LEM Privacy Statement

Introduction

This Privacy Statement for customers, business partners, and visitors (hereinafter referred to as “Privacy Statement”) outlines the methods by which personal data is collected, processed, handled, used, stored, and protected. This Privacy Statement covers all personal information of individuals that is collected and processed from:

  • websites, portals, apps we own or operate;
  • Visit of our sites;
  • Purchase or use of our products, solutions, applications or services;
  • Subscription and receipt of our newsletter or participation in our online communities;
  • live events, trade shows and other sites and public events;
  • customer support;
  • Request for information from suppliers, customers, distributors, business partners and leads, prospects.

We may provide additional privacy statements with specific information when you share personal data as a job applicant or as a LEM employee.

LEM operates globally and is subject to various privacy and data protection laws and regulations worldwide. To comply with local legal requirements, an add-on to this Privacy Statement may be issued for certain countries. If there is a discrepancy between this Privacy Statement and any add-on or local legislation and/or standards, the add-on or local requirements will apply.

To comply with relevant legal requirements, the terms of this Privacy Statement may be modified or amended at any time.

Who we are

In this Privacy Statement, the terms “we”, “us”, or “our” refer to LEM International SA and any subsidiary of LEM Holding SA (“LEM”). LEM International SA. (Route du Nant-d’Avril 152, 1217 Meyrin, Geneva, Switzerland) is responsible for data processing under this Privacy Statement.

What types of personal information do we collect?

For the purpose of this Privacy Statement, “personal data” (or personal information) is any information relating to an identified or identifiable living person who can be identified, directly or indirectly, by an identifier such as a name, an identification number, location data, or by reference to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Different pieces of information, when collected can lead to the identification of a person, also constitute personal information.

Depending on your interactions with us, we may handle different categories of personal information provided by you, including but not limited to the following:

  • Name and last name, gender;
  • E-mail address, physical address, phone number, fax number, country;
  • Account and user log-in data;
  • Reviews, feedback, comments;
  • Interactions with promotional or marketing campaigns and offers;
  • Content created by you within LEM communities;
  • Registration, subscription and attendance data from live training and promotional events;
  • Downloads from websites or apps;
  • Meta information such as time and/or duration of your interaction with us;
  • IP address, MAC address of the devices you use to interact with us;
  • Your actual or inferred location, as determined by the information provided above, may be utilized. We may use your IP address to ascertain your general region to tailor our services and to enhance your experience;
  • Information related to your interests (products or services that you are visiting or videos viewed on our websites platforms);
  • Information related to your requests for information, requests for support and your transactions with LEM;
  • Details concerning your preferences for receiving communications, subscribing to our publications or newsletters, engaging with additional content, as well as completing surveys and participating in market research;
  • Profile information includes your username, password, photo, interests, social media account ID, and preferences;
  • Cookies, cookie preferences, log files, and other technical data are collected, including details about your device and its configuration (such as operating system and language settings), browser details and settings, information regarding user activity on websites and apps, Internet provider details, approximate location, and time of use. More information about the use of cookies and tracking technologies is available in the Cookie Statement;
  • Site security and visit information like access control data, and CCTV recordings;
  • Information from third-party sources may be collected in accordance with applicable laws. This includes data from social media platforms when you interact with us on sites such as Facebook, Twitter, Instagram, or LinkedIn, as well as information from commercially available sources, including business partners like advertisers, event or webinar organizers, event or webinar partners, and joint marketing partners;
  • Public blogs, forums, issue trackers, and wikis may be available. Information provided on these websites, including profile details linked to posting accounts, can be viewed, collected, and used by anyone with access to these services. Posts and certain profile data may continue to be accessible after account termination.

Children’s Personal Information

LEM does not provide products or services to individuals under 18. We do not knowingly collect information from children under 18 or target our services to anyone under 18. If we find a child under 18 has submitted personal information, we will delete it promptly. Parents or guardians with questions, or concerns about a child's data, can contact us at: privacy@lem.com.

Cookies

When visiting our websites or digital platforms, we and third-party partners may use cookies, SDKs, web beacons, and other similar technologies for tracking service usage and optimizing functionality on our platforms.

Information collected or generated by third parties is processed and stored by those parties in accordance with their own privacy policies, over which we have no control or responsibility.

For additional details about our use of cookies and tracking technologies, please refer to our Cookie Statement. We obtain explicit consent for non-essential cookies and provide clear options to manage cookie preferences.

