1 Introduction
We know that you care about your personal data and how it is used. On our end, we are committed to making sure that we are doing everything we can to fulfill applicable legal requirements on the processing of your personal data.
Therefore, in this privacy policy, we describe the personal data we collect, how and why we use it, and what choices and rights you have regarding your personal data.
This privacy policy applies when you enter into contracts with us, apply for a job position, visit our website https://www.luminarventures.com, fill out an investment form, contact us in various ways, or engage in other interactions with us (e.g., during events organized by us).
When referring to “we” or “us”, we mean Luminar Ventures Management Company AB, reg. no. 559307-5434, which is responsible for the use of personal data described herein.
Please read this privacy policy carefully to understand how your data is used when interacting with us.
For the avoidance of doubt, please be assured that any processing of your personal data is conducted in accordance with the GDPR (Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data).
If you have any questions about this privacy policy, you can always reach out to us at info@luminarventures.com.
2 What is personal data?
Personal data means any data that can be used to identify you, such as your name, address, contact information, device data(as your device may disclose your approximate location or be otherwise connected to you), and more. For the sake of simplicity, we also refer to personaldata as “data” in this privacy policy.
3 For what purposes will we use your data?
We use your data for the following purposes.
Evaluating potential investments. We collect and use personaldata from company representatives and other individuals identified as part of a due diligence process, to evaluate a company of a potential investment. This processing is based on our legitimate interest in operating our business, specifically to perform preparatory measures at your request before entering into a business relationship with you or the company you represent.
Entering into and managing agreements. If you are a company representative, we will process your contact details provided in agreements or other related documentation.This processing is necessary for the performance of the applicable agreement we have with you.
Fulfilling our contractual obligations. We use personal data to fulfil our undertakings and obligations under existing agreements. This processing is necessary for the performance of the applicable agreement we have with you.
Invoicing, administration, bookkeeping, and receiving payment. If you or the company you represent have entered into any agreement with us, we may process your contact details for invoicing and administration purposes, as well as to receive and report our payments. The processing is necessary for the performance of the applicable agreement we have with you and for compliance with legal obligations that we are subject to, such as retaining certain accounting information in accordance with the Swedish Accounting Act.
Communication and service queries. We process your contact details and information provided in communication with us to respond to service queries and other requests. The processing is based on our legitimate interest to provide support to you following your explicit request.
Organizing and hosting events. We process your contact details and information provided in communication with us to organise and host events that you sign up for and/or attend. This processing is based on our legitimate interest to invite you to events that are of interest to you.
Business operations. We use personal data to aggregate business information that enables us to operate, make informed decisions, and report on the performance of our business. This may involve interactions with various entities such as business partners, investors, regulatory authorities, and service providers. This processing is necessary to serve our legitimate interest to operate our business.
Protecting our business. We may process your personal data to fulfil legal requirements, safeguard our legal rights and prevent fraud and other illegal or harmful activities that could affect us, our services, or our business partners. This processing is based on our legitimate interest to protect our business.
Marketing and announcements. To keep our investors informed and engaged, we may reach out to representatives of current and potential investors who are of interest to us. This includes providing updates on upcoming investments and informing existing investors about previous investments. This processing is based on our legitimate interest in operating our business and keeping our investors informed about our activities and investment decisions.
Recruiting. If you apply for a position with us, we will process your job application and related information to make an informed decision regarding employment. This may include conducting background checks. We undertake these measures to fulfil our legal obligations as an employer and to pursue our legitimate interest in ensuring a thorough and effective recruitment process, which includes verifying the information provided by candidates.
Ensuring website functionality. When you visit our website, we process technical data to provide a secure and functioning website. This processing is based on our legitimate interests to provide a functioning website.
4 Okay, and what data will we collect?
What data we collect about you depends on why you’re in contact with us and what data you share with us. For the purposes above, we may process the following types of data about you.
Contact details and business-related personal details, such as name, e-mail address, phone number, and information regarding your business journey. Such information may include details about your role within the company, your professional background, key projects you have worked on, and your business achievements.
Social security number or other personal identification number, when necessary for a secure identification.
Generic information about you, such as age, city of residence, and gender identity.
Information provided or collected during recruitment processes, which may include photos and other information included in your resume or cover letter, as well as information included in notes and evaluations executed by using connection with application reviews and job interviews. In addition to the before mentioned standard information, we may also conduct background checks which can vary based on the nature of the position. A background check may include information on criminal convictions, verification of education and employment history, as well as professional references.
Other information provided when communicating with us by email, web forms, or contact us by mail or other offline means, as well as information shared with us during meetings, which may include in-meeting content such as video, audio, images and text.
Automatically collected general technical data about your device, such as your device’s IP or MAC number. This data is collected using essential cookies necessary for the basic functioning and security of our website.
