services are controlled and operated by us from the Netherlands and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the Netherlands. Your personal data may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your personal data will be transferred to countries outside of your country of residence that may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal data.
In case of disclosure to third parties who assist us in organizing the Services we will ensure that, where relevant, contractual safeguards are implemented to ensure the protection of your personal data when disclosing your personal data to a third party. This may include transferring personal data to other countries (including countries other than where you are based that have a different data protection regime than is found in your country), including countries outside the European Economic Area (“EEA”).
If you are located in the EEA, some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en. For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as the Lumileds Privacy Code for Employee Information (see below) with regard to transfers within the Lumileds group (binding corporate rules as described in article 47 GDPR) or standard contractual clauses for transfers outside the Lumileds group (as described in article 46 (2) (c) and (d) GDPR). You may obtain a copy of our Binding Corporate Rules and/or these standard contractual clauses by contacting [email protected].
We retain your personal data for as long as needed or permitted in light of the purposes outlined in this Statement and consistent with applicable law. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or keep using the Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
We ask that you not send us or disclose any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
Changes to This Privacy Notice
The Services that Lumileds provides are always evolving and may change from time to time without prior notice to you. For this reason, we reserve the right to change or add to this Statement accordingly.
We will post a prominent notice on our Websites to notify you of any significant changes to this Statement, and will indicate at the top of the notice when it was most recently updated. We encourage you to check back often to review the latest version.
The new Statement will be effective upon posting. If you do not agree to the revised notice, you should alter your preferences, or consider stopping using our Websites. By continuing to access or make use of our Services after the changes become effective, you agree to be bound by the revised Statement.
How to Contact Us
If you have any questions about this Statement, please contact us at [email protected].
Lumileds Group, attention Global Privacy Officer, The Base (Tower B5), Evert van de Beekstraat 1, 1118 CL Schiphol, the Netherlands.