Privacy and Cookie Policy
Last updated: August 8, 2025
Introduction
Welcome to Lucentum Aerospace, LLC's Privacy and Cookie Policy. We are committed to protecting your personal information and respecting your privacy. This policy explains how we collect, use, and safeguard personal data (also referred to as "personal information") when you use our website (lucentumaerospace.com). It is designed to comply with applicable privacy laws, including the European Union's General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), and other relevant United States privacy laws.
By using our website or providing us with your information, you agree to the terms of this Privacy and Cookie Policy.
Information We Collect
We only collect personal information that is necessary for the purposes described in this policy. The types of personal data we may collect include:
· Contact Information: When you fill out our contact form or otherwise reach out to us, we may collect your name, company or organization, job title, email address, and phone number. This information is provided directly by you and is used to communicate with you and respond to your inquiries.
· Technical Data: When you visit our website, certain information may be collected automatically by our web server or through essential cookies. This can include your Internet Protocol (IP) address, browser type, operating system, referring URL, and the date and time of your visit. We collect this data to ensure the website functions properly, maintain security, and analyze basic traffic (without identifying any individual). We do not use this data for profiling or marketing purposes.
We do not intentionally collect any sensitive personal data (such as information about health, race, religion, or political opinions), nor do we knowingly collect any information from children (see Children’s Privacy below).
California Notice: In the past 12 months, we have collected the above types of personal information, which correspond to the following categories defined in the CCPA: identifiers (e.g. name, contact details); professional or employment-related information (e.g. company, job title); and internet or other electronic network activity information (e.g. IP address and site usage data). We collect these categories of information directly from you (for contact details) and automatically from your interactions with our site (for technical data).
How We Use Your Information
We use the personal information we collect for the following purposes:
· To Respond to Inquiries: The primary use of your contact information is to communicate with you. If you contact us via the website (for example, to request information about our services), we will use your name and contact details to respond to your inquiry or provide the requested information.
· To Operate and Improve Our Website: We use technical data (like server logs and essential cookies) to ensure our site functions correctly, to troubleshoot issues, and to protect against fraud or security threats. This helps us maintain a secure and user-friendly website.
· To Comply with Legal Obligations: In certain cases, we may need to process and retain your information to fulfill our legal obligations, such as complying with applicable laws, regulations, court orders, or enforcement requests.
· To Enforce Our Rights: We may use information as necessary to enforce our website’s terms and conditions, to protect our rights, privacy, safety, or property, and those of our users or others.
We will not use your personal information for any purpose that is incompatible with the purposes described above without obtaining your consent. In particular, we do not use the information you provide to send unsolicited marketing communications.
Legal Bases for Processing (EU/UK Visitors)
If you are in the European Economic Area (EEA) or the United Kingdom, we process your personal data on the following legal bases, as established by the GDPR:
· Consent: By contacting us and providing your personal information, you are giving consent for us to use that information to respond to you. You may withdraw your consent at any time, though this will not affect the lawfulness of processing based on consent before its withdrawal.
· Legitimate Interests: We may process certain data as necessary for our legitimate interests, provided those interests are not overridden by your data protection rights. For example, it is in our legitimate interest to maintain the security of our website (using IP addresses and technical data to detect and prevent fraud or attacks) and to communicate with business contacts or prospective clients who have reached out to us. If you contact us in a professional capacity, we rely on our legitimate interest in responding and maintaining that correspondence.
· Legal Obligation: We will process personal data if necessary to comply with a legal obligation to which we are subject. For instance, we may retain correspondence or information as required by law or to respond to lawful requests by public authorities.
(If you later enter into a contract with us, we may also process your personal data as necessary to perform that contract, but currently our website’s primary function is informational and for contact purposes.)
Cookies and Similar Technologies
What are Cookies? Cookies are small text files that are stored on your device when you visit websites. They are widely used to make websites work efficiently and to provide information to the site owners. There are different types of cookies, such as essential (necessary) cookies, analytics cookies, and advertising cookies.
How We Use Cookies: On lucentumaerospace.com, we only use cookies that are strictly necessary for the operation of the website. These essential cookies enable core functionality such as security and network management, or allow you to use features like filling out forms. Because they are necessary for the site to function, we do not request your consent to use these essential cookies. We do not use any non-essential cookies. This means:
· We do not use analytics cookies (e.g., Google Analytics) to track your behavior.
