Privacy & Cookies Policy

Effective Date: 25th August 2025
Last Updated: 25th August 2025

LUMA CIRCLE LTD (“Company,” “we,” “us,” or “our”) respects your privacy and is committed to protecting your personal data. This Privacy & Cookies Policy explains how we collect, use, and safeguard your information in compliance with the UK GDPR, EU GDPR, and applicable data protection laws.

1. Data Controller

The data controller within the meaning of the GDPR is:

LUMA CIRCLE LTD
71–75 Shelton Street
Covent Garden
London WC2H 9JQ
United Kingdom
Company No.: 16666936
Email: hello@lumacircle.co

2. Personal Data We Collect

We may collect and process the following personal data:

  • Contact data (name, email address, telephone number)

  • Application and program data (information submitted via forms, surveys, or applications, including through Tally)

  • Payment and transaction data (processed securely by third-party providers; we do not store full payment card details)

  • Technical and usage data (IP address, browser type, operating system, referring URLs, device identifiers, pages visited, time spent — via cookies, Google Analytics, Hotjar)

  • Marketing and communication data (email preferences, engagement with our newsletters, interactions with advertising via Brevo and Google Ads)

3. How We Collect Your Data

  • Directly from you when you sign up, apply, or contact us

  • Through cookies and analytics when you use our website

  • Via integrations between tools (e.g. Tally forms connected via Zapier into Brevo)

4. Legal Bases for Processing

We process personal data only where a legal basis applies under Article 6 GDPR:

  • Consent (Art. 6(1)(a)): e.g. newsletter subscriptions, marketing cookies

  • Contract (Art. 6(1)(b)): providing services, processing applications or purchases

  • Legal obligation (Art. 6(1)(c)): record-keeping for tax and accounting purposes

  • Legitimate interest (Art. 6(1)(f)): improving services, running advertising campaigns, ensuring site security

5. Purposes of Processing

Your data may be used for:

  • Processing applications and delivering services

  • Managing program registrations and communication

  • Sending newsletters, updates, and marketing (with consent)

  • Running advertising campaigns (Google Ads, Brevo)

  • Improving website performance and user experience (analytics, Hotjar)

  • Automating business workflows (Zapier)

  • Complying with legal obligations

6. Third-Party Processors

We may share your data with the following service providers:

  • Squarespace, Inc. – website hosting

  • Google LLC – analytics and advertising (Analytics, Ads)

  • Brevo – email marketing and automation

  • Hotjar Ltd. – user experience insights

  • Tally – online forms and surveys

  • Zapier, Inc. – workflow automation

Some providers are located outside the UK/EU (e.g. US). In such cases, transfers are safeguarded by Standard Contractual Clauses (SCCs) or equivalent mechanisms.

7. Data Retention

We retain personal data only as long as necessary:

  • Contact data: until you unsubscribe or request deletion

  • Application and program data: retained for service delivery, then archived or deleted after [X years]

  • Transaction records: minimum of 6 years (legal obligation)

  • Analytics data: 14–26 months (depending on provider settings)

8. Your Rights

Under GDPR, you have the right to:

  • Access your personal data (Art. 15)

  • Rectify inaccurate data (Art. 16)

  • Request deletion (“right to be forgotten”) (Art. 17)

  • Restrict processing (Art. 18)

  • Data portability (Art. 20)

  • Object to processing (Art. 21)

  • Withdraw consent at any time (Art. 7(3))

You may also lodge a complaint with a supervisory authority:

  • UK: Information Commissioner’s Office (ICO) – www.ico.org.uk

  • Portugal: Comissão Nacional de Proteção de Dados (CNPD) – www.cnpd.pt

To exercise your rights, contact us at hello@lumacircle.co.

9. Cookies

What Are Cookies?

Cookies are small text files stored on your device when you visit our website. They help us provide functionality, improve site performance, and deliver relevant advertising.

Types of Cookies We Use

  • Strictly Necessary Cookies (essential for website operation; cannot be disabled)

  • Analytics Cookies (Google Analytics, Hotjar – help us understand how visitors use the site)

  • Marketing Cookies (Google Ads, Brevo – help us deliver relevant advertising)

Managing Cookies

On your first visit, you will see a cookie banner allowing you to accept or reject non-essential cookies. You can also manage cookies through your browser settings or withdraw consent at any time.

For more information on cookies and how to control them, visit www.aboutcookies.org.

10. Data Security

We apply appropriate technical and organizational measures to safeguard personal data, including secure hosting, encryption, and restricted access.

11. Updates to this Policy

We may update this Privacy & Cookies Policy from time to time. Any material changes will be posted on this page with an updated revision date.

Contact
For questions regarding this policy or your data rights, please contact us at:
hello@lumacircle.co