policies

Privacy & cookie policy

Last updated: 20 October 2024

Lumen Later Life Living Pty Ltd understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits and/or makes use of this website, www.mypodplan.co.uk (“Our Site”) as a (potential) user/member or representative for third-party service providers/merchants/advertisers and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site and/or services. If you do not accept and agree with this Privacy Policy, you must stop using Our Site and services immediately.

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1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

  • Account means an account required to access and/or use certain areas and features of Our Site;
  • Cookie means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 13, below;
  • Cookie Law means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 (for as long as this is applicable in the United Kingdom), and all applicable United Kingdom data protection and privacy regulation;
  • Personal data means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site or otherwise. This definition shall, where applicable, incorporate the definitions provided in the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”) (for as long and to the extent this is applicable for Our activities) and United Kingdom data protection and privacy regulation;
  • Special Category Data means personal data of particular sensitive character, e.g., related to health, diet, gender, etc.; and
  • We/Us/Our means Lumen Later Life Living Pty Ltd.

2. Information About Us

  • 2.1 Our Site is owned and operated by Lumen Later Life Living Pty Ltd, a limited company registered in England under company number 11355315, whose registered address is 92 Station Lane, Hornchurch, Essex, RM12 6LX, United Kingdom.
  • 2.2 Our VAT number is 332 8025 26.
  • 2.3 Our Data Protection Officer is Jacqueline Cleveland, who can be contacted by email using the contact details below in section 14.

3. What Does This Policy Cover?

This Privacy Policy applies to your use of Our Site and/or services including but not limited to as a (potential) user/member or representative for third-party service providers/merchants/advertisers. Our Site may contain links to other websites. Please note that We have no control over how your personal data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

  • 4.1  As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold (for as long and to the extent this is applicable to Our activities):
    - 4.1.1 The right to be informed about Our collection and use of personal data;
    - 4.1.2 The right of access to the personal data We hold about you (see section 12);
    - 4.1.3 The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in section 14);
    - 4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 14);
    - 4.1.5 The right to restrict (i.e. prevent) the processing of your personal data;
    - 4.1.6 The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
    - 4.1.7 The right to object to Us using your personal data for particular purposes; and
    - 4.1.8 Rights with respect to automated decision-making and profiling
  • 4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the United Kingdom’s supervisory authority, the Information Commissioner’s Office.
  • 4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

5. What Personal Data Do We Collect?

Depending upon your use of Our Site and/or services or relationship with Us, we may collect some or all of the following personal data relating to the user or contact person as well as non-identifiable web browsing information such as the following (please also see section 13 on Our use of cookies and similar technologies):

  • 5.1 Name;
  • 5.2 Company name;
  • 5.3. Address;
  • 5.4 Email address;
  • 5.5 Telephone number;
  • 5.6 IP address;
  • 5.7 Web browser type and version;
  • 5.8 Operating system; and
  • 5.9 Special category data (under particular circumstances).

We share information with service providers that help us perform Website functions and administer our Services as follows:

  • Stripe - We do not collect financial information such as credit/debit card numbers, but our payment provider Stripe collects such information. Please refer to Stripe’s privacy policy for further information.
  • Our service provider Memberspace collects personal information for the purpose of providing private access to sections of Our Site and to allow us to monitor how users interact with Our Site. You can read Memberspace’s privacy and data processing policies here and manage cookie settings here.
  • Our email automation provider Flodesk collects limited data for the sole purpose of sending emails to members and/or partners. You can read Flodesk’s privacy and data processing policies here.
  • Our service provider Bubble.io collects anonymized information for the purpose of providing members with access to the PodVault feature. You can read Bubble.io’s privacy and data processing policies here.
  • We use Google Analytics to conduct data analytics on the usage of our Services. You can read Google’s privacy and data policies here.
  • We use Calendly to allow the scheduling of meetings with members, potential members, or partners. You can read Calendly’s privacy and data processing policies here.
  • We use both Zoom and Microsoft Teams for online meetings. Zoom’s privacy and data policies can be found here. Teams privacy and data policies can be found here.

6. How Do We Use Your Personal Data?

Depending upon your use of Our Site and/or services or relationship with Us, we may collect some or all of the following personal data relating to the user or contact person as well as non-identifiable web browsing information such as the following (please also see section 13 on Our use of cookies and similar technologies):

