Statement of Privacy

PURPOSE

Maintaining your privacy is important to Lukkap. This document, last updated December 2011, describes how Lukkap uses the information that it collects from customers, clients and employees. This document applies to different sources of information that Lukkap uses in conducting its business, including information about:

Clients – individuals receiving Lukkap career related services

Employees – individuals employed by Lukkap

DATA PRIVACY COMPLIANCE

Lukkap is committed to complying with all applicable data protection laws in those countries where it does business. We assign ownership of our data privacy practices at local and corporate office market we operate to provide open communication and dispute resolution to our customers, clients and employees. We abide by the “Safe Harbor” framework developed by the European Commission.

CLIENTS: WHAT LUKKAP COLLECTS ABOUT YOU

We collect information about our clients, such as name and contact details in order to best tailor and deliver our program services. Information is stored on secured servers, and is made available to you at any time, upon your request, for any corrections, edits, or deletions to the information.

Many of our clients are referred to Lukkap by a Lukkap customer – an employer or other sponsor organization that pays Lukkap for the services. In such cases, for purposes of invoicing and reporting to such organizations, Lukkap may share basic, non-personal information about your individual services (such as the fact that you engaged in the services, how often and that you completed your program or services).  Lukkap does not share or in any way distribute or sell your personally identifiable information to any third party.

Lukkap does not willfully report or disclose to any third party personally identifiable individual demographic data, including, but not limited to, age, gender, or race, unless we have received express permission.  All such personal demographic information collected by Lukkap in the course of a client’s program is reported only in aggregate (i.e. without attributing it to you).  We store and analyze this information to adapt program content and functionality to best serve your career development or transition needs, to gauge the needs and interests of future program participants, and to improve the quality of our ongoing services.  In this regard, we may use your personal information for the following purposes:

To ensure Lukkap web site content is relevant to your needs.

To deliver services – such as newsletters, events, or training – that you specifically request.

To help us create, publish, and improve content most relevant to you and other persons receiving Lukkap services.

We may also use your contact information to send you e-mail messages about your services. Only Lukkap (or agents working on behalf of Lukkap) will send you these direct mailings. We will offer our clients choices about receiving further communications from us, uses of information beyond the purposes for which it was provided, and the transfer of personal data to third parties. Lukkap obtains consent for the use and dissemination of any information deemed sensitive.

Lukkap may disclose your personal information if required to do so by law or in the good-faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Lukkap or a Lukkap web-site; (b) protect and defend the rights or property of Lukkap, or (c) act in urgent circumstances to protect the personal safety of Lukkap employees, users of Lukkap products or services, or members of the public.

Your information may be stored and processed by Lukkap in Spain or any other country in which Lukkap or its affiliates, subsidiaries or agents maintain facilities, and by providing your information, you consent to any such transfer of information outside of your country.

LUKKAP EMPLOYEES: WHAT LUKKAP COLLECTS ABOUT YOU

The amount of personal information you are required to supply will normally be limited to only that which is necessary for Lukkap to supply employment-related services to you.

When hiring employees, we may ask you for your name, contact information, e-mail address, or other personal information such as work experience, education, and skills.  In order to process payroll and administer other employment related benefits for our employees, we may collect personal data from you such as name, address, and any other personal identification information, including a social security number or tax identification number. Lukkap does not collect or store social security numbers from customers or clients. This data will be used to process payroll or administer employment benefits either through our operations or an agent of Lukkap. When collecting payroll data electronically or manually, we will ensure that collection and processing meets all privacy requirements.

When hiring employees, we may also collect certain data that is considered by some countries to be “sensitive,” such as information required to provide health care benefits. Our collection of this data is either compatible with employment law or is vital to the interests of the employee. In order to comply with statutes, rules and regulations pertaining to equal employment opportunities or to assist us in compiling data for affirmative action practices, we may also ask employees to provide gender or racial information. This provision of this type of information will be voluntary, unless it is required by law, and will not hinder employment opportunities. If we collect sensitive information, we will ask for your consent to collect, store, and in some cases, transfer this data to third parties including payroll service companies, health insurance organizations, other benefits providers,for government agencies as required by law. We take all reasonable security measures to protect the confidentiality and integrity of sensitive data collected, stored, and used by our company.

Personal data relating to employees may be used in the administration, management and carrying out of your employment, including determining your employment status, selecting and administering employee benefits, determining compensation and incentive programs, processing employee payroll and making related payments, conducting performance evaluations, and managing company insurance programs.

We may also use your contact information to send you e-mail messages about your employment with Lukkap. Only Lukkap (or agents working on behalf of Lukkap) will send you these direct mailings. We will offer our employees choices about receiving further communications from us, uses of information beyond the purposes for which it was provided, and the transfer of personal data to third parties. DBM obtains consent for the use and dissemination of any information deemed sensitive.

Lukkap may disclose your personal information if required to do so by law or in the good-faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Lukkap or a Lukkap web-site; (b) protect and defend the rights or property of Lukkap, or (c) act in urgent circumstances to protect the personal safety of Lukkap employees, users of Lukkap products or services, or members of the public.

Your information may be stored and processed by Lukkap in Spain or any other country in which Lukkap or its affiliates, subsidiaries or agents maintain facilities, and by providing your information, you consent to any such transfer of information outside of your country.

THE SECURITY AND ACCESSIBILITY OF YOUR INFORMATION, THIRD PARTIES, OUTSIDE LINKS

Security and Accessibility:

Lukkap is committed to protecting the security of your personal information. We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use or disclosure. Lukkap houses its data on secure servers that incorporate security logging and intrusion safeguards.  Data is carried on Lukkap’s secure worldwide network and Lukkap’s systems restrict access to personal data to Lukkap staff on a limited basis, with access levels restricted according to roles.

You have the right to view the personal information in your file upon request. Upon reviewing, you may also request edits, corrections, deletions or additions to the personal information in your Lukkap files to ensure that your information is correct and current.

Employees: Please speak with your Lukkap Manager or contact the Talent Department.

Clients: Please speak with your consultant for further information, or contact info@lukkap.com.

Third Parties:

Agents of Lukkap may provide supportive services, such as e-mail list management services for Lukkap’s newsletter, hosting for Lukkap web sites, employee payroll and benefits administration, and so forth. However, we do not authorize these third parties to use any information disclosed to them for any purpose other than the support of Lukkap.

Outside Links:

This privacy statement applies solely to Lukkap. Lukkap web sites may contain links to other sites. Please be aware that Lukkap is not responsible for the privacy practices of such other sites. We encourage our web site users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. We do not knowingly add sites that treat personal information casually.

QUESTIONS, COMMENTS, AND CONTACT INFORMATION

If you have any questions or complaints regarding Lukkap’s data privacy policy as related to your specific information, or to request access to your data, please contact us at info@lukkap.com, or by postal mail:

Paseo de la Castellana, 82

Madrid, 28046