The term “Lancium” is used herein to refer individually and collectively to Lancium, Inc., Lancium LLC, and its various affiliates and subsidiaries. Lancium’s mailing address is: 9950 Woodloch Forest Drive, Suite 1600, The Woodlands, TX 77380.
Lancium can also be reached via email by firstname.lastname@example.org.
1. Privacy Commitment
Lancium collects different information about you in different situations, which are described in more detail below. This information may include your name along with information such as: address, email address, phone number, fax number, IP address, or other information that might identify you as an individual (“Personal Information”).
As a general matter, we may disclose Personal Information:
- when authorized by you or when necessary to provide a service you have requested;
- to communicate with you about issues related to you or your account, or a request for service;
- when necessary to comply with an order of a government agency or court, when requested by a government regulator, or as otherwise required by law, or requested in writing by law enforcement;
- to investigate and address system problems and to protect the security of the Website; or
- to a purchaser in connection with the sale, assignment, or other transfer of all or part of our business or company.
Additionally, we may disclose your Personal Information to individual vendors, contractors and third-party service providers who assist us in providing you with services, or with other permitted uses of your Personal Information (subject to appropriate confidentiality agreements and controls).
The following sections describe in more detail the information we collect and how we use that data.
2. Information We Collect Automatically
When you visit our Website, we collect limited analytical information about interactions with the Website. We use this information for a number of purposes including updating our web pages to make them more user-friendly, diagnosing problems, and for security purposes. This information may also be used in the aggregate in order to evaluate our Website’s effectiveness and to improve performance.
3. Information We Collect Directly from Users
In connection with your use of the Website, we may collect your name, addresses, telephone number, and email address when you provide it to us. We use this information to provide any requested service, notify you about updates or changes to our Website, or alert you when new services, options, products, or features become available. You should not send us or disclose any sensitive personal information via the Website.
4. Information We Collect From Job Applicants
If you apply for a job via the Website, we collect information that we need to evaluate your application, such as your resume, contact, and job application information. We endeavor not to disclose information contained in resumes or job applications to third parties, except as provided in this policy. We endeavor to limit internal access to resumes and job applications to those individuals who need to know this information. We use the information you provide as necessary to evaluate your job application. In connection with your job application, we may provide your information to certain third parties (subject to appropriate confidentiality agreements), including for the purpose of administering and processing your application, and performing background checks and drug screenings.
5. Information We Collect From Vendors and Potential Vendors
As a vendor or potential vendor to Lancium, we collect the information that we need, including Personal Information of vendor contacts, to process applications to become a vendor to Lancium. For example, we may use this information to conduct background checks and drug screenings about vendor employees and contractors. We may also use it to evaluate vendor’s work and proposals to work, process payments, comply with reporting obligations, and for other internal business purposes.
6. Email Addresses, Postal Mail Addresses, and Phone Numbers
Individuals who supply their addresses (email or postal mail) or phone numbers (land-line or cell) may receive periodic messages from Lancium with information on new products and services, upcoming events or news that may be of interest, account-related information, information about your job or vendor application, information on your job-related activities (if employed by Lancium). If you do not want to receive such communications from Lancium in the future (except with respect to communications in connection with your Lancium account, your request for service, your job or vendor application, or your job-related activities, if employed by Lancium), please let us know by emailing us at email@example.com and telling us that you do not want to receive these types of communications. We will comply with such requests as required by law.
Please note that because there is no consistent industry understanding of how to respond to “Do Not Track” signals, we do not alter our data collection and usage practices when we detect such a signal from your browser.
7. Information Sharing
We may share your Personal Information with vendors, contractors or service providers and contractors to help us provide the Website and fulfill obligations to you, such as to database and cloud service providers, hosting platforms, customer management services, cybersecurity services, and professional services such as legal and accounting. We share this information based upon applicable valid legal bases including legitimate interests and performance of a contract. We may also share your Personal Information any time we have your consent. We may freely share aggregated information.
