PRIVACY POLICY INTRODUCTION

Lumenova ("Lumenova", "we", "us", or "our") is committed to protecting the privacy and security of personal information entrusted to us. Lumenova provides electrical and solar services to residential, commercial, and industrial customers, including electrical installations, maintenance, repairs, solar energy systems, inspections, project assessments, quotations, installations, servicing, and related electrical and renewable-energy services.

This Privacy Policy explains how Lumenova collects, uses, stores, protects, and discloses personal information when you interact with us, including when you:

Visit our website;

Request an electrical or solar quotation;

Request a site inspection or assessment;

Enquire about our services;

Engage Lumenova to perform electrical or solar works;

Communicate with our staff or representatives;

Provide information concerning a property, project, or installation;

Purchase equipment or services from us;

Communicate with us regarding an existing installation;

Submit a warranty or service request;

Interact with us through email, social media, or other communication channels; or

Otherwise interact with Lumenova in connection with our business.

This Privacy Policy is designed to address Lumenova's obligations under applicable Philippine privacy laws, including Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and applicable guidance and regulations issued by the National Privacy Commission ("NPC").

Where the EU General Data Protection Regulation ("GDPR") applies to our processing of personal data, Lumenova will also comply with the applicable requirements of the GDPR.

1. ABOUT LUMENOVA

Lumenova is an electrical and solar services business operating in the Philippines.

Our services may include the following:

Electrical Services

Residential electrical works

Commercial electrical works

Industrial electrical works

Electrical installations

Electrical repairs

Electrical maintenance

Electrical inspections

Testing and commissioning

Switchboard and distribution-board works

Lighting installations

Power installations

Electrical upgrades

Fault finding and diagnostics

Electrical compliance-related services

Electrical project works

Other electrical services provided by Lumenova

Solar and Renewable Energy Services

Residential solar installations

Commercial solar installations

Industrial solar installations

Solar photovoltaic (PV) systems

Solar panel installation

Solar inverter installation

Battery energy storage systems

Solar system upgrades

Solar system maintenance

Solar inspections

Solar monitoring

Solar repairs

Solar system assessments

Solar quotations and proposals

Energy-related assessments

Other renewable-energy services provided by Lumenova

The actual services offered by Lumenova may change from time to time.

2. COMPANY AND PRIVACY CONTACT DETAILS

Business Name: Lumenova

Website: lumenova.com.ph

Privacy Email: privacy@lumenova.com.ph

For privacy-related enquiries, requests, complaints, or concerns, you may contact:

Lumenova Privacy Team

Email: privacy@lumenova.com.ph

Where required by applicable law, Lumenova will designate and publish the details of a Data Protection Officer ("DPO").

3. OUR PRIVACY COMMITMENT

Lumenova is committed to handling personal information responsibly and transparently.

We seek to follow the following principles:

Transparency

We will provide appropriate information about how and why personal information is collected and used.

Legitimate Purpose

We will collect and process personal information for legitimate and specific business purposes.

Proportionality

We will seek to collect only information that is reasonably necessary and relevant to the purpose for which it is processed.

Accuracy

We will take reasonable steps to ensure that personal information used by Lumenova is accurate, complete, and current where necessary.

Security

We will implement reasonable and appropriate organisational, physical, and technical measures to protect personal information.

Retention

We will retain personal information only for as long as reasonably necessary for its intended purpose or where otherwise required or permitted by law.

4. INFORMATION WE MAY COLLECT

Depending on your relationship with Lumenova, we may collect different types of personal and project-related information.

4.1 Customer Identification Information

This may include:

Full name

Preferred name

Company name

Business name

Position or job title

Customer or account identifier

Identification information where legitimately required

5. CONTACT INFORMATION

We may collect:

Email address

Residential address

Property address

Business address

Project address

Billing address

Installation address

Mailing address

Contact information provided through business correspondence

For electrical and solar projects, a property or installation address may be necessary so that Lumenova can assess, quote, schedule, and perform the requested works.