5 What legal grounds do we have for processing your data?
This section details the legal grounds for processing your data, ensuring transparency and helping you understand its use. For more information on the legal basis for each purpose for which we use your data, please refer to section 3 above (“For what purposes will we use your data?”).
Fulfilment of contract
Some of the data processing described above is necessary for us to provide the services that you have requested and to fulfil what we have agreed in the applicable agreement entered into between you and us. If we do not have access to this data, we will not be able to provide all parts of the services to you.
Legitimate interest
Some of the data processing is based on our legitimate interest to use the data. For an interest to be considered legitimate, our use of the data may not override your fundamental rights or interests. When we use data based on legitimate interest, we believe we have a reasonable cause for using the data and have assessed that the use will not violate your rights or interests. For example, we find that we have a legitimate interest in using certain data for managing our business operations, enabling smooth surfing on our website and improving our services.
Legal requirements
In addition to what is stated above, we may also need to collect and store data in order to comply with certain legal obligations we are subject to, such as retaining accounting information in accordance with the Swedish Accounting Act.
6 Who can access your data?
Third-party suppliers
For the purposes we have describe in section 3 above (“For what purpose will we use your data?”) it is sometimes necessary for us to share your data with third parties. We use certain partners to help us provide, improve, promote, and protect our services. For example, we use suppliers for data storage and web hosting on our behalf. We may also use suppliers for the recording and transcription of information shared by you during meetings. These suppliers may only use your data in accordance with our instructions and we only share such data that is required to perform the service in question. We do not sell any personal data to partners or any other third parties.
Authorities
We may share data to authorities or other third parties when required by law or regulations, or when it is necessary to ensure the safety and security of our services, or to protect or defend our legitimate rights and interests, or those of our users, employees, directors or shareholders.
Other third parties
If we were to be merged or sold (in whole or inpart), your data will be shared with or transferred to the merged or buying entity. In such a case, your data will continue to be processed in accordance with this privacy policy. Please also note that your personal data may be shared with our group companies to be used by them for similar purposes as described in this privacy policy, for example to manage our investments.
7 What are cookies and how are they used?
What are cookies?
Some of your personal data is obtained automatically from your device using “cookies” or similar tracking technologies when you visit our website. Cookies are small text files that are used to store or access information stored on your computer or mobile device.
How we use cookies
We only use essential cookies to ensure the basic functionality of our website. These cookies are necessary for maintaining security, enabling you to fill in forms and questionnaires, and ensuring the website functions as intended. We do not use cookies for analytical purposes orto track your activity on other websites.
How to accept or decline cookies
Essential cookies, which are necessary for the website to function properly, will be installed automatically on your device based on our legitimate interest in providing you with a functioning and safe website. Since we only use essential cookies, there is no need to set cookie preferences for other types of cookies.
8 Where is your data stored?
The data that we collect about you is mainly processed and stored within the European Union but may be transferred to other countries where our partners or suppliers are located or maintain facilities. Before transferring data outside of the European Union, we will ensure adequate mechanisms to protect your data, for example by using the Standard Contractual Clauses as approved by the European Commission.
9 For how long do we store your data?
How long we keep your data will vary depending on the purpose for which we collected the data. Asa general rule, your data is used as long as it’s necessary for the purpose we collected the data for. The purposes for the data collection are listed under “For what purposes will we use your personal data?”.
In some cases, we need to store your data longer to comply with applicable laws (including those regarding document retention), resolve disputes with any parties and otherwise as necessary to allow us to conduct our business. All data that we store will be subject to this privacy policy.
10 What rights do you have?
You always have the following rights in relation to your personal data:
The right to access your data. You always have the right to understand what personal information we process about you and request a copy of your data.
The right to correct inaccurate information. You always have the right to correct or ask us to correct any inaccurate data about you.
The right to request erasure or restriction of your data. You have the right to have us erase or restrict the use of your data that is no longer needed for the purposes for which we collected the data. You also have a right to object to any processing you find unlawful or unnecessary for the informed purposes.
The right to data portability. When technically possible, you havethe right to get your data transferred to another service.
You may exercise your rights described above by sending a request to info@luminarventures.com. We will respond to your request within 30 days. Please note that there may be restrictions for us to erase certain data, such as data that we are required to store by law or regulations.
We are always committed to handle any request, complaint, or concern that you may have about our use of your data in a lawful, fair and transparent way. If, however, you believe that your rights have been violated you always have the right to file a complaint with the Swedish Authority for Privacy Protection (https://www.imy.se), or supervisory authority in your country of residence.
11 Changes and updates to this privacy policy
Occasionally we may, in our discretion, make changes to this privacy policy. If we make any material changes, we will notify you over e-mail or otherwise as appropriate under the circumstances.
Last amended 2024-11-08.
12 Company details
Luminar Ventures Management Company AB
Company reg.no. 559307-5434
Sveavägen 17, 111 57 Stockholm