· We do not use advertising or marketing cookies.
· We do not use tracking cookies to profile you or collect information about your browsing across other sites.
In summary, our cookie use is limited to what is essential for you to navigate and use our site’s features.
Embedded Content from Third Parties: Our website may include embedded content provided by third parties. For example, we feature an interactive graphic from an external service called Flourish. This embedded content functions similarly to visiting the third-party’s own website for that piece of content.
According to the provider, Flourish does not place any cookies on your device when its content is embedded on our site. However, when you view the embedded content, your browser may automatically send certain technical data (such as your IP address and browser details) to the third-party content provider in order to retrieve the content. We do not control data collected by third-party embeds for their purposes. We encourage you to review the privacy policies of any third-party services that provide content on our site. (Aside from the Flourish embedded graphic, we do not use any other third-party analytics or social media plugins on our site.)
Managing Cookies: Since we only use essential cookies, there is no need for a cookie consent banner on our site. If you prefer to block or delete cookies, you can do so through your web browser settings. Most browsers allow you to refuse new cookies, disable existing cookies, or notify you when new cookies are being set. Please note that if you disable or delete cookies that are necessary for the site to function, some features of our website may not work properly for you.
“Do Not Track” Signals: Some web browsers offer a “Do Not Track” (DNT) feature that lets you signal websites that you do not want to be tracked. Given that we do not engage in tracking activities or use non-essential cookies, our website does not change its behavior in response to DNT signals. We do not track users across third-party websites, and we do not allow third parties to track you on our site.
Sharing and Disclosure of Information
We treat your personal information with care and confidentiality. We do not sell, rent, or trade your personal information to third parties for their own marketing or other purposes. We also do not share your information with third parties, except in the limited scenarios described below:
· Service Providers: We may share your information with trusted third-party service providers who perform services on our behalf, such as web hosting companies, email delivery services, or IT support. These service providers are given access only to the information necessary to perform their functions, and they are contractually obligated to protect your information and use it only for the purposes of providing services to us.
· Business Transfers: If we ever decide to restructure or sell all or part of our business, or if we merge with another business, your personal information may be transferred to the new owners or partners as part of that transaction. In such cases, we will ensure that the confidentiality of personal data is maintained and you are notified as required by applicable law.
· Legal Requirements: We may disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to comply with a legal obligation. This includes situations where we might respond to lawful requests by public authorities (such as a court order, subpoena, or government request), or where disclosure is necessary to establish, exercise, or defend our legal rights. We may also disclose information to investigate or assist in preventing security threats, fraud, or other malicious activity, or to protect the rights, property, or safety of Lucentum Aerospace, our users, or others.
Aside from the parties and purposes described above, your information is not shared with any other third parties. Importantly, we do not disclose your personal data to third parties for their own advertising or marketing purposes, and personal data you provide to us (such as through the contact form) is kept private and is not publicly visible on our website.
California Notice: In the last 12 months, we have not sold any personal information, and we have not shared personal information for cross-context behavioral advertising (as defined under the CPRA). We may have disclosed personal information to service providers for legitimate business purposes (for example, providing our web services or facilitating communications, as described above), but such disclosures are not sales. Because we do not sell personal information, we do not offer an opt-out from the sale of personal information. If this ever changes, we will update this policy and provide a clear way to opt-out.
Data Security
We take reasonable and appropriate measures to protect the personal information we hold from unauthorized access, alteration, disclosure, or destruction. These measures include technical, administrative, and physical safeguards. For example, our website is hosted on secure servers, and we use measures such as firewalls and encryption where appropriate. We also limit access to personal data: only personnel or service providers who need the information to perform a specific task or purpose are granted access to personal information, and they are subject to confidentiality obligations.
Please note that while we strive to protect your personal information, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee absolute security. You should also take care with how you handle and disclose your personal information and avoid sending sensitive information via unencrypted email. If you have reason to believe that your interaction with us is no longer secure (for example, if you suspect a security vulnerability on our website), please contact us immediately.
Data Retention
We will retain your personal information only for as long as necessary to fulfill the purposes we collected it for, including any legal, accounting, or reporting requirements. For example, if you contact us with an inquiry, we will keep your contact information and correspondence for as long as is needed to respond to you and follow up, and for a reasonable period thereafter in case you have additional questions or to maintain records of our communications.