  • 5.1 Name;
  • 5.2 Company name;
  • 5.3 Address;
  • 5.4 Email address;
  • 5.5 Telephone number;
  • 5.6 IP address;
  • 5.7 Web browser type and version;
  • 5.8 Operating system; and
  • 5.9 Special category data (under particular circumstances).
  • 6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will at all times comply with Our obligations and safeguard your rights under the United Kingdom data protection and privacy regulation for as long as the extent this is applicable to Our activities and the GDPR. For more details on security, see section 7 below.
  • 6.2 Our collection and use of your personal data will always have a lawful basis. If you are in preliminary contact with Us in order to possibly become a user/member or third-party service provider/merchant/advertiser, our collection and use of your personal data serve the purpose of establishing or fulfilling a contract with you and is based on your consent. Our collection and use of any Special Category Data is also based on your explicit consent. Any storage and/or processing of your personal data subsequent to your termination of any formalized relationship between you and Us will be based on Our legitimate interest to continue to handle such information, e.g., for record keeping and/or public interest purposes. Specifically, We may use your data for the following purposes:
    - 6.2.1 Providing and managing your Account;
    - 6.2.2 Providing and managing your access to Our Site;
    - 6.2.3 Personalising and tailoring your experience on Our Site;
    - 6.2.4 Supplying Our products and services to you (please note that We require your personal data in order to enter into a contract with you);
    - 6.2.5 Managing your supply of products and services to Us;
    - 6.2.6 Personalising and tailoring Our products and services for you;
    - 6.2.7 Replying to emails from you;
    - 6.2.8 Sending you emails. You may unsubscribe or opt out at any time by pressing unsubscribe on any correspondent email, or contact Us using the contact details below in section 14 and requesting it;
    - 6.2.9 Market research; and
    - 6.2.10 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.
  • 6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 (for as long and to the extent this is applicable for Our activities) and United Kingdom data protection and privacy regulation.
  • 6.4 Third parties whose content appears on Our Site may use third-party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
  • 6.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
  • 6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
    - 6.6.1 We shall as a default keep your data on file for 36 months from your last activity.
    - 6.6.2 You can as a user who has not entered into a contract with Us delete your account at any time, which will delete your data from our database.

7. How and Where Do We Store and/or Transfer Your Personal Data?

  • 7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6 or for as long as We have your permission to keep it.
  • 7.2 The security of your personal data is essential to Us, and to protect your data, We take a number of important measures, including the following:
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    - 7.2.1 limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
    - 7.2.2 procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where We are legally required to do so;

  • 7.3 We may store or transfer some or all of your personal data to countries not part of the European Economic Area (the “EEA” consists of all EU member states, Norway, Iceland, and Liechtenstein). These including the United Kingdom are known as “third countries” and may not have data protection laws that are as strong as those in the EEA. This means that We will endeavour to take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be under the GDPR (for as long and to the extent this is applicable for Our activities) as follows:

    - 7.3.1 We may share your data within the group of companies of which We are a part. Where this involves the transfer of personal data outside the United Kingdom or the EEA, our group ensures that personal data is protected by requiring all companies within the group to follow the same rules with respect to personal data usage. These are known as “binding corporate rules”.
    - 7.3.2 We may share your data with external third parties that are based outside of the United Kingdom or the EEA. The following safeguards are applied to such transfers:
    - 7.3.2.2 We use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation.
  • 7.4 Please contact us using the contact details below in section 14 for further information about the particular data protection mechanisms used by Us when transferring your personal data to a third country.

8. Do We Share Your Personal Data?

  • 8.1 We may share your data with other companies in Our group to supply better services attached to our core business. This includes Our holding company and its subsidiaries.
  • 8.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
  • 8.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
  • 8.4 Any transfers of your personal data to third-party data processors used by Us that are not located within the United Kingdom or the EEA will follow the principles laid out in section 7.
  • 8.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.

9. What Happens If Our Business Changes Hands?

  • 9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which we originally collected it.

10. How Can You Control Your Personal Data?

  • 10.1 In addition to your rights under the GDPR (for as long and to the extent this is applicable to Our activities) and the United Kingdom data protection and privacy regulation, set out in section 4, when you submit personal data to Us via Our Site or otherwise, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by manageing your Account).

11. Your Right to Withhold Information

  • 11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
  • 11.2 You may restrict Our use of Cookies. For more information, see section 13.

12. How Can You Access Your Personal Data?

  • 12.1 You have the right to ask for a copy of any of your personal data held by Us (where such data is held). No fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details using the contact details below in section 14.

13. Our Use of Cookies

  • 13.1 Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data are protected and respected at all times.
  • 13.2 By using Our Site you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than Us. Third-party Cookies are used on Our Site for Advertising purposes or to deliver Our service to you. For more details, please refer to sections 5.9 & 6, above, and to section 13.6 below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
  • 13.3 All Cookies used by and on Our Site are used in accordance with the current Cookie Law.
  • 13.4 Before Cookies are placed on your computer or device, you will be shown a popup or push notification requesting your consent to set those Cookies. By giving your consent to placing Cookies, you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
  • 13.5 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party Cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
  • 13.6 You can choose to delete Cookies on your computer or device at any time, however, you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
  • 13.7 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

14. Contacting Us

  • 14.1 If you have any questions about Our Site or this Privacy Policy, please contact Us by email at support@mypodplan.co.uk or by post to Lumen Later Life Living Pty Ltd, 92 Station Lane, Hornchurch, Essex, RM12 6LX, United Kingdom.
  • 14.2 Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 12, above).

15. Changes to Our Privacy Policy

  • We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Site and/or services following the alterations. We recommend that you check this page regularly to keep up-to-date.
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