Privacy Policy
1. Introduction
At Lumi Creative, your privacy matters to us. We are committed to respecting and protecting the personal information you share with us, whether you are visiting our website, making an enquiry, completing a questionnaire or working with us on a project. This Privacy Policy explains what personal information we collect, why we collect it, how we use and store it, and your rights under UK data protection law.
2. Who We Are
Lumi Creative is a business partnership operated by Pamela Cozens and Deryck Cozens, based on the Isle of Bute, Scotland. We provide social media management, content creation, graphic design, website design and digital marketing services. For the personal information we collect and use to manage our own business, Lumi Creative acts as a data controller.
Business name: Lumi Creative
Business structure: Partnership
Partners: Pamela Cozens and Deryck Cozens
Location: Isle of Bute, Scotland, United Kingdom
Website: https://www.lumicreative.net
Email: info@lumicreative.net
3. Information We Collect
Depending on how you interact with Lumi Creative, we may collect:
• Your name, business name and job role.
• Your email address and telephone number.
• Business contact details and website information.
• Information you provide through our website, Google Forms and client questionnaires.
• Details about your business, goals, services and project requirements.
• Emails, messages and other communications with us.
• Photographs, videos, testimonials and other materials supplied for agreed projects.
• Information required for quotations, contracts, invoicing and payment records.
• Technical information about website visits, where collected through cookies or analytics tools.
We aim to collect only the information reasonably necessary for the purposes explained in this policy. Please avoid including sensitive personal information in our enquiry forms unless we have specifically requested it and explained why it is needed.
4. How We Use Information
We may use your personal information to respond to enquiries, understand your business needs, prepare quotations, communicate with you, provide agreed services, manage client relationships, maintain project records, issue invoices, meet legal obligations, maintain business security, improve our website and services, and send marketing communications where permitted by law.
Submitting an enquiry or onboarding questionnaire does not automatically subscribe you to marketing emails.
5. Our Legal Bases for Processing Information
Under UK data protection law, we must have a lawful basis for using personal information. Depending on the purpose, we may rely on contract or steps before entering a contract, legitimate interests, legal obligation, or consent. Contract may apply when preparing a quotation or providing contracted services. Legitimate interests may apply to appropriate business communications, client relationships and protecting our business. Legal obligation may apply to accounting, tax and other legal requirements. Consent may apply to certain marketing communications or non-essential cookies. Where we rely on consent, you may withdraw it at any time.
6. Website Enquiries and Google Forms
We use online questionnaires, including Google Forms, to understand prospective clients’ requirements and gather information needed for enquiries and projects. Information submitted through these forms may be processed and stored using Google Forms, Google Sheets and associated Google services. We use it to review your enquiry, contact you, discuss your requirements and, where appropriate, prepare a proposal or deliver agreed services. You do not need to provide every optional detail, and you can contact us to correct information you have submitted. We do not automatically use questionnaire responses for unrelated marketing purposes.
7. Client Projects and Content
Clients may provide business materials, photographs, videos, website content, social media information and other project files. We use these materials for the agreed purposes of the project. Where materials contain personal information about other individuals, such as employees, customers or people appearing in photographs, the client may also have data protection responsibilities. Depending on the service, Lumi Creative may act as a data processor on behalf of a client. Where appropriate, responsibilities and instructions will be addressed in our client agreement or a separate data processing agreement. We do not publish personal information or client materials outside the agreed scope of work without an appropriate basis.
8. How We Store and Protect Information
We take reasonable technical and organisational measures to protect the personal information we hold. These may include password-protected accounts, appropriate access controls, security settings and restricting access to those who need it for legitimate business purposes. We use digital services including our Wix website, Google services, email and business communication platforms. Although no digital system can guarantee absolute security, we take reasonable steps to protect information against unauthorised access, loss, misuse and disclosure.
9. Sharing Personal Information
We do not sell your personal information. We may share it with trusted third-party service providers where necessary to operate our business or deliver agreed services. These may include website hosting and management providers including Wix; online form, email and cloud storage providers including Google; business communication and social media platforms; accounting and payment service providers; and other professional or technical providers required for an agreed project. We may also disclose information where required by law. Where applicable, we use providers with appropriate data protection arrangements.
10. International Data Transfers
Some digital platforms we use may process personal information outside the United Kingdom. Where an international transfer is subject to UK data protection requirements, we will ensure that an appropriate lawful transfer mechanism or safeguard applies.
11. How Long We Keep Your Information
We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, or where required by law. General enquiries and unsuccessful quotations are normally kept for up to 12 months after our last communication. Client onboarding questionnaires and completed project materials are normally kept for the duration of the relationship and up to three years afterwards. Contracts and relevant business correspondence are normally kept for up to six years where appropriate. Financial and accounting records are kept for the period required by tax and accounting law. Marketing information is kept while we have an appropriate lawful basis, subject to opt-outs and review. We may retain information longer to comply with legal obligations, resolve disputes or defend legal claims. When no longer required, we securely delete or anonymise it where appropriate.
12. Cookies and Website Analytics
Under UK data protection law, you may have the right to:
• Request access to personal information we hold about you.
• Ask us to correct inaccurate or incomplete information.
• Request deletion of your personal information in certain circumstances.
• Request restrictions on how your information is used.
• Object to certain types of processing.
• Request transfer of your information where applicable.
• Withdraw consent where processing relies on consent.
These rights are subject to applicable legal conditions and exceptions. To exercise your rights or ask a question about your personal information, please email info@lumicreative.net. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s independent data protection regulator.
ICO website: https://ico.org.uk
13. Marketing Communications
We may occasionally share updates about Lumi Creative, our services or relevant business news. We will only send electronic marketing communications where we have an appropriate legal basis and comply with applicable electronic marketing rules. Where consent is required, we will request it separately. You can opt out at any time by following the instructions provided or contacting info@lumicreative.net.
14. Your Data Protection Rights
These rights are subject to applicable legal conditions and exceptions. To exercise your rights or ask a question about your personal information, email info@lumicreative.net. You also have the right to complain to the Information Commissioner’s Office (ICO), the UK’s independent data protection regulator. ICO website: https://ico.org.uk
15. Links to Other Websites
Our website may include links to third-party websites, social media platforms and other online services. We are not responsible for the privacy practices of external websites. We recommend reviewing their privacy information before providing personal details.
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our services, business practices or legal requirements. The latest version will be published on our website with an updated revision date.
17. Contact Us
If you have questions about this Privacy Policy or how we handle your personal information, please contact:
Lumi Creative
Pamela Cozens and Deryck Cozens
Isle of Bute, Scotland, United Kingdom
Email: info@lumicreative.net
Website: https://www.lumicreative.net
Helping small businesses shine online.