6. ELECTRICAL AND SOLAR PROJECT INFORMATION

When you request electrical or solar services, Lumenova may collect information relating to the relevant property, site, or project.

This may include:

Property address

Type of property

Residential, commercial, or industrial classification

Building information

Electrical system information

Existing electrical equipment

Switchboards and distribution equipment

Solar system information

Solar panel information

Inverter information

Battery information

Energy consumption information

Electricity usage information

System capacity

Electrical drawings

Site plans

Photographs

Videos

Measurements

Inspection information

Installation information

Equipment serial numbers

Warranty information

Service history

Fault information

Maintenance records

Project specifications

Quotation information

Project documentation

Some of this information may relate to a property or business rather than an identifiable individual. However, where such information can reasonably be linked to an identifiable person, Lumenova will handle it in accordance with applicable privacy laws.

7. SITE PHOTOGRAPHS AND VIDEOS

Electrical and solar projects may require Lumenova to take photographs or videos of:

Electrical installations

Switchboards

Wiring

Solar panels

Inverters

Batteries

Rooftops

Equipment

Electrical meters

Installation locations

Property structures

Project works

These images may be collected for legitimate business purposes, including:

Preparing quotations

Assessing a project

Documenting existing conditions

Planning installations

Recording completed works

Quality assurance

Safety

Compliance

Warranty purposes

Maintenance

Fault diagnosis

Project records

Communicating project information to authorised customers or contractors

Where photographs or videos contain identifiable individuals, Lumenova will handle them in accordance with applicable privacy requirements.

Lumenova will not use identifiable customer photographs for public marketing purposes without an appropriate lawful basis and, where required, consent.

8. ELECTRICAL, ENERGY, AND CONSUMPTION INFORMATION

For solar and electrical projects, we may collect information necessary to design, assess, or service an installation.

This may include:

Electricity consumption information

Electricity bills voluntarily provided by customers

Energy usage data

Electrical load information

Solar generation information

Inverter data

Battery information

System monitoring information

Meter information

Electrical capacity

Historical usage information

This information may be used to:

Assess energy requirements

Design solar systems

Estimate system capacity

Prepare proposals

Evaluate energy requirements

Troubleshoot systems

Monitor system performance

Provide maintenance

Provide customer support

9. WEBSITE AND TECHNICAL INFORMATION

When you visit the Lumenova website, certain information may be collected automatically depending on the technologies implemented on the website.

This may include:

IP address

Browser type

Operating system

Device type

Device information

Approximate location

Language preference

Referring website

Pages visited

Date and time of access

Website interactions

Session information

Diagnostic information

Security information

This information may be used to operate, secure, maintain, and improve our website.

10. INFORMATION SUBMITTED THROUGH WEBSITE FORMS

If you submit an enquiry through a Lumenova website form, we may collect information such as:

Name

Email address

Property address

Project address

Type of property

Service required

Project description

Electrical requirements

Solar requirements

Information contained in uploaded files

Photographs

Drawings

Electricity bills

Other information you voluntarily provide

We use this information to respond to your enquiry and, where requested, prepare a quotation, proposal, assessment, or service.

11. QUOTATIONS AND PROPOSALS

When preparing electrical or solar quotations, Lumenova may process:

Customer details

Project details

Property information

Site information

Equipment requirements

Electrical specifications

Solar specifications

Energy information

Photographs

Drawings

Measurements

Pricing information

Proposed system designs

Quotation history

Correspondence

Quotation information may be retained as part of our legitimate business records.

12. CONTRACTS AND PROJECT DELIVERY

When you engage Lumenova, we may process information necessary to:

Enter into contracts

Administer contracts

Schedule works

Coordinate technicians

Coordinate subcontractors

Procure equipment

Order materials

Arrange site access

Perform electrical works

Perform solar works

Complete installations

Conduct inspections

Test and commission systems

Provide project documentation

Issue invoices

Manage warranties

Provide ongoing support

13. SUPPLIERS, CONTRACTORS, AND SUBCONTRACTORS

Electrical and solar projects may involve suppliers, electricians, engineers, installers, subcontractors, consultants, and other service providers.

