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1. Purpose Of This Privacy Policy

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This Privacy Policy Sets Out The Terms Under Which Luzrumo, Unipessoal Lda Collects, Uses, Stores, Organises, Consults, Shares, Protects, Retains, And Otherwise Processes Personal Data In The Context Of Its Business Activities.

Luzrumo Operates As A Portugal-Based International Education Consulting And Student Support Business. Its Activities Include, Among Others, Educational Guidance, Admissions Support, Application-Related Assistance, Relocation And Mobility Coordination, Student-Settlement Support, Career Guidance, Digital Business Operations, And The Sale Of Merchandise And Related Products Through Digital Means. Those Activities Are Reflected In The Company’s Registered Corporate Object.

This Privacy Policy Applies To Personal Data Processed In Connection With:

• The Use Of The Website.

• Enquiries And Pre-Contract Communications.

• Bookings, Purchases, And Service Delivery.

• Contact With Students, Parents, Guardians, Family Representatives, Institutions, Partners, And Service Providers.

• Digital Marketing And Brand Activities.

• Merchandise Sales And Related E-Commerce Activity.

• Internal Administration, Compliance, Security, And Record-Keeping.

This Privacy Policy Should Be Read Together With The Company’s Terms And Conditions, Cookies Policy, Booking Rules, And Any Other Relevant Legal Notices Published By Luzrumo.

 

2. Identity Of The Data Controller

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For The Purposes Of Applicable Data Protection Law, The Data Controller Is:

LUZRUMO, UNIPESSOAL LDA
Registered Office: Rua Hermano Neves, 18, Piso 3, Escritório 7, V6064, 1600-477 Lisboa, Portugal
NIPC: 519422821

In This Privacy Policy, The Terms “Luzrumo”, “The Company”, “We”, “Us”, And “Our” Refer To LUZRUMO, UNIPESSOAL LDA.

 

3. Persons Whose Data May Be Processed

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Luzrumo May Process Personal Data Relating To The Following Categories Of Individuals:

• Visitors To The Website.

• Prospective Clients.

• Existing Clients.

• Students.

• Parents And Legal Guardians.

• Family Representatives Acting On Behalf Of Students Or Minors.

• Business Contacts.

• Institutional Contacts.

• Partner Representatives.

• Prospective Or Current Agents, Consultants, And Contractors.

• Purchasers Of Merchandise Or Other Products Sold Through The Website.

• Individuals Whose Data Is Contained In Client Files, Where Such Inclusion Is Relevant To The Service Requested And Lawfully Permitted.

 

4. Categories Of Personal Data Processed

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Depending On The Nature Of The Relationship, The Service Requested, And The Stage Of The Client Journey, Luzrumo May Process The Following Categories Of Personal Data.

 

4.1 Identification And Contact Information

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This May Include:

• Full Name.

• Email Address.

• Telephone Number.

• Postal Address.

• Country Of Residence.

• Nationality.

• Language Preference.

• Date Of Birth Or Age, Where Relevant To The Service.

 

4.2 Booking, Transaction, And Administrative Data

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This May Include:

• Booking Details.

• Scheduled Sessions.

• Purchased Services, Packages, And Add-Ons.

• Payment Status.

• Billing Details.

• Invoice Information.

• Records Of Cancellation, Rescheduling, Refund Requests, Or No-Shows.

• Administrative Notes Relating To Service Delivery.

 

4.3 Education And Case-Related Information

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This May Include:

• Academic Background.

• School Or University Interests.

• Current Or Previous Educational History.

• Grades, Transcripts, Certificates, Diplomas, Or Similar Records.

• Programme Preferences.

• Destination Preferences.

• Language Level.

• Budget Information Where Relevant.

• Admissions Status.

• Relocation Needs.

• Interview Preparation Materials.

• CVs, Motivation Letters, Personal Statements, Recommendation Letters, And Related Documents.

• Internal Case Notes And Follow-Up Records.