We may share Personal Information with a buyer or successor in the event of a merger, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which Personal Information held by us may be among the assets transferred.
8. Submissions to Lancium
9. Your Rights and Choices
We respect your privacy and seek to provide you with options to manage the Personal Information collected about you while you are using the Website. We abide by the privacy laws applicable to you based upon your jurisdiction.
Notice to California Residents:
Please note the CCPA contains certain exceptions to applicability with respect to employees, job applicants and business contacts. These rights do not apply to California job applicants, employees, or business contacts.
You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable Consumer request, we will disclose to you:
- The categories of Personal Information we collected about you;
- The categories of sources for the Personal Information we collected about you;
- Our business or commercial purpose for collecting, sharing, or selling that Personal Information;
- The categories of third parties with whom we share that Personal Information;
- The specific pieces of Personal Information we collected about you (also called a data portability request) and provide a copy to you in an electronic or paper format; and
- The categories of Personal Information, if any, we disclosed for a business purpose to a third party.
You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable Consumer request, we will delete (and direct our Contractors and Service Providers to delete) your Personal Information from our (and their) records, unless an exception applies (as described below).
As permitted by CCPA we may delete your Personal Information by (a) permanently and completely erasing the Personal Information on our existing systems with the exception of archived or back-up systems; (b) de-identifying the Personal Information; or, (c) aggregating the Personal Information.
We may deny your deletion request if retaining the information is necessary for us or one of our Contractors or Service Providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.);
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal, regulatory or law enforcement obligation; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative of that person and
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm that the Personal Information relates to you. Making a verifiable Consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable Consumer request to verify the requestor’s identity or authority to make the request.
Upon receiving a data access, correction, data port or deletion request from you, we will verify your identity based on the information we have on file for you. Upon verification of your identity, we will proceed to process your request (subject to the exceptions stated above). We endeavor to confirm receipt of your request within ten (10) days of receiving it. We will respond to a verifiable Consumer request within forty-five (45) days of its receipt. If we require more time (up to an additional forty-five (45) days), we will inform you of the reason and extension period in writing. We will deliver our written response via email to the email address associated with you or, if we are unable to determine your email address, via mail.
Any disclosures we provide will only cover the 12-month period preceding the verifiable Consumer request receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. We will not discriminate against you simply for exercising your rights under the CCPA.
Notice to Residents of Non-U.S. Countries: Our headquarters is in the United States. The Personal Information we or our service providers and contractors collect may be stored and processed in servers within or outside of the United States and certain Personal Information may be accessible by persons or companies outside of the United States who provide services for us. As such, we and our service providers and contractors may transfer your Personal Information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take reasonable steps to ensure that your Personal Information receives an adequate level of protection in the jurisdictions in which we process it.
Notice to Residents of the European Union and United Kingdom:
If you are a resident of the European Union or the United Kingdom (also referred to as a “Data Subject”), the General Data Protection Regulation (“GDPR”) provides you with additional rights regarding our use of your Personal Data. This section is provided pursuant to the GDPR. Each capitalized term used, but not defined, in this section shall have the meaning given to such term in the GDPR. This section describes how we collect, share, disclose, and process the Personal Data of residents of the European Union and United Kingdom. “Personal Data” means any information relating to an identified or identifiable natural person (referred to ‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person and includes all “Personal Information” otherwise referred to in this Policy.
If you are located in the European Union or the United Kingdom, you have certain rights regarding the Personal Data that we maintain about you, which in certain circumstances you will be able to exercise. The rights are as follows:
- Access: You may request a copy of the Personal Data we maintain about you.
- Portability: If we maintain your Personal Data based on your consent or so that we can enter into or perform under a contract with you, you have the right to obtain your Personal Data from us that you consented to give us, that is necessary to enter into or perform the contract, or that is necessary to provide member benefits to you. We will give you your Personal Data in a structured, commonly used and machine-readable format.
- Correction: If you believe your Personal Data is incorrect, you may request that we correct, amend or delete your Personal Data that is inaccurate or incomplete.
