Last updated: 9 December 2024

This Privacy Notice contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint. Please read this privacy notice carefully.

“We”, “us” or “our” means Lumenate Growth Limited. We are a company registered in England and Wales with company number 12254320. Our registered address is at: Runway East Temple Meads 101 Victoria St, Redcliffe, Bristol, England, BS1 6PU. More information about us and our business is available on our website: https://lumenategrowth.com/. We are the provider of the Lumenate Application (the “App”) and the mediation services provided through the App (our “Services”). We are registered with the Information Commissioner’s Office in the UK with reference number ZA854929.

We collect, use and are responsible for certain personal data about you. Our processing of your personal data is subject to the UK General Data Protection Regulation (UK GDPR). Where you are based in Europe, we are also subject to the EU General Data Protection Regulation (EU GDPR) as the App and our Services are available to citizens based in the EU, as well as the UK. 

  1. PERSONAL DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual from which that individual can be identified. 

This Privacy Notice applies to personal data we collect about you when you register for an account on our App, use our App and Services (including purchasing our Premium Services), connect to our App through social media sites, provide us with feedback, request customer support, or otherwise contact us.

We may collect and process the following personal data about you:

  • Identity data: your name;
  • Contact data: you email address used to register with the App;
  • Profile data: the information you use to register with the App and create an account, including your username and password, and approximate age segment;  
  • Financial data: your payment information used to purchase our Premium Services. We do not collect or process credit or debit card (“Payment Card”) data. The applicable App Store (e.g. Apple’s App Store or GooglePlay Store), collect Payment Card data for purchases of our Premium Services made through the App. Such payment processors generally provide us with some limited data related to you, such as a unique, anonymous token that enables you to make additional purchases using the data they’ve stored, and your card’s type, expiration date, billing address, and the last four digits of your card number. How such third parties handle your personal data is governed by their individual privacy notices; 
  • Technical data: information about how you use and interact with the App and our Services. We use mobile analytics technology to allow us to better understand the functionality of our App on your device as well as to analyse behaviour within the App. This may record information such as how often you use the Services, how you engage with the pages of the App and other usage and performance data.. We may link the data we store within our analytics tools to any personal data you submit within the App itself. We may also use dynamic links to tell us where the App was accessed, opened or downloaded from – this does not gives us information about your device and only identifies which link you used to access our App (if any) and therefore the route that you came from. Once you access the App, we will also collect technical data from your device – please be aware that you are able to login to the App from multiple devices and so device information will be collected from any device that is used to log in.
  • Marketing and communications data: this includes your preferences in receiving marketing communications from us and our third parties and your preferences about how we communicate with you for these purposes. We also collect information about you when you click through to the App from advertisements on third party sites (including websites or social media sites and applications);
  • Any other information about you which you provide to us when you communicate with us to provide feedback and survey responses. 
  • Any other information you may provide to the Lumenate Guide from time to time, although we ask you not to input any personally identifiable information into the Lumenate Guide (see ‘Lumenate Guide – Artificial Intelligence Powered Chatbot’ below).

We collect and use this personal data to provide you with access to our App and to provide our Services. If you do not provide personal data we ask for, it may delay or prevent us from creating your account or being able to provide our Services. 

  1. HOW YOUR PERSONAL DATA IS COLLECTED

We collect most of your personal data directly from you when your sign-up and use the App. However, we may also collect information from you indirectly, from your use of the App through our user behaviour analytics tools and tracking pixels, which monitor how you interact and use the App and our Services, such as what pages your visit, what times of the day you use our Services, how long you use the App during each session (etc). 

We may also collect personal data about you from third parties such as Apple, Google or social media sites (such as Facebook, Twitter, Instagram or TikTok) when you utilise our third party log-in functionality – when this happens, the third party that you select will provide us with your name and email address. 

  1. LUMENATE GUIDE – ARTIFICIAL INTELLIGENCE POWERED CHATBOT

Our Lumenate Guide allows App users to exchange messages with a ‘bot’ (or automated service) in order to receive tailored session recommendations and to assist the user with preparing for their chosen sessions. 

Any responses that you receive when using the Lumenate Guide are powered by artificial intelligence (AI).

The Lumenate Guide is an additional feature within the App to help enhance user experience. It is not necessary to use the Lumenate Guide to access our services though and if you do decide to use it, you have complete discretion about what messages you send. Although we ask you not to input any personally identifiable information into the Lumenate Guide. If you nevertheless chose to do so then your personal information would be shared with and processed by OpenAI L.L.C, the third party tool we have chosen to provide the chatbot functionality.

We have entered into a data processing agreement with OpenAI L.L.C and have reviewed their security certification information, to ensure that any information they process on our behalf is subject to sufficient safeguards. As OpenAI L.L.C is a US company we have assessed the risk of the international transfer of any personal data to OpenAI L.L.C and have implemented appropriate safeguards.  

OpenAI L.L.C will process any data that you input into the Lumenate Guide, during your chat session and then for a further retention period of up to 30 days.  