 

4.4 Identity, Travel, And Mobility Documentation

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Where Relevant To The Service Purchased, Luzrumo May Process Copies Of, Or Data Taken From, Documents Such As:

• Passports.

• Identity Cards.

• Residence Permits.

• Travel Documents.

• Visa-Supporting Documentation.

• Student Mobility Documents.

• File-Readiness Documentation Used In Admissions Or Relocation Contexts.

Such Processing Shall Be Limited To What Is Reasonably Necessary For The Relevant Service, Including Identity Verification, Application Preparation Support, Mobility Coordination, And Related Administrative Assistance.

 

4.5 Parent, Guardian, And Minor-Related Data

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Where A Service Concerns A Minor, Luzrumo May Process Personal Data Relating To:

• The Minor Student.

• The Parent Or Parents.

• Legal Guardians.

• Other Family Representatives Or Authorized Contacts.

 

4.6 Communications And File-Management Data

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This May Include:

• Email Correspondence.

• Form Submissions.

• Meeting Notes.

• Session Notes.

• Client File Updates.

• Internal Follow-Up Notes.

• Administrative Communications.

• Coordination Records With Institutions, Partners, Or Providers.

 

4.7 Technical, Device, And Usage Data

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This May Include:

• IP Address.

• Browser Type.

• Device Information.

• Log Data.

• Website Usage Information.

• Cookie And Similar Identifier Data, Subject To The Relevant Cookie Settings And Applicable Law.

 

4.8 Special Categories Or Particularly Sensitive Information

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Luzrumo Does Not Intentionally Seek To Collect Sensitive Personal Data Unless Such Processing Is Relevant, Necessary, And Lawfully Permitted In The Context Of The Requested Service.

In Some Cases, The Company May Receive Limited Sensitive Or Particularly Delicate Information, Including:

• Health-Related Information Relevant To Travel, Insurance, Accommodation, Student Welfare, Or Educational Support Needs.

• Disability-Related Or Learning-Support Information.

• Welfare, Safeguarding, Or Wellbeing-Related Information.

• Other Sensitive Information Voluntarily Shared By The Client And Relevant To The Case.

Where Such Data Is Processed, Luzrumo Will Seek To Limit The Processing To What Is Strictly Necessary, To Restrict Access On A Need-To-Know Basis, And To Treat Such Data With An Increased Level Of Confidentiality.

Clients Are Requested Not To Share Sensitive Information That Is Unnecessary For The Relevant Service.

 

5. Sources Of Personal Data

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Luzrumo May Obtain Personal Data:

• Directly From The Data Subject.

• From A Parent, Guardian, Or Authorized Family Representative.

• Through Contact Forms, Booking Tools, Checkout Processes, And Other Website Functionalities.

• Through Email, Messaging, Video Calls, And Other Forms Of Communication.

• Through Documents Provided By The Client.

• Through Cookies And Similar Website Technologies.

• From Institutions, Partners, Or Providers Where Necessary For Coordination Purposes And Lawfully Permitted.

• From Publicly Available Professional Sources Where Relevant For Legitimate Business Contact Purposes.

 

6. Purposes Of Processing

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Luzrumo May Process Personal Data For The Following Purposes.

 

6.1 Website Operation And Technical Administration

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To Operate, Maintain, Secure, Test, Improve, And Administer The Website And Its Functionalities.

 

6.2 Enquiries And Pre-Contract Management

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To Respond To Questions, Service Enquiries, Pre-Booking Requests, And Preliminary Communications.

 

6.3 Booking, Contracting, And Service Delivery

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To Manage Bookings, Confirm Appointments, Open Files, Deliver Consultations, Coordinate Packages, And Provide Purchased Services.

 

6.4 Education Guidance And Admissions Support

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To Assess Educational Needs, Prepare Recommendations, Support School, Boarding School, Language School, College, University, Pathway, Preparatory, And Short-Programme Cases, Review Documentation, And Facilitate Education-Related Support.