Why do we collect your personal information?

Based on our relationship with you, your interactions with us, the websites you visit, or the products or services you use, we may collect personal information for various purposes, including:

  • Performance and execution of contracts;
  • Content and Advertising Analytics;
  • Direct marketing activities, such as conducting data analysis to deliver marketing information that may be relevant to you (including newsletters, advertising emails, messages, brochures, magazines, in-app messages, and other electronic or printed communications);
  • Invitations to events and competitions;
  • Management of leads and sales of our products and services through our network of distributors and business partners;
  • Business analysis and development, management reporting;
  • Developing and improving our products and/or services;
  • Responding to requests and providing customer support;
  • Protecting our intellectual properties;
  • Compliance with legal obligations;
  • Protecting our rights and third-party rights;
  • Security and maintenance reasons (debugging, fraud prevention, mitigation, and detection of cyber and malware attacks),

Legal Basis

The processing of your personal data is carried out in accordance with at least one legal basis, which may vary depending on the type of personal data and the intended purpose of processing. These legal bases include: (i) your explicit and informed consent, which you may withdraw at any time; (ii) fulfillment of a contract with you or steps taken prior to entering into a contract; (iii) compliance with applicable legal obligations; or (iv) our legitimate interests - such as operating our business efficiently and enhancing the quality of our products and services - or those of third parties to whom your personal data may be transferred.

Sharing your information with third parties?

We may share your personal data for the purposes outlined in this Privacy Statement with the types of third parties identified below:

  • LEM affiliates and subsidiaries;
  • External service providers acting on our behalf, such as newsletter distributors, IT hosting providers, marketing service providers, cloud service providers, data analysis service providers, SaaS providers;
  • Distributors and business partners which may contact you to assess interest in and sell our products or services. They are prohibited from using shared information to sell other products and must comply with relevant personal data protection laws;
  • Professional advisors such as lawyers, bankers, auditors, and insurers, where necessary for the required service;
  • Social Media;
  • Business and academic partners when required for specific joint research projects.

In accordance with applicable laws, all third parties who receive your personal information are required to implement appropriate safeguards for its protection. When engaging external service providers, we ensure they process your personal information solely for the purposes outlined in this Privacy Statement. We do not sell or license your personal information to third parties.

Additionally, LEM may disclose your personal data to third parties in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or part of LEM's business, assets, or stock, including situations related to bankruptcy or similar proceedings.

LEM will also share or release information, including personal data, if (i) LEM has your permission to make the disclosure, (ii) when LEM believes release is appropriate or required to comply with the applicable laws and/or to respond to requests from competent public and government authorities including public and government authorities outside your country of residence, (iii) in connection with any ongoing or prospective legal proceedings, (iv) enforce or apply LEM Terms of Use and other or agreements, or (v) protect the rights, property or safety of LEM and other users (fraud prevention and cybersecurity protection).

Marketing Preferences

If you receive marketing communications, you may opt out of these messages at any time. Each email will include clear instructions on how to unsubscribe from further marketing communications.

LEM shall comply with your request as soon as reasonably practicable. Please also note however that LEM may keep sending you important administrative and transactional messages (i.e. service notifications) in connection with a transaction, your orders, updates or notifications about products you have purchased from LEM, or information about your account.

Social Computing

LEM may offer social computing tools to facilitate online collaboration and information sharing among registered users. Such tools can include forums, wikis, blogs, instant messaging, open-source development platforms, and other forms of social media. When registering for certain social computing features on LEM sites or apps, you may be required to provide specific personal data. This personal data, along with any other information collected during the registration process, will be governed by this Privacy Policy, except for any data or information that you choose to make public or share directly with other participants. Additionally, these tools may be governed by supplemental terms of use and may carry additional privacy notices.

All content or information, including personal data, that you post or share with other participants on third-party social media platforms is governed by the terms of use and privacy policies of those platforms, and is not covered by this Privacy Statement.

Third party websites

LEM sites or apps may contain hyperlinks directing users to third-party websites. LEM does not exercise control over these external sites or their practices and therefore has no responsibility for their policies, operations and processing activities. This Privacy Policy does not extend to the privacy and security measures, data collection, processing, usage, storage, or disclosure policies of such third parties.

International Transfers of Your personal data

LEM may transfer your personal data to any affiliated LEM group company globally for processing, storage, and use in accordance with this Privacy Policy. Additionally, LEM may share personal data with third-party service providers situated in jurisdictions other than your own. Consequently, your personal data may be transferred to territories outside the European Economic Area (the “EEA”), including countries that may not provide data protection standards equivalent to those applicable within the EEA.

