1. Introduction

This Privacy Policy explains how Luven Labs Limited (“Luven Labs”, “we”, “us”, “our”) collects, uses, shares and protects your personal data when you use our website, platform and related services (together, the “Services”).

Luven Labs operates a platform that connects candidates/job seekers with clients/employers by matching candidates to vacancies and related opportunities. In doing so, we process personal data about both candidates and client contacts.

This Privacy Policy also explains your privacy rights and how to exercise them.

By using our Services, you acknowledge that you have read and understood this Privacy Policy.

2. Who we are and how to contact us

Controller: Luven Labs Limited, registered in England and Wales

Registered office:

1 Elmfield Park
C/O Stf Professional
Bromley
Greater London
United Kingdom
BR1 1LU

Contact email for privacy and support

help@aluena.com

Luven Labs Limited is the “data controller” for personal data we collect and use in connection with the Services, except where we state otherwise.

3. Scope of this Privacy Policy

This Privacy Policy applies to personal data we process when you:

• Visit or use our website or landing pages

• Register as a candidate or client

• Submit your CV, job vacancy or any other data through our forms

• Interact with us by email or other communication channels

• Use any features or tools on the Luven Labs platform

It does not apply to third-party websites, tools or services that we do not own or control. Those services are governed by their own privacy policies.

4. Personal data we collect

“Personal data” means any information that identifies or can reasonably identify an individual.

Depending on how you use the Services, we may collect the following categories of personal data:

4.1 Data you provide to us directly

Candidates (job seekers)

When you register your interest or otherwise interact with us, you may provide:

• Name and contact details (e.g. email, phone)

• CV and employment history

• Skills, experience and qualifications

• LinkedIn profile or other professional links

• Role preferences, location preferences

• Salary expectations and current/previous compensation ranges

• Notice period and availability

• Any other information you choose to include in your CV, messages, or forms

Clients (employers / hiring organisations)

When you register as a client or submit a vacancy, you may provide:

• Company name and business contact details

• Contact person’s name, role, email and phone number

• Job descriptions and role requirements

• Salary ranges and benefits

• Information about your hiring challenges and processes

• Any other business-related information you choose to provide

General communications

When you contact us (e.g. by email, forms, or support), we may also collect:

• The content of your message or enquiry

• Any additional information you choose to provide

4.2 Information collected automatically

When you visit our website or use our Services, we automatically collect certain information using cookies and similar technologies (see Section 7 below), including:

• IP address and approximate location (based on IP)

• Device type, operating system and browser type

• Date and time of access

• Pages viewed and navigation paths

• Clicks and other interactions

• Session duration and frequency of visits

We may use analytics tools to collect information about how users interact with our website, such as:

• Which pages are visited and in what order

• How long users spend on pages

• Basic interaction events (e.g. clicks, page views)

This data helps us understand how our Services are used and how to improve them. We do not use PostHog in this version of the Services.

4.3 Information from other sources

We may receive information about you from:

• Publicly available professional sources (e.g. LinkedIn)

• Referrals from other candidates or clients

• Third-party services we use (e.g. hosting, email, analytics)

• Group companies, partners or affiliates (now or in future), where permitted by law

Where we receive data from third parties, we process it in accordance with this Privacy Policy.

5. How we use your personal data and legal bases

We process personal data only where we have a lawful basis under the UK GDPR, EU GDPR and Data Protection Act 2018. The main legal bases we rely on are:

• Performance of a contract

• Legitimate interests

• Consent

• Compliance with legal obligations

5.1 To provide and operate our Services

We use personal data to:

• Register and manage candidate and client profiles

• Match candidates with suitable vacancies and clients

• Communicate with candidates about roles and opportunities

• Communicate with clients about candidates and hiring needs

• Facilitate introductions and shortlists

• Handle enquiries and provide customer/support services

Legal basis: performance of a contract; legitimate interests (providing and improving our Services).

5.2 To improve and develop our platform and analytics

We use usage and analytics data to:

• Understand how users navigate and interact with our website

• Analyse performance, funnels and engagement

• Identify issues, improve usability and refine user journeys

• Develop new features, products or services

We may also create aggregated or anonymised datasets for internal use or commercial insights.

Legal basis: legitimate interests (improving and developing our Services).

5.3 Marketing and business development

We may use your contact details to:

• Send updates about roles, candidates, news or features

• Inform you about services, events or opportunities

• Run outreach and business development campaigns

You can opt out of marketing communications at any time by using the unsubscribe link or contacting us at help@aluena.com.

Legal basis: legitimate interests (business development and marketing); in some cases, consent where required by applicable law.

5.4 Compliance, security and legal purposes

We may process your data to:

• Comply with legal and regulatory obligations

• Respond to lawful requests from authorities

• Enforce our Terms & Conditions or other agreements

• Detect, prevent or investigate potential fraud, abuse or security incidents

• Establish, exercise or defend legal claims

Legal basis: legal obligations; legitimate interests (protecting our rights, users and Services).

5.5 Automated decision-making and profiling

We may use algorithms and tools to:

• Score or rank candidate–role matches

• Suggest roles to candidates

• Suggest candidates to clients

These processes are used to prioritise and surface relevant matches but are not intended to be the sole basis for significant decisions about individuals. Human review and discretion remain part of any hiring or engagement process.

Legal basis: legitimate interests (efficient matching and improved service); in some cases, performance of a contract.

If you have concerns about automated processing, you can contact us at help@aluena.com.

