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1. Who we are

Luma Media Ltd is a private company registered in England with company number 11174385 and having it's registered address at 1st Floor Cloister House Riverside, New Bailey Street, Manchester, M3 5FS.

Cyber Framework Solutions Ltd is a trading style of Luma Media Ltd who is the data holder of any personal information provided to Cyber Framework Solutions Ltd. Luma Media Ltd is registered with the Information Commissioners Office, registration number: ZA313166.

If you've any questions about how we use your personal information and protect your privacy you can contact us at: compliance@lumamedia.co.uk

Luma Media Ltd is committed to protecting the privacy of all customers and users of our Website, Related Sites and services. This Policy explains our information collection and disclosure practices and goes into detail about, who we are, what information we collect about you, how we might use, store, and share that information.

This privacy policy is only applicable to us and personal information which may be collected and obtained by us. CyberFrameworkSolutions.com may choose to amend the content within this privacy policy at any time. Should this occur, we will update the policy and the revised policy will be posted on this website.

2. Personal information we Collect

You are free to access and browse our website CyberFrameworkSolutions.com at your convenience and do not have to provide us with any personal information or data (please see ‘Cookies’ section).

While using our Website and Related Sites we may collect the following information/ data from you:

Name
Residential Address
Telephone Number

Email
Information surrounding your current energy bill usage.

IP Address- this is a unique number associated with a computer or device which enables it to communicate with other computers and devices over the internet.

3. How we use your information to contact you as part of your Cyber Framework Solutions enquiry

Cyber Framework Solutions Ltd and partners, will keep you informed with the progress of your enquiry. Unless you have stated otherwise you may be contacted via telephone, email and SMS to provide information and alerts relating to our services and our associate companies. We may also receive personal information/data from third parties, which enables us to offer Identified potential customers products, and services who have expressed interest in our products and services. Any information/data obtained from third parties is checked in regard to accuracy and we will endeavour to check your information with you on occasion

Lawful basis for collecting your personal data.

We ensure we have a valid, lawful reason for collecting and using your personal information for each activity we carry out.

Consent:

When you submit the Cyber Framework Solutions Ltd form with Luma Media Ltd, we process your personal data on the basis that you have provided your consent to be contacted by Luma Media Ltd and our panel of solar installation partners. You can withdraw your consent to us processing your personal data at any time by clicking the “unsubscribe” option in any SMS, email we or any associated third party send you.

Alternatively, you can withdraw your consent by contacting our Data Protection Officer at compliance@lumamedia.co.uk or using the contact details stated further down this page. If you change your mind about agreeing to us processing your personal data, this will not have any effect on the lawfulness of any processing we have carried out before you changed your mind.

Contact:

Your personal data will also be processed on the basis that we need this information to fulfil our obligations under the contract we have entered into with you by introducing you to a Cyber Framework Solutions Ltd implementer. Luma Media Ltd and Cyber Framework Solutions Ltd will contact you regarding your Cyber Framework Solutions Ltd enquiry.

Legitimate Interest:

We have a legitimate interest in processing your data (i.e to share your cyber enquiry form with our implementers) to obtain the framework or audit you have enquired for.

You can object to us processing your personal data in this way by contacting our Data Protection Officer at compliance@lumamedia.co.uk or using the contact details stated further down this page.

It is your responsibility to ensure that any information we have on record for you is kept up to date-and correct. If you do require any of your information to be updated, then please contact us as soon as possible so we can ensure it is corrected.

If you require your preferences to be updated, then please contact our Compliance Manager as soon as possible (details set out below).

4. What personal information do we collect

We collect personal information about you when you give this to us when you submit the Cyber Framework Solutions Ltd enquiry form on our website to request a quote from us. The collection of this information is the first step in entering into a contract with you.

In the course of providing the Services to you, we may also store information about how you use our Sites, for example, the pages viewed, the website from which you came to visit our Sites, changes you make to information you supply to us, details of the quotes you request and your applications.

We will store the information you provide and may use it to pre-populate fields on the Sites and to make it easier for you to use the Sites when making return visits

We may monitor or record your calls, emails, SMS or other communications but we will do so in accordance with data protection legislation and other applicable law. Monitoring or recording will always be for business purposes, such as for quality control and training (e.g. where you call our compliance or customer service department), to prevent unauthorised use of our telecommunication systems and Sites, to ensure effective systems operation, to meet any legal obligation and/or to prevent or detect crime.

We will periodically review your personal information to ensure that we do not keep it for longer than is permitted by law.

5. Who do we share your personal information with

When you complete an enquiry, you consent to us disclosing your personal information with the following parties:

CyberFrameworkSolutions.com and Luma Media Ltd -

(i) to communicate with you, including sending you information about products and services which may be of interest to you;

(ii) to speed up form filling, or to personalise, or improve your experience on its website, mobile applications or other similar devices, channels or applications; or

(iii) in accordance with its privacy policy.

Related companies - when we use your information for administrative, management forecasting and planning and statistical purposes, and compliance monitoring.

