Privacy Policy - Luminance Group


Welcome to Luminance's privacy policy.

Luminance is committed to protecting your personal data and respecting your privacy. This policy will inform you on how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.


This policy referred to set outs the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following privacy policy to understand how we collect and use your personal data, for example when you contact us, visit our website (the "Site"), apply for a job, or use our products and services.

The Site is not intended for children, and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.


For the purposes of processing your data, Luminance is made up of Luminance Technologies Ltd or Luminance, Inc ("Luminance Group"). This privacy policy is issued on behalf of the Luminance Group so when we mention "Luminance", "we", "us" or "our" in this privacy policy, we are referring to the relevant company in the Luminance Group.

Our privacy team is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, please contact the team at [email protected] .

You have the right to make a complaint at any time to the Information Commissioner's Office, the United Kingdom (“UK”) regulator for data protection issues ( We would, however, appreciate the chance to deal with your concerns before you approach the Information Commissioner's Office, so please contact us in the first instance.


Our Site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Site, we encourage you to read the privacy policy of every website you visit . If you follow a link to any of these websites, please note that Luminance does not accept any responsibility or liability for these policies.


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).

Luminance may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.



Luminance may collect information about your computer, including your IP address, operating system, browser type and system admiration.


Cookies are small text files that websites save to your computer. These pieces of information are used to improve services for you through, for example:

Session cookies allow us to track your actions during a single browser session, for example to remember the items returned from a search. They do not remain on your device beyond your session.

Persistent cookies remain on your device between sessions and allow us to authenticate you and to remember your preferences.

Session and persistent cookies can be either first or third-party cookies. A first-party cookie is set by the website being visited. A third-party cookie is issued by a different website to that being visited.

Our Site may use a third-party cookie provided by Google Analytics to gather anonymized information for the benefit of all web users. Luminance do not use behavioural targeting cookies. All our cookies fall within the International Chamber of Commerce classifications Strictly Necessary, Functionality and Performance and none within the classification Behavioural Targeting.

If at any time you wish to disable our cookies you may do so through the settings on your browser, but if you do so you will not be able to use certain important features of our service.

To learn more about cookies and how to manage them, visit .


If you are making a job application or inquiry, you may provide us with a copy of your CV or other relevant information. We may use this information for the purpose of considering your application or inquiry. Except when you explicitly request otherwise, we may keep this information on file for future reference.


If you purchase or use our products or services, we may use your personal data for purposes which include but are not limited to:

Certain products and services may include features that collect additional personal data for other purposes, as described in the applicable customer agreement. For detailed information, please also refer to the applicable product or service description.


Your personal data is securely stored by Luminance on the Luminance servers located in Cambridge, United Kingdom. Luminance has set up systems and processes to prevent unauthorized access or disclosure of your data.


We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following ways:

Please see the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.


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

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.


Type of Data

Lawful Basis for processing (including basis of legitimate interest)

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and deliver your order, including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include

(a) Notifying you about changes to our terms or privacy policy (or otherwise as applicable)

(b) Asking you to leave a review, provide feedback or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To administer and protect our business and this Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)


We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box on the form on which Luminance collects your data. We will not sell or rent your data to third parties or share your data with third parties for marketing purposes. We may use third party software to send you information for marketing purposes but such third parties will not have access to or be able to read your personal information.


As a global company, we have international sites and users all over the world. Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. When you give us personal data, that data may be used, processed or stored anywhere in the world, including countries outside the European Economic Area (“EEA”). It may also be processed by staff operating outside the EEA, who work for us or for one of our suppliers.

Luminance places substantial importance on protecting the confidentiality of personal information and seeks the cooperation of all its suppliers in furthering this goal. Luminance will only transfer personal information to a supplier where the supplier has provided assurances that they will provide at least the same level of privacy protection as is required by this policy. Where Luminance has knowledge that a supplier is using or sharing personal information in a way that is contrary to this policy, Luminance will take reasonable steps to prevent or stop such processing.

We take appropriate safeguards to protect your privacy, your fundamental rights and freedoms, and the ability to exercise your rights. For example, if we transfer personal information from the EEA, the UK, and/or Switzerland to another country, such as the United States, we will implement an appropriate data transfer instrument, such as entering into standard data protection clauses approved by the European Commission or competent governmental authority (as applicable) with the data importer. Following the adequacy decision by the European Commission and the UK Government, Luminance currently relies on the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. Data Privacy Framework as a legal framework for transfers of personal information from the EU to the United States and from the UK to the United States, respectively.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.



