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Privacy Policy

The Nexa Lumen entity, as outlined in the Nexa Lumen’s Terms of Service, ("NexaLumen"), offers web hosting, domain name registration, and associated products and services to customers and subscribers ("Subscribers") (referred to collectively as “You” or "Users").
NexaLumen is dedicated to upholding the highest standards of data privacy while providing a range of quality products and services to its customers and subscribers. At NexaLumen, safeguarding the privacy and security of our Users is our top priority. We are committed to safeguarding the information you entrust to us.

When we mention "NexaLumen," "we," "us," or "our" in this Policy, we are referring to NexaLumen, which is responsible for protecting your personal information in accordance with this Privacy Policy ("Data Controller").

This Privacy Policy ("Policy") outlines how NexaLumen processes information that may directly or indirectly identify an individual ("Personal Data") collected through our website, services (“Service”), forums, and mobile applications ("Platform").
All personal data is handled in compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

For any inquiries about this Policy or requests concerning the processing of personal data, please reach out to us at [email protected]
NexaLumen is committed to processing all Personal Data by the fundamental principles of data processing:
1. Lawfulness, fairness, and transparency:

NexaLumen shall handle Personal Data in a lawful, fair, and transparent manner in relation to the data subject.
2. Purpose limitation: 

NexaLumen shall only collect and process Personal Data for specified, explicit, and legitimate purposes. Personal Data shall not be further processed in a manner that is incompatible with these purposes.
3. Data minimization: 

NexaLumen shall ensure that the Personal Data collected is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.
4. Accuracy: 

NexaLumen shall strive to ensure the accuracy of Personal Data and, where necessary, keep it up to date.
5. Storage limitation: 

NexaLumen shall retain Personal Data in a form that permits identification of data subjects for no longer than is necessary for the purposes for which it was processed.
6. Integrity and confidentiality 

NexaLumen shall process Personal Data in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing, accidental loss, destruction, or damage, through the use of suitable technical or organizational measures.
All information stored on NexaLumen's Platform is regarded as highly confidential. It is securely stored and can only be accessed by qualified and authorized personnel.
3.1. The information you provide to us.
NexaLumen Platform information necessary for use

When you utilize the NexaLumen Platform, we request and gather certain personal information from you. This data is essential for ensuring the proper execution of the contractual agreement between you and us, as well as for us to fulfill our legal responsibilities. Failure to provide any of this information or opting to delete or object to the processing of such data may lead to the deactivation of your NexaLumen Account.
Account Registration Details: 

When signing up for NexaLumen, we mandate minimal information - namely, your email address and password. On occasion, additional information such as your first and last name, along with identity verification and contact details, may be requested, particularly for domain name registration where it is designated as WHOIS information.
Login Credentials: 

We gather Login scope and Email scope from Google, as outlined in https://developers.google.com/identity/protocols/oauth2/scopes?hl=en. From Facebook (Meta), we collect email, name, and surname based on your preference.
Identity Verification:  

In compliance with regulations established by the Internet Corporation for Assigned Names and Numbers ("ICANN"), NexaLumen may gather identity verification details (e.g., passport images, national ID card, valid driver's license, or other relevant documents permitted by law) prior to registering a new domain name.
Payment Details:  

To facilitate payment processing for ordering and utilizing features on the NexaLumen Platform (e.g., web hosting, domain name registration), we may request financial information. We utilize third-party payment processor services and do not retain credit card information; instead, we receive payment status information and store only the last four digits of credit cards.
Communications and Messaging: 

Information is collected regarding communications with NexaLumen (via general inquiries) along with any provided or disclosed information. To address your inquiries, access may be required to details within your NexaLumen Account, purchase history, etc.
Job Applicants' Data: 

Information provided by job applicants applying to career positions published on https://www.NexaLumen.com/career, via email, or other means is also collected. Refer to Section 5 for further details.
Visitors and Users of User's Websites or Services: 

Information regarding visitors and users of our Users' websites or services ("Users-of-Users") may also be gathered, solely on behalf of our Users.
You also have the option to furnish us with information when completing a form, performing a search, updating or supplementing details in your NexaLumen Account, participating in surveys, contributing to community forums, engaging in promotions, or utilizing other features of the NexaLumen Platform. We recommend refraining from sharing any information on the NexaLumen Platform that you prefer to keep private. Should you choose to upload content to your account or publish it on your website, or provide it through any other means while using any Service, you do so at your own discretion.
NexaLumen processes the information you provide to us on the legal basis of:

• Your explicit consent, is given when voluntarily submitting your Personal Data details through sign-up forms, emails, requests, or inquiries.

• The establishment and execution of contractual agreements and obligations between NexaLumen and the User.

• The pursuit of NexaLumen's legitimate interests as the Data Controller and manager of the NexaLumen platform.

• Compliance with legal obligations applicable to NexaLumen, which may include ICANN rules among others.

• https://www.icann.org/resources/pages/approved-with-specs-2013-09-17-en#whois.

To protect your personal information, please observe at least the following minimum requirements:

Please refrain from including personal details such as your name, address, phone number, email, ID number, birth date, bank account number, card number, or other sensitive information in the subject line of your request or file name.

Additionally, avoid mentioning personal identifiers like your personal code, payment card number, financial details, health information, family member details, or any other sensitive data in the body of your requests, emails, or similar communications with us.

Ensure that any remaining personal data is only provided to the extent necessary for your letter, request, or inquiry.

You have the right to delete your data

You have the option to access, modify, update, or remove your contact information by logging into your NexaLumen platform Account.

It's important to note that you can only delete your email address when deactivating your NexaLumen Account. To deactivate your Account, please send a request to [email protected], and you will receive additional instructions.
Information pertaining to your participation in calls or meetings:

If you contact NexaLumen or schedule a meeting, NexaLumen Ltd. may record these conversations for quality management purposes. This allows us to uphold and enhance the quality of NexaLumen services in line with our standards and policies. For this purpose, we will process the following data: your email address, the date and time of the conversation, its duration, audio and/or video recordings, and any other personal data provided voluntarily during the conversation. 

Additionally, the provided email address and/or phone number may be used to facilitate communication with you regarding your matter.

In such instances, processing is deemed necessary to serve the legitimate interests pursued by NexaLumen (as per Article 6(1)(f) of the GDPR), or is based on your consent when you agree to video recording by enabling video, or provide specific data voluntarily (under Article 6(1)(a) of the GDPR).

These recordings will be retained for up to 30 days and then deleted as soon as technically feasible.

3.2. The information we collect when you use our platform

When utilizing the NexaLumen Platform or reaching out to us through any communication channel, we may gather data, including personal information, regarding the services you utilize and your usage patterns.

This data is essential for ensuring the proper execution of the agreement between you and us, enabling us to fulfill legal obligations, and aligning with our legitimate interest in delivering and enhancing the features of the NexaLumen Platform.
Data collection automatically:
Log Data and Device Information:

When accessing and utilizing the NexaLumen Platform, we automatically gather log data and device details, even if you haven't created a NexaLumen Account or logged in. This includes information such as Internet Protocol (IP) addresses, browser types, Internet service providers (ISPs), referring/exit pages, operating systems, date/time stamps, and clickstream data.
Tracking Technologies and Cookies:

We employ various technologies like cookies, beacons, tags, scripts, and similar methods, including CI codes (click tracking), ISC (source tracking), and ITC (item tracking codes). Additionally, we automatically collect information about your device's operating system, phone model, device ID, and customer number. For further details on the usage of these technologies, please refer to our privacy policy. see our Cookies Policy.
Usage Information:

We utilize a tool named "Google Analytics" to gather data regarding your interactions with the NexaLumen Platform. This includes the pages you visit, the content you view, your searches for listings, bookings you've made, and other activities on the NexaLumen Platform. As a result, Google, Inc. installs a persistent cookie on your web browser to recognize you as a unique user during your future visits to this site. For more information please visit Google.
Geo-location Data:

We gather data about your general location, determined by information like your IP address, to enhance your user experience and adhere to relevant legal obligations, such as taxation and pricing requirements. This information is only collected when you access the NexaLumen platform using your device.
NexaLumen processes this information based on the following legal grounds:

• Your explicit consent

• Execution and fulfillment of contractual agreements and obligations between NexaLumen and the User

• Pursuit of NexaLumen's legitimate interests as the Data Controller and manager of the NexaLumen platform
We utilize, retain, merge, and handle information, including personal data, concerning you to deliver, comprehend, enhance, and advance the NexaLumen Platform, establish and sustain a reliable and more secure environment, and adhere to our legal responsibilities.
To Identify:

Personal identification information is gathered and processed to verify User identity, facilitate service usage and domain name registration, and offer support. Additionally, it may be utilized to communicate important updates, including changes to Terms of Use and this Policy.
To Create and Maintain Trusted Environment: 

We authenticate provided information such as ID numbers, email addresses, and phone numbers to prevent fraud, spam, abuse, and ensure a secure environment.
To Create Aggregated Statistical Data: 

We use aggregated and inferred non-personal information for market research, analysis, and business improvement purposes.
To Stay Connected: 

Data on usage, devices, and operating systems is utilized for server diagnostics, platform administration, and optimization of applications and services.
To Customize Marketing: 

Data analysis is conducted based on user-provided information and interactions with the NexaLumen Platform to offer personalized offers.
To Send Service and Billing Messages: 

Important information regarding services, maintenance, support tickets, payments, and policy changes may be communicated through various channels without opt-out options.
To Inform about Unfinished Orders: 

Email notifications about unfinished orders are sent to improve user experience, with the option to opt-out provided.
To Register Domain: 

Domain name registration information may be publicly accessible through WHOIS searches, in compliance with ICANN rules. NexaLumen is not responsible for solicitations resulting from WHOIS searches.
To Contact You: 

Communication may occur regarding account notifications, troubleshooting, dispute resolution, fee collection, surveys, updates, and enforcement of agreements, via email, telephone, text messages, or portal.
To Gather Feedback: 

Feedback may be solicited via email to improve services, potentially involving sharing your name, email address, and reference number with an external company.
• To deliver, manage, and enhance the Services.
• To bolster data protection measures and deter fraudulent activities.
• To adhere to relevant legal requirements and regulations.
We may gather, store, and handle specific information concerning visitors and users of our Users' websites or services, solely on behalf of and as directed by our Users. Each User has the ability to collect and manage information, including personal data, through their website, with such information then being stored by NexaLumen. 

As outlined in the Terms of Service, in certain limited instances, NexaLumen may be considered a "data processor" of such information related to visitors and users of our Users' websites or services. 

The Users who control and operate these websites are regarded as the "data controllers" of this information and are solely responsible for ensuring compliance with all relevant laws and regulations, including privacy and data protection laws.

Users are responsible for the security, integrity, and lawful usage of information pertaining to visitors and users of their websites or services, as well as for obtaining necessary consents, permissions, and providing any required notices for the collection and usage of such information.

NexaLumen does not have a direct relationship with individual visitors and users of our Users' websites or services whose personal data is processed. If you are a customer of any of our Users and wish to make requests regarding your personal data, please contact the relevant User(s) directly.

For further details on the data processing arrangement between NexaLumen and our Users, please refer to our Terms of Service.
NexaLumen invites all eligible candidates to apply for any open positions listed on https://www.NexaLumen.com/career. Applicants are required to provide their contact details and resume ("Applicant Information") through the designated Position Application Form on our website or via other provided channels.