To protect your rights we only store and transfer your personal data in compliance with applicable legal requirements (i) to a region or country where an adequate level of protection for personal data is provided, or (ii) based on applicable requirements for the transfer of personal data such as, EU Standard Contractual Clauses, or (iii) based on certification mechanisms, or (iv) based on other transfer mechanisms provided by applicable data protection and data security laws.

How do we safeguard your personal information?

Appropriate technical and organizational measures have been implemented to reduce risks, including accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to information. These measures are designed to comply with relevant data protection and data security laws.

Security risks exist with all internet and information technologies, and absolute security of personal information cannot be ensured. It is recommended that you take steps to safeguard your information. You should consider using encryption and other protective measures when transmitting personal information across home networks, wireless routers, WiFi networks, or similar devices to reduce the risk of unauthorized access. When using unencrypted, open-access, or otherwise unsecured networks (such as the internet), you are responsible for the security of your own information.

In the event of any actual or potential unauthorized access, disclosure, alteration, or loss of personal information, we will promptly implement remedial actions. Where required by applicable laws and regulations, we will also notify relevant government authorities and affected individuals without undue delay.

How long do we retain your information?

The duration for which your information is retained depends on the purpose for which it is utilized. In certain instances, specific legal obligations require data to be preserved for a minimum period. Absent such legal requirements, we retain your information only as long as necessary to fulfill the original collection purpose.

LEM will retain personal data: (i) as required by applicable law, (ii) if the data is relevant to ongoing or anticipated legal proceedings, or (iii) in order to establish, exercise, or defend LEM’s legal rights, including sharing information with others for fraud prevention and cybersecurity purposes.

Your Rights in Relation to your personal data

Pursuant to relevant laws and regulations, you may be entitled to specific rights regarding your personal information, which may include but are not limited to the following:

  • request access to your personal data held by LEM and obtain information regarding that data, such as the purposes for its processing, recipients to whom it has been or will be disclosed, the retention period, details of any automated decision-making processes, and your right to submit a complaint to a supervisory authority;
  • request LEM to rectify any inaccurate personal data concerning you and complete any incomplete personal data;
  • request LEM to delete or anonymize your personal data if it is no longer needed;
  • object to or limit LEM’s processing of your personal data, including for direct marketing, and opt out of further marketing emails;
  • request LEM to supply an electronic copy of the personal data in a structured, commonly used, and machine-readable format;
  • contact the data protection supervisory authority of your country if you have any concern about the use of your personal data.

These rights may be restricted or excluded in certain circumstances, such as when there are uncertainties regarding identity, to protect other individuals, to safeguard legitimate interests, or to fulfill legal requirements.

You may contact us using the details provided below. When your inquiry is received, you will be asked to verify your identity and specify the type of information requested. Requests will be addressed in accordance with relevant timelines and at no cost, unless responding would require disproportionate effort. Applicable laws and regulations in certain jurisdictions may impose restrictions on the exercise of personal information rights. In such instances, LEM will act in accordance with those legal requirements.

LEM may be required to retain certain information for backup and record-keeping purposes in accordance with applicable legal obligations, or to complete transactions initiated before a request for change or deletion (for example, if you make a purchase or enter a promotion, it may not be possible to change or delete the provided personal data until that purchase or promotion is complete).

Automated decision making

“Automated individual decision-making” refers to decisions made entirely by automated means, without any relevant human intervention, that have legal effects or otherwise significantly impact the individual concerned. We do not currently engage in such automated decision-making. Should we choose to implement automated individual decision-making in specific cases, you will be informed accordingly and provided with the opportunity to request a human review of the decision if you disagree with its outcome. If we implement such processes in the future, you will have the right to obtain human intervention, express your point of view, and contest the decision.

Concerns and Complaints

If you have concerns about how your personal information is processed, you may contact us at privacy@lem.com. We will address your request upon authentication of your identity. A response will be provided within a reasonable timeframe. You may also submit a formal complaint to the appropriate regulator in your jurisdiction.

Contact Details

LEM has appointed a Data Protection Officer (DPO) responsible for overseeing our data protection strategy. You may contact the DPO at: privacy@lem.com.

If you have any questions, concerns, or complaints regarding this Privacy Statement, please contact us at: privacy@lem.com