Lumina Consulting Services Ltd - Privacy Policy
Updated: January 12, 2026

1. Purpose of this Policy

This privacy policy:

• Explains how Lumina processes personal information;

• Applies to personal information you provide to us directly or that we obtain from other sources in the course of providing HR, immigration, and related consulting services; and

• Describes your rights regarding your personal information.
   

2. Responsible Parties

Lumina acts as the Data Controller for personal information we collect and process. In some cases, Lumina may act as a Data Processor on behalf of a client, in which case the client remains the Data Controller. If we process information on behalf of a client, inquiries about personal information should be directed to the client in their role as Data Controller.

​

3. Information We Collect​

a. Information you provide to us

We collect personal information necessary to provide our services, including but not limited to:

• Individuals (employees, contractors, job applicants): Full name, contact details, résumé/CV, references, qualifications, nationality, date of birth, employment history, and other information relevant to HR, recruitment, payroll, or immigration services.

• Employers/Clients: Company details, payroll information, employee lists, benefits, and employment contracts.

b. Information we collect from third parties

• References, verification of qualifications, background checks (where relevant and lawful);

• Publicly available information and information provided by clients or authorized third parties;

• Immigration-related documents and government submissions.
   

4. How We Use Your Personal Information

We use personal information for purposes including:

• Providing HR, recruitment, payroll, and immigration services to clients and individuals;

• Administering client engagements, including billing and communications;

• Recruitment services: Assessing suitability for roles, managing and completing interviews and reference/police background checks;

• HR services: Managing onboarding/offboarding, payroll, employee administration, and benefits;

• Immigration services: Processing work permits, visas, and residence applications;

• Marketing and communications (with consent), such as newsletters or updates about our services.

We process information on lawful grounds under PIPA, including consent, contractual necessity, or legitimate interest where appropriate.

​

5. Sharing and Disclosure

Lumina does not share personal information with third parties except:

• Authorized service providers (e.g., IT providers, payroll processors, verification services) under contract and restricted to performing services on our behalf;

• As required by law or regulatory authorities;

• With your consent or as otherwise permitted by law.

We ensure that any third parties handling personal information adhere to appropriate safeguards.

​

6. Security of Personal Information

We implement reasonable technical and organizational measures to protect personal information from unauthorized access, disclosure, or loss. This includes secure storage, access controls, and encrypted transmission where appropriate.

​

7. Data Retention

Personal information is retained only for as long as necessary to fulfill the purposes for which it was collected or to meet legal and contractual obligations. After this period, information is securely destroyed or anonymized.

​

8. Your Rights

Under PIPA, you have the right to:

• Access the personal information we hold about you;

• Correct or update inaccurate information;

• Request deletion where the information is no longer needed;

• Withdraw consent where consent is the basis for processing;

• Restrict or object to processing in certain circumstances.

Requests can be made by contacting our Privacy Officer (details below). We aim to respond promptly, generally within 30 days.

​

9. Transfers of Personal Information

Where necessary, personal information may be transferred to service providers or partners outside Bermuda. All of our third‐party service providers are required to take commercially reasonable and appropriate security measures to protect your Personal Data. We only permit our third‐party service providers to process your Personal Data for specified purposes and in accordance with our instructions.

We ensure transfers are conducted securely and in compliance with PIPA.

​

10. Policy Updates

This policy may be updated from time to time. The most recent version will be posted on our website. Continued engagement with Lumina after updates constitutes acceptance of the revised policy.

​

11. Contact Us

For questions about this policy, your personal information, or to exercise your rights, please contact:

Privacy Officer: Lisa-Jayne Metschnabel
Email: privacy@luminabda.com
Address: Lumina Consulting Services, Ltd - Cedar House, 41 Cedar Avenue, Hamilton, HM 12, Bermuda

​

You may also contact the Bermuda Privacy Commissioner at privcom@privacy.bm for guidance or to lodge a complaint.