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Effective Date: 08/12/2025

Last Updated: 08/12/2025

1. Introduction

Welcome to Lumos Digital Marketing (“we,” “our,” or “us”). We are a digital marketing agency committed to protecting the privacy and security of your personal information.

This Privacy Policy explains how we collect, use, share, and protect your personal data when you visit our website lumosdigital.co.uk (the “Site”) or engage with our services.

For the purposes of the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018, Lumos Digital Marketing is the Data Controller.

2. The Data We Collect

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

• Identity Data: Includes first name, last name, username, or similar identifiers.

• Contact Data: Includes billing address, delivery address, email address, and telephone numbers.

• Technical Data: Includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

• Usage Data: Includes information about how you use our website, products, and services.

• Marketing and Communications Data: Includes your preferences in receiving marketing from us and your communication preferences.

We do not collect any Special Categories of Personal Data (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

3. How We Collect Your Data

We use different methods to collect data from and about you including through:

• Direct Interactions: You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:

  • Enquire about our services;

  • Subscribe to our newsletter;

  • Request marketing to be sent to you; or

  • Give us feedback.

• Automated Technologies: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and similar technologies.

• Third Parties: We may receive personal data about you from various third parties, such as analytics providers (e.g., Google Analytics) and advertising networks (e.g., Google Ads, Meta/Facebook) based inside or outside the UK.

4. How We Use Your Personal 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 circumstances:

Purpose/Activity	Type of Data	Lawful Basis for Processing
To respond to your enquiries via our contact forms or email.	Identity, Contact	Consent (if you reached out) or Legitimate Interest (to reply to a business query).
To manage our relationship with you (including notifying you about changes to terms or privacy policy).	Identity, Contact, Marketing	Performance of a Contract or Legal Obligation.
To deliver relevant website content and advertisements to you and measure the effectiveness of the advertising we serve.	Identity, Contact, Usage, Technical	Legitimate Interest (to study how customers use our services to develop them and grow our business).
To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences.1	Technical, Usage2	Legitimate Interest (to define types of customers for our products and services and to keep our website updated and relevant).3
To send you marketing communication4s (newsletters, offers).	Identity, Contact, Marketing	Consent (we will ask for your explicit opt-in before sending newsletters). You can opt-out at any time.

5. Disclosures of Your Personal Data

As a digital agency, we utilize a stack of trusted third-party service providers to help us run our business. We may share your personal data with:

• Service Providers: Companies that provide IT and system administration services (e.g., website hosting, CRM systems, email marketing platforms).⁵

   

   

• Professional Advisers: Including lawyers, bankers, auditors, and insurers.⁶

   

   

• Sub-cont⁷ractors: Freelancers or partner agencies who assist us in delivering specific client projects (under strict confidentiality agreements).

   

   

• Regulators: HM Revenue & Customs, regulators, and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.

• Business Transfers: Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International Transfers

Some of our external third parties (such as Google, Mailchimp, or cloud hosting providers) may be based outside the United Kingdom (UK) so their processing of your personal data will involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

7. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

8. Data Retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, and whether we can achieve those purposes through other means.

9. Your Legal Rights

Under the UK GDPR, you have rights regarding your personal data:

• Request access to your personal data (commonly known as a “data subject access request”).

• Request correction of the personal data that we hold about you.

• Request erasure of your personal data (the “right to be forgotten”).

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party).

• Request restriction of processing of your personal data.

• Request the transfer of your personal data to you or to a third party.

• Withdraw consent at any time where we are relying on consent to process your personal data.

If you wish to exercise any of the rights set out above, please contact us. You will not have to pay a fee to access your personal data. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. We try to respond to all legitimate requests within one month.

10. Cookies and Tracking Technologies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.⁸⁹

 

We use the following types of cookies:¹⁰¹¹

 

• Strictly necessary cookies: Required for the operation of our website.¹²¹³

   
   

   

• Analytical/performance cookies: Allow us to recognize and count t¹⁴he number of visitors (e.g., ¹⁵Google Analytics).

   
   

   

• Functionality cookies: Used to recognize you when you return to our website.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

11. Links to Third-Party Websites¹⁶

This website 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 y¹⁷ou. We do not control these third-party websites and are not responsible for their privacy statements.

 

12. Contact Details

If you have any questions about this Privacy Policy or our privacy practices, please contact us:

Full Name of Legal Entity: Lumos Digital Marketing

Email Address: [email protected]

Postal Address: 163 Holland Street, Denton, Manchester, M34 3GG

Telephone Number: 0161 304 5698

Website Contact: lumosdigital.co.uk/contact

Right to Complain

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.