Where reasonably necessary, Lumenova may provide relevant project information to authorised parties involved in delivering the requested services.

Information shared may include:

Customer name

Project address

Site information

Scope of works

Equipment information

Drawings

Photographs

Access requirements

Project schedules

Relevant technical information

Lumenova will seek to limit information sharing to what is reasonably necessary for the relevant project or service.

14. WHY WE COLLECT PERSONAL INFORMATION

Lumenova may collect and process personal information for purposes including:

Responding to enquiries

Providing electrical services

Providing solar services

Preparing quotations

Conducting site assessments

Designing systems

Scheduling installations

Delivering projects

Managing contractors

Ordering equipment

Coordinating suppliers

Providing maintenance

Troubleshooting

Managing warranties

Processing payments

Issuing invoices

Maintaining business records

Providing customer support

Improving our services

Maintaining website security

Preventing fraud

Complying with legal obligations

Resolving disputes

Protecting our legal rights

15. LEGAL BASIS FOR PROCESSING – PHILIPPINES

Lumenova will process personal information only where a lawful basis exists under applicable Philippine law.

Depending on the circumstances, processing may be based on:

Consent

Contractual necessity

Steps taken at your request before entering into a contract

Compliance with a legal obligation

Legitimate interests

Protection of life and health

Other lawful grounds recognised under Philippine law

Lumenova will seek to ensure that processing follows the principles of transparency, legitimate purpose, and proportionality under the Philippine Data Privacy Act.

16. GDPR – WHERE APPLICABLE

The GDPR may apply to Lumenova in certain circumstances, including where Lumenova offers services to individuals in the European Union or otherwise falls within the territorial scope of the GDPR.

Where the GDPR applies, Lumenova will identify and rely on an appropriate lawful basis for processing.

These may include:

Consent

Contractual necessity

Legal obligation

Legitimate interests

Protection of vital interests

Public interest where applicable

17. CONSENT

Where Lumenova relies on consent, consent will be obtained in an appropriate manner.

Consent should be:

Voluntary

Specific

Informed

Understandable

Capable of being withdrawn

Where consent is withdrawn, Lumenova will stop processing based on that consent unless another lawful basis permits continued processing.

Withdrawal of consent does not affect processing that was lawfully carried out before withdrawal.

18. COOKIES

The Lumenova website may use cookies and similar technologies.

These may include:

Essential Cookies

Used for necessary website functionality and security.

Analytics Cookies

Used to understand website traffic and user interactions.

Preference Cookies

Used to remember certain website preferences.

Marketing Cookies

Where applicable, used to measure advertising performance or support marketing activities.

Where applicable law requires consent for non-essential cookies, Lumenova will provide an appropriate consent mechanism.

Users may also manage cookies through their browser settings.

19. THIRD-PARTY TECHNOLOGY AND SERVICES

Lumenova may use third-party services to operate its website and business.

Depending on the systems we use, these may include:

Website hosting providers

Cloud storage providers

Email providers

Customer relationship management platforms

Accounting systems

Payment processors

Analytics providers

Advertising platforms

Communication platforms

Cybersecurity providers

Project management systems

Document management systems

Third-party providers may process personal information on behalf of Lumenova where necessary to provide their services.

Where required, Lumenova will implement appropriate contractual and security safeguards.

20. DATA SHARING

Lumenova may share personal information where reasonably necessary for legitimate business, contractual, or legal purposes.

Recipients may include:

Authorised employees

Electricians

Solar installers

Engineers

Consultants

Contractors

Subcontractors

Suppliers

Equipment manufacturers

Professional advisers

Accountants

Lawyers

Insurers

Technology providers

Payment processors

Government authorities

Regulators

Courts

Law-enforcement authorities where legally required

Lumenova does not sell customer personal information as a business practice.

21. MANUFACTURERS AND EQUIPMENT PROVIDERS

For certain electrical and solar services, Lumenova may need to provide limited customer or project information to equipment manufacturers or authorised distributors.

