Privacy Policy

IN FORCE SINCE: 01.10.2023

At dotLumen, one of our main priorities is the privacy of our visitors. This Privacy Policy contains information about what data is gathered and recorded when someone visits or interacts with our website, as well as information on how we use that data, what are your rights and how you can exercise them.

The dotLumen.com domain name is currently under the property of DotLumen SRL (hereinafter dotLumen), a private company headquartered in the European Union (Cluj-Napoca, Romania).

This Privacy Policy applies only to our online activities and is valid for visitors to our website with regards to the information that they shared and/or was collected by accessing www.dotlumen.com. This Policy is not applicable to any information collected offline or via channels other than this website.

It’s important that you check back often for updates to the Policy as we may change it from time to time to reflect changes to our use of cookies and/or personal data. Please check the date at the top of this page to see when this Policy was last revised. Any changes to this Policy will become effective when we make the revised Policy available on our website.

Our privacy policy follows the subsequent structure:

General clauses regarding:
- What information do we collect?
- How do we use the collected information?
- To whom do we disclose the collected information?
- How do we keep collected information secure?
- Where do we send the collected information?
- How long do we keep the collected information?

Special clauses applicable when:
- submitting a contact form;
- subscribing to our newsletter and/or agreeing to marketing communications;
- registering on our waiting list;
- submitting a request for participation in clinical trials or similar investigations.

Cookies policy

Your rights and how to exercise them.

GENERAL CLAUSES

What information do we collect?

When interacting with our website, we might collect various types of information, some of which is considered personal data.

Personal data means any information that can lead to the identification of a person, directly or indirectly, in particular by reference to an identifier such as a name, location information, an online identifier (e.g., IP address) or one or more factors specific to the physical, physiological, mental, economic, cultural or social identity of a person.

The information we might collect can fall in the subsequent categories:

personal data: information that can be used to identify you such as your name and contact details;
usage data: information about how you interact with our website, including your IP address, browser type, device type, pages visited, and the time and date of your visits;

cookies: we may use cookies and other tracking technologies to collect information about your online activities, preferences, and browsing history;
other data: information you sent by submitting forms.

How do we use the collected information?

We may use your information for various purposes, including but not limited to:

provide products or services that you requested;
respond to your questions or requests for information;
subject to your separate consent, to inform you about new products and services;
subject to your consent, to send you newsletters, inform you about events and news;
meet our legal obligations;

protect the security and confidentiality of your information, including preventing unauthorized access and fraud.

dotLumen processes the personal data for the purposes described above. From a legal perspective, we process the mentioned data based on the following reasons:

to be able to provide the services requested (performance of a contract);
to promote our business interests and develop our services/products: for example, to manage our relationship with you after requesting our services or other information (legitimate interests);

to comply with the law, regulatory obligations and legal processes;
your consent.

To whom do we disclose your information?

We will disclose your data internally within our business, but only to those who need it to further provide services or help with your requests.

We will also disclose your information to the following entities, only to the extent that this will be necessary to provide our services, complete your requests or develop our products:

service providers: companies that provide services for or on behalf of us, provided they have implemented policies for safeguarding the information.
other parties, when required by law or as necessary to protect our business. For example, information requested by law enforcement authorities, provided that legal requirements are respected.
other parties in connection with corporate transactions: after taking steps to ensure the confidentiality and protection of data, information may be disclosed to a third party in the context of mergers or transfers, acquisitions or sales, as well as in the event of a bankruptcy.
other parties with your consent or at your direction: we may share information about you with third parties when you explicitly consent to or request such sharing.

How do we keep collected information secure?

Our company's website is hosted on the Wix.com platform. Wix.com provides us with the online platform that allows us to reach you. Your data may be stored through Wix.com’s data storage, databases and the general Wix.com applications. They store your data on secure servers behind a firewall.

Besides the above measure, we also ensure the protection of the collected information by means such as the following:

restricting the number of individuals within our company with access to the data;
training our staff regarding privacy;
implementing working procedures (guidelines) with an emphasis on confidentiality and data protection;
using secure IT systems;
using secure data transmission networks (secure internet connection);

Where do we send the collected information?

Data recorded through your interaction with the website may be transferred, stored and processed outside of your country of residence.

As mentioned previously, our company is hosted on the Wix.com platform. As part of our contractual terms with them, Wix shall only transfer information from the EEA, Switzerland and the United Kingdom using the applicable mechanisms required to ensure that the relevant cross-border transfer is in compliance with applicable data protection laws.

Regarding information from other countries, Wix shall process any data only as long as it complies with the applicable legal requirements in the region.

For more information about the privacy policy of the Wix platform, please consult their designated section at www.wix.com.

How long do we keep the collected information?

We will not retain your personal information for longer than is necessary for the purpose for which it was collected. This means that information will be destroyed or deleted from our systems when it is no longer needed.

We establish the period for which we retain the data based on the following guidelines:

as long as stated by applicable laws, requirements of a contract or other legal obligations;
as long as necessary for the purpose for which it was collected or is processed;
as long as necessary for statistical purposes, after taking appropriate safeguards, such as anonymizing the information to ensure that an identification of a person is no longer possible.

For more details on particular information, such as cookies, name or contact details, please read the Cookie Policy and/or the special clauses section.

SPECIAL CLAUSES

This section of the privacy policy provides information about personal data collected by interacting with our website in particular situations. It describes what data is collected, the purpose for which is collected and the period for which we store it.

Contact forms

name:

purpose: fulfilling you request to contact you and/or provide the information/service/product you asked;

duration: as long as necessary to fulfill your request, but no longer than 6 months.

e-mail:

purpose: fulfilling you request to contact you and/or provide the information/service/product you asked;
duration: as long as necessary to fulfill your request, but no longer than 6 months.

other information offered in the message content:

purpose: fulfilling you request to contact you and/or provide the information/service/product you asked;
duration: as long as necessary for statistical purposes, only after the information was anonymized as to impede identification; otherwise, no more than 6 months.

Newsletters/Marketing Communications

When you subscribe to our newsletter, we collect the following information:

e-mail:

purpose: to deliver news about our services/products/events or send other similar communications;

duration: until exercising you right to unsubscribe.

By subscribing to our newsletter, as well as by checking the button for marketing communications you are explicitly consenting to processing of any of the data provided for marketing purposes, including profiling. Your consent can be withdrawn at any time, by clicking the unsubscribe button, available in the content of any message to you, as well as on our website, in the newsletter subscription section.

Waiting list registration

If you choose to submit a form to register on our waiting list, we collect the following information:

name:

purpose: for marketing communications, to inform you about the development and availability of our services and/or products, as well as for business and statistical purposes, in order to assess the level of interest in our services and/or products;
duration: until the product is available on the market in the subject’s region and eligible for acquisition through state funded programs or until consent is withdrawn, whichever takes place first.

address:

purpose: for marketing communications, to inform you about the development and availability of our services and/or products, as well as for business and statistical purposes, in order to assess the level of interest in our services and/or products;
duration: until the product is available on the market in the subject’s region and eligible for acquisition through state funded programs or until consent is withdrawn, whichever takes place first.

phone number:

purpose: for marketing communications, to inform you about the development and availability of our services and/or products, as well as for business and statistical purposes, in order to assess the level of interest in our services and/or products;

duration: until the product is available on the market in the subject’s region and eligible for acquisition through state funded programs or until consent is withdrawn, whichever takes place first.

e-mail:

purpose: for marketing communications, to inform you about the development and availability of our services and/or products, as well as for business and statistical purposes, in order to assess the level of interest in our services and/or products;
duration: until the product is available on the market in the subject’s region and eligible for acquisition through state funded programs or until consent is withdrawn, whichever takes place first.

recognition as a disabled person by state authorities:

purpose: for business and statistical purposes, to assess eligibility for government subsidies for the acquisition of our products;
duration: until the product is available on the market in the subject’s region and eligible for acquisition through state funded programs or until consent is withdrawn, whichever takes place first.

Clinical Investigation

When requesting to participate in a clinical trial or similar investigations, we collect the following data:

name:

purpose: to contact you to provide details about our trials;
duration: as long as necessary for the specified purpose, but no longer than 6 months.

e-mail:

purpose: to contact you to provide details about our trials;
duration: as long as necessary for the specified purpose, but no longer than 6 months.

other information offered in the message content:

purpose: to fulfill your request, and potentially assess your initial suitability for our trials, based on the information you provided;

duration: as long as necessary for the specified purpose, but no longer than 6 months.

COOKIE POLICY

The Cookie Policy describes the different types of cookies that may be used in connection with our website, as well as how you can manage them.

What are cookies?

A cookie is a small text file that a website stores on your computer or mobile device when you visit the site.

Cookies can be classified by different criteria: purpose, duration, and provenance.

By duration, cookies can be:

session cookies – they are temporary and expire once you close your browser (or once your session ends).
persistent cookies — they remain on your hard drive until you erase them, or your browser does, depending on the cookie’s expiration date.