In general, once personal data is no longer needed for the purposes outlined in this policy, we will delete it or anonymize it in our systems. In certain cases, we may retain data longer if required by law (for instance, retaining certain business records for compliance or tax purposes) or if necessary to protect our legal rights (such as information related to legal disputes). When we have no ongoing legitimate need to process your personal information, we will ensure it is either securely deleted or stored in a way that it is isolated and protected until deletion is possible.
International Data Transfers
Lucentum Aerospace is based in Spain, and the personal data we collect is generally processed and stored in Spain or other countries within the European Union. However, the information you provide through our website could be accessed or transferred to locations outside of your state, province, or country. For example, if you are located outside of the EU and you contact us, your information will be transferred to the EU. Additionally, we may use certain service providers or email systems that are based outside the EU or that use servers in other jurisdictions (for example, a U.S.-based email service).
Whenever we transfer personal data out of the European Economic Area (EEA) to third countries that are not deemed to provide an adequate level of data protection, we will ensure appropriate safeguards are in place as required by GDPR. This may include using specific contractual clauses (Standard Contractual Clauses) approved by the European Commission, or ensuring the recipient is certified under an approved framework (such as the EU-U.S. Data Privacy Framework, if applicable) or other legally recognized provisions. These measures are put in place to protect your personal information and ensure that your rights and protections travel with your data.
If you have any questions about international data transfers or the safeguards we apply, you can contact us using the information provided in the Contact Us section below.
Your Privacy Rights
Depending on your jurisdiction (for example, whether you are in the EU or California, or another U.S. state with privacy laws), you may have certain rights regarding your personal information. We are committed to honoring applicable rights requests in accordance with the relevant data protection laws.
Your Rights Under GDPR (EU/EEA and UK)
If you are located in the European Union, European Economic Area, or the United Kingdom, you have the following data subject rights under the GDPR and corresponding UK law:
· Right to Access: You have the right to request confirmation of whether we are processing your personal data, and if so, to request a copy of the personal data we hold about you. We will provide you with a copy of your information in a commonly used electronic format, unless you request otherwise.
· Right to Rectification: You have the right to request that we correct any inaccuracies in your personal data or complete any data that is incomplete. If you believe any information we hold about you is inaccurate or out-of-date, please let us know and we will rectify it.
· Right to Erasure: You have the right to request the deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or when other conditions are met (for example, if you withdraw consent and no other legal basis for processing applies). This is sometimes referred to as the “right to be forgotten.” Please note that this right is not absolute – sometimes we may need to retain certain information to comply with legal obligations or for legitimate business reasons.
· Right to Restrict Processing: You have the right to ask us to restrict or suspend the processing of your personal data in certain circumstances – for example, if you contest the accuracy of the data or if you want us to preserve data for legal reasons.
· Right to Data Portability: You have the right to request a copy of personal data you have provided to us in a structured, commonly used, and machine-readable format, and you have the right to transmit that data to another data controller where technically feasible. This right applies when the processing is based on your consent or a contract with you, and the processing is carried out by automated means.
· Right to Object: You have the right to object to our processing of your personal data in certain situations. In particular, you can object to processing that is based on our legitimate interests, and we will assess whether we have compelling grounds to continue processing. You also have the right to object at any time to any processing of your data for direct marketing purposes – however, note that we currently do not process your data for direct marketing.
· Right to Withdraw Consent: If we are processing your personal data based on your consent, you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of any processing we conducted prior to your withdrawal.
· Right to Lodge a Complaint: If you believe that we have infringed your data protection rights, you have the right to lodge a complaint with a supervisory authority, particularly in the EU Member State where you live or work, or where an alleged infringement took place. For example, if you are in Spain, you can contact the Spanish Data Protection Agency (AEPD).
To exercise any of your rights under GDPR, please contact us at the email address provided in the Contact Us section. We will respond to your request in accordance with applicable law, typically within one month.
Your Rights Under California Law (CCPA/CPRA)
If you are a resident of California, you are entitled to certain rights with respect to your personal information under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA). These rights include:
· Right to Know: You have the right to request that we disclose what personal information we collect, use, disclose, and (if applicable) sell or share. You may request that we provide you with the specific pieces of personal information we have about you, as well as additional details such as the categories of personal information we have collected, the categories of sources of that information, the business or commercial purposes for collecting it, and the categories of third parties with whom we share it. (This Privacy Policy is intended to provide much of that information.) Upon verifiable request, we will provide the required information for the 12-month period preceding your request.
