Privacy Policy

Introduction

Welcome to Lucid Group Communications Limited’s and its global affiliates’ (“Lucid”) privacy policy. 

Lucid respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. 

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.

1. Purpose of this privacy policy

This privacy policy aims to give you information on how Lucid collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter. 

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them. 

Controller

Lucid is made up of different legal entities. This privacy policy is issued on behalf of the Lucid Group so when we mention “Lucid”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Lucid Group responsible for processing your data. For a full list of entities in the Lucid Group, see the Glossary below.

We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the Data Protection Officer using the details set out below. 

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our Data Protection Officer in the following ways:

Full name of legal entity: Lucid Communications Group Limited

Email address: [email protected]

Postal address: Middlesex House, 34-42 Cleveland St, London W1T 4JE, UK

Complaints

You have the right to make a complaint at any time and may lodge a complaint to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. 

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 1 February 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We do not make any representations or warranties about any third-party website, we have no control over the information, services, products they provide, or the manner or methods they employ to collect, store, access, or otherwise use your personal data. When you leave our website, we encourage you to read the privacy policy of every website you visit. If you provide personal data at a third-party websites, you are subject to the privacy policy of the operator of that website, not our Privacy Policy.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website. 
• Profile Data includes your username and password, your interests, preferences, feedback and survey responses.  
• Usage Data includes information about how you use our website, products and services. 
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • create an account on our website;
  • when you update or change your account information;
  • when you communicate with us via e-mail, telephone or other methods;
  • subscribe to our service or publications; 
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; 
  • apply for employment with us (please see our candidate privacy notice); or
  • give us feedback or contact us. 

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies. Please see our cookie policy for further details on our use of cookies.

• Third parties or publicly available sources. We will receive personal data about you from various third parties as set out below. 

Technical Data from the following parties:

• analytics providers such as Google; 
• advertising networks;
• search information providers;
• Identity and Contact Data from publicly available sources such as corporate registries (e.g. Companies House and the Electoral Register in the UK);
• identity verification services; 
• fraud detection service providers; 
• credit bureaus;  
• mailing list providers; and
• publicly available sources.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data. Although, where we are required by law, we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

If you choose not to provide any personal data that is necessary for us to provide you with specific products or services, we may not be able to provide those products or services to you.

5. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we  use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below. 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy (b) Asking you to leave a review or take a survey	(a) Identity  (b) Contact  (c) Profile  (d) Marketing and Communications	(a) Performance of a contract with you  (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey	(a) Identity  (b) Contact  (c) Profile  (d) Usage  (e) Marketing and Communications	(a) Performance of a contract with you  (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity  (b) Contact  (c) Profile  (d) Usage  (e) Marketing and Communications  (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical  (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you	(a) Identity  (b) Contact  (c) Technical  (d) Usage  (e) Profile  (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business)
To send you marketing communications based on what we think you may want or need, or what may be of interest to you (including via email and text)	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile Data	Where we are required by law, we will obtain your consent to send you direct marketing communications via email and text. We will also get your express opt-in consent before we share your personal data with any third party for marketing purposes.  Otherwise, we rely on our legitimate interests (to promote our products and services).  You can ask us to stop sending you marketing messages at any time by contacting us.
To prevent fraud (including identity fraud) and abuse, verify your identity and authenticate users	(a) Identity  (b) Contact  (c) Profile  (d) Usage  (e) Marketing and Communications  (f) Technical	(a) Necessary to comply with a legal obligation (b) Necessary for our legitimate interests (to protect our business from fraudulent activity)
To identify and fix problems with the services	(a) Identity  (b) Contact  (c) Profile  (d) Usage  (e) Marketing and Communications  (f) Technical	(a) Performance of a contract with you (b) Necessary for our legitimate interest (to spot and solve issues related to our services)
To conduct data analysis, testing, market research, monitor and analyse usage and activity trends	(a) Identity  (b) Contact  (c) Profile  (d) Usage  (e) Marketing and Communications  (f) Technical	Necessary for our legitimate interest (to keep our website updated, to develop products/services, to assist our marketing strategy)
To resolve disputes, establish, exercise, and defend legal claims.	(a) Identity  (b) Contact  (c) Profile  (d) Usage  (e) Marketing and Communications  (f) Technical	Necessary for our legitimate interest (protecting the business from potential legal and reputational risks)
Send you notices of a transactional, administrative or relationship nature, or as required by law	(a) Identity  (b) Contact  (c) Profile  (d) Usage  (e) Marketing and Communications  (f) Technical	(a) Necessary to comply with a legal obligation (b) Necessary for performance of a contract

