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 is committed to total transparency on how we collect, process and use the data of our customers and contributors.
For the purpose of 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 Ms Poppy Millett as our data protection officer. They can be contacted via email at the following address: email@example.comINFORMATION WE MAY COLLECT FROM YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, transfer and process the following different kinds of personal data about you:•
Information that you provide by filling in forms on our website (www.weareluminate.co/), via email, post or during telephone calls with us, including identity and contact information i.e. first name, last name, billing address, delivery address, email address. This includes information provided at the time of making enquiries in relation to, or the purchasing of, or feedback on our products and services. We may also ask you for information when you report a problem with our site.•
If you contact us, we may keep a record of that correspondence and may send marketing materials to you from time to time.•
Any media (i.e. images or video) you upload to the site. Please avoid uploading media with embedded location data (EXIF GPS) included as visitors to the website can download and extract location data from images on the website.•
When visitors leave comments on the site we collect the data shown in comment form, the visitor’s IP address and browser user agent string to help spam detection. After approval of your comment, your and profile picture may be visible to the public in the context of your comment.•
Details of transactions you carry out by email, telephone or post, including bank details, VAT registration number and company registration number, and records of the fulfilment of your orders.•
Details of the terms and conditions and privacy statements regarding your relationship with us.•
Details of your visits to our website or telephone calls with us including, but not limited to, traffic data, location data, weblogs, other communication data and the resources that you access.•
We may seek information from third parties such as credit risk assessors, bank references and Companies House
We may also collect, process and use more sensitive personal data including data concerning physical and mental health.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.IP ADDRESSES AND COOKIES
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 pattern and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our site and to deliver a better and more personalised service.
If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.
They enable us:•
To estimate our audience size and usage pattern. •
To speed up your searches. •
To recognise you when you return to our site.
Our site uses the following cookies:•
Google Analytics 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.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. WHERE WE STORE YOUR PERSONAL DATA
Your 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) and HubSpot (HubSpot, Inc).
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.
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. Where we engage with third parties to process data on our behalf, they do so on the basis of written instructions or legally binding contracts, are under a duty of confidentiality and are obliged to implement appropriate and organisational measures to ensure the security of the data.
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 and HubSpot and Google Analytics.
Legal ground for processing and uses made of the information:
We will process your personal data for any of the following reasons:-•
For the performance of a contract to which you are party; •
To ensure compliance, and regulatory and legal obligations are being met;•
Where is it necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; and •
Because you have given us consent to do so.
Luminate Ltd has a legitimate interest in processing personal data before, during and after the end of a relationship or contract, except where such interests are overridden by your interests or fundamental rights and freedoms.
We use information held about you in the following ways:•
To provide you with the products, services or information that you request from us. •
To carry out our obligations arising from any contracts entered into between you and us. •
To provide information on request to product providers in the course of your application and our on-going relationship.•
To ensure that content from our site is presented in the most effective manner for you and for your computer or internet enabled device.•
To notify you about changes to our service.•
For marketing purposes, to provide you with information about goods and services which we think you may be interested in or where you have consented to be contacted for such purposes.
If you are a new or existing customer, we will contact you by email, post or telephone only. CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.DISCLOSURE OF YOUR INFORMATION
Your personal information will be shared internally with staff and regular contractors when access to the data is necessary for the performance of their roles.
We may disclose your personal information to third parties:•
In order to process orders as part of a service to which you have consented i.e. the fulfilment of your order, the processing of your payment details and the provision of support services. In these circumstances the data will be subject to confidentiality arrangements.•
Website comments may be checked through an automated spam detection service.•
Website comments may be provided to Gravatar (an Automattic Inc company) to see if you are using their service. After approval of your comment, your profile picture is visible to the public in the context of your comment.•
In the event that we sell or buy any business or assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. •
If Luminate Ltd, the business or its assets are acquired by a third party, we may disclose your personal data to any prospective buyer. In addition your personal data will be one of the transferred assets. •
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.HOW LONG DO WE HOLD YOUR DATA?
Luminate Ltd hold 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 which 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 indefinitely so as to be able to provide documentary evidence to HMRC in the event of an investigation of your organisation.
All credit history with your organisation will be kept for a maximum of seven years.
If you leave a comment on our website, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.YOUR RIGHTS
Luminate Ltd is committed to ensure 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 made an enquiry via the site, or have left comments, 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 of 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 the 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 which 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 of 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 firstname.lastname@example.org
. 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 email@example.com
or calling 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 firstname.lastname@example.org
, by calling on 01625 545 745 or by post at:
Cheshire, SK9 5AF
You also have the right to ask us not to process your personal data for marketing purposes and to oppose 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 email@example.com
or calling us on (0)203 637 7417.