Privacy policy.
This privacy notice tells you what to expect us to do with your personal information.
Contact details
Email: naureen@luminateadvisers.com
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
Names and contact details
Addresses
Occupation
Payment details (including card or bank information for transfers and direct debits)
Transaction data (including details about payments to and from you and details of products and services you have purchased)
Usage data (including information about how you interact with and use our website, products and services)
Information relating to compliments or complaints
Video recordings
Audio recordings (eg calls)
Records of meetings and decisions
We collect or use the following personal information for the operation of client or customer accounts:
Names and contact details
Addresses
Purchase or service history
Marketing preferences
We collect or use the following personal information for information updates or marketing purposes:
Names and contact details
Addresses
Profile information
Marketing preferences
Purchase or account history
We collect or use the following personal information to comply with legal requirements:
Name
Contact information
Identification documents
Client account information
Any other personal information required to comply with legal obligations
We collect or use the following personal information for dealing with queries, complaints or claims:
Names and contact details
Address
Payment details
Account information
Purchase or service history
Customer or client accounts and records
Financial transaction information
Correspondence
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are in brief set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. You can read more about this right here.
Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
Your right to erasure - You have the right to ask us to delete your personal information. You can read more about this right here.
Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
Your right to object to processing - You have the right to object to the processing of your personal data. You can read more about this right here.
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. You can read more about this right here.
Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. You can read more about this right here.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Personal data is collected and processed to enable the development of products and services offered by Luminate Advisers Limited and its services which is key to the success of Luminate Advisers Limited and therefore to the benefit of Luminate Advisers Limited, its owners and employees, actual or prospective clients, suppliers, partners, and affiliates.
Our lawful bases for collecting or using personal information for the operation of client or customer accounts are:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Personal data is collected and processed to enable the effective management of client accounts by Luminate Advisers Limited which is key to the success of Luminate Advisers Limited and therefore to the benefit of its owners and employees, actual or prospective clients, suppliers, partners, and affiliates.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Personal data is collected and processed to enable the marketing and promotion of products and services offered by Luminate Advisers Limited and its services which is key to the success of Luminate Advisers Limited and therefore to the benefit of Luminate Advisers Limited, its owners and employees, actual or prospective clients, suppliers, partners, and affiliates.
Our lawful bases for collecting or using personal information to comply with legal requirements:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
Personal data is collected and processed to enable the management of queries, complaints and/or claims to ensure client satisfaction in relation to the products and services offered by Luminate Advisers Limited and its services which, in turn, is key to the success of Luminate Advisers Limited and therefore to the benefit of Luminate Advisers Limited, its owners and employees, actual or prospective clients, suppliers, partners, and affiliates.
Where we get personal information from
Directly from you
Publicly available sources
Suppliers and service providers
How long we keep information
We retain information for a maximum of 7 years from the end of your relationship with us in order for us to meet the purposes outlines above in this Privacy Policy, including complying with our legal obligations and in order to bring or respond to queries, complaints or legal claims:
Names and contact details
Addresses
Occupation
Payment details (including card or bank information for transfers and direct debits)
Transaction data (including details about payments to and from you and details of products and services you have purchased)
Usage data (including information about how you interact with and use our website, products and services)
Information relating to compliments or complaints
Video recordings
Audio recordings (eg calls)
Records of meetings and decisions
Purchase, account or service history
Marketing preferences
Profile information
Identification documents
Client account information
Any other personal information required to comply with legal obligations
Correspondence
Who we share information with
Data processors
Accountancy, Tax & Company Secretarial Services companies
This data processor does the following activities for us: Provide accountancy, tax and company secretarial services
Others we share personal information with
Insurance companies, brokers or other intermediaries
Professional or legal advisors
Regulatory authorities
Organisations we’re legally obliged to share personal information with
Publicly on our website, social media or other marketing and information media
Suppliers and service providers
Professional consultants
How to complain
If you have any concerns about our use of your personal data, you can make a complaint to us using the contact details at the top of this privacy notice.
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint
Last updated
14 January 2025