Privacy Policy

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1. About Luma

The website www.luma.co.uk (Site) is operated by MI Money Ltd trading as Luma (we). MI Money Ltd is part of the Media Ingenuity Group (MI Group). Aside from owning and operating the Media Ingenuity brand, the Media Ingenuity Group also owns and operates the brands TotallyMoney (www.totallymoney.com) Better Compare (www.bettercompare.co.uk) Fluid (fluid.co.uk) and Granite (www.granitecard.co.uk) (MI Group Brands).

For the purpose of the Data Protection Act 1998 (Act), the data controller is MI Money Ltd (ICO Registration Number Z2112995) of Media Ingenuity Ltd, Churchill House, 142-146 Old Street, London EC1V 9BW or feedback@luma.co.uk.

The Act imposes regulations on how we collect, store and process your personal information. As required by the Act, we are registered as a data controller – details of which can be found online at www.informationcommissioner.gov.uk. This privacy policy explains:

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, we will also notify you by email. Questions, comments and requests regarding this privacy policy are welcomed – and should be sent to Media Ingenuity Ltd, Churchill House, 142-146 Old Street, London EC1V 9BW or feedback@luma.co.uk.

2. What information do we collect from you?

We may collect and process the following information about you:

2.1 Information that you provide by filling in our online forms or which you may subsequently provide when visiting our Site. The provision of our service may also require us to store the information you give us, together with details of your financial information – and to combine the information you provide on separate visits to our Site. We may also ask you for information when you report a problem online.

2.2 Details of your transactions carried out through our Site. Also, the fulfilment of your requests by our third party providers – either a broker or an intermediary (Service Provider) – or directly through a provider, such as a mortgage or insurance company (Product Provider).

2.3 Details of your visits to our Site including traffic, location and other communication data – and the resources that you access.

2.4 Information about your computer including, where available, your IP address, operating system and browser type. This is used for system administration; to report aggregate information to our advertisers; and to enable us to analyse trends of behaviour. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

2.5 If you contact us, we may keep a record of that correspondence. For research purposes, we may also sometimes ask you to complete a survey, although you do not have to respond.

3. Cookies

3.1 We may obtain information about your general internet usage by using a cookie file which is stored on your browser – or the hard drive of your computer. Cookies contain information that is transferred to your hard drive. Some of these cookies are essential for the Site to operate. They help us to:
(a) Improve our site and deliver a better and more personalised service
(b) Estimate audience size and usage pattern
(c) Store information about your preferences
(d) Observe your browsing history
(e) Speed up your searches
(f) Recognise you when you return to the Site.

3.2 If you register with us, or if you continue to use our Site, you agree to our use of cookies.

3.3 Cookies are widely used in order to make websites work, or run more efficiently, as well as to provide information to the owners of the Site.

3.4 Please note that our advertisers, Service Providers and Product Providers may also use cookies, over which we have no control.

3.5 You may opt-out or decline the use of cookies at any time – but in doing so, the Site may not perform or function as we intend, and your access may be limited. You can decline cookies through controls and settings which are unique to your chosen internet browser. For more information, consult the help file on your browser. Unless you have adjusted your settings to refuse cookies, our system will issue them as soon you visit our Site.

3.6 You can find out even more about cookies at [cookie policy]

4. Where do we store your personal data?

4.1 All of the information that you give us is stored on secure servers. We will periodically review this information to ensure that we do not keep it for any longer than is necessary. The maximum period we will retain your personal information will be ten years, unless a longer period is prescribed by law.

4.2 The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by members of staff who are located outside the EEA – who either work for us or for one of our third party providers. They may be working on fulfilling your order, processing your payment details or offering support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all the steps necessary to ensure that your data is treated securely – and in accordance with this privacy policy.

4.3 The internet is not a secure medium. However, we have put in place various security procedures to protect your information. Firewalls are used to block unauthorised traffic to the servers – and the actual servers are located in a secure location which can only be accessed by authorised personnel. We use industry-standard encryption technology to ensure that all your personal and transactional information is encrypted before transmission to certain Product Providers or Service Providers. Our security policies are in place to safeguard your privacy from unauthorised access or improper use – and we will continue to enhance our security as and when new technology becomes available.

