Last updated: November 2025
GOVERNING LAW
These terms and conditions are governed by and to be interpreted in accordance with English law and in the event of any dispute arising in relation to these terms and conditions or any dispute arising in relation to the website, whether in contract or tort or otherwise, the English courts will have exclusive jurisdiction over such dispute.
PRIVACY POLICY
Luminate Ltd are committed to protecting and respecting your privacy and personal data. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. It also sets out your privacy rights and how the law protects you. Luminate Ltd are committed to total transparency on how we collect, process and use the data of our customers and contributors.
For the General Data Protection Regulations (GDPR), the data controller is 8 Devonshire Square, London, EC2M 4PL (collectively referred to as "we", “us” or “our” in this policy).
We have appointed a data protection contact/person responsible for data protection compliance. You can contact them at:
poppymillett@weareluminate.coPERSONAL DATA WE COLLECT FROM YOUPersonal data” means information that identifies you. We may collect, use, store and process the following categories of data:
INFORMATION YOU PROVIDE DIRECTLY
This includes information provided:
• via our website (www.weareluminate.co)
• via third-party platforms such as LinkedIn or Eventbrite
• via email, phone, online forms, social media messages or post
• when registering for or attending our events or webinars
• when enquiring about, purchasing or providing feedback on our services.
This may include:
• Name, job title, organisation
• Email address, phone number, postal address
• Payment details, invoicing information, VAT and company registration numbers
• Any information you provide when corresponding with us.
DATA COLLECTED BY LINKEDIN
We may collect data from:
• LinkedIn Lead Generation Forms
• LinkedIn Event registrations
• LinkedIn messages
• LinkedIn Insight Tag (see Cookie section)
• Engagement with Luminate content or ads on LinkedIn
This may include your name, email address, employer, job role and other profile information you choose to share with us.
DATA COLLECTED VIA EVENTBRITE
When you register for Luminate events on Eventbrite, we may receive:
• Your name and contact details
• Ticket type, event preferences
• Organisation information
• Any questions or data you provide during sign-up
TECHNICAL & USAGE DATA
We may collect:
• IP address
• Browser type and version
• Time zone setting and location
• Device type
• Pages visited and interactions with our site
• Traffic data, weblogs, communication data
Collected via tools including Google Analytics, HubSpot, LinkedIn Insight Tag and AddToAny.
SENSITIVE DATA
We process special category data relating to mental or physical health only where necessary (e.g., with explicit consent for counselling sessions or workshop support) and with an appropriate lawful basis. Our lawful basis under Article 6 UK GDPR is consent, and our condition for processing under Article 9 UK GDPR is explicit consent (Art. 9(2)(a)).
COOKIES AND TRACKING TECHNOLOGIESIn accordance with the UK Privacy and Electronic Communications Regulations (PECR), non-essential cookies – including those used for analytics, tracking, and marketing – will only be set on your device where you have provided your explicit consent through our cookie banner or preferences centre. You may withdraw your consent at any time by clicking on the cookie icon in the bottom left of your browser and selecting your preferences.
We may collect information about your computer, including, where available, your IP address, operating system and browser type, for system administration and to report aggregate information to us. This is statistical data about our users' browsing actions and patterns and does not identify any individual. They help us to improve our site and to deliver a better and more personalised service.
They enable us:
• To estimate our audience size and usage patterns.
• To speed up your searches.
• To recognise you when you return to our site.
Non-essential cookies (including analytics and marketing cookies) will only be activated after you give consent in our cookie banner.
COOKIES USED ON OUR WEBSITE
• AddToAny (sharing tools)
• Google Analytics (usage analytics)
• HubSpot (marketing automation, forms, analytics)
• LinkedIn Insight Tag (analytics, ad measurement, audience insights)
ADDTOANY.COM
The cookie is used by cdn services like CloudFare to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It does not correspond to any user ID in the web application and does not store any personally identifiable information.
GOOGLE ANALYTICS
This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.
Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may update or withdraw your consent at any time by adjusting your cookie preferences.
