Lucid. (the “Company”) respects the privacy of its customers, employees, business partners, and others, and strives to process personal information in accordance with the laws of the countries in which it conducts business. This global privacy and data protection policy (the “Policy”) sets forth the privacy principles that the Company follows with respect to personal information it collects, uses, and discloses globally, except to the extent the Company is required to collect, use, or disclose personal information to respond to a legal or an ethical obligation, or is expressly permitted or authorized by an applicable law, rule, or regulation to collect, use, or disclose personal information for certain purposes consistent with that law, rule, or regulation.
This Policy applies to all personal information collected, used, and disclosed by or on behalf of the Company, in any format including electronic, paper, or verbal.
For purposes of this Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, the Company or to which the Company discloses personal information for use on the Company’s behalf.
“Company” means Lucid., including its subsidiaries, affiliates, predecessors, successors, and divisions, but excluding joint ventures to which the Company is a party. “Personal Information” means any information or set of information that identifies or is used by or on behalf of the Company to identify an individual. Personal Information does not include information that is encoded or anonymized, or publicly available information that has not been combined with non-public personal information. “Sensitive Personal Information” means Personal Information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information about an individual’s health or sex life, Social Security Number, drivers’ license number, or other government-issued identification number, credit or debit card number, or financial account information. In addition, the Company will treat as Sensitive Personal Information any information received from a third party where that third party treats and identifies the information as sensitive.
Necessity: The Company collects, uses, and discloses the Personal Information necessary for identified business purposes, and retains the information in identifiable form only as long as necessary.
Choice: The Company will offer individuals the opportunity to choose whether Personal Information about them is (a) to be disclosed to a nonagent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual, or (c) to continue to be used for certain types of ongoing processing, such as ongoing commercial e-mail, facsimile, telemarketing, or direct mail communications.
For Sensitive Personal Information, the Company will give individuals the opportunity to affirmatively and explicitly consent (opt-in) to the disclosure of the information to a non-agent third party or to the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual, except where such disclosure or secondary use is required or expressly permitted by law.
The Company will provide individuals with reasonable mechanisms to exercise their choices.
Data integrity: The Company will use Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. The Company will take reasonable steps to ensure that Personal Information is accurate, complete, current, and relevant to its intended use.
Onward transfer: The Company will obtain written assurances from its agents that they will collect, use, and disclose Personal Information only as instructed by the Company, and that they will safeguard Personal Information with at least the same level of protection as is provided by this Policy as well as applicable laws, rules, regulations, and orders, and that they will require the same of any subcontractor. Where the Company has knowledge that an agent is using or disclosing Personal Information in a manner contrary to this Policy, the Company will take reasonable steps to prevent or stop the use or disclosure.
Access and correction: Upon request, the Company will grant individuals reasonable access to factual Personal Information that it holds about them. In addition, the Company will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be factually inaccurate or incomplete.
Security: The Company will implement reasonable administrative, physical, and technical safeguards to protect Personal Information in its possession from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, and will contractually require the same of its agents. The Company will evaluate any security incident reasonably expected to involve Sensitive Personal Information or where otherwise required by law, and will report any unauthorized disclosure of Sensitive Personal Information to governmental authorities and impacted individuals as required by and in accordance with applicable laws.
Enforcement: The Company will conduct compliance audits, reviews, and assessments of its relevant privacy practices to verify adherence to this Policy. Any employee that the Company determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.
Dispute resolution: Any questions or concerns regarding the use or disclosure of Personal Information should be directed to the responsible corporate official. The Company will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Information in accordance with the principles contained in this Policy.
Questions or comments regarding this Policy should be submitted to firstname.lastname@example.org.
This Policy may be amended from time to time, consistent with the requirements of applicable privacy laws, rules, regulations, and orders. The Company will take the following steps to provide notice of any changes to this Policy, such as posting a notice on its corporate website or sending communications regarding planned changes to its customers when such changes materially impact the way in which Personal Information about existing customers is used, and providing choices to existing customers regarding how Personal Information about them will be used and disclosed after the changes are implemented whenever this Policy is changed in a material way.