We do not retain the contents of any chats, unless you use our in-App feature to flag any concerns with a conversation and choose to share any messages with us to allow us to deal with your concerns. In these circumstances we will only retain the messages you have chosen to share with us until we have resolved your concern, or such longer period as is necessary to bring or defend any legal claim.

If you have any questions or concerns about your use of the Lumenate Guide please contact us at [email protected]. You can also flag specific messages to us within the App.

  1. HOW AND WHY WE USE YOUR PERSONAL DATA

We must have a legal basis for processing your personal data. We consider that we have a legal basis where:

  • you have given us consent to do so for the specific purposes which we have told you about;
  • performance of a contract with you – i.e. it is necessary for us to do so to enable us to provide you with our Services that you have requested from us by registering with the App; 
  • to pursue our legitimate interests – a legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. Our legitimate interests include things such as providing our Services, improving the services we offer and developing new services, including new or different features and functionality for the App;
  • to comply with our legal obligations; or
  • the law otherwise permits or requires it.

We have set out below a list of all the ways we may use your personal data and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.

What we use your personal data for (the purpose) Type of data Legal basis
To register you as a new user of the App. Identity data Contact dataProfile data Performance of a contract with you
To deliver our Services to you via the App. Identity data Contact dataProfile dataTechnical dataAny other information you may provide to the Lumenate Guide
  • Performance of a contract with you 
  • To pursue our legitimate interests of developing our services, providing tailored services and understanding how our customers use the App
To carry out our obligations arising from our contract with you including: facilitating payment for the Premium Services through the App; or providing you with information and otherwise meeting our obligations.  Identity data Contact dataProfile dataFinancial dataMarketing and communications data Performance of a contract with you
To respond to your enquiries or to process your request in relation to your information (or otherwise). Identity data Contact dataProfile dataMarketing and communications data Performance of a contract with you
To manage our relationship with you including: notifying you about changes to our Terms, this Privacy Notice; or asking you to leave a review or provide feedback.  Identity data Contact dataProfile data
  • Performance of a contract with you 
  • Necessary for our legal obligation
  • Necessary for our legitimate interests (to improve the Services we offer) 
To use your data analytics to improve the App and our Service, enhance the user experience through the App or otherwise develop new services and features. Technical data
  • Necessary for our legitimate interest to develop our business, provide the best service possible to our users and fix errors with our App
To maintain a suppression list should you opt-out of receiving marketing communications Identity data  Necessary for our legitimate interests and to comply with our legal obligations (to ensure that we are not at risk of breaching data protection laws by communicating with you when you’re asked us not to)
Marketing and targeted advertising Identity dataTechnical dataMarketing data Necessary for our legitimate interest to grow our business, provide the best service possible to our users and reach new users

Where we process special category personal data, we will also ensure we are permitted to do so under data protection laws, e.g.:

  • we have your explicit consent;
  • the processing is necessary to protect your (or someone else’s) vital interests where you are physically or legally incapable of giving consent; or
  • the processing is necessary to establish, exercise or defend legal claims.

  1. MARKETING

We can only use your personal information to send you marketing messages if we either have your consent or a ‘legitimate interest’. A ‘legitimate interest’ is when we have a business or commercial reason to use your information. It must not unfairly go against what is right and best for you.

The personal data we have for you is made up of: what you tell us and the data we collect about you when you use our services; or data provided to us from third parties we work with. We consider your information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which services and offers may be relevant for you.

We want to ensure that you are informed and aware of the latest features, services, promotions and events that we can offer you. As detailed in the table above, we may send you communications such as those which relate to any Service or App updates or request feedback from you about your user experience of the App. We consider that we can lawfully send these communications to you as we have a legitimate interest to do so, namely to effectively provide you with the best service we can and to grow our business.

In addition, from time to time we may want to send you additional communications either directly from us or from our named third parties. This includes sending you push notifications through the App. If we decide to do this, we will ask for your consent and clearly set out the purposes for which we’re relying on that consent. 

By consenting to receive additional communications (by app push notifications or email) from us and any named third parties that feature at the point of obtaining consent in respect of such information, we will process your personal data in accordance with this Privacy Notice. If you have provided your consent to receive marketing communications from us and you change your mind, you can change your preferences and unsubscribe at any time by changing the settings on your device or contacting us at [email protected]. 

If you choose not to receive this information, we will be unable to keep you informed of new services and promotions that may interest you.

Targeted Advertising

We use targeted advertising through third party sites, such as social media sites and applications (like Facebook ,Twitter and Instagram etc). This means that you may see an advertisement for our App or Services when using third party websites and applications. We are able to track users who choose to click through the advertisement to access and/or sign up to our App, and we are able to identify which third party website or application you were using when you accessed our App. 