This may be necessary for:

Warranty registration

Equipment warranty claims

Technical support

Equipment commissioning

Product registration

Fault diagnosis

Replacement equipment

Manufacturer support

Only information reasonably necessary for the relevant purpose will be shared.

22. GOVERNMENT AND REGULATORY COMPLIANCE

Electrical and solar projects may require interaction with relevant government agencies, utilities, regulators, permitting authorities, or other authorised organisations.

Where necessary, Lumenova may process or disclose personal and project information for:

Permits

Approvals

Inspections

Electrical compliance

Solar approvals

Utility requirements

Regulatory requirements

Safety requirements

Legal obligations

Such processing will be carried out in accordance with applicable law.

23. PAYMENT INFORMATION

Where applicable, Lumenova may collect information necessary to:

Issue invoices

Process payments

Reconcile accounts

Manage accounts receivable

Process refunds

Maintain financial records

Where payments are processed by third-party payment providers, those providers may independently process payment information under their own privacy policies.

24. DATA RETENTION

Lumenova will retain personal information only for as long as reasonably necessary for:

Providing services

Managing customer relationships

Project records

Warranties

Maintenance

Accounting

Tax requirements

Legal compliance

Dispute resolution

Legitimate business purposes

Electrical and solar project records may need to be retained for an appropriate period because they can be relevant to:

Warranties

Maintenance

Future repairs

System history

Safety

Compliance

Customer service

Legal requirements

When information is no longer required, Lumenova will take reasonable steps to securely delete, destroy, anonymise, or otherwise dispose of it.

25. DATA SECURITY

Lumenova implements reasonable and appropriate organisational, physical, and technical safeguards designed to protect personal information.

Depending on the circumstances, these may include:

Access controls

Account authentication

Password protection

Encryption

Secure cloud systems

Backups

Restricted access

Confidentiality requirements

Staff awareness and training

Security monitoring

Secure document handling

Vendor security controls

Incident response procedures

Access to customer and project information will be limited to individuals who reasonably require access for legitimate business purposes.

26. DATA BREACHES

Lumenova maintains procedures for identifying, assessing, and responding to personal data breaches and security incidents.

If a breach occurs, Lumenova will assess:

The nature of the incident

The information involved

The individuals affected

Potential risks

Required containment measures

Applicable notification requirements

Where notification is required by law, Lumenova will notify the relevant parties and regulatory authorities within the applicable timeframe.

27. PHOTOS, PROJECT DOCUMENTATION, AND MARKETING

Lumenova may maintain photographs, videos, drawings, and other documentation relating to completed electrical and solar projects.

These may be used internally for:

Project records

Quality control

Safety

Warranty purposes

Maintenance

Technical reference

Dispute resolution

Where Lumenova wishes to use identifiable customer, property, or project images publicly for marketing, Lumenova will obtain an appropriate lawful basis and, where required, consent.

28. CUSTOMER PROPERTY INFORMATION

Because Lumenova performs electrical and solar work at physical properties, we may collect information concerning:

Property location

Building type

Roof configuration

Electrical infrastructure

Solar equipment

Electrical equipment

Access arrangements

Site conditions

Installation areas

This information may be necessary to safely and properly perform the requested services.

We will use property information only for legitimate business, service, safety, compliance, or legal purposes.

29. YOUR RIGHTS UNDER PHILIPPINE LAW

Subject to applicable legal limitations, you may have rights including:

Right to Be Informed

The right to know how your personal information is collected and processed.

Right to Access

The right to request access to personal information held by Lumenova about you.

Right to Correct

The right to request correction of inaccurate, incomplete, or outdated information.

Right to Object

The right to object to certain processing where permitted by law.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw that consent subject to applicable limitations.

Right to Data Portability

Where applicable, the right to obtain personal information in a structured and commonly used electronic format.

Right to Erasure or Blocking

Where applicable, the right to request deletion, destruction, or blocking of personal information.

Right to Damages

The right to seek damages where provided by applicable law.

