PURPOSE OF THIS NOTICE
Luxe Protection Films and its affiliated companies are committed to safeguarding the accuracy, confidentiality, and security of your personal information. This Privacy Notice outlines (1) the types of personal information we collect, (2) how we collect, use, disclose, transfer, and store that information, and (3) your rights in relation to your personal information.
If you have any questions regarding this Privacy Notice, please email privacy@luxeprotectionfilms.com or call (510) 952-9036.
PURPOSE OF COLLECTING PERSONAL INFORMATION
Luxe Protection Films and its affiliated companies (collectively, “Luxe”) are committed to conducting business with honesty, integrity, and respect for human rights. Our values extend to how we treat our employees, partners, suppliers, and all stakeholders. Luxe has zero tolerance for human trafficking, forced labour, or any form of modern slavery in our operations or supply chain.
Luxe’s Business and Structure
Luxe Protection Films collects and processes your personal information to comply with our legal, regulatory, and contractual obligations. This data allows us to recruit, employ, compensate, provide benefits to, and train you during your time working with Luxe Protection Films. We will never collect any unnecessary personal data from you, nor will we use your information in any way that isn’t outlined in this notice.
This notice applies to all current and former employees, workers, and contractors. It does not form part of any employment contract or any contract for services. Luxe Protection Films may update this notice periodically. If changes are made, we will provide you with an updated version as soon as reasonably possible.
DATA PROTECTION PRINCIPLES
Luxe Protection Films will comply with applicable data protection laws. This means the personal information we collect and hold about you must be:
- Used lawfully, fairly, and in a transparent manner.
- Collected only for specific, legitimate purposes that we’ve clearly communicated to you, and not used in any way that conflicts with those purposes.
- Relevant to the purposes we’ve outlined and limited strictly to what is necessary.
- Accurate and kept up to date.
- Retained only for as long as is necessary to fulfil the purposes we’ve shared with you.
- Stored and processed securely to protect against unauthorised access, loss, or misuse.
USE OF PERSONAL INFORMATION
Luxe Protection Films only collects and processes your personal information where we have a valid legal basis for doing so.
“Personal data” or “personal information” refers to any data that can identify an individual. It does not include information where your identity has been removed (anonymous data).
Some types of personal information are considered more sensitive and require extra protection — this includes data relating to health, sexual orientation, or criminal background.
The personal information collected by Luxe Protection Films may be used for the following purposes:
- Recruitment and pre-employment screening
- Administration of employee benefits
- Processing payroll, expenses, bonuses, stock options, or other incentive payments
- Performance evaluations and career development
- Monitoring professional registrations and accreditations
- Planning and organising business travel, transportation, and accommodation
- Coordinating insurance cover for business-related activities
- Administration of international assignments, including documenting entitlements, securing immigration documents, engaging third-party vendors, tax filings, and health requirements
- Ensuring employees have the legal right to work in a given location
- Tracking absences and sickness
- Managing holiday and other types of leave requests
- Equal opportunities and diversity monitoring
- Preparing reports for company operations, regional and corporate reporting, headcount, statutory compliance, and management information
- Managing processes related to resignation, termination, or end-of-assignment
- Handling disciplinary, grievance, misconduct, or code of conduct investigations
- Providing employment references when requested
- Maintaining emergency contact details for you and your listed dependents
- Processing and resolving employee claims
- Verifying your identity
- Managing Luxe’s IT and computer hardware/software assets
- Conducting staff surveys
- Facilitating business communications using your work email account
- Handling whistleblower reports
- Implementing security and monitoring systems
Additionally, Luxe Protection Films may share your personal data with trusted third-party partners who process data on our behalf. These may include:
- Recruitment and staffing providers
- Payroll and employee benefits service providers
- IT and software support partners
- Insurance brokers, providers, and administrators
- Banks and financial institutions
- Travel service providers
- Professional advisors such as legal counsel, accountants, tax consultants, or business advisors
Luxe may also share your information with affiliated companies where necessary for business operations, internal reporting, or employment-related purposes. In situations involving a merger, acquisition, corporate restructure, or sale of business assets, your data may be transferred to the relevant business entity. Where this happens, Luxe will take reasonable steps to ensure that the new entity continues to honour the terms of this Privacy Notice.
We may also disclose your personal information if required by law, or in order to protect our legal rights — such as with government bodies, regulatory authorities, or law enforcement agencies.
Whenever third-party processors handle your personal data on behalf of Luxe Protection Films, we take care to ensure they uphold strict data protection standards and implement suitable safeguards to prevent unauthorised access, use, or disclosure.
HOW IS YOUR PERSONAL INFORMATION COLLECTED?
At Luxe Protection Films, we collect personal information about employees, workers, and contractors through the application and hiring process. This is typically provided directly by you, the candidate, or in some cases through recruitment agencies or background screening providers.