- Deletion or Restriction of Processing: You may request that we erase or restrict the processing of your Personal Data.
- Object to Processing: You may object to the processing of your Personal Data in certain circumstances when we process your Personal Data for the purposes of our legitimate interests.
- Right to Complain: You have the right to file a complaint with a supervisory authority, in particular in the European member state of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of your Personal Data infringes upon your rights.
- Withdraw Consent: If we are processing your Personal Data based on your consent to do so, you may withdraw that consent at any time.
Some of these rights can be exercised online via your account. For example, you can review and modify certain information relating to your use of our Website and unsubscribe to email messages. If you are unable to manage your request via your online account, then please contact us using the contact information at the end of this policy.
We collect Personal Data that is reasonably necessary for us to provide our Website. Subject to applicable exceptions, we will obtain your consent before collecting, using and disclosing your Personal Data for the specified purposes. In addition to circumstances in which you consent to the use of your Personal Data, the Personal Data we collect may be used or processed where we have a legitimate interest in or other legal basis for processing such data. The categories of your Personal Data we collect and the purposes for which we collect such Personal Data are provided in this policy. If we use Personal Data in ways other than described in this Policy, we will provide you with specific notice at the time of collection. The ways in which we share your Personal Data and the purposes for which we share it are provided in this policy. If we use Personal Data in ways other than described in this Policy, we will provide you with specific notice at the time of collection.
We only process Personal Data when we have a legal basis to do so including:
- When you have consented to the processing of your Personal Data, including processing your Personal Data consistent with this Policy, including the advertising purposes disclosed in this Policy;
- When processing is necessary to perform our obligations to you or fulfill a request you have made to us;
- When processing is necessary to comply with a legal obligation that applies to us; or
- When processing is necessary for purposes that are in our legitimate interests and you have given any required explicit or implicit consent to such processing, including protecting the security of our Website, improving the functioning of our Website, or providing you with information about products in which you have expressed interest.
If we need to process your Personal Data to fulfill our obligations to you, failure to provide that Personal Data will mean that we cannot perform our obligations. If we collect your Personal Data for one purpose and need to process it for second purpose, we will provide you with additional information regarding this secondary purpose to ensure fair and transparent processing before we engage in further processing. Collecting and processing your Personal Data to create both general and targeted advertising is a primary purpose for collecting your Personal Data.
10. Data Security
We maintain administrative, technical and physical safeguards designed to protect Personal Information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
11. Children’s Data
Our Services are for adults and are not directed to children. Should an individual whom we know to be a child under the age of 18 send Personal Information to us, we will delete or destroy such information as soon as reasonably possible. If you believe a child has provided us with Personal Information, please contact us through the means indicated at the end of this policy to request deletion.
12. General Provisions
When you access our Services, we will retain your Personal Information as long as it is necessary for the processing purpose in question or in accordance with our data retention policy. We determine the appropriate retention period based on the nature and sensitivity of the Personal Information being processed, the risk of harm due to unauthorized access versus the benefit of retention, and whether we can achieve the purposes of processing through other means. We may retain your Personal Information for longer periods if required by law, if you give us your permission, or in case of a legal dispute in which your Personal Information may be used as evidence.
We do not profile or use automated decision making.
As part of our customer service assurance practice, telephone conversations over phones may be monitored or recorded as a part of normal business operations. Monitored or recorded calls will be used for quality assurance and training purposes.
13. Links to Other Websites
Our Website may contain links to other sites for your convenience and information. These sites may be operated by companies not affiliated with Lancium. Linked sites may have their own privacy policies or notices, which we strongly suggest you review if you visit them. We are not responsible for the content of any sites that are not affiliated with us, any use of those sites, or the privacy practices of those sites.
9950 Woodloch Forest Drive, Suite 1600
The Woodlands, TX 77380
Attn: Legal Department
Phone: (833) 526-2486
Last Updated: October 1, 2022