We recognize the importance of privacy and confidentiality for our applicants and are dedicated to maintaining the privacy of Applicant Information, utilizing it exclusively for NexaLumen's internal and group company recruitment purposes. This includes identifying applicants, assessing their applications, making hiring decisions, and communicating with applicants via phone or written correspondence.

NexaLumen may retain Applicant Information for up to one year after the position for which the application was submitted has been filled or closed. This enables us to reconsider applicants for other opportunities within NexaLumen, use their Applicant Information as a reference for future applications, and utilize it for additional employment and business-related purposes if the applicant is hired.

If you have previously submitted Applicant Information to NexaLumen and would like to access, update, or delete it from our systems, please contact us at [email protected].
When registering an Account on our Platform, you have the option to provide consent and/or opt-out preferences for receiving various offers and/or notifications directly via email, phone (SMS and/or WhatsApp messages), or within your Account settings. 

We utilize the provided contact details and your chosen preferences for direct marketing purposes (including sending offers or newsletters) and/or for issuing service expiration notices/renewal reminders.

Depending on your selected preferences, this communication may be customized, taking into consideration any additional information you have provided to us (such as location, social media profile details, purchase history, etc.), or information collected or generated from other sources as outlined below.

Please be aware that if you opt-in to receive service expiration notices/renewal reminders via SMS/WhatsApp, we reserve the right, but are not obligated, to send such notices/reminders for each Service.

Consent can be revoked / objected to

If a User wishes to change their preferences communication (revoke consent or object), they are free to exercise such option at any time they wish by (1) following the instructions to unsubscribe in the received email (usually, by clicking on a link for that purpose at the bottom of our e-mail) / text message; (2) visiting and adjusting User’s personal account settings (communication preferences).

You may also at any time refuse to receive information from us by sending an email to [email protected]
Platform Development:

We utilize data, including public feedback, to conduct research and development aimed at enhancing our platform. This is done to provide you and other users with an improved, more user-friendly, and personalized experience, thus driving membership growth.
Customer Support: 

Data is employed to assist you and address issues. We utilize this data, which may include your communications, to investigate, respond to, and resolve complaints and issues, such as bugs.
Aggregate Insights: 

Data is used to generate aggregated insights. We leverage your data to create and share aggregated insights that do not personally identify you.
Security and Investigations: 

Data is utilized for security, fraud prevention, and investigations. We employ your data, including your communications, when deemed necessary for security purposes or to investigate potential fraud or other violations of our Terms of Use or this Policy, as well as attempts to harm our users.
We gather and obtain your Personal data directly from you (including your device) as well as from the subsequent origins:

• Social network providers (like Facebook, Google, etc.);
• Third-party service providers, suppliers, and our collaborators;
• Other lawful channels.
We typically keep your personal information for as long as necessary to deliver our services and fulfill our legal obligations. Once your personal information is no longer needed, we ensure its secure deletion.

Should you wish to cease our use of your personal information, you can request the erasure of your personal information and the closure of your NexaLumen Account.
Following the deactivation of your Account, we will still retain certain data to comply with relevant legal requirements, such as tax, accounting, legal reporting, AML, and others, for the duration mandated by such obligations.

A profile containing de-identified information (where your email will be changed to [email protected], and your name, surname, and contact details will be erased) including purchased services, login details, payment information, etc.

In such cases, we may also retain some of your personal information (i.e., after closing your NexaLumen Account):

• For as long as necessary to safeguard our legitimate business interests, such as detecting and preventing fraud, and enhancing safety. If we suspend your NexaLumen Account for safety reasons, we may keep certain information to prevent you from creating a new NexaLumen Account in the future.

• To the extent required to fulfill our legal obligations. We may retain some of your information for tax, legal reporting, and auditing purposes.

• Forum posts or other publicly visible information may remain accessible on the NexaLumen Platform even after your NexaLumen Account is deactivated. However, any attribution of such information to you will be removed. Additionally, some copies of your information (such as log records) may persist in our database but will no longer be linked to personal identifiers.