We may also gather additional information from third parties such as:
- Former employers (for reference checks)
- Credit reference agencies
- Other background check providers
Once employed, we continue to collect relevant personal information during your time with us — this includes information generated through your day-to-day job activities, interactions with internal systems, communications, and any updates to your employment status.
HOW WE WILL USE INFORMATION ABOUT YOU
We will only use your personal information when we have a valid legal basis to do so. In most cases, this will include:
- Fulfilling our obligations under your employment contract
- Complying with applicable laws and regulatory requirements
- Acting in our legitimate business interests (or those of a third party), provided these interests are not overridden by your personal rights and freedoms
In less common cases, we may also process your personal information if:
- It is necessary to protect your vital interests, or those of another individual
- It is required for reasons of public interest or for official business purposes
We make every effort to ensure your data is handled transparently, securely, and in a way that respects your privacy at every stage of your employment journey with Luxe.
TYPES OF PERSONAL INFORMATION WE COLLECT
Luxe Protection Films collects and processes a range of personal data to manage the employment relationship effectively. This includes standard personal details, employment-related information, and – in some cases – special categories of sensitive personal data where required.
The information we collect includes, but is not limited to:
- Full name
- Residential address
- Personal phone numbers
- Personal email address
- Date of birth / age
- Nationality
- Country of birth
- Marital or civil partnership status
- Gender
- Race or ethnicity
- Immigration or visa status
- Social security number or equivalent identification number
- Driver’s license details
- Curriculum vitae (CV) and work history
- Qualifications and certifications
- Hire date and termination date
- Employment status, department, job title, and business unit
- Salary, wages, bonuses, and other compensation data
- Standard contracted hours and work schedule
- Bank account information for payroll
- Employee ID number
- Corporate credit card usage (if applicable)
- Vacation and leave records
- Performance management data and appraisal records
- Disciplinary records and grievance procedures
- Training and development history
- Professional achievements and recognitions
- Assigned equipment or technology (e.g. laptops, phones)
- Photographs or video footage (for ID, company use, or security)
- Emergency contact and dependent information
- Participation in retirement plans or benefits programmes
- Union membership (if disclosed or applicable)
We may also collect and process more sensitive data where required:
- Racial or ethnic origin
- Religious or philosophical beliefs
- Sexual orientation or gender identity
- Political opinions (where voluntarily disclosed or relevant under law)
- Trade union membership
- Health-related information, such as:
- Records of sickness absence
- Information about medical conditions or disabilities
- Occupational health reports
- Data relating to claims under permanent health insurance
- Health information used for pension or insurance purposes when employment ends
- Genetic or biometric data (if applicable and legally permissible)
- Information about criminal convictions and offences (where permitted or required by law)
We only collect and process this information where necessary, and we take appropriate steps to ensure it is handled securely, lawfully, and in line with relevant privacy regulations.
HOW WE USE PARTICULARLY SENSITIVE PERSONAL INFORMATION
Certain types of personal data are legally defined as “special category” or particularly sensitive information. This includes details about your health, racial or ethnic background, sexual orientation, religious beliefs, and trade union membership. These data types require a higher level of protection, and Luxe Protection Films is committed to handling them with the utmost care.
We only process sensitive personal information when we have a clear legal basis to do so and where appropriate safeguards are in place, including maintaining a dedicated policy document as required by law.
We may process sensitive personal data in the following situations:
- With your explicit written consent (only in limited, clearly defined circumstances).
- Where it’s necessary for us to fulfil our legal obligations or exercise specific employment rights.
- Where it serves a significant public interest, such as diversity and equal opportunities monitoring.
- Where it is necessary to protect your vital interests or someone else’s, for example in a medical emergency.
- Less commonly, we may process sensitive personal data:
- In connection with actual or potential legal claims;
- Where you are not capable of giving consent, and the information is required to protect your interests or someone else’s;
- Where you have already made the information public.
WHEN WE USE YOUR SENSITIVE PERSONAL INFORMATION
In general, we will only use this kind of information if it is directly related to your employment and we’re legally allowed to do so. Here are some examples of how and why we may use it:
Health and Disability Information:
We may process details relating to your physical or mental health, including any disability status, in order to:
- Make sure the workplace is safe and meets your needs
- Assess your ability to carry out your job duties
- Implement reasonable adjustments where required
- Monitor and manage sick leave or absence
- Administer health-related benefits
This helps us comply with employment laws and ensure proper support is provided during your time with Luxe.
Risk of Harm:
If we believe there’s a risk to your physical, emotional or mental well-being—or to someone else’s—we may process relevant sensitive data to protect those involved.
Diversity & Equal Opportunities:
We may use data relating to your race, ethnic origin, religion or belief, sexual orientation, or other protected characteristics to ensure fair treatment, equal opportunity monitoring, and compliance with diversity initiatives or legal reporting requirements.