Right to Lodge a Complaint

The right to lodge a complaint with the National Privacy Commission where applicable.

30. YOUR RIGHTS UNDER THE GDPR

Where the GDPR applies, you may also have rights including:

Right to access

Right to rectification

Right to erasure

Right to restriction of processing

Right to data portability

Right to object

Right to withdraw consent

Rights relating to automated decision-making and profiling where applicable

These rights are subject to the applicable GDPR conditions and exemptions.

31. HOW TO EXERCISE YOUR RIGHTS

To exercise a privacy right, contact:

Lumenova Privacy Team

Email: privacy@lumenova.com.ph

Your request should include:

Your name

Your email address

The nature of your request

Relevant information that will help us identify the information concerned

We may request reasonable information to verify your identity before releasing or modifying personal information.

32. PRIVACY REQUESTS

Lumenova will review and respond to valid privacy requests within the applicable period required by law.

We may refuse or limit a request where permitted or required by applicable law.

For example, limitations may apply where complying with a request would:

Violate another person's rights

Conflict with a legal obligation

Interfere with legal proceedings

Compromise security

Interfere with fraud prevention

Affect legitimate legal claims

Where permitted, Lumenova will explain why a request cannot be fulfilled.

33. DIRECT MARKETING

Where permitted by applicable law, Lumenova may send information regarding:

Electrical services

Solar services

Energy solutions

Promotions

New services

Company updates

Relevant offers

Where consent is required, Lumenova will obtain appropriate consent.

You may unsubscribe from marketing communications at any time by contacting:

privacy@lumenova.com.ph

Unsubscribing from marketing does not necessarily stop important service-related communications.

34. CHILDREN'S PRIVACY

Lumenova's electrical and solar services are generally directed toward property owners, businesses, organisations, and other customers rather than children.

We do not knowingly collect children's personal information through our website for purposes unrelated to the provision of legitimate services.

If you believe that a child has provided personal information to Lumenova without appropriate authorisation, please contact:

privacy@lumenova.com.ph

35. THIRD-PARTY WEBSITES

Our website may contain links to third-party websites.

These websites operate independently and may have their own privacy policies.

Lumenova is not responsible for the privacy practices, security, or content of third-party websites.

We recommend reviewing the privacy policy of any third-party website before providing personal information.

36. SOCIAL MEDIA

Lumenova may use social media platforms to communicate with customers and promote our electrical and solar services.

If you interact with Lumenova through a social media platform, that platform may independently collect and process your personal information.

Your interaction with those platforms is governed by their respective privacy policies and terms.

37. INTERNATIONAL DATA TRANSFERS

Some of Lumenova's technology providers may process or store information outside the Philippines.

Where personal information is transferred internationally, Lumenova will take reasonable measures to protect the information and comply with applicable privacy requirements.

Where the GDPR applies, Lumenova will implement appropriate safeguards for international transfers where required.

38. GDPR EU REPRESENTATIVE

Where Lumenova becomes subject to a legal requirement under the GDPR to appoint an EU representative, the representative's details will be published in this Privacy Policy.

EU Representative: Not currently designated.

If Lumenova is not legally required to appoint an EU representative, no representative is designated under this section.

39. AUTOMATED DECISION-MAKING

Lumenova does not ordinarily use personal information to make automated decisions that produce legal or similarly significant effects on individuals.

If such processing is introduced in the future, Lumenova will implement the safeguards required by applicable privacy laws.

40. PRIVACY BY DESIGN

Where reasonably appropriate, Lumenova considers privacy and security when implementing new systems, technologies, and business processes.

We seek to:

Minimise unnecessary data collection

Restrict access to authorised persons

Protect information throughout its lifecycle

Securely dispose of information when no longer required

Assess privacy risks associated with new technologies and systems

41. EMPLOYEES, CONTRACTORS, AND PROJECT PERSONNEL

Lumenova may process personal information concerning:

Employees

Electricians

Solar installers

Engineers

Consultants

Contractors

Subcontractors

Project personnel

Suppliers

Such information may be processed for:

Project coordination

Scheduling

Site access

Safety

Compliance

Training

Credential verification

Contractor management

Payroll and accounting

Business administration

Appropriate privacy and security measures will apply to such information.