• To resolve disputes and enforce our agreements, as well as to pursue or safeguard our legitimate interests.

• As we protect the NexaLumen Platform from accidental or malicious loss and destruction, residual copies of your personal information may remain in our backup systems for a limited period of time.

• Domain name registration data: Currently, when registering a domain, we are required to provide personal information about the domain owner, which is displayed in the WHOIS directory and is public. For further details, please refer to https://www.icann.org/registrants.
We may transfer your Personal Data to third parties while collecting and processing it.
11.1. With your permission
Your Personal Data will be shared with companies, organizations, or individuals outside our group when you give your consent.
11.2. How are your personal data processed?
• Users' Personal Information may be stored, processed, and managed by NexaLumen and its authorized affiliates and service providers in various locations, including the United Kingdom, Netherlands, Lithuania, or Cyprus, as necessary for the provision of our Services and to comply with legal requirements.

• Job Applicants' Information will be stored, processed, and managed primarily in Lithuania, at the location(s) relevant to the applied position(s), and may also be securely stored in cloud storage provided by our Third-Party Services.

• NexaLumen Ltd is headquartered in Cyprus, an EU member state that provides an adequate level of protection for the Personal Information of EU residents.

• Our affiliates and service providers, including third-party data centers, servers, website administration services, and marketing providers, are contractually obligated to maintain the security and confidentiality of your personal data, regardless of the legal requirements in their respective jurisdictions.

• Domain name registration data and identification information is shared with third parties in compliance with ICANN regulations. For more details, please refer to https://www.icann.org/resources/pages/approved-with-specs-2013-09-17-en#whois.
We may share anonymized information publicly and with our partners, such as publishers and advertisers, to illustrate usage trends on our platform.

In the event of a merger, reorganization, acquisition, or sale, we will uphold the confidentiality of any Personal Data and provide appropriate notices to all affected Users.

Some of our servers are located outside the EU or European Economic Area (EEA), including in the US, Brazil, Singapore, Indonesia, Australia. Depending on your preferences or the Services you use, your personal data, as well as the personal data of your users, may be transferred to processors or other recipients in these third countries. We ensure that such transfers comply with GDPR and other applicable laws.

We have established agreements with data processors and sub-processors in third countries to ensure that data transfers outside the EU or EEA comply with GDPR standards. These agreements adhere to the European Commission's approved standard contractual clauses for such transfers.

Additionally, personal data may be transferred to third countries based on other legal grounds compatible with GDPR requirements.

In certain circumstances, NexaLumen may be required to disclose personal data to public or competent authorities, including for national security or law enforcement purposes, in accordance with applicable data protection laws.
11.3. Obligations related to data localization
If you live in a jurisdiction with "data localisation" or "data residency" requirements, which mandate that the Personal Information of residents must be stored within the jurisdiction's boundaries, we will comply with these obligations if legally required.

You understand that in doing so, we may still collect, store, and utilize your Personal Information in other locations.
11.4. Advertising and targeting
We utilize Facebook, Google, and other advertising and marketing platforms. It's important to review the privacy policies of these service providers. For further details on targeted advertising, along with your options to opt-out and exercise other rights, please refer to the respective websites of these service providers. - https://lt-lt.facebook.com/policies/ads#; https://policies.google.com/technologies/ads.
11.5. The features of social media
Our Services offer various Social Media features and widgets, as well as single sign-on options like "Facebook Connect" or "Google Sign-in", along with interactive mini-programs such as the "Facebook Like" button or the "Share this" button ("Social Media Features"). These features may gather details like your IP address or the page you're currently viewing on our Website, and may utilize cookies to function effectively. Social Media Features can be hosted by third parties or directly on our Services. Your interactions with these Social Media Features from third parties are subject to their individual policies.
11.6. Using and disclosing personal information is our legal obligation
We will disclose your Personal Data to state and public authorities without prior consent only when it's legally mandated, including situations where we need to take legal action to protect our rights. Additionally, we may disclose information if we have a good faith belief that such action is necessary to comply with applicable laws, regulations, legal processes, or enforceable governmental requests, as well as to enforce our Terms of Services, investigate potential violations, or address fraud, security, or technical issues.
11.7. Other
Your personal data may be shared in ways not outlined above, either with your explicit consent or if we are legally required to do so.
NexaLumen has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. Among other things, we offer HTTPS secure access to most areas on our Services. We also regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third-Party Services for further enhancing the security of our Services and protection of our Visitors' and Users' privacy.

