1. Introduction
Lumière ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website or use our placement services.
By using our services or providing us with your information, you consent to the practices described in this Privacy Policy.
2. Information We Collect
2.1 Information You Provide Directly
We collect information that you voluntarily provide to us, including:
- For Families: Name, email address, phone number, physical address, number of children, children's ages, household requirements, employment preferences, and any other information you provide in inquiry forms or during consultations.
- For Nannies: Name, email address, phone number, nationality, languages spoken, years of experience, professional qualifications, employment history, references, CV/resume, and any other information you provide in your application.
- Background Check Information: With your explicit written consent, we collect information necessary to conduct background screenings, including Social Security number (or equivalent), date of birth, and driver's license information.
2.2 Information Collected Automatically
When you visit our website, we may automatically collect certain information about your device and usage, including:
- IP address
- Browser type and version
- Device type and operating system
- Pages visited and time spent on pages
- Referring website or source
- Date and time of visit
We collect this information using cookies and similar tracking technologies (see Section 8 for details).
3. How We Use Your Information
We use the information we collect for the following purposes:
- To Provide Our Services: To match families with qualified nannies, facilitate placements, and provide ongoing support.
- To Communicate With You: To respond to your inquiries, schedule consultations, provide updates on your application or search, and send service-related communications.
- To Conduct Background Checks: To verify credentials, employment history, and conduct criminal background screenings as part of our vetting process (with explicit consent).
- To Improve Our Services: To analyze website usage, understand user preferences, and enhance our website and services.
- To Send Marketing Communications: With your consent, to send newsletters, updates, and information about our services (you may opt-out at any time).
- To Comply With Legal Obligations: To meet legal, regulatory, and compliance requirements.
4. Legal Basis for Processing (GDPR Compliance)
Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:
- Consent: You have given explicit consent for us to process your personal information for specific purposes (e.g., background checks, marketing communications).
- Contractual Necessity: Processing is necessary to fulfill our contractual obligations to you (e.g., providing placement services).
- Legitimate Interests: Processing is necessary for our legitimate business interests, such as improving our services and ensuring the safety of placements, provided these interests do not override your rights.
- Legal Obligation: Processing is necessary to comply with applicable laws and regulations.
5. How We Share Your Information
We do not sell, rent, or trade your personal information. We may share your information only in the following circumstances:
5.1 With Your Consent
- Families and Nannies: We share relevant information between matched families and nannies to facilitate placements. We only share information necessary for the placement process.
5.2 With Service Providers
We may share information with trusted third-party service providers who assist us in operating our business, including:
- Background Check Providers: To conduct criminal background checks, employment verification, and reference checks (with explicit consent).
- Email Service Providers: To send communications and newsletters.
- Website Analytics: To analyze website traffic and usage (e.g., Google Analytics).
- Hosting Providers: To host our website and store data securely.
All service providers are contractually obligated to protect your information and use it only for the purposes we specify.
5.3 For Legal Reasons
We may disclose your information if required by law, legal process, or government request, or if we believe disclosure is necessary to:
- Comply with legal obligations
- Protect our rights, property, or safety, or that of others
- Prevent or investigate fraud, security issues, or illegal activity
6. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.
- Active Clients/Candidates: We retain your information for the duration of our relationship and for a reasonable period thereafter to provide ongoing support.
- Background Check Records: We retain background check authorization forms and results for 5 years, as required by the Fair Credit Reporting Act (FCRA) and similar regulations.
- Marketing Lists: If you opt-in to marketing communications, we retain your contact information until you unsubscribe.
- Website Analytics: Anonymous usage data may be retained indefinitely for analytical purposes.
Upon your request, we will delete or anonymize your personal information, subject to any legal obligations requiring retention.
7. Your Rights
Under GDPR and applicable data protection laws, you have the following rights regarding your personal information:
- Right to Access: You can request a copy of the personal information we hold about you.
- Right to Rectification: You can request that we correct any inaccurate or incomplete information.
- Right to Erasure: You can request that we delete your personal information (subject to legal obligations).
- Right to Restrict Processing: You can request that we limit how we use your information.
- Right to Data Portability: You can request a copy of your data in a structured, machine-readable format.
- Right to Object: You can object to our processing of your information for certain purposes, such as direct marketing.
- Right to Withdraw Consent: If processing is based on consent, you can withdraw your consent at any time.
To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days.
8. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies to enhance your experience and analyze usage.
8.1 What Are Cookies?
Cookies are small text files stored on your device that help us recognize you and remember your preferences.
8.2 Types of Cookies We Use
- Essential Cookies: Necessary for the website to function properly.
- Analytics Cookies: Help us understand how visitors use our website (e.g., Google Analytics).
- Functional Cookies: Remember your preferences and settings.
8.3 Managing Cookies
You can control cookies through your browser settings. Please note that disabling cookies may affect website functionality.
9. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices of these sites. We encourage you to review their privacy policies before providing any personal information.
10. Children's Privacy
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected information from a child under 18, we will promptly delete it.
11. International Data Transfers
Your information may be transferred to and processed in countries outside your country of residence. We ensure that appropriate safeguards are in place to protect your information in accordance with applicable data protection laws.
12. Data Security
We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:
- Encryption of sensitive data (e.g., background check information)
- Secure storage systems with access controls
- Regular security assessments
- Confidentiality agreements with employees and service providers
While we strive to protect your information, no method of transmission or storage is 100% secure. We cannot guarantee absolute security.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post the updated policy on this page with a revised "Last Updated" date. We encourage you to review this policy periodically.
For material changes, we will provide notice through our website or by email (if you have provided your email address).