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 email@example.com.
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.
3.1 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.
3.3 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.
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.
4.3 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.
6.3 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:
(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.
(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 firstname.lastname@example.org and writing ‘unsubscribe’ in the subject line.
All unsubscribe requests will be processed within seven working days.
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.