HUBSPOT
Our website uses cookies provided by HubSpot, Inc. (“HubSpot”), a customer relationship management and marketing automation platform. HubSpot sets several non-essential cookies that help us understand how visitors interact with our website, assist with customer service, allow us to manage forms and enquiries, and support our legitimate interest in improving our services - where such processing is permitted under UK GDPR and where you have given consent under PECR.
The HubSpot cookies used on our website may include:
• Analytics cookies: to understand visitor behaviour, such as pages viewed, time spent on the site and navigation patterns.
• Tracking cookies: to identify repeat visits and link onsite behaviour to marketing emails and forms where you have explicitly opted in.
• Functionality cookies: to enable features such as live chat, form completion, and saving user preferences.
HubSpot may collect your IP address, browser type, device identifiers, and usage patterns. Data may be stored on servers located in the United States. HubSpot participates in regulatory frameworks designed to provide adequate safeguards for international data transfers, and we have implemented appropriate measures to ensure your personal data is processed securely and in accordance with UK GDPR.
HubSpot cookies are non-essential. You may update or withdraw your consent at any time by adjusting your cookie preferences.
LINKEDIN INSIGHT TAGS
If you interact with our content on LinkedIn or visit our site after viewing our ads, LinkedIn may collect:
• IP address
• Device information
• Pages viewed
• Engagement data
This helps us understand the effectiveness of our content and shows aggregate analytics. You can manage your LinkedIn advertising preferences directly in your LinkedIn account.
Where we rely on consent for the use of cookies or similar technologies, we will request this via our cookie banner before any non-essential cookies are placed on your device. You may update or withdraw your consent at any time by adjusting your cookie preferences.
THIRD-PARTY LINKSOur website may include links to and embedded content from third-party websites i.e., plug-ins, applications videos, images, and articles. Clicking on those links or interacting with the embedded content may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
LEGAL BASIS FOR PROCESSING YOUR DATA We process your personal data only when permitted by law. This includes:
• Contract performance - when providing services you have purchased.
• Legal obligations - e.g., tax, accounting or regulatory requirements.
• Legitimate interests - e.g. operating our business, improving services, responding to enquiries, promoting relevant wellbeing content.
• Consent - for marketing emails, cookies, and any sensitive data.
You may withdraw consent at any time.
HOW WE USE YOUR DATAWe use your data to:
• Provide the services, workshops, programmes or information you request
• Register you for events and manage attendance
• Communicate with you regarding your enquiry, contract or participation
• Provide customer service and technical support
• Understand how our website and content are used
• Improve our services
• Send relevant marketing communications (where legally permitted i.e., marketing emails are only sent to those who have opted in)
• Manage business operations, invoicing and accounts
• Detect and prevent fraud or misuse of our website
FAILURE TO PROVIDE PERSONAL DATAIf you choose not to provide necessary data (e.g., workshop registration details or invoicing information), we may not be able to deliver the services requested.
WHERE WE STORE YOUR PERSONAL DATAYour data is encrypted and stored on secure servers in the United States. Space on these servers is supplied to Luminate Ltd by third parties: Dropbox (Dropbox International Unlimited Company), HubSpot (HubSpot, Inc) and Mailchimp (Intuit Limited).
By submitting your personal data, you agree to its storage and processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
Unfortunately, the transmission of information via the internet is not completely secure. Any online transmission of personal data is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. Third parties are under legally binding contracts and obliged to implement appropriate and organisational measures to ensure the security of the data.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
The data that we collect from you will be stored and/or transferred to countries outside the European Economic Area (EEA) as stated above in relation to Dropbox, HubSpot, Mailchimp and Google Analytics. When we transfer your personal data outside the UK, we ensure it is protected by entering into UK International Data Transfer Agreements (IDTA) or Standard Contractual Clauses (SCC) with our service providers, so your information is handled safely and in compliance with UK data protection law. Copies of our UK IDTA/SCC documentation are available upon request.