Change of purpose 

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

• Lucid Group.  We share your personal data with other Lucid Group affiliates, subsidiaries and group companies where it is in our legitimate interests to do so for internal administration purposes and for the Purposes set out in this privacy policy. 
• Service Providers. We share your personal data with third parties that provide us with services that enable us to operate our website and provide you with our service. 
• Law enforcement and/or government agencies.  In certain circumstances, we may be required to share your personal data with law enforcement and/or government agencies. 
• Additional Third Parties. We may share your personal data with legal counsel, accounting firms, investigators, information technology providers to (i) enforce this Privacy Policy and our Terms of Services, including investigation of potential violations hereof; (ii) detect, prevent, or otherwise address fraud, security or technical issues; (iii) respond to user support requests, or (iv) protect our rights, property or safety, our users and the public. 
• Company Sale. Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy. 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

Your personal data will be shared with or accessed by other companies within the Lucid Group and/or third party service providers. Due to the global nature of Lucid’s business, this will involve transferring your data outside your country of residence.

Whenever we transfer your personal data outside your country of residence, we ensure a similar degree of protection is afforded to it in the recipient country by ensuring at least one of the following safeguards is implemented: 

• We transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; and/or
• We use specific contracts approved for use in your country of residence which give personal data the same protection it has in your country of residence (such as the EU Standard Contractual Clauses and/or UK International Data Transfer Addendum).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data internationally. 

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

10. Your legal rights

Depending on where you reside, you may have various rights under applicable data protection laws in relation to your personal data. These may include the right to: 

• Request access to your personal data
• Request correction of your personal data
• Request erasure of your personal data
• Object to the processing of your personal data
• Request restriction of processing your personal data
• Request transfer of your personal data to another organisation
• Right to withdraw consent

For more information on these rights, and specific rights that apply in your jurisdiction, please see the Glossary below.  If you wish to exercise any of the rights set out above, please contact us.  

No fee usually required

You will not usually have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of the other rights you may have). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

11. Children

The Services are not directed to or intended for children under 13 years of age. We do not knowingly solicit, collect or maintain information from those we actually know are under 13, and no part of our Services are targeted to attract anyone under 13. We also do not send e-mail correspondence to anyone who advises that they are under the age of 13.  If we later obtain actual knowledge that a user is under 13 years of age we will take steps to remove that user’s Personal Information from our systems.  If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us (see “Contact details” above) so that we may delete and remove such information from our system.

12. Glossary

LUCID GROUP

The Lucid Group is made up of the following entities: 

Lucid Communications Group Limited, Middlesex House, 34-42 Cleveland St, London W1T 4JE, UK

DiD Agency Group LLC, 30 South 15th Street, Suite 1300, Philadelphia, PA 19102

Synetic Life Sciences Limited, Middlesex House, 34-42 Cleveland St, London W1T 4JE, UK

Lighthouse Medical Communications Limited, 30 South 15th Street, Suite 1300, Philadelphia, PA 19102

LAWFUL BASIS

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of a contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

YOUR LEGAL RIGHTS

Depending on where your reside, you have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. 

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: 

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims. 
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. 

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. 

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

YOUR LEGAL RIGHTS FOR US RESIDENTS

California users rights

Pursuant to California Civil Code Section 1798.83, also known as the “Shine The Light” law, California residents have the right to request in writing from businesses with whom they have an established business relationship: (i) a list of the categories of Personal Information, such as name, address, e-mail address, and the type of services provided to that individual, that a business has disclosed to third-parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third-parties. We do not share Personal Information with third parties for those parties’ direct marketing. To request the above information, California residents can e-mail us at [email protected] or write to us at Lucid Group Communications Limited, 30 South 15th Street, Suite 1300, Philadelphia, PA 19102. Please note that, under California law, a business is only required to respond to such a request twice in any calendar year.

Do Not Track. Some web browsers may let you enable a “do not track” feature that sends signals to the websites you visit, indicating that you do not want your online activities tracked.  This is different than blocking or deleting cookies, as browsers with a “do not track” feature enabled may still accept cookies.  There is currently no industry standard for how companies should respond to “do not track” signals, although one may develop in the future.  We do not respond to “do not track” requests or signals at this time.

Nevada users rights

Nevada law allows Nevada consumers to “opt out” of the sale of their personal data (referred to as “covered information” under the Nevada law) to third parties.  “Covered information” includes your name, address, social security number, and online service activity. A “sale” is defined as the exchange of covered information for monetary consideration by the website operator to a person for that person to then license or sell the covered information to additional persons.  Lucid does not sell this information to third parties, so no opt-out is required. If you are a Nevada consumer and wish to request additional information, please e-mail us at [email protected] or write to us at Lucid Group Communications Limited, 30 South 15th Street, Suite 1300, Philadelphia, PA 19102.