NexaLumen has implemented various security measures to safeguard the Personal Information you entrust to us. These measures include physical, electronic, and procedural safeguards. For instance, we provide secure HTTPS access to most areas of our Services. We continuously monitor our systems for potential vulnerabilities and threats and explore new methods and third-party services to enhance the security of our platform and protect the privacy of our Visitors and Users.

Despite our efforts, it's important to note that we cannot guarantee the absolute security of your Personal Information or any User Content you share with us or others. We advise you to create strong passwords for your User Account and refrain from sharing sensitive information that could potentially cause you harm if disclosed.
If you have any concerns or questions regarding the security of our Services, please feel free to reach out to us at [email protected]
You have various rights concerning the safeguarding of your Personal Data, which are governed by GDPR and relevant laws. These rights are subject to certain limitations, restrictions, and conditions as outlined in the legislation.:

• The right to access the data we hold about you.
• The right to correct any inaccuracies in your information.
• The right to transfer your data to yourself or another controller, where technically possible (subject to limitations under GDPR).
• The right to have your data deleted under certain circumstances, such as when it is no longer needed for its original purpose or has been unlawfully processed.
• The right to restrict the processing of your data for legitimate reasons.
• The right to object to the processing of your Personal Data, particularly in cases of legitimate interest or direct marketing activities, as outlined in this Policy.

Some of the rights mentioned above are straightforward to exercise. For example, you can access, update, or modify your details at any time by visiting your personal account settings or by contacting us via email at [email protected] to opt out of receiving communications from us and our partners.

If you object to the processing of your Personal Data based on legitimate interest, we will carefully review your request. Depending on the circumstances, this may lead to the closure or deactivation of your Account.

Users also have the right to file a complaint with the National Data Protection Agency in their country of residence if they believe their rights have been violated. However, we encourage attempting to resolve any disputes by reaching out to us first for a peaceful resolution.
By using the NexaLumen Platform, all Users are assumed to have thoroughly reviewed and agreed to the terms outlined in this document. If anyone disagrees with this Policy, they should refrain from using our website and mobile applications. 

We reserve the right to modify our Policy at any time and will notify users as outlined in Section 17. Continued use of NexaLumen's website and mobile applications constitutes acceptance of the updated Policy.

This Policy forms an integral component of NexaLumen's Terms and Conditions.
Before utilizing information for purposes not outlined in this Policy, we will seek your consent.
If you have any questions or comments regarding this Privacy Policy, please contact us at: [email protected]
Our Policy encompasses all services provided by us and our affiliates, including NexaLumen, a private limited liability company registered in the Republic of Bulgaria under code 207736544, with its legal address at Sofia, Bulgaria. However, it does not extend to services with separate privacy policies that do not incorporate this Policy.

Our Policy does not cover services provided by other entities or individuals, including products or websites that may appear in search results, sites featuring our services, or other sites linked to our services.
Our Policy is subject to occasional updates. Any changes to the Policy will be published on our website, and if deemed significant, we may also provide additional notice, such as email notifications for certain services, regarding the Policy updates.
If you have additional inquiries about the data collected by NexaLumen or its usage, please don't hesitate to reach out to the Data Protection Officer using the contact information provided above.
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