DATA SHARING We share your personal data only when necessary:
• With Luminate employees and contractors
• With third-party processors such as HubSpot, Mailchimp, LinkedIn, Eventbrite
• With payment providers, hosting providers and IT support
• With credit reference agencies where relevant
• With regulators, auditors or HMRC where legally required
• With potential buyers in the event of a business sale (under confidentiality agreements)
We never sell your personal data.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
DATA RETENTION Luminate Ltd holds your personal data depending on the type of service we undertake on your behalf.
By law, we have to keep certain information about our customers for six years after you cease being a customer for tax purposes. Following such time, your data will be archived.
Data obtained that does not proceed to a contractual obligation on either parties’ behalf will be retained for 2 years and then archived.
Data obtained, which then proceeds to a continuous trading relationship, will be retained for as long as the trading relationship remains active and for up to six years thereafter, in line with HMRC and contractual limitation requirements.
All credit history with your organisation will be kept for a maximum of seven years.
YOUR RIGHTSLuminate Ltd is committed to ensuring the protection of your rights under applicable laws. You will find below a summarisation of your different rights:
RIGHT OF ACCESS
You can request access to your personal data. If you enquired on the site, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You may also request rectification of inaccurate personal data or to have incomplete personal data completed. Please note that we may need to verify the accuracy of the new data you provide to us.
RIGHT TO BE FORGOTTEN
Your right to be forgotten entitles you to request the erasure of your personal data in cases where:
• The processing of your data is no longer necessary
• You choose to withdraw your consent
• You object to the processing of your personal data (see below)
• Your personal data has been unlawfully processed
• There is a legal obligation to erase your personal data
Please note that we may not always be able to comply with your request for erasure for specific legal, administrative or security reasons, which will be notified to you, if applicable, at the time of your request.
RIGHT TO RESTRICTION OF PROCESSING
You may request that processing of your personal data be restricted and/or suspended in the cases where:
• You contest the accuracy of the personal data;
• We no longer need the personal data for the purposes of processing;
• The use of the data is unlawful but you do not want us to erase it;
• You need us to hold the data even if we no longer require it, as you need it to establish, exercise or defend legal claims;
• You have objected to processing for legitimate reasons.
RIGHT TO DATA PORTABILITY
You can request, where applicable, the transfer of your personal data to you, or to a third party (where technically feasible). This right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
RIGHT TO OBJECT TO PROCESSING FOR THE PURPOSES OF DIRECT MARKETING
You may exercise your right to object to the processing of your personal data, e.g., for the purposes of profiling or marketing communications or if you object to the legitimate interest being relied upon.
When we process your personal data on the basis of your consent, you can withdraw your consent at any time. This will not affect the lawfulness of the processing carried out before you withdrew your consent. We may not be able to provide certain products or services to you if you withdraw your consent. We will advise you if that is the case at the time you withdraw.
If you wish to exercise any of the rights above, then please contact poppymillett@weareluminate.co. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we can refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally, it could take us longer than one month if your request is particularly complex or you have made a number of requests. If this is the case, we will notify you and keep you updated.
RIGHT TO LODGE A COMPLAINT TO THE COMPETENT SUPERVISORY AUTHORITY
If you have a privacy-related complaint against us, please do get in touch at poppymillett@weareluminate.co or call us on (0)203 637 7417 or by post, at:
8 Devonshire Square,
London, EC2M 4PL
If you are dissatisfied with our response, you may then seek further recourse by contacting the UK supervisory authority for data protection issues - The Information Commissioner’s Office – at international.team@ico.org.uk, by calling on 01625 545 745 or by post at:
Water Lane,
Wycliffe House,
Wilmslow,
Cheshire, SK9 5AF
You also have the right to ask us not to process your personal data for marketing purposes and to object to the processing of your data where Luminate Ltd is relying on legitimate interest as a legal ground for processing.
You can also exercise any of these rights at any time by either emailing us at poppymillett@weareluminate.co or calling us on (0)203 637 7417.
Our site may, from time to time, contain links, plug-ins or applications to and from the websites of our group companies, partner networks, advertisers and affiliates. If you follow a link to any of these websites or enable these connections, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
CHANGES TO OUR PRIVACY POLICY
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.
CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be emailed
poppymillett@weareluminate.co or
melcrate@weareluminate.co