Where we use third party companies to provide elements of our service for us and they store or process your data, we ensure we have a contract in place with them to outline our expectations and their responsibilities. We require third party companies to agree that they will not share your personal information with any other organisation without our authorisation, they will process all information securely and they must employ safeguards and implement measures that offer your information at least the same level of protection that our own practices provide.

6. Data Retention

We'll hold on to your information for at least as long as is needed to be able to provide our services to you. After this point we review the data that we hold to decide whether we need to keep hold of your information any longer, for example to deal with a complaint or for any legal reasons that may arise from a complaint being made.

We may also hold your information for administrative, management forecasting and planning and statistical purposes, in which case, we will limit what types of information we keep where possible to minimise risk and safeguard personal information.

In retaining any personal information, we ensure that we have a lawful basis before the decision is made to keep personal information about you.

7. Custom and lookalike audiences

We like to work with Facebook, Google, TikTok and other platforms (“Platforms”) to reach out to you with adverts for other Products that you might be interested in. We also like to use Platforms to reach out to other people who might like to use our service.

We do this in two ways. In both cases, your information, along with other information, is used to create a custom audience and/or a lookalike audience. Whenever an audience is shared with a Platform, the data is first hashed and pseudonymised, meaning that any data within the audience that could identify a person is replaced with an artificial identifier. So, the process is secure. Also, we don’t share more data than we need to for the purpose of creating the audience.

Custom audience – A custom audience is a list of our existing customers. From time to time, we share this with Platforms. As explained above, the data is first hashed and pseudonymised. The Platform uses this audience to show our customers our adverts for other Products that they might be interested in. Lookalike audience – A lookalike audience is an audience created by the Platform. From time to time, we share with Platforms a list of customers. The Platform uses this list to find and create lookalikes – i.e. other Platform users who have similar characteristics to the customers – to which it shows our adverts. Again, as explained above, the data is first hashed and pseudonymised.

8. Cookies

A cookie is a small text file that is placed on your computer by a website that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. Web browsers generally allow you to control cookies through the browser settings and you can clear your cookies at any time.

We use cookies on our sites. To find out more about the cookies we use (including the purposes for which we use them) and to manage your cookie settings, visit our cookies preference centre via the 'Cookies Settings' button found on our sites.

9. Your Data Protection Rights

If you reside in the EEA or the UK, you have a number of important rights and choices as to how your personal information is treated under the UK General Data Protection Regulation (GDPR). Those rights are as follows:

You can ask for copies of your personal information;

You can ask us to rectify inaccurate or incomplete personal information;

You can ask us to erase your personal information;

You can ask us not to use your personal information for marketing;

You can ask us to restrict the processing of your personal information;

You can object to the processing of your personal information;

You can ask that we transfer your personal information to another organisation or to you

You can complain about our processing of your personal information;

and

To the extent that the legal basis of our processing of your personal information is consent, you can withdraw that consent.

These rights are subject to certain limitations and exceptions. You can learn more about the rights of data subjects here.

10. Transferring your Data

There may be instances where we need to transfer your information outside the UK. For example, where you are using our services outside of the UK, we may need to transfer your information outside the UK.

As of 1 January 2021, the UK is no longer a part of the EEA. Although the UK is no longer part of the EEA, we will still hold your data to the same level of protection as we did when we were part of the EEA. This means that for any transfer of your data outside of the UK, we will continue to take steps to ensure that it is protected to the same level of protection that applies to transfers of data outside of the EEA.

Certain countries have a European Commission adequacy decision, which means they are considered to offer an adequate level of data protection and we will continue to only transfer data to those countries on this basis.

Other countries do not have the same level of legal protection as countries in the EEA, or with an adequacy decision. If we do transfer your data in this way, we will take steps to ensure that it is protected to the same levels that apply in the EEA. This may include, for example, adopting the EU’s standard contractual clauses.

11. Changes and Amendments to our Privacy Policy

We may update this policy from time to time by publishing a new version on our Website. You should check this page occasionally to ensure you are happy with any changes to this Policy. If you do not agree to the changes or how we use your Personal Information, you should stop using our Website or services immediately. From time to time, we may update this Privacy Policy. This Privacy Policy is our most up-to-date version and it supersedes any earlier version.

12. How to Make a Complaint

Cyber Framework Solutions Ltd always aim to be fair and honest in everything we do, so If you have a complaint about any aspect of our service we’re keen to resolve it as quick as possible.

In the first instance you should contact the Complaints Department by sending an email to compliance@lumamedia.co.uk.

13. How to contact us

We always have our customer’s best interests at heart and we want to hear from you, especially if:

You have any requests or queries in relation to your personal information;
You want to exercise any of your rights as set out above;
You have a complaint.
You can contact our Data Protection Officer by emailing: compliance@lumamedia.co.uk.

Or if you'd like to, you can email to us at:

Cyber Framework Solutions Ltd
Data Protection
Email - info@cyberframeworksolutions.com

Last reviewed: 12/07/2023, 13:00:05

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