September 23, 2021
This Validator Privacy Notice applies to our privacy practices related to our business-oriented products and service offerings that may be purchased by individual cryptocurrency validators rather than business entities. In the event of any conflicts between this Validator Privacy Notice and a separate agreement between you and us, the terms of the separate agreement shall apply to the extent permitted by law. This Validator Privacy Notice does not apply to any products, services, websites, or content that are offered by third parties or have their own privacy notice. Any obligations Lumen may have as a processor of Personal Information acting at a customer’s direction will be set forth in separate terms and/or notices.
What does this Validator Privacy Notice cover?
Like most companies that provide services online, we have certain information about our current and potential customers and visitors to our website, and we use that information to market our products and services, enter contracts for services, install, support and bill for services, and otherwise carry-out our commercial relationship with such customers. This Validator Privacy Notice sets out the types of Personal Information we may collect, the ways that we may use Personal Information and why we use that Personal Information.
This Validator Privacy Notice describes the processing activities we may undertake with your Personal Information to administer our commercial relationship and market our products and service offerings. It describes the security measures to protect Personal Information, the circumstances under which we may disclose Personal Information to a third party, and how to exercise your rights to access Personal Information in our possession.
As used in this Validator Privacy Notice, “Personal Information” refers to any information relating to you as a person. It may be information that by itself can identify you, such as your name, or it may be information that identifies you only when combined with other available information.
What Personal Information do we collect?
We may collect the following types of Personal Information from you:
- Information you provide us. We may collect your forename, middle name, surname, salutation, email address, postal address, phone number and similar contact data; payment information; location information; and login information
- Website and Portal activity information. If you visit LUMEN’s public-facing websites, we and third parties may analyse your activity on the LUMEN website and place cookies (see below about cookies) your browser or device that collect Personal Information. If you interact with our websites or provide information through a LUMEN portal, we collect information about your interaction with LUMEN including monitoring, recording and analysing your activity on the site; any content you request or download from us; any changes you make to the customer account(s) you are authorised to manage, enquiries you submit, feedback and other, similar commercial activity information; and information from any cookies or web beacons (see below, for cookies and web beacons).
- Communications. If you receive LUMEN electronic marketing materials, we and third parties may analyse your interaction with those materials. If you communicate with LUMEN using telecommunications services like voice calling or text messaging, we and third parties may also analyse Personal Information collected during such interactions with us.
- Additional information. We may collect identity verification information, such as utility, internet service, or similar statements. We may also collect information about you from other sources, including business partners, service providers, and publicly available sources.
There may be circumstances where we request Personal Information other than as identified above. We will do this only where necessary or justified to improve the services we provide and to increase the relevance of your service portfolio. That Personal Information will be treated the same as the other Personal Information identified in this Validator Privacy Notice.
How do we use your Personal Information?
We use your Personal Information to provide the services and allow you to manage your customer account(s) and to measure and improve our offerings to you. We also use your Personal Information to contact you about our products and service offerings, to respond to your enquiries, and to market and promote offerings that may interest you.
We use your Personal Information only for the purpose for which it was obtained and keep it only as long as necessary. We do not sell your Personal Information to third parties. We seek to collect only Personal Information that is relevant and necessary and to collect it from reputable sources. We do not use your Personal Information for purposes unrelated to marketing and providing our products and services.
How do we protect your Personal Information?
We use a variety of security and operational measures to help prevent your Personal Information from unauthorised access, use or disclosure. We limit our collection and use of your Personal Information to the minimum necessary.
We limit the availability of your Personal Information to those who use that information for the purposes specified in this Validator Privacy Notice. We have procedures in place to ensure that your Personal Information cannot be accessed by others. We collect the Personal Information we need for the legitimate purpose to contact you about products and service offerings you purchase or may be interested in purchasing. We provide an option to opt-out of any future communications in every marketing communication we send out. We endeavour not to call phone numbers registered with the appropriate do-not-call registries.
Who do we share Personal Information with and why?
We may share your Personal Information with other entities, including our business partners, affiliates, subsidiaries and third parties that provide certain functionalities for some of our products and service offerings to the extent applicable to your interaction with LUMEN and your management of your customer account(s). We may also share your Personal Information with other entities, including our affiliates and subsidiaries, to the extent applicable to our marketing activities related to our products and service offerings.
We provide services in more than 60 countries around the globe and, as such, operate through multiple affiliates and subsidiaries. We partner with other parties to provide certain products and service offerings. We use channel partners to engage in sales and marketing activities on our behalf to provide our products and service offerings. In order to engage in those activities, we may provide your Personal Information to those parties to contact you about our products and service offerings.
We may share your Personal Information with regulators, government bodies and tax authorities (local and overseas) when required by applicable laws and/or regulations; to any relevant party, claimant, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal claims in accordance with applicable law and regulation; and to any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offenses in accordance with applicable law and regulation.
Where do we send your Personal Information?
LUMEN provides products and services around the world. In certain circumstances, we transfer your Personal Information outside of your country or region or to international organisations as necessary to conduct our business operations, provide our services, and engage in our marketing activities. These areas and international organisations may not be subject to laws that provide the same level of protection for Personal Information as the country in which you are located. Accordingly, when transferring your Personal Information to any such area or international organisation we use safeguards to ensure the security and protection of your Personal Information, including the use of standard agreements approved by various country and regional governments.
We may transfer your Personal Information to our affiliates and subsidiaries throughout the world for storage and use related to your interaction with LUMEN. In particular, the Personal Information used to confirm and enable you to interact with LUMEN and Personal Information contained in our systems, records and activity logs may be accessible by our affiliates and subsidiaries located in the United States and other countries around the world. Where appropriate, our affiliates and subsidiaries that are located in countries that do not have legal requirements to provide adequate protection for Personal Information have signed a contract and agreed to other terms to ensure that Personal Information is adequately protected in accordance with global data protection requirements.
We also may transfer your Personal Information to our suppliers, partners and other third parties throughout the world to the extent applicable to your interaction with LUMEN and your management of your customer account(s). We will not transfer your Personal Information to organisations located outside the country or region in which you are located unless they have adequate data protection mechanisms in place and there is a proper legal basis for making such a transfer. We further restrict any third party from using the Personal Information we provide them related to your interaction with LUMEN and management of your customer account(s) for any purpose other than as described in this Validator Privacy Notice.
Personal information held in our company marketing databases may be accessible by our affiliates, subsidiaries and business partners located in the United States and other countries around the world. Where appropriate, our affiliates, subsidiaries and business partners have signed a contract and agreed to other terms to ensure that Personal Information is adequately protected in accordance with global data protection requirements.
How can you access and control your Personal Information?
In certain countries or regions, you have the right to ask us to provide you access to the Personal Information we have about you, to request correction and erasure of your Personal Information, the right to ask us to restrict our use of your Personal Information, to object to our use of your Personal Information, including selling Personal Information and, in certain circumstances, the right to direct us to send your Personal Information to another entity.
If you would like to request us to do any of the preceding, send your request to our Data Protection Officer at: