Luminato Limited respects your privacy and is committed to protecting your personal data. This privacy policy sets out how we collect, use and protect your personal data and tells you about your privacy rights and how the law protects you.

Our contact details

Name: Luminato Limited
Address: 71-75 Shelton Street, Covent Garden, London WC2H 9JQ
Email: [email protected]

This Privacy Policy was completed on 5th November 2020. We keep this Privacy Policy under regular review, and we may change it from time to time by updating this page. You will be deemed to have accepted the terms of the Privacy Policy on your first use of our website following the alterations. We recommend that you check this page regularly.

The type of personal information we collect

We currently collect and process the following information:

• Personal identifiers including first name, last name, company name and social media usernames
• Contact identifiers including telephone number, email address, company address and billing address
• Financial identifiers including bank account and payment card details
• Business practice identifiers including communications with you, information relevant to services being provided, or business issues being discussed.

How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you. We also receive personal information indirectly from:

• Other people within your business, by word of mouth, by recommendation via professional or personal networks, or by other relevant third parties.
• Through widely available public sources such as social media platforms, Companies House, the press, your website, and other providers of business and financial information.

This personal information is provided to us for one or more of the following reasons:

• To enquire about our services and, more specifically, to ascertain the viability of our services meeting your needs
• To enter into contractual arrangements for the provision of our services
• To communicate with us for the duration of our service provision to you
• To receive and pay invoices for the services we provide
• To be introduced to third party services that may benefit your business

We use the information that you have given us in order to:

• Liaise with you and respond to your queries prior to agreeing a contract for the provision of services
• Fulfil our contractual obligations in providing our service to you
• Communicate with you and manage our relationship with you for the duration of our service provision to you
• Optimise our service offering, our website and our Client relationships
• Assess your suitability for introduction to third party suppliers that may benefit your business
• Manage and maintain records of business communications, services and finances
• Comply with regulatory and other legal obligations
• Manage payments, fees and charges, and collect and recover money owed to us
• Prevent or detect fraud or other illegal activities
• Protect our business interests, including investigating complaints, managing insurance and claims, and protecting or enforcing our legal rights

As well as communicating with you using our communications systems (such as email), we may also connect with you or follow you on social media, in order to keep up to date with your activities and business issues of interest.

We may send marketing communications to you using the personal, contact and business practice identifiers you provide to us or published by you for business purposes. We will only do this if relevant to specific issues raised by you, or in which you have expressed an interest, or otherwise with your consent. We will maintain records of marketing communications with you.

We may share your personal information with:

• Our service providers and professional advisers, such as cloud-based hosting, storage and email service providers and accounting systems
• HMRC, regulatory bodies and other law enforcement authorities
• Third parties that we introduce you to for provision of additional services that may benefit your business
• Our insurers where relevant
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.
• Other third parties where required or permitted by law, or with your consent

Wherever possible, we and our sub-processors will host and process your data within the European Economic Area. Some of our sub-processers (our service providers as detailed above) host and process your data outside of the European Economic Area. In these instances, our sub-processors will host and process your data in a country that is recognised as adequate by the EU to receive and process EU personal data, or in a country that has appropriate safeguards in place as prescribed by the EU, i.e. by entering into the European Commission’s Standard Contractual Clauses with the sub-processor.

Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing your personal information are:

• We have a contractual obligation – to enable us to carry out the contract we have entered or are about to enter with you
• We have a legitimate interest – we legitimately need the information to be able to perform our services for you, to communicate with you whilst performing the services, and to manage the corresponding financial agreements for the services
• Your consent – we will only process your information where you have provided your consent for us to do so. You are able to remove your consent at any time. You can do this by contacting Rachel Green, Director, Luminato Limited, [email protected]

How we store your personal information

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the personal data we collect.

We will hold the personal data that we collect for a period of six years following the conclusion of the contractual agreement or the closure of the relevant matter, whichever is sooner.

Your data protection rights

Under data protection law, you have rights including:

Your right of access – you have the right to ask us for copies of your personal information.

Your right to rectification – you have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure – you have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing – you have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing – you have the right to object to the processing of your personal information in certain circumstances.

Your right to data portability – you have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at Luminato Limited, [email protected] if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at Luminato Limited, [email protected]

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk