Effective Date: January 21, 2026
This Privacy Policy describes how Lumen Career ("Lumen", "we", "us", "our") collects, uses, and shares personal information through our website at https://lumencareer.com and our AI-powered recruitment platform (collectively, the "Service").
This Privacy Policy applies to:
By using our Service, you agree to the collection, use, and sharing of your information as described in this Privacy Policy.
We collect personal information from individuals and companies who register for and use our Service:
Account and Contact Information:
Service Usage Information:
Communications:
Automatically Collected Information:
We collect and maintain professional contact information about candidates to provide recruitment services to our customers:
Professional Information:
Sources of Candidate Information:
We obtain candidate information from:
We do not collect sensitive personal data about candidates (such as health information, political affiliations, or protected characteristics under data protection laws).
We use cookies and similar technologies to operate and improve our Service:
Essential Cookies:
Analytics Cookies:
Cookie Management:
You can control cookies through your browser settings. Note that disabling cookies may limit your ability to use certain features of the Service.
For more information about Google Analytics and how to opt out, visit: https://tools.google.com/dlpage/gaoptout
We use customer information to:
Provide the Service:
Improve and Develop the Service:
Communicate with You:
Protect and Secure:
We use candidate information to:
Legal Basis for Processing (GDPR):
We do not sell your personal information. We share personal information only in the following circumstances:
Service Providers:
We share information with third-party service providers who perform services on our behalf:
AI Service Providers:
We use AI technology to power features of our Service. We share data with:
We require all AI service providers to:
Data Enrichment Providers:
We use third-party data enrichment providers to obtain candidate contact information from publicly available sources. These providers operate as independent data controllers and are responsible for their own compliance with applicable data protection laws.
Customers (for Candidate Data):
We share candidate professional information and contact details with our customers for legitimate recruitment and hiring purposes. Our customers are independent data controllers and are responsible for their own compliance with data protection laws when using candidate information.
Professional Advisors:
We may share information with lawyers, accountants, auditors, and other professional advisors as necessary in the course of their services to us.
Legal Obligations:
We may disclose information to:
Business Transfers:
If we are involved in a merger, acquisition, sale of assets, or bankruptcy, your information may be transferred as part of that transaction. We will provide notice before your information is transferred and becomes subject to a different privacy policy.
With Your Consent:
We may share information for other purposes with your consent.
If you are located in the European Economic Area (EEA), United Kingdom, or other jurisdictions with applicable data protection laws, you have the following rights:
Right to Access:
You can request access to the personal information we hold about you.
Right to Rectification:
You can request that we correct inaccurate or incomplete personal information.
Right to Erasure (Right to be Forgotten):
You can request that we delete your personal information in certain circumstances, such as:
Right to Restrict Processing:
You can request that we restrict processing of your personal information in certain circumstances.
Right to Data Portability:
You can request a copy of your personal information in a structured, commonly used, and machine-readable format.
Right to Object:
You can object to processing of your personal information based on legitimate interests, including for direct marketing purposes.
Right to Withdraw Consent:
Where we process your information based on consent, you can withdraw that consent at any time.
Right to Lodge a Complaint:
You have the right to lodge a complaint with a supervisory authority, in particular in the EU member state or country where you live, work, or where an alleged infringement of data protection law occurred.
For users in Portugal, the supervisory authority is:
Comissão Nacional de Proteção de Dados (CNPD)
Website: https://www.cnpd.pt/
Email: [email protected]
For Customers:
To exercise any of these rights, please contact us at [email protected]. You may also update certain account information by logging into your account.
For Candidates:
If you are a candidate and wish to:
Please contact us at [email protected] with the subject line "Candidate Privacy Request." Please include your name and email address so we can locate your information.
We will remove your data from our database and provide guidance on removal from third-party data sources. Please note that we cannot control third-party data providers, but we will assist you in exercising your rights with them.
We will respond to your request within 30 days (or as otherwise required by applicable law). We may ask for additional information to verify your identity before processing your request.
Opt-Out of Marketing Communications:
You can opt out of marketing emails by:
You will continue to receive transactional and service-related emails even if you opt out of marketing communications.
Customer Information:
We retain customer account information for as long as your account is active. After you delete your account, we will retain your information for 30 days to allow for account recovery, and then permanently delete it, except:
Candidate Information:
We retain candidate information for as long as necessary to provide our recruitment services to customers. Candidates may request deletion of their information at any time by contacting us at [email protected], and we will remove their data from our systems.
Aggregated Data:
We may retain anonymized, aggregated data indefinitely for analytics and business purposes. This data cannot be used to identify individuals.
Lumen is based in Portugal. We process and store data primarily within the European Economic Area (EEA). However, some of our service providers may process data outside the EEA, including in the United States.
When we transfer personal data outside the EEA, we ensure appropriate safeguards are in place, such as:
We implement appropriate technical and organizational security measures to protect personal information against unauthorized access, alteration, disclosure, or destruction, including:
However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.
If we become aware of a data breach that affects your personal information, we will notify you and relevant authorities as required by applicable law.
Our Service is not directed to children under the age of 16, and we do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from a child under 16, we will take steps to delete that information as soon as possible.
If you believe we have collected information from a child under 16, please contact us at [email protected].
Our Service may contain links to third-party websites, applications, or services that are not operated by us. This Privacy Policy does not apply to third-party services. We are not responsible for the privacy practices of third parties. We encourage you to read the privacy policies of any third-party services you use.
When you connect third-party services to our Service (such as Gmail), those services may collect information according to their own privacy policies.
Our Service uses Google APIs, including Gmail APIs, to provide certain features. Our use of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.
This means:
For more information about how we handle Gmail data, please see Section 6 of our Terms & Conditions.
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:
We encourage you to review this Privacy Policy periodically. Your continued use of the Service after changes are posted constitutes your acceptance of the updated Privacy Policy.
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Email: [email protected]
Last Updated: January 21, 2026