 

6.5 Relocation, Mobility, And Student-Settlement Support

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To Coordinate And Provide Administrative Assistance Relating To Accommodation, Insurance, Telecommunications, Transportation, And Related Settlement Support.

 

6.6 Career, Internship, And Employability Support

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To Provide CV Review, LinkedIn Review, Interview Preparation, Internship Guidance, And Related Career Services.

 

6.7 Coordination With Partners And Institutions

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To Liaise With Schools, Universities, Language Providers, Accommodation Providers, Insurers, Telecom Providers, Transport Providers, Internship-Related Partners, And Other Providers Where This Is Necessary For The Relevant Service Or Coordination Purpose.

 

6.8 Payment, Invoicing, Accounting, And Financial Administration

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To Process Payments, Issue Invoices, Maintain Financial Records, Manage Refunds Or Payment Disputes, And Comply With Accounting, Tax, And Related Administrative Obligations.

 

6.9 Merchandise And Product Sales

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To Process Orders, Manage Product Fulfilment, Coordinate Delivery Or Shipping Where Applicable, And Handle Customer Service Relating To Goods Sold Through The Website.

 

6.10 Marketing, Communications, And Business Development

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To Send Information About Services, Updates, Promotions, Content, Or Relevant Business Communications, Where Permitted By Law Or Based On Valid Consent.

 

6.11 Compliance, Risk Management, And Protection Of Legal Interests

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To Maintain Internal Records, Protect The Company’s Rights, Prevent Fraud, Manage Disputes, Comply With Legal Obligations, Defend Legal Claims, And Maintain Operational And Security Controls.

 

7. Legal Bases For Processing

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Luzrumo May Rely On One Or More Of The Following Legal Bases For The Processing Of Personal Data, Depending On The Nature Of The Data And The Relevant Context:

• Performance Of A Contract.

• Steps Taken At The Request Of The Data Subject Prior To Entering Into A Contract.

• Compliance With A Legal Obligation.

• Legitimate Interests Pursued By Luzrumo Or A Relevant Third Party, Provided Such Interests Are Not Overridden By The Rights And Freedoms Of The Data Subject.

• Consent, Where Required Or Appropriate.

• Any Other Lawful Basis Recognised By Applicable Data Protection Law.

Where Luzrumo Relies On Legitimate Interests, Those Interests May Include, Without Limitation:

• Business Administration.

• Internal Record-Keeping.

• Service Delivery.

• Quality Control.

• Security.

• Fraud Prevention.

• Dispute Management.

• Debt Recovery.

• Protection Of Commercial And Legal Interests.

• Service Improvement.

• Controlled Business Communications.

Where Consent Is Relied Upon, The Data Subject May Withdraw Such Consent At Any Time, Without Affecting The Lawfulness Of Processing Carried Out Before Withdrawal.

 

8. Data Relating To Minors

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Because Some Luzrumo Services Relate To Children And Teenagers, The Company May Process Personal Data Relating To Minors In The Context Of Educational Guidance, School And Boarding-School Cases, Family Support, Relocation Support, And Related Services.

Luzrumo Expects Data Relating To Minors To Be Shared By Or Through A Parent, Legal Guardian, Or Other Person Lawfully Authorized To Act On The Minor’s Behalf. The Company Reserves The Right To Request Reasonable Confirmation Of Such Authority Where Appropriate.

 

9. Disclosure And Sharing Of Personal Data

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Luzrumo May Share Personal Data Only Where Necessary, Appropriate, And Lawful.

 

9.1 Internal Access

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Personal Data May Be Accessed Internally By Authorized Personnel, Agents, Consultants, Contractors, And Representatives Of Luzrumo Who Need Such Access In Order To Perform Their Duties.

Access Shall Be Limited On A Need-To-Know Basis.

 

9.2 Service Providers And Processors

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Luzrumo May Use Third-Party Service Providers To Support Its Operations, Including Providers Of:

• Website Hosting.

• Booking And Scheduling Systems.

• Video Meeting Platforms.

• Email And Communication Services.

• Payment Processing.