42. BUSINESS CONTACT INFORMATION

Lumenova may process information relating to representatives of:

Commercial customers

Industrial customers

Property managers

Building managers

Contractors

Builders

Developers

Suppliers

Manufacturers

Consultants

Engineering firms

Other organisations

This may include:

Name

Company

Position

Business email

Business address

Project information

Business correspondence

Such information will be processed for legitimate business purposes and in accordance with applicable privacy laws.

43. ACCURACY OF INFORMATION

Lumenova seeks to maintain accurate and relevant information.

If your personal information changes or you believe that information we hold is inaccurate, please contact:

privacy@lumenova.com.ph

We may request reasonable information to verify the requested correction.

44. CHANGES TO THIS PRIVACY POLICY

Lumenova may update this Privacy Policy from time to time.

Updates may reflect:

Changes to our electrical services

Changes to our solar services

Changes to our website

New technologies

Changes in our business

Changes in privacy practices

Changes in legislation

Regulatory requirements

The current version will be published on the Lumenova website.

The Last Updated date at the beginning of this Privacy Policy will be amended whenever material changes are made.

Where required by law, Lumenova will provide additional notice or obtain consent before implementing material changes to processing activities.

45. PRIVACY COMPLAINTS

If you have concerns regarding how Lumenova has handled your personal information, we encourage you to contact us first so that we can investigate and attempt to resolve the matter.

Lumenova Privacy Team

Email: privacy@lumenova.com.ph

If you are not satisfied with our response, you may have the right to lodge a complaint with the National Privacy Commission of the Philippines, subject to applicable procedures.

National Privacy Commission:

privacy.gov.ph

46. GDPR SUPERVISORY AUTHORITY

Where the GDPR applies, you may have the right to lodge a complaint with the relevant data protection supervisory authority in the EU/EEA country where you live, work, or believe an infringement occurred.

47. DATA PROCESSORS

Lumenova may engage third-party organisations to process personal information on our behalf.

Where appropriate, Lumenova will take reasonable steps to ensure that processors:

Process information only for authorised purposes

Maintain confidentiality

Implement appropriate security measures

Restrict access to authorised personnel

Assist with applicable privacy obligations

Securely delete or return information when required

48. LEGAL CLAIMS AND DISPUTES

Lumenova may retain and process relevant information where reasonably necessary to:

Establish legal claims

Exercise legal rights

Defend legal claims

Investigate disputes

Comply with legal proceedings

Obtain professional legal advice

49. GOVERNING LAW

This Privacy Policy is primarily governed by the laws of the Republic of the Philippines, including the Data Privacy Act of 2012 (Republic Act No. 10173) and applicable implementing regulations.

Where another data protection law, including the GDPR, applies to a particular processing activity, Lumenova will comply with the mandatory requirements of that applicable law.

50. SEVERABILITY

If any provision of this Privacy Policy is determined to be invalid, unlawful, or unenforceable, the remaining provisions will continue to apply to the extent permitted by applicable law.

51. CONTACT LUMENOVA

For questions, requests, complaints, or concerns regarding privacy and personal information, please contact:

LUMENOVA

Electrical & Solar Solutions

Residential | Commercial | Industrial

Website:

lumenova.com.ph

Privacy Email:

privacy@lumenova.com.ph

52. ACKNOWLEDGEMENT

By using the Lumenova website, you acknowledge that you have had an opportunity to review this Privacy Policy.

Where applicable law requires consent for a specific processing activity, Lumenova will obtain consent through an appropriate mechanism.

Nothing in this Privacy Policy is intended to remove, restrict, or limit any rights available to you under applicable Philippine or international privacy laws.

LUMENOVA

Electrical & Solar Solutions

Residential | Commercial | Industrial

Privacy Email: privacy@lumenova.com.ph