This policy explains which personal data Luscii collects about you as an employee, contractor or temporary staff member, why and on what legal basis, who can see it, how long it’s kept and what your rights are. Questions and requests go to the Privacy Expert.

Nucleus: Live · Owner: @Anne Pasdeloup · Reviewed: 24 Sept 2026

1. Introduction

Luscii (the "Company", "we", "our" or "us") values the trust of our employees and is committed to protecting their personal information. This Employee Privacy Policy ("Policy") applies to all our employees, contractors and temporary staff ("employees" or "you") and describes how we collect and use your personal data during and after your working relationship with us.  The Company is the data controller of your personal data. We encourage you to carefully read this Policy, together with any other privacy notice or policy we may provide on specific occasions.

2. Purposes for using your personal data

  1. We refer to Appendix 1 for the categories of personal data that we collect and use about you.  We collect and use this personal data for the administration and management of day-to-day aspects of your employment with us. More specifically, we use your data for the following purposes:
    1. administration of the contract we have entered into with you;
    2. the administration of working hours and payment of wages;
    3. for making decisions about your continued employment with us;
    4. for making arrangements for employment termination;
    5. for management of personnel (e.g. employee performance reviews, assessment, development and training requirements);
    6. the administration and operation of the Company's policies and procedures;
    7. complying with applicable laws and regulations, such as maternity or parental leave legislation, working time and health and safety legislation, taxation rules, compliance with requests from governmental agencies or judicial services and other employment laws and regulations applicable to us;
    8. dealing with employee legal disputes and to establish, exercise and defend (potential) legal claims;
    9. to ensure your health and safety in the workplace and to assess your fitness to work, to provide appropriate workplace adjustments, to monitor and manage sickness absence and to administer benefits;
    10. for work planning purposes (e.g. planning and assignment of tasks to our employees)  k. liaising with insurance, pension and health providers and complying with our obligations in that regard;
    11. in the framework of our whistleblowing system;
    12. for the management of IT systems and operational processes within the Company (e.g. our HR systems, logs and monitoring of email or Internet use).
    13. other purposes permitted by applicable privacy and data protection legislation including legitimate interests pursued by the Company where this is not overridden by the interests or fundamental rights and freedoms of our employees.
    14. in the framework of our communication and collaboration platforms (e.g. global directory, communication portal, exchange and storage of information).

3. Legal bases for collection and use of your personal data

At all times, we collect and use your personal data in accordance with applicable data protection laws. This means that we will only use your personal data if this is adequate, relevant and limited to what is necessary in relation to the purposes for which the data were collected (as set out above).

The Company only processes your personal data on the basis of one of the following legal bases:  a. To perform the contract we have entered into with you;  b. To comply with a legal obligation to which we are subject;  c. Where this is necessary for our legitimate (business) interests (or those of a third party) and your interests and fundamental rights do not override those interests. Legitimate interest pursued by us include the purposes described in the section above headed "Purposes for using your personal data" under (f), (i) and (l) to (n). Furthermore, our legitimate interests are our interests to secure, defend and develop our business and people and to make strategic and corporate responsibility decisions that we deem necessary. Where required, we will inform you about further legitimate interests where this becomes relevant.  d. Where we have your explicit consent. In principle, we do not rely on your consent for processing your personal data. However, in limited circumstances we may approach you for your consent to allow us to process certain personal data. If we do so, we will provide you with full details of the data that we would like and the reason we need it, so that you can carefully consider whether you wish to freely consent. We will also inform you about the fact that you can revoke your consent at any time and how you should do that. You should be aware that withholding your consent will never have an impact on your employment with us or will otherwise negatively affect you.

4. Retention of your personal data

We retain your personal data for as long as required to satisfy the purpose for which they were collected and used, unless a longer period is required by law or necessary to defend a legal claim. Usually, we retain your data for the duration of your employment with us. However, longer statutory retention periods apply to certain records. As statutory retention periods can vary depending on the record at stake, please contact the Privacy Expert or [email protected] to find out more.

5. Security

We take reasonable steps to ensure that your personal data are properly secured using appropriate technical, physical, and organizational measures, so that they are protected against unauthorised or unlawful use, alteration, unauthorised access or disclosure, accidental or wrongful destruction, and loss.  We take steps to limit access to your personal data to those persons who need to have access to it for one of the purposes listed in this Policy. Furthermore, we contractually ensure that any third party processing your personal data equally provides for confidentiality and integrity of your data in a secure way.

6. Who has access to your personal data?

We may share personal data of our employees with:  a. Other employees of the Company. On a strict need to know basis only;  b. Other HR employees of the Omron Group. On a strict need to know basis only.  c. Service Providers. We may engage third party service providers, and affiliated entities to provide services to us on our behalf. In providing their services, they may access, receive, maintain or otherwise process personal data on our behalf. Consistent with applicable legal requirements, we take commercially reasonable steps to require third parties to adequately safeguard your personal data and only process it in accordance with our instructions.  d. Third parties in case of legal requirement. We may also disclose your personal data if we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe necessary or appropriate to disclose personal data to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Policy; to respond to any claims against us; and, to protect the rights, property, or personal safety of the Company, our customers, or the public.  e. Third parties in connection with Corporate Transaction. In addition, information about employees may be disclosed as part of any merger, sale, transfer of the Company’s assets, acquisition, bankruptcy, or similar event.  Notwithstanding anything else in this Policy, we may share anonymized information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.

7. International transfers

Your Personal Data may be transferred to countries outside of your jurisdiction to countries whose data protection laws may be less stringent than yours. We will ensure that appropriate safeguards are in place to protect your personal data and that transfer of your personal data is in compliance with applicable data protection laws. Where required by applicable data protection laws, the Company has ensured that service providers (including Company’s affiliates) sign standard contractual clauses as approved by the European Commission or other supervisory authority with jurisdiction over the relevant exporter. Employees can obtain a copy of any standard contractual clauses in place which relate to transfers of your personal data by contacting Privacy Expert or [email protected].

8. Your rights

Subject to the conditions set forth in the applicable law, you have the right to request, review, correct, update, suppress, restrict or delete personal data that you have provided to us during the employment relationship, or if you would like to request to receive an electronic copy of such personal data for purposes of transmitting it to another company, you may contact us as indicated in the Contact us section below. We will respond to your request consistent with applicable law.  In your request, please tell us what personal data you would like to have changed, whether you would like to have it suppressed from our database, or otherwise let us know what limitations you would like to put on our use of it. We will try to comply with your request as soon as reasonably practicable.  Please note that we may need to retain certain personal data for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion.  In the event your personal data is processed on the basis of your consent, you can withdraw consent at any time by sending an email to Privacy Expert or [email protected] specifying your request, without affecting the lawfulness of processing based on consent before its withdrawal.  You may lodge a complaint with a supervisory authority, in particular in your Member State of residence, if you consider that the collection and use of your personal data infringes this Policy or applicable law.

Contact us  If you have any questions or concerns regarding our use of your personal data, or to exercise any of your rights, please send an e-mail to Privacy Expert or [email protected].