On 10 July 2023, the European Commission’s adequacy decision for the EU-U.S. DPF entered into force, followed by the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) on 17 July 2023 and the UK extension to the EU-U.S. DPF on 12 October 2023.

Luminance complies with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF as set forth by the U.S. Department of Commerce. Luminance has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF.

Luminance relies on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF as a legal framework for transfers of personal information received from European Union and the United Kingdom.

We have certified to the U.S. Department of Commerce that we adhere to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.

Luminance will rely on the Swiss-U.S. DPF as a legal framework to transfer personal information from Switzerland once the applicable local authorities approve the adequacy decisions. In the meantime, Luminance continues to rely on the standard data protection clauses for the purposes of Swiss data protection law.

To learn more about the Data Privacy Framework (DPF) Program, and to view our certification, please visit

Our certification may be located here.


In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Luminance commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU and UK and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact Luminance at [email protected].

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, Luminance commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities and the UK Information Commissioner’s Office and the Gibraltar Regulatory Authority and the Swiss Federal Data Protection and Information Commissioner with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF.


You may, under certain conditions, invoke binding arbitration for complaints regarding DPF compliance which may not be resolved by any of the other DPF mechanisms. Further information regarding this option may be found at Annex I to the DPF Principles, located here:


The Federal Trade Commission has jurisdiction over Luminance’s compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF.


We remain responsible for all the personal information we receive under the DPF and that we subsequently transfer to third parties acting as agents on our behalf if they process personal information in a manner inconsistent with the DPF principles, unless we prove we are not responsible for the event giving rise to the damage.


Luminance endeavours to hold all personal data securely in accordance with our internal security procedures and applicable law.

We update and test our security on an ongoing basis. Luminance will do its best to protect your personal data, but Luminance cannot guarantee the security of your data transmitted to our site through the internet; any such transmission is at your own risk. Once we have received your information, we will maintain the appropriate administrative, physical, technical and organizational measures to protect your personal data accessed or processed by us against unauthorized or unlawful processing or accidental loss, destruction, damage or disclosure.

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.

If you receive an email which claims to come from us but does not use our domain, or if you are suspicious that an email may not be approved by us, then please send a copy of the email to [email protected] so we can investigate.


We may share your personal data with the parties set out below for the purposes set out in the table above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.


Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the Glossary to find out more on how the rights listed below:


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 could 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 a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.


Luminance reserves the right to amend this policy at any time, for any reason, without notice to you. You should check our Site to see the current policy that is in effect and any changes that may have been made to it.

This policy was last amended on 5 January 2024.



Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.




You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that 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.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

(end of policy)

Luminance Technologies Ltd — Anti-Slavery Policy Statement

Pursuant to s54 of the Modern Slavery Act 2015, this Policy Statement confirms the steps Luminance Technologies Ltd (“We”) has taken and will continue to take to prevent modern slavery and human trafficking in any part of our business and supply chain.

Our Business & Risk

We have offices in the UK and the US and are a primarily a hosted technology company. In light of where we do business, where our suppliers are based and the industry in which we operate, we consider that there is a very low risk that modern slavery and human trafficking may affect our business.

Our Policies

We have adopted policies and procedures which are designed to:

Our Supply Chain

Our process for contracting with suppliers includes checks to remain vigilant to any risk of modern slavery and human trafficking. We require staff engaged in the process for the selection of suppliers to conduct reasonable checks and due diligence to ensure that modern slavery and human trafficking does not affect any supplier or partner. This due diligence may include (but is not limited to) raising enquiries with the supplier / partner, asking them to provide a copy of relevant policies and their employee handbook and, where necessary, verifying the physical working conditions for the supplier's / partner's staff and contractors.

We also include appropriate contractual commitments and protections in our agreements with our suppliers where necessary, requiring those suppliers to implement effective systems and controls to prevent slavery and human trafficking from affecting any part of their business and supply chain. We also require them to provide us with a summary of the steps they take from time to time to prevent modern slavery and human trafficking (including details of any relevant staff and supplier policies and details of due diligence conducted on their suppliers.

In respect of staff employed by the company, our Employee Handbook makes clear to employees the actions and behaviour expected of them when representing the organisation. We strive to maintain the highest standards of employee conduct and ethical behaviour when operating and managing our supply chain.

In addition, our HR team continues to ensure that we comply with all applicable laws in the territories in which we are based and we only use specified, reputable employment agencies to source labour. We are proud of the work environment we provide to our staff and the vibrant culture that permeates our business.


Our staff are advised to take particular care for organisations that provide services from higher risk territories. Staff are also advised to notify the legal and HR teams immediately if they have any concerns so that we can then take appropriate action.