In order to do this, we use a third party provider, Adjust, who provides mobile analytics and attribution services. As part of the services they provide to us, Adjust technology (specifically SDKs and APIs) process the following data from you: 

  • Hashed IP address
  • Mobile identifiers such as the ID for Advertising for iOS (IDFA), Google Advertising ID or similar mobile identifiers
  • Installation and first opening of the App on your mobile device
  • Your interactions within the App (e.g. in-app purchases, registration)
  • Information regarding which advertisements you have seen or clicked on
  • For the Unbotify/Fraud product additionally: sensory data including touch events, counting text changes, accelerometer, gyroscope, battery, light sensor, device hardware specifications and operating system version

The above data is used to track our marketing performance as a business, to match you to our marketing campaigns and to understand how you and our other users engage with our App and Services. Adjust is not able to identify you personally from the data they collect or from the services they provide to us. For more information about how Adjust process your data, please see their privacy notice.  

We use this information to reach as many new users as possible and develop our marketing strategy. Analysing this data allows us to provide the best user experience and grow our business.

We will always treat your personal data with the utmost respect and never sell it with other organisations for marketing purposes.

  1. WHO WE SHARE YOUR PERSONAL DATA WITH

We share information about you as follows and as otherwise described in this Privacy Notice:

  • with companies and contractors that perform services for us or enable us to operate our App – e.g. email service providers; payment processors, our customer support platform provider, android and Apple app stores and other service providers, as well as OpenAI L.L.C our third party AI tool for the Lumenate Guide, in the event that you input any personally identifiable information into the Lumenate Guide (although we ask you not to do this);
  • other third parties we use to help us run our business, (e.g. marketing agencies or cloud hosting providers) including our subscription management services operated by RevenueCat, our analytics through Mixpanel, and our attribution platform provided by Adjust;
  • in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including court order, subpoena, or other lawful requests by public authorities to meet national security or law enforcement requirements;
  • with your consent or at your direction – e.g. you may choose to share actions you take on our Services with third-party social media services via the integrated tools we provide via our Services;
  • share some personal data with other parties, such as potential buyers of some or all of our business or during a restructuring—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations.

We also have to share information or data in order to meet any applicable law, regulation, legal process or enforceable governmental request. 

We may also share anonymised, aggregated data with third parties for research purposes – this is not considered to be personal data as it cannot identity you as an individual. 

  1. HOW LONG YOUR PERSONAL DATA WILL BE KEPT

We will keep your personal data while you have an account with us or we are providing our Services to you. Thereafter, we will keep your personal data for as long as is necessary:

  • to respond to any questions, complaints or claims made by you or on your behalf;
  • to show that we treated you fairly;
  • to keep records required by law.

We will not keep your personal data for longer than necessary. Different retention periods apply for different types of personal data.  When it is no longer necessary to keep your personal data, we will delete or anonymise it.

  1. TRANSFERRING YOUR PERSONAL DATA OUT OF THE UK AND EEA

To deliver provide you with access to the App and deliver Services to you, it is sometimes necessary for us to share your personal data outside the UK and EEA, e.g.:

  • with your and our service providers located outside the UK/EEA; and/or
  • if you are based outside the UK/EEA.

Under data protection law, we can only transfer your personal data to a country or international organisation outside the UK and EEA where:

  • the UK government or, where the EU GDPR applies, the European Commission, has decided the particular country or international organisation ensures an adequate level of protection of personal data (known as an ‘adequacy decision’);
  • there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for data subjects. The safeguards will usually include using legally-approved standard data protection contract clauses; or
  • a specific exception applies under data protection law – this may be where:  1) you have explicitly consented  to the proposed transfer after having been informed of the possible risks; 2) the transfer is necessary for our performance of a contract with you; 3) the transfer is necessary for a contract in your interests, between us and another person; or 4) the transfer is necessary to establish, exercise or defend legal claims.

We may also transfer information for the purpose of our compelling legitimate interests, so long as those interests are not overridden by your interests, rights and freedoms. Specific conditions apply to such transfers and we will provide relevant information if and when we seek to transfer your personal data on this ground.

  1. YOUR RIGHTS

You have the following rights, which you can exercise free of charge:

Access The right to be provided with a copy of your personal data
Rectification The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten) The right to require us to delete your personal data—in certain situations
Restriction of processing The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
Data portability The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object The right to object:
—at any time to your personal data being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights.

  1. KEEPING YOUR PERSONAL DATA SECURE

We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

  1. HOW TO COMPLAIN

Please contact us if you have any query or concern about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner or any relevant European data protection supervisory authority. The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

  1. CHANGES TO THIS PRIVACY NOTICE

This privacy policy was last updated in May 2024. We keep our privacy policy under regular review to make sure it is up to date and accurate. If we change our privacy policy from time to time, we will post the details of any changes on our website. We may also take reasonable steps to notify you if such changes affect how your personal data is processed.

  1. HOW TO CONTACT US
    1. Individuals in the UK

You can contact us by post or email if you have any questions about this Privacy Notice or the information we hold about you, to exercise a right under data protection law or to make a complaint, using the following details: 

  • Email: [email protected] 
  • Post: Runway East Temple Meads 101 Victoria St, Redcliffe, Bristol, England, BS1 6PU

  1. INDIVIDUALS IN THE EEA – OUR EU REP

We have appointed Thomas Galea to be our data protection representative within the EEA. Their contact details are [email protected]. Individuals within the EEA can contact us directly (see above) or contact our European representative.