By provenance, cookies are:

first-party cookies — they are set by the website you are visiting and only that website can read them.
third-party cookies —are placed on your device, but by a third party, which usually provides a service for the website you are browsing.

By purpose, cookies can be:

essential cookies —they are strictly necessary for you to browse the website and use its features. These kinds of cookies are automatically enabled and cannot be turned off as they are vital for browsing the website.
functional cookies — also called “preferences cookies,” allow the website to remember choices you have made in the past, like what language you prefer. Their role is to deliver a better user experience, so you do not have to set your choices every time you visit the website.
analytics cookies — also known as “performance cookies” or “statistics cookies”. They collect information about how you use a website, such as which pages you visited, or which links you clicked on. None of this information can be used to identify you. It is all aggregated and, therefore, anonymized. Their sole purpose is to improve website functions. The category includes cookies from third-party analytics services as long as the cookies are for the exclusive use of the owner of the website visited.
marketing cookies —these ones enable websites and their potential partners to deliver more relevant advertising, tailored to match you interests.

What type of cookies do we use and how?

On our website we use essential, functional, analytics and marketing cookies. Only essential cookies are automatically enabled, as they are vital for the core functionality of the website. All other cookies can be accepted or denied by choosing the appropriate settings in the cookie banner, available at the bottom of the webpage.

As our website is hosted on the Wix.com platform, some of the cookies are also received by Wix’s domain.

In the table below, you can see the name, purpose and duration of the cookies that can be placed on our website:

XSRF-TOKEN:

purpose: security;
duration: session.

purpose: security;
duration: session.

svSession:

purpose: used in connection with user login;
duration: 12 months.

SSR_caching:

purpose: used to indicate the system from which the site was rendered;

duration: 1 minute.

_wixCIDX:

purpose: system monitoring/debugging;
duration: 3 months.

_wix_browser_sess:

purpose: system monitoring/debugging;
duration: session.

consent-policy:

purpose: used for cookie banner parameters;
duration: 12 months.

smSession:

purpose: used to identify logged in site members;
duration: session.

purpose: security and anti-fraud;

duration: session.

bSession:

purpose: system effectiveness measurement;
duration: 30 minutes.

fedops.logger.X:

purpose: stability/ effectiveness measurement;
duration: 12 months.

wixLanguage:

purpose: save user language preference;
duration: 12 months.

_wixUIDX:

purpose: system monitoring/debugging;
duration: 4 months.

How can you manage cookies?

You can adjust your preferences and withdraw your consent through the cookie banner, available in the bottom section of the webpage.

The available buttons in the cookie banner act as per the following:

Accept – confirms your consent to all types of cookies we use.
Deny all – denies all type of cookies we use, except essential cookies, without which you would not be able to browse the website.
Cookie Settings – opens a pop-up window, where you can select your preferences for each type of cookie (marketing, analytics, functional).

You can also update your browser settings at any time if you want to remove or block cookies from your device (see your browser's "help" menu to learn how to remove or block cookies).

YOUR RIGHTS AND HOW TO EXERCISE THEM

According to the applicable legislation in the European Union, you have the following rights:

right to be informed by dotLumen about the type, purpose, and legal grounds of the processing of your data;
right of access to data, which comprises the right to obtain a confirmation from dotLumen on whether it processes personal data concerning you and also the right to obtain a copy of the respective data;
right to rectification of personal data without undue delay;
right to deletion of data without undue delay;

right to restrict processing when considering that personal data is inaccurate, the processing is unlawful or dotLumen no longer needs it;
right to notification of rectification, deletion or restriction of processing of personal data;
right to object to the processing of personal data concerning you, including the creation of profiles on the basis of these provisions;
right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly affects you to a significant extent;
right to lodge a complaint with the National Supervisory Authority for Personal Data Processing or any other competent authority. Prior to filing a complaint with the National Supervisory Authority for Personal Data Processing, the person must contact dotLumen at contact@dotlumen.com to firstly exercise his/her rights. If no response has been received within one month of the receipt of the request by dotLumen or the complainant is dissatisfied with the response received, a complaint may be lodged to the competent authority. The complaint must be accompanied by evidence.

You can exercise any of the above rights, as well as withdraw your consent to the processing of your personal data for the purposes stipulated in this privacy policy at any time by notifying dotLumen at contact@dotlumen.com.

If you have any further questions about our privacy policy, please send us an e-mail at contact@dotlumen.com.