Last Updated: Oct 11, 2019

This privacy policy (the "Policy") sets forth the general principles to be applied by Lemento for the use, collection, retention, protection and disclosures of Personal Data, including Personal Data relating to current and prospective clients, employees, and suppliers or otherwise obtained in the operations. All Processing of Personal Data by Lemento shall be carried out in compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679.

Lemento values your privacy and strive to make our policies clear and transparent to our Clients. This Privacy Policy describes Lemento's collection, use, and disclosure of personal data, as well as the rights You have with respect to Your Personal Data. For any questions regarding this Privacy Policy please contact Us at info@lemento.com.

IF YOU WANT TO ACCESS, EDIT OR OBTAIN YOUR PERSONAL DATA OR DATA COLLECTED ABOUT YOU, PLEASE CONTACT US.

If you are interested in and wish to review what personal data Lemento potential have on you, contact us. If you wish for Lemento to erase or not share your personal data at all, simply fill out here. If you decide to opt out from any future prospect search, Lemento will not continue to Process nor disclose your information.

1. SCOPE

Lemento uses a search service with a built-in email system. The search algorithm relieves relevant contact information on people with the purpose to help our clients to connect with potential prospects over business matters that matter to them. All personal contact information is generated by the algorithm upon each individual request.

Please note that Lemento care deeply about your privacy and how any data is being shared.

If you come across a breach of this Privacy Policy or wish to file a complaint on how Lemento processed your personal data or in any way think your privacy has not been handled in accordance with this Privacy Policy, do not hesitate to contact us directly at info@lemento.com.

2. GENERAL

This Privacy Policy outlines Lemento's ("Lemento", "the Company", "our", "us" or similar) practices with respect to generating, collecting, using and disclosing your information when providing our Product or Services . This also constitutes a part of Lemento's Terms of Service (collectively, the "Agreement").

Lemento uses a search algorithm. Therefore any personal data provided by the system will always be retrieved from the open web or computationally just-in-time predicted based on pattern recognition. Email addresses are sometimes retrived from 3rd party vendors.

Lemento care deeply about your security and privacy. Lemento commits to protect the privacy of:

  • Visitors of Lemento's website (the "Site")

  • Our clients who use the Lemento product ("Clients"),

  • Individuals' contact information, most commonly an email address, title, full name and current employer ("Prospect"), which is collected and obtained in Lemento's Search Algorithm.

The term "you" shall refer to Clients or Prospects, as applicable.

Lemento may change its Privacy Policy in Lemento's sole discretion. Lemento encourages Visitors, Clients and Prospects to frequently visit this page and pay attention to any changes to this Privacy Policy.

This Privacy Policy will cover information about practices related to:

  • Lemento's Search Algorithm

  • Use of Cookies

  • What type of information Lemento collect and why

  • How Lemento care about and protect your information

  • What happens in the case of a Business transfer

  • How to best get in contact with Lemento

3. DEFINITIONS

Controller shall mean the natural or legal person or entity which alone or jointly with others determines the purposes and means of the Processing of Personal Data.

Personal Data shall mean any information relating to an identified, or in some jurisdictions, identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to one or more factors specific to his/her physical, physiological, mental, economic, cultural or social identity or by information such as identification number, bank or credit card records, social security/insurance number, telephony/fax number, email address and address.

Process(ing) shall mean any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.

Processor shall mean a natural or legal person, which Processes Personal Data on behalf of the Controller.

4. SEARCH ALGORITHM

Lemento uses a search algorithm service with a built-in email system. The search algorithm relieves relevant contact information on people with the purpose to help our clients to connect with potential prospects over business matters that matter to them. Lemento never store any data on our prospects nor do Lemento intend to do so - all personal contact information is generated by the algorithm upon each individual request.

IF YOU WANT TO ACCESS, EDIT OR OBTAIN YOUR PERSONAL DATA OR DATA COLLECTED ABOUT YOU, PLEASE CONTACT US.