INFORMATION ABOUT CRIMINAL CONVICTIONS
Luxe Protection Films only processes information relating to criminal convictions where the law explicitly permits us to do so. This usually applies when processing is necessary to fulfil our legal or contractual obligations, and always in accordance with our Data Protection Policy.
We generally do not expect to hold any information regarding criminal convictions.
We will only collect details about criminal convictions when it is appropriate based on the nature of the role you are applying for or working in, and where we have a lawful basis to do so. Such information may be collected as part of the recruitment process or provided directly by you during your employment.
AUTOMATED DECISION-MAKING
Automated decision-making occurs when decisions are made by electronic systems using personal data without any human involvement. Luxe Protection Films will only use automated decision-making in the following situations:
- Where you have been informed about the decision and given a minimum of one month to request a review or reconsideration.
- Where it is necessary to perform the employment contract with you, and where appropriate safeguards are in place to protect your rights.
- In rare cases, where you have given explicit written consent and where suitable measures exist to ensure your rights are protected.
If any automated decision involves particularly sensitive personal data, such as health or ethnicity information, we will either obtain your explicit written consent or demonstrate that the decision is justified by public interest, alongside applying necessary safeguards.
You will never be subject to decisions that significantly affect you based solely on automated processing unless we have a lawful basis and have properly informed you.
Currently, Luxe Protection Films does not use automated decision-making to make employment-related decisions. If this changes in the future, we will notify you in writing.
DATA SHARING
Luxe Protection Films may need to share your personal data with third parties, including external service providers and other entities within the Luxe group.
We require all third parties to respect the confidentiality and security of your data and to process it in strict accordance with applicable data protection laws.
Your personal information will only be shared with third parties when it is legally required, necessary to manage your working relationship with Luxe, or when we have a legitimate interest in doing so.
Third-party service providers may include contractors and designated agents who carry out activities such as payroll and pension administration, benefits provision and management, and IT support services.
All third-party providers engaged by Luxe must implement appropriate security measures to protect your personal information in line with our internal policies. We do not permit any third party to use your personal data for their own purposes. Their processing is strictly limited to the purposes we specify and must follow our instructions at all times.
DATA RETENTION
Luxe Protection Films retains your personal data only for as long as is reasonably necessary for the purposes for which it was collected and processed, in line with our data retention policy. We may also retain data as required to comply with legal obligations, resolve disputes, or enforce agreements.
When determining the appropriate retention period for your personal data, we consider:
- The amount, nature, and sensitivity of the data collected.
- The potential risks of harm resulting from unauthorised use or disclosure of your data.
- The purposes for which we process the data and whether these can be achieved through alternative means.
- Applicable legal and regulatory requirements.
In some cases, Luxe may anonymise personal information so that it can no longer be linked back to you, allowing us to use such data without further notice.
Once you are no longer an employee, worker, or contractor of Luxe Protection Films, your personal information will be securely retained and destroyed in accordance with applicable laws and regulations.
EUROPEAN UNION DATA PROTECTION RIGHTS AND ADDITIONAL INFORMATION
CHANGES TO THIS PRIVACY NOTICE
CONTACT INFORMATION
APPENDIX A – YOUR RIGHTS UNDER THE GDPR
EU employees, unless otherwise specified by the GDPR, have the following rights concerning their personal data:
- The right to request a copy of the personal data Luxe holds about you.
- The right to ask Luxe to correct any inaccurate or outdated personal data.
- The right to request erasure of your personal data when it is no longer necessary to retain it.
- The right to restrict how your personal data is processed.
- The right to receive your personal data in a structured, commonly used format to transfer it to another data controller.
- The right to object to the processing of your personal data.
- If Luxe obtained your consent to process personal data, you have the right to withdraw that consent at any time.
Please note, these rights are not absolute, and Luxe may legally refuse or limit your requests where applicable.
EXERCISING YOUR RIGHTS
You can exercise any of your data protection rights by contacting Luxe using the details provided above.
If we have reasonable doubts about your identity when processing your request, we may ask for additional information to confirm who you are.
APPENDIX B – TRANSFER OF DATA ABROAD
In the course of your employment, Luxe may transfer your personal data outside the European Economic Area (EEA) to affiliated companies or third-party service providers, including those based in the USA.
Where data is transferred to countries that the European Commission has not recognised as having adequate data protection, Luxe will implement appropriate safeguards to protect your personal information.
If you would like more details on the specific transfer mechanisms Luxe uses, please contact us using the contact information above.
LODGING A COMPLAINT
Luxe only processes your personal data as described in this Privacy Notice and in line with applicable data protection laws.
If you wish to raise a complaint about how your personal data is processed or if you are unhappy with how we have handled your information, please contact Luxe as described above.
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