5. How do we use your information?

5.1 We use your information in the following ways:
(a) To process a request for a quotation or an application for a product or service made through our Site.
(b) To carry out our obligations arising from any contracts entered into between you and third party providers via our Site.
(c) To allow you to access and use our services – and help you participate in the interactive features of our Site and services if and when you choose to do so.
(d) To ensure that content from our Site is presented in the most effective manner for you and for your computer; to allow us to tailor aspects of our overall service and Site towards you; to notify you about changes to our services; and to analyse your trends in behaviour while on our Site.
(e) For marketing and remarketing of products and services via electronic means (email and SMS) by Media Ingenuity and companies under other MI Group Brands – but only when you have agreed to be contacted in this way.
(f) We may contact you on the following occasions:
(i) Shortly after you have completed a form on the Site – to check that you received the required service from our Service Providers and/or Product Providers.
(ii) On the anniversary of the date that you registered your details to our site our Site – to check that the service you received or product you purchased was satisfactory.
(iii) When we are marketing or remarketing products and services by Media Ingenuity or companies under the other MI Group Brands – but only when you have agreed to be contacted for these purposes.
(g) To provide aggregate information about our users to third party advertisers. For example, we may inform them that: 500 men aged under-30 have clicked on their advertisement on any given day. This helps advertisers reach the kind of audience they want to target

6. Where do we disclose your information to third parties?

6.1 By submitting information to our Site, you are consenting for your data to be used by us – and our third party providers. This consent applies to both ordinary personal data and sensitive personal data, such as information about your health, debts, criminal proceedings or convictions.

6.2 Before you provide us with any information about other people, you must get their permission first. This applies to both ordinary and sensitive personal data. In submitting their details, you are confirming to us that you have their permission to do so –and that they understand how their information will be used under the terms of this privacy policy.

6.3 Please be aware that once you use our Site or our services, you will be regarded as having given your consent for us to disclose your personal information to the following parties:
(a) If you apply for a product or service through our Site, we will need to disclose the information you enter to the relevant Product Provider or Service Provider. This information is necessary to process your purchase or application. The Product Provider or Service Provider will contact you by electronic means (email and SMS), or by telephone, to deal with your application or enquiry or to request feedback from you on your application, enquiry or the services we provide to you (“Feedback”). We may reproduce Feedback on our website or through our other marketing channels in order to enhance our products and service to you and so that other customers are better informed before making a purchase. When we do reproduce Feedback, we will never publish any of your Personal Data along with the Feedback and if you prefer, you can always ask us at any time to stop reproducing your feedback. We will hold all personal information in confidence and only use it to assist you with your purchase or application – with certain exceptions which are detailed in this privacy policy.
(b) If you apply for a credit-based product through our Site, our Product Provider or Service Provider may use your personal information to perform a search with a credit reference agency. You will be asked to consent to this before your application is submitted.
(c) Where you have applied for a payday loan, our Product Providers may also forward your details to a credit reference agency who will then carry out a credit check on you before providing the loan. You will be asked to consent to this before your application is submitted.
(d) For the purpose of compliance monitoring by The Financial Conduct Authority, Office of Fair Trading, Information Commissioner and/or other regulatory/governing bodies it is our legal obligation to disclose or share your personal data. This is also the case when we want to enforce or apply our terms of use and other agreements; to protect the rights, property or safety of Media Ingenuity Group staff, customers – or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
(e) In the event that your choice of third party provider does not approve your application, or offers a less attractive product or service than you had originally applied for, we will pass on your details to other third parties who might be able to offer a similar or alternative product that meets your criteria.
(f) As defined in section 1159 of the UK Companies Act 2006, we may also disclose your personal information to any member of the Media Ingenuity Group – which means our subsidiaries, as well as our ultimate holding company and its subsidiaries.
(g) We may disclose your personal information to third parties if:
(i) We buy or sell any business or assets – in which case we may disclose your personal data to the prospective seller or buyer.
(ii) Media Ingenuity Ltd or a substantial amount of its assets are acquired by a third party. In this case, the personal data we hold about our customers will be one of the transferred assets. But we will not provide your information if you haven’t given us your consent.

6.4 Please note that when you enter a contract with a Product Provider or Service Provider via our Site, the information you provide, and any further information requested by the Product Provider or Service Provider will be held by them for the purposes set out in their individual privacy policies. Once you are contracted to a Service Provider or Product Provider, we have no control over how they use your personal information or to whom it is disclosed.

7. Your right to opt-out

7.1 You have the right to opt-out of the processing of your personal data for marketing or remarketing purposes. Before collecting your data, we will tell you if we – or any third party – intend to use it for such purposes.

7.2 At any time, you can opt-out of receiving marketing messages from any of the Media Ingenuity Group companies by:
(a) Ticking or unticking certain boxes on the forms we use to collect your data
(b) Clicking on the ‘unsubscribe’ link on any marketing emails you receive
(c) Emailing feedback@luma.co.uk and writing ‘unsubscribe’ in the subject line.

All unsubscribe requests will be processed within seven working days.

7.3 Occasionally, our Site may contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that they all have their own privacy policies – and we do not accept any responsibility or liability for them. Always check these policies before you submit any personal data to these websites. If you wish to unsubscribe from marketing sent by, or on behalf of, a third party, you will have to unsubscribe through them. Details of how to do this should be set out in their privacy policy.

7.4 The Act gives you the right to access any information held about you –at any time. However, an access request may be subject to an administration fee of £10.