Lemento's algorithms process the open web in order to identify Prospects and the most accurate contact information related to the Prospect. The purpose of processing any personal data is to enable relevant and mutually beneficial business connections. Any personal data is processed on the basis of our legitimate interest of providing our Services and fulfilling our business agreements as a Processor.

Please do review the section "Your Rights Regarding Your Personal data" to learn more on your rights in accordance with applicable privacy and data protection regulations.

5. INFORMATION COLLECTED

Lemento generates, computationally predicts and collects information for Prospects that is available for the public on the open web. Email addresses are sometimes retrived from 3rd party vendors.

Lemento strives to keep the minimum amount of personally identifying information needed for Lemento's processing activities, such as providing its Product or Services. Lemento has different retention policies for Clients, Prospects and Visitors.

Personal Data will be Processed in accordance with applicable law and any applicable contractual obligations.

5.1 Prospects

Lemento only collects information limited to what's necessary or appropriate for the legitimate interest of:

  • Fulfilling the Agreement with Lemento's Clients

  • Administering Client's payment to Lemento

  • Providing a better Client and Visitor experience

  • Providing support to Clients

Lemento does not disclose personal data other than as what is being mentioned and disclosed in this Privacy Policy document. Prospects, Clients and Visitors can always request to erase or obtain any personal data. If a Client refuse to supply personally identifying information, that may cause major limits for Lemento to fulfill their business agreement.

The data is limited to:

  • Full Name

  • Professional email address with a corporate domain.

  • Current employer

  • Current professional title

5.2 Visitors

Lemento collects non-personally identifying information on Visitors to the Site. The purpose of this data collection is to prevent scraping, hacking or any other potential security threats. Lemento also uses this non-personally identifying information to measure activity behaviour on the site and use potential insights to bring our Visitors a better experience. This data is limited to:

  • IP-address

  • Browser information

  • Language preference

  • Referring site

  • Visitor location

  • Date and time of visit

  • Frequency in visits

5.3 Clients

Lemento collects personally identifying information on our Clients. Lemento uses this data to monitor the activity on the Site and use of the Product in order to provide a pleasant Service. Lemento also use this data for billing and transactional information pursuant to the Clients use of the Site and Service. This data is limited to:

  • Full name of the Client

  • Billing address

  • Email address

  • VAT number

  • IP-address

  • Browser information

  • Language preference

  • Search queries

  • Referring site

  • Visitor location

  • Date and time of visit

  • Frequency in visits

Lemento will by all reasonable means protect its product against unauthorized access and hence any processed personally identifying information.

Lemento will disclose personally identifying information if requested by the government in response to a court order or subpoena. Lemento might, in good faith, disclose personally identifying information to protect any intellectual property or rights of Lemento or third parties.

Lemento only disclose personally identifying information to of its employees, contractors and partners with a non-disclosure agreement or has an explicit need to process the information in order to provide sub-services available in Lemento's Product or Service. Lemento reserves the right to engage partners of any kind, including subcontractors to make sure the Product or Service is being provided to Lemento's Clients. Lemento will guarantee that any data transfer outside of EU will be made in accordance with the law and current data protection legislation.

5.4 Retention

5.4.1 Clients

Lemento will only keep data on Clients for a reasonable retention period in order to provide its Product or Service and fulfill the agreement to the Client, which is 7 years from the Processing Date. Lemento will keep personally identifying information on its Clients for accounting purposes for 10 years from the Processing Date.

5.4.2 Visitors

Lemento will only keep non-personally identifying data on Visitors for a reasonable retention period in order to provide its Product or Service, which is 2 years from the Processing Date.


Clients and Prospects can at any time request their personal data to be removed by using this form. Lemento will immediately remove any personally identifying information on Prospects and Clients unless Lemento need to comply with the current legislation.

6. COOKIES

Lemento uses cookies in order to provide a better Product and Service to Lemento's Clients and Visitors. Lemento uses third-party Services who set the cookies. Lemento allow partners to recognize the Visitors or Clients computer whenever they might interact with the Site. Please note that this Privacy Policy covers only Lemento's Services the use of cookies. This Policy does not, in any way, cover the use of cookies by any partners.