6. Sharing your personal data

We may share personal data with the following categories of recipients, where lawful and appropriate:

6.1 Clients and candidates

• Candidate data (e.g. CVs, profiles) may be shared with clients in relation to relevant opportunities.

• Client data (e.g. contact details, job descriptions) may be shared with candidates in relation to roles they are being considered for.

Once shared, clients and candidates become separate controllers of that data for their own purposes (e.g. hiring, internal records) and are responsible for their own compliance with data protection laws.

6.2 Service providers and processors

We use third-party service providers to help us operate and improve our Services, such as:

• Cloud hosting and infrastructure

• Analytics services (where used)

• Communication and email tools

• CRM, productivity and other SaaS tools

• Security and monitoring services

These providers act as “processors” on our behalf and must only process personal data in accordance with our instructions and applicable law, under appropriate contracts.

6.3 Group companies, partners and affiliates

We may share data with:

• Current or future group companies, subsidiaries or affiliates

• Selected partners with whom we collaborate or co-develop services

Where personal data is shared, it will only be used for purposes compatible with this Privacy Policy.

6.4 Legal, regulatory and business transfers

We may disclose personal data:

• Where required by law, regulation, court order or governmental request

• To enforce our Terms & Conditions or protect our rights, property or safety

• In connection with a potential or actual corporate transaction (e.g. merger, acquisition, sale of assets, restructuring). In such cases, personal data may be transferred as part of the transaction, subject to appropriate safeguards.

7. Cookies and tracking technologies

Our website uses cookies and similar technologies (such as localStorage, sessionStorage and scripts) to:

• Enable core functionality of the site

• Remember your preferences

• Perform basic analytics and performance monitoring

Some cookies are strictly necessary for the website to function and are set without your consent. Other cookies (such as analytics/performance cookies) may be used to understand how our website is used and to improve it.

Where required by law, we will ask for your consent before setting non-essential cookies. You can change your preferences at any time via the “Cookie Settings” link on our website or by adjusting your browser settings.

For further information, please see our Cookie Policy, which forms part of this Privacy Policy.

Note: In this version of our Services, we do not use PostHog. If we introduce new analytics providers in the future, we will update this Privacy Policy and/or our Cookie Policy accordingly.

8. International data transfers

We are based in the United Kingdom and may process and store personal data in the UK, the European Economic Area (EEA) and other countries.

Where personal data is transferred outside the UK or EEA and the destination country does not provide an equivalent level of data protection, we will ensure appropriate safeguards such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission and/or UK authorities

• The UK International Data Transfer Addendum or similar instruments

• Other lawful transfer mechanisms under the UK GDPR / EU GDPR

You can contact us at help@aluena.com for more information about international transfers and safeguards.

9. Data retention

We retain personal data for as long as reasonably necessary to:

• Provide and support the Services

• Fulfil the purposes described in this Privacy Policy

• Comply with legal, regulatory and accounting requirements

• Resolve disputes and enforce our agreements

We may retain anonymised or aggregated data indefinitely.

When personal data is no longer required, we will delete it or anonymise it in line with our data retention practices and applicable law.

10. Data security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration or disclosure, including:

• Secure hosting and access controls

• Encryption in transit where appropriate

• Restricted access to personal data on a need-to-know basis

• Monitoring and logging of system activity

However, no system can be fully secure, and we cannot guarantee absolute security. If we become aware of a data breach that may affect your rights and freedoms, we will notify you and the relevant authorities where required by law.

11. Your rights

Depending on where you are located and subject to applicable law, you may have the following rights in relation to your personal data:

• Right of access – to obtain confirmation that we process your data and request a copy.

• Right to rectification – to request correction of inaccurate or incomplete data.

• Right to erasure – to request deletion of your data in certain circumstances.

• Right to restriction – to ask us to restrict processing in certain cases.

• Right to object – to object to processing based on our legitimate interests or for direct marketing.

• Right to data portability – to receive certain data in a structured, commonly used format and transmit it to another controller.

• Right to withdraw consent – where processing is based on consent, you may withdraw it at any time (this does not affect processing carried out before the withdrawal).

To exercise your rights, please contact us at help@aluena.com. We may need to verify your identity before acting on your request.

You also have the right to lodge a complaint with a supervisory authority. In the UK, this is:

Information Commissioner’s Office (ICO)

Website: https://ico.org.uk/

Telephone: +44 (0)303 123 1113

If you are located in the EU/EEA, you may also contact your local data protection authority.

12. Children’s data

Our Services are not intended for children under 18, and we do not knowingly collect personal data from anyone under 18.

If you believe a child under 18 has provided us with personal data, please contact us at help@aluena.com, and we will take reasonable steps to delete such data and, if applicable, close any associated account.

13. Third-party websites and services

Our Services may contain links to third-party websites, services or content that we do not control. If you follow those links or interact with third-party services, their own privacy policies will apply.

We are not responsible for the privacy practices, content or security of third-party sites or services. You should review their privacy information before providing personal data.

14. Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our Services, legal requirements or data processing practices.

When we make material changes, we will:

• Post the updated Privacy Policy on our website, and

• Update the “Last updated” date at the top of this page

In some cases, we may provide additional notice (e.g. by email or on the platform). Your continued use of the Services after the updated Privacy Policy takes effect will constitute acceptance of the changes.

15. Contact us

If you have any questions, concerns or requests regarding this Privacy Policy or our data practices, you can contact us at:

Luven Labs Limited

help@aluena.com
1 Elmfield Park
C/O Stf Professional
Bromley
Greater London
United Kingdom
BR1 1LU