· Right to Delete: You have the right to request that we delete personal information we have collected from you, subject to certain exceptions. Once we receive and confirm a verifiable deletion request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. For example, we may retain information necessary to complete a transaction you requested, to detect security incidents, to comply with legal obligations, or other reasons permitted by law.
· Right to Correct: You have the right to request that we correct inaccurate personal information that we hold about you. Upon verifying your identity and the accuracy of the new information, we will correct our records accordingly.
· Right to Opt-Out of Sale or Sharing: You have the right to opt out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising. However, as noted above, we do not sell personal information, nor do we share your information for targeted advertising purposes. Therefore, there is no need to submit a request to opt-out, as we do not engage in those practices. We also do not use or disclose sensitive personal information for any purpose that would trigger a right to limit its use under California law.
· Right to Non-Discrimination: We will not discriminate against you for exercising any of your California privacy rights. This means we will not deny you services, charge you a different price, or provide a different level of quality of services just because you exercised your rights under the CCPA/CPRA. (Please note that if the deletion of certain information makes it impossible for us to provide a service you request, we will inform you of that consequence and honor your decision whether or not to proceed.)
· Shine the Light: Separately from the CCPA, California’s “Shine the Light” law allows users to request information about our disclosure of personal information to third parties for their direct marketing purposes. However, we do not disclose personal information to third parties for their direct marketing purposes.
Submitting Requests: If you are a California resident and wish to exercise any of your rights under CCPA/CPRA, please contact us using the information in the Contact Us section below. You can make a request by email. Please specify which right you wish to exercise and provide us with enough information to verify your identity. We will only use the personal information provided in a rights request to verify the request and to fulfill it.
Authorized Agents: You may designate an authorized agent to make a request on your behalf. If you do so, we will take steps to verify that the person acting as agent is properly authorized to do so, which may include requesting that you provide a signed written authorization or that the agent provides proof of their authorization and your identity.
We aim to respond to verifiable consumer requests within the timeframes set by law (typically within 45 days, with the possibility of a 45-day extension when reasonably necessary). If we need more time, we will inform you of the reason and extension period in writing.
Other U.S. State Privacy Rights
Several U.S. states (such as Virginia, Colorado, Connecticut, and others) have enacted their own privacy laws that provide residents with rights regarding their personal information (for example, rights to access, correct, or delete personal data, and to opt out of certain data uses). If you are a resident of a U.S. state that provides privacy rights, you may contact us to exercise those rights. We will honor valid requests in accordance with applicable state laws.
In general, we extend the core privacy rights to all our users, not just those in specific jurisdictions. This means that regardless of where you live, you can contact us with concerns or requests about your personal information, and we will do our best to accommodate your request in line with our legal obligations and company policies.
Children’s Privacy
Our website and services are not directed to children under the age of 13 (and in certain jurisdictions, such as the EU, our site is not intended for children under the age of 16). We do not knowingly collect personal information from anyone under 13 years old. If you are under 13, please do not provide any personal information to us.
If we become aware that we have inadvertently collected personal data from a child under 13 (or under 16, where applicable law provides a higher age threshold), we will take steps to delete that information as soon as possible. If you are a parent or guardian and you believe we might have collected information from your child, please contact us immediately so we can address the issue.
Changes to This Policy
We may update this Privacy and Cookie Policy from time to time to reflect changes in our practices, technologies, legal requirements, or for other operational reasons. When we make changes, we will revise the "Last updated" date at the top of this policy. Any changes will become effective when we post the revised policy on our website.
If the changes are significant, we may provide a more prominent notice (such as adding a statement on our homepage or contacting you via email if we have your email address) to inform you of the updates. We encourage you to review this policy periodically to stay informed about how we are protecting your information.
Contact Us
If you have any questions, concerns, or requests regarding this Privacy and Cookie Policy or your personal data, please do not hesitate to contact us. We are here to help and address any issues you may have.
You can reach us by email at rod.pirniakan@lucentumaerospace.com.
We will respond to your inquiries as soon as reasonably possible, and certainly within any timeframes required by law.
Thank you for trusting Lucentum Aerospace with your personal information. We value your privacy and will continue to work hard to protect it.