Visitors and Clients can at any time opt-out from Lemento's cookie use by setting your browser to opt out from letting the Site place any such cookies. Please do note that this setting is not recommended. Lemento visitors who do not want Lemento to place cookies on their computers might see drawbacks and specific features or the Product or the Service might not function at all.

7. HOW Lemento PROTECTS YOUR INFORMATION

Lemento will establish all reasonable and appropriate safeguards to protect Personal Data from unauthorized use, disclosure, destruction and alteration. Lemento will ensure to do our very best to respect your choices and requests regarding your personal data.

You always have the right to know how Lemento use your personal data. You also have the right to request any personal data records on you erased. Lemento can not guarantee that your information may be accessed by unauthorized individuals, companies or similar. Lemento will review the requirements under national law for the Processing of Personal Data, including without limitation any duty to notify data protection authorities, and any duty to appoint a data privacy officer. Your information may be transferred to organizations outside the European Union.

Please review your rights regarding the processing of your personal data.

  • Right of Access: Lemento will support any request made by you to access your personal data. Lemento will share a copy of personal data being processed by Lementos Services. Lemento will provide any personal data on promptly and free of charge. Please note that this Privacy Policy will respond to the purpose for processing of personal data. You may at any time requests access to your data by filling in your relevant details here.

  • Request to access and correction of Personal data: If an individual makes a request to access Personal Data relating to him or her, or requests to have errors in his or her Personal Data corrected and can demonstrate the existence of a relevant error or omission, Lemento will consider and satisfy such request, where it considers it as appropriate or where it is required to do so by applicable law. If stipulated in national law, an administration fee for complying with such a request may be charged.

You may request to edit or update any missing data that Lemento process about you, by contacting Lemento at info@lemento.com and point out any errors or personal data that you wish to update. Lemento will not accept nor save inaccurate data edits. Please note that Lemento may remove incomplete or inaccurate information, at any time and at our own discretion.

  • Right of Erasure: Lemento will accept requests at any time to erase your personal data and promptly act on your request. If Lemento notices any overriding legitimate interest for keeping your personal data for the processing, e.g. to comply with legal obligations or similar, Lemento will inform you about the process and the exception from this Privacy Policy. Lemento will always erase personal data on Prospects if requested by the individual it concerns. You may at any point request to erase your data by contacting us at info@lemento.com.

7.1 Unauthorized access

Lemento apply industry standard security procedures to protect your personal and to prevent unauthorized access and use of any such information. Lemento cannot be held responsible for the acts of those who gain unauthorized access or abuse our Services. Lemento will not make any warrants to prevent such access.

7.2 Transfer of Personal data outside the European Union

Lemento is a global company it may hence be necessary to transfer personal outside the European Union. Lemento will ascertain that any transfer of data outside the EU/EEA is performed in accordance with the applicable data protection legislation.

8. BUSINESS TRANSFER

If Lemento goes out of business, enters bankruptcy or a substantial part of its assets are acquired, Clients, Prospects and Visitors information would be one of the assets that is transferred or acquired by a third party.

You acknowledge that such transfers may occur, and that any acquirer of Lemento may continue to use your personal data as set forth in this policy.

9. GOOGLE USER DATA

Additional Limits on Use of Your Google User Data: Notwithstanding anything elsein this Privacy Policy, if you provide Lemento.com access to the following types of your Google data, Lemento.com's use of that data will be subject to these additional restrictions:

Lemento.com will only use access to read, write, modify or control Gmail message bodies (including attachments), metadata, headers, and settings to provide a web email client that allows users to compose, send, read, and process emails and will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.

- Lemento.com will not use this Gmail data for serving advertisements.

- Lemento.com will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for Lemento.com's internal operations and even then only when the data have been aggregated and anonymized.

10. HOW TO CONTACT US

Please do not hesitate to reach out to:

Lemento bvba
Stanislas Leclefstraat 18
2600 Berchem, Belgium

or via email at info@lemento.com.


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