• Invoicing And Accounting Support.

• Cloud Storage.

• Customer Relationship Management Tools.

• Workflow And Administrative Systems.

• IT, Security, And Technical Support.

Such Providers May Process Personal Data On Luzrumo’s Behalf And Subject To Appropriate Contractual And Compliance Arrangements.

 

9.3 Institutions And External Providers

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Where Relevant To The Service Purchased, Luzrumo May Share Necessary Personal Data With:

• Schools.

• Boarding Schools.

• Language Schools.

• Colleges.

• Universities.

• Pathway And Preparatory Providers.

• Short-Programme Providers.

• Accommodation Providers.

• Insurers.

• Telecom Providers.

• Transport Providers.

• Internship And Career-Related Providers.

• Other Relevant External Providers.

Such Sharing Shall Be Limited To Data Reasonably Necessary For The Relevant Application, Coordination, Referral, Or Support Purpose.

 

9.4 Professional Advisers And Authorities

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Luzrumo May Disclose Personal Data To Lawyers, Accountants, Auditors, Insurers, Tax Authorities, Regulators, Supervisory Authorities, Courts, Law Enforcement Bodies, Or Other Public Authorities Where Disclosure Is Legally Required Or Otherwise Lawfully Justified.

 

10. Document Handling, Storage, And Access Control

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Because Luzrumo’s Services May Involve Important Educational, Administrative, Identity, And Mobility Documents, The Company Applies Internal Controls Intended To Protect Such Documentation.

 

10.1 Controlled File Management

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Documents Received From Clients May Be Stored, Reviewed, Organised, Used, And Retained For Legitimate Service, Compliance, Administrative, Security, And Record-Keeping Purposes.

 

10.2 Restricted Access

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Access To Documents And Client Files Is Restricted To Authorized Persons Who Need Access To Perform The Relevant Service Or Support Function.

 

10.3 Limited External Sharing

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Where Documents Need To Be Shared With A Partner Institution Or Third-Party Provider, Luzrumo Will Seek To Limit Such Sharing To The Minimum Reasonably Necessary For The Relevant Purpose.

 

10.4 Operational Security

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Luzrumo Applies Reasonable Technical And Organisational Measures Intended To Reduce The Risk Of Unauthorized Access, Misuse, Unlawful Disclosure, Accidental Loss, Or Improper Alteration.

10.5 Client Responsibility

Clients Should Send Documents Through The Channels Approved By Luzrumo And Should Avoid Sending Unnecessary Sensitive Information.

 

11. International Transfers Of Personal Data

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Given The International Nature Of Luzrumo’s Business Model, Personal Data May In Certain Cases Need To Be Transferred To, Accessed From, Or Processed In Jurisdictions Outside The European Economic Area, Including Where:

• An Educational Institution Or Partner Is Located Abroad.

• A Service Provider Operates Internationally.

• A Case Concerns A Non-EEA Destination.

• A Digital System Or Infrastructure Involves Cross-Border Processing.

Where Such Transfers Occur, Luzrumo Intends To Rely On Lawful Transfer Mechanisms And Appropriate Safeguards To The Extent Required By Applicable Data Protection Law.

 

12. Retention Of Personal Data

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Luzrumo Retains Personal Data Only For As Long As Necessary For The Relevant Purpose Or Purposes, Subject To Applicable Legal, Tax, Accounting, Compliance, Complaint-Handling, Dispute-Management, Security, And Record-Keeping Requirements.

Retention May Vary Depending On The Category Of Data And The Relevant Context. By Way Of General Principle:

• Enquiry Data May Be Retained For A Reasonable Period To Permit Follow-Up And Internal Record-Keeping.

• Client File Data May Be Retained For The Duration Of The Service Relationship And A Reasonable Period Thereafter For Compliance, Defence, And Administrative Purposes.

• Accounting And Invoicing Records May Be Retained For The Period Required By Applicable Law.

• Marketing Data May Be Retained Until Consent Is Withdrawn, An Objection Is Raised, Or The Data Is Otherwise No Longer Necessary.

