The processing of personal data will be carried out exclusively on the basis of an agreement between Luminos Software and our clients or on the basis of a law or other binding regulation, EU or national. (art. 28 paragraph 3 GDPR).
Luminos Software will process personal data exclusively on the basis of written instructions from our clients, in their capacity as data controllers, unless a law or other binding regulation (EU or national) obliges us to (other) processing. In such a case, we will inform our clients prior to processing unless the relevant law or regulation prohibits us from doing so. The written instructions from our clients shall at least describe the subject matter, duration, nature and purpose of the processing, the type of personal data and the categories of data subjects, and the rights and obligations of our clients in their capacity as data controllers. (art. 28 paragraph 3, paragraph 3 sub a GDPR).
Luminos Software will not disclose or make available personal data for purposes other than those indicated in the processing agreements between us and our clients in their capacity as data controllers, or on the basis of a law or other binding regulation, EU or national (art. 28 paragraph 3 sub b GDPR).
Luminos Software takes appropriate technical and organizational security measures when processing personal data, taking into account what is technically possible, against risks such as loss, destruction, unauthorized access, unlawful use, unlawful changes and unlawful disclosure (art. 28 paragraph 3 sub c, art. 32 GDPR).
Luminos Software will actively provide information regarding our own establishment location as well as the establishment locations of processors appointed by us and the reason why we process personal data.
Luminos Software provides full cooperation without unreasonable delay to requests from any person for information about what personal data we have about him/her, which reach us through our clients, in their capacity as data controllers. The relevant personal data will be made available factually and in a clearly readable form to our clients; if this request cannot be accommodated, we will state the reason for this. Full cooperation will also be provided for successful requests for rectification and erasure of personal data, restriction of the processing of personal data and portability of personal data. (art. 28 paragraph 3 sub e GDPR).
Luminos Software ensures that we are able to account at any time for the manner in which we implement our privacy behavioral rules.
Luminos Software will not store processed personal data longer than is necessary for the purpose for which this data was collected, as indicated and set out in the relevant processing agreements concluded between us and our clients, unless a law or other binding regulation (EU or national) applicable to us obliges us to a different retention period. In such a case, we will inform our clients prior to entering into the processing agreement unless the relevant law or regulation prohibits us from doing so (art. 28 paragraph 3 sub g GDPR).
Luminos Software will, after the end of the processing agreement, delete all personal data, return it to the relevant client and remove existing copies according to the choice of the client, unless we are obliged on the basis of a law or regulation (EU or national) to retain this data (art. 28 paragraph 3 sub g GDPR).
Luminos Software will not transfer personal data to a country, territory and/or organization outside the EEA unless the relevant country, territory and/or organization guarantees adequate protection with regard to the rights and freedoms of data subjects in connection with the processing of personal data. This classification will be made exclusively on the basis of art. 45 paragraph 1 GDPR.
Our privacy behavioral rules form an integral part of the Luminos Software corporate culture and are respected and complied with by all employees.