Last Updated: December 2025
This privacy policy explains how Lumarrae Workplace Transformation (a trading name of Luminate Group Ltd) collects and uses information when you visit our website, blog, or social media channels.
We're committed to protecting your privacy. This policy is written in plain English because privacy matters, and you shouldn't need a law degree to understand what we do with your data.
Note: This policy covers website visitors only. If you become a coaching client, separate privacy terms will apply to your coaching services.
1. WHO WE ARE
Data Controller: Luminate Group Ltd (trading as Lumarrae Workplace Transformation)
Company Number: SC774457 (Registered in Scotland)
Registered Office: 272 Bath Street, Glasgow G2 4JR
ICO Registration: We are registered with the Information Commissioner's Office for data protection compliance.
Contact for Privacy Questions: [email protected]
2. WHAT INFORMATION WE COLLECT
When You Visit Our Website:
- Which pages you visit and how long you stay
- How you found us (search engine, social media, link from another site)
- Your approximate location (city/region level, not precise address)
- Device type and browser
- IP address
When You Book a Consultation:
- Your name
- Email address
- Any information you provide about your coaching needs
- Company name (if booking for an organisation)
When You Sign Up for Our Mailing List:
- Your name
- Email address
When You Comment on Our Blog or Social Media:
- Whatever information you choose to share publicly
- Your social media profile information (if you comment via social platforms)
3. HOW WE USE YOUR INFORMATION
Website Analytics:
- To understand which content is most helpful
- To see how people find our website
- To improve website design and functionality
- To fix technical problems
Consultation Bookings:
- To schedule your consultation
- To send you confirmation and reminders
- To prepare for our conversation
Mailing List:
- To send you helpful resources and insights (only if you opted in)
- To notify you about our programmes and services
- To invite you to workshops or events
You can unsubscribe from our mailing list anytime - every email has an unsubscribe link.
4. LEGAL BASIS FOR PROCESSING YOUR DATA
Under GDPR, we need a legal reason to use your data:
Legitimate Interest: We have a legitimate interest in understanding how our website is used and improving our services.
Consent: For marketing emails, we only contact you if you've explicitly opted in.
Contract: When you book a consultation, we need your contact information to deliver that service.
5. WHO WE SHARE YOUR DATA WITH
We don't sell or rent your data to anyone. Ever.
We only share your information with:
Service Providers:
- Booking system: To schedule consultations
- Email platform: To send you updates and resources (if you opted in)
- Analytics tools: Google Analytics and HubSpot (see Cookies section below)
- Website hosting: To keep the website running
All these providers are GDPR-compliant and contractually obliged to protect your data.
Legal Requirements:
We may disclose information if required by law (e.g., court order).
6. COOKIES & ANALYTICS
What Are Cookies?
Cookies are small text files stored on your device when you visit websites. They help websites remember your preferences and understand how you use the site.
What Cookies We Use:
Essential Cookies:
These make the website work properly (e.g., remembering items in your booking). You can't turn these off, but they don't track you across the internet.
Analytics Cookies:
We use Google Analytics and HubSpot to understand:
- How many people visit our site
- Which pages are most popular
- How long people stay
- How they found us
This helps us improve the website and create helpful content.
No Advertising Cookies:
We don't use cookies to track you across the internet or show you targeted ads.
Managing Cookies:
You can control cookies through your browser settings. Blocking analytics cookies won't affect how the website works, but it means we can't see which content is most helpful.
Learn more about cookies: www.aboutcookies.org
7. AI-GENERATED CONTENT ON OUR WEBSITE
Images & Visual Content:
Some images on our website, including certain professional headshots of our team, are AI-generated or AI-enhanced. We use AI tools to create professional, high-quality visual content that represents our brand effectively.
Why We Use AI:
- To create consistent, professional imagery
- To maintain visual quality across the website
- For accessibility reasons when traditional photography isn't feasible
What This Means for You:
AI-generated images on our website don't collect or process your personal data. They're simply visual assets, like any other website imagery.
8. HOW WE PROTECT YOUR DATA
Security Measures:
- All data is stored securely using encrypted cloud services
- Website uses SSL encryption (https://)
- Access to data is restricted to authorized team members only
- We use secure booking and email platforms
What We Can't Guarantee:
No internet transmission is 100% secure. We take every reasonable precaution, but we can't guarantee absolute security.
9. HOW LONG WE KEEP YOUR DATA
Website Analytics:
Analytics data is kept for 26 months, then automatically deleted.
Consultation Bookings (If No Programme Purchase):
If you book a consultation but don't proceed with a programme, we'll keep your contact details for 12 months in case you change your mind. After that, we'll delete them.
Mailing List:
We'll keep you on our mailing list until you unsubscribe.
Right to Request Earlier Deletion:
You can ask us to delete your data sooner (see Your Rights below).
10. YOUR RIGHTS
Under GDPR, you have the following rights:
Right to Access:
You can ask us what information we hold about you. We'll provide a copy free of charge.
Right to Correction:
If information we hold is wrong, you can ask us to correct it.
Right to Deletion ("Right to be Forgotten"):
You can ask us to delete your information.
Right to Restrict Processing:
You can ask us to stop using your data in certain ways (e.g., for marketing) while still keeping it on file.
Right to Data Portability:
You can ask for a copy of your data in a commonly-used format.
Right to Object:
You can object to us using your data for certain purposes (e.g., marketing). We'll stop unless we have a compelling reason to continue.
Right to Withdraw Consent:
If we're processing your data based on consent (e.g., marketing emails), you can withdraw that consent anytime.
How to Exercise Your Rights:
Email us at [email protected]
We'll respond within 30 days (usually much faster).
11. MARKETING EMAILS
We ONLY Send Marketing Emails With Your Permission:
We'll only add you to our mailing list if you explicitly opt in.
What We Send:
- Helpful resources and insights on leadership development
- Updates about our programmes
- Invitations to workshops or events
- Research findings and case studies
Unsubscribing:
Every email has an unsubscribe link. Click it and you're off the list immediately. No questions asked, no hard feelings.
12. SOCIAL MEDIA
When you interact with our social media pages (LinkedIn, etc.):
Third-Party Platforms:
Social media platforms have their own privacy policies. We're not responsible for how those platforms handle your data.
What We See:
We can see publicly available information from your profile (name, profile picture, public posts) when you interact with our content.
What We Don't Do:
We don't scrape or collect data from social media platforms. We only see what the platforms show us through their standard interfaces
13. LINKS TO OTHER WEBSITES
Our website may link to external sites (e.g., research papers, LinkedIn profiles, partner organizations). We're not responsible for how those sites handle your data. Please check their privacy policies.
14. CHANGES TO THIS POLICY
We may update this privacy policy occasionally to reflect changes in how we work or legal requirements.
The "Last Updated" date at the top shows when we last changed this policy.
Continued use of the website after changes means you accept the updated policy.
15. COMPLAINTS
If you're unhappy with how we've handled your data, please contact us first:
We'll do our best to resolve the issue.
If you're still not satisfied, you have the right to complain to the Information Commissioner's Office (ICO):
- Website: www.ico.org.uk
- Phone: 0303 123 1113
16. CONTACT US
Questions About This Privacy Policy?
Luminate Group Ltd (trading as Lumarrae Workplace Transformation)
Company No. SC774457 (Registered in Scotland)
272 Bath Street, Glasgow G2 4JR
Email: [email protected]
Website: www.lumarrae.com
In Plain English: We collect basic analytics to improve our website, only send marketing emails if you opt in, protect your data carefully, and never sell it to anyone.