• Technical And Security Data May Be Retained For Periods Appropriate To Security And Operational Needs.

When Data Is No Longer Necessary, Luzrumo May Delete, Anonymise, Aggregate, Or Securely Archive It As Appropriate.

 

13. Security Measures

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Luzrumo Takes Reasonable Technical And Organisational Measures Intended To Protect Personal Data Against Accidental Or Unlawful Destruction, Loss, Alteration, Unauthorized Disclosure, Or Unauthorized Access.

Such Measures May Include, As Appropriate:

• Role-Based Access Controls.

• Password Protection.

• Segregation Of Access.

• Controlled File Permissions.

• Use Of Digital Systems Intended For Professional Business Use.

• Internal Confidentiality Expectations.

• Limited Internal Sharing.

• Basic Monitoring And Record-Keeping Of Significant Actions Where Appropriate.

However, No Method Of Storage Or Transmission Can Be Guaranteed To Be Absolutely Secure, And Luzrumo Cannot Guarantee Absolute Security.

 

14. Rights Of Data Subjects

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Subject To Applicable Law, Data Subjects May Have The Right To:

• Obtain Confirmation As To Whether Personal Data Concerning Them Is Being Processed.

• Access Their Personal Data.

• Request Rectification Of Inaccurate Or Incomplete Data.

• Request Erasure In Certain Circumstances.

• Request Restriction Of Processing In Certain Circumstances.

• Object To Certain Types Of Processing.

• Request Data Portability Where The Legal Conditions Are Satisfied.

• Withdraw Consent Where Processing Is Based On Consent.

• Lodge A Complaint With A Competent Supervisory Authority.

Luzrumo May Request Reasonable Information To Verify Identity Before Acting On A Request.

 

15. Marketing Communications

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Luzrumo May Send Marketing Or Promotional Communications Where Permitted By Law Or Based On Valid Consent.

Where Required, Consent Will Be Requested. Where Marketing Communications Are Sent On Another Lawful Basis, A Clear Opt-Out Or Unsubscribe Mechanism Should Generally Be Available.

A Recipient May Withdraw Consent Or Object To Marketing Communications At Any Time.

 

16. Automated Decision-Making

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Luzrumo Does Not Intend To Make Decisions Producing Legal Effects Or Similarly Significant Effects Based Solely On Automated Processing Without Meaningful Human Involvement, Unless Such Processing Is Lawfully Justified And Properly Explained.

 

17. Complaints And Supervisory Authority

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If A Data Subject Believes That The Processing Of Personal Data By Luzrumo Infringes Applicable Law, The Data Subject May Have The Right To Lodge A Complaint With The Competent Supervisory Authority.

In Portugal, The Relevant Supervisory Authority Is The Comissão Nacional De Proteção De Dados (CNPD). (cnpd.pt)

Luzrumo Appreciates The Opportunity To Attempt To Resolve Concerns Directly Before A Matter Is Escalated, But This Does Not Affect Any Legal Right To Contact The Competent Supervisory Authority.

 

18. Third-Party Websites And External Services

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The Luzrumo Website May Contain Links To Third-Party Websites, Booking Tools, Payment Systems, Partner Portals, Educational Institutions, Or Other External Services.

Luzrumo Is Not Responsible For The Privacy Practices, Content, Security, Or Data Processing Policies Of Such Third Parties. Users Should Review The Relevant Third Party’s Own Privacy Documentation Before Providing Personal Data.

 

19. Changes To This Privacy Policy

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Luzrumo Reserves The Right To Amend Or Update This Privacy Policy From Time To Time In Order To Reflect Legal, Technical, Operational, Or Business Developments.

The Version Published On The Website At The Relevant Time Shall Normally Be The Version In Force.

 

20. Contact

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Questions Concerning This Privacy Policy Or The Processing Of Personal Data By Luzrumo May Be Addressed To The Company Through The Contact Details Provided On The Website’s Legal Or Contact Pages.