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Privacy Policy

Lumiere Cleaning Ltd

Last Updated: 25 October 2025

1. INTRODUCTION

Lumiere Cleaning Ltd (Company Number 16773397) ("we", "us", "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use our online marketplace platform connecting clients with independent cleaning professionals.

Registered Office: 71-75 Shelton Street, London, England, WC2H 9JQ
Contact: info@lumierecleaning.co.uk
Website: www.lumierecleaning.co.uk

This Privacy Policy complies with:
- UK General Data Protection Regulation (UK GDPR)
- Data Protection Act 2018
- Privacy and Electronic Communications Regulations (PECR)

Data Controller: Lumiere Cleaning Ltd is the data controller for personal data processed through our Platform.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

FOR CLIENTS:
- Name, email address, phone number
- Home address and property details
- Payment information (processed securely via Stripe - we do not store full card details)
- Booking preferences and special requirements
- Access instructions (key locations, entry codes)
- Communication history with us and Service Providers
- Reviews and ratings you submit

FOR SERVICE PROVIDERS (CLEANERS):
- Full name, email, phone number
- Home address and postcode
- Right to work documentation
- DBS check results (where applicable)
- Self-employment status and HMRC registration
- Public Liability Insurance details
- Bank account details for payments
- Availability and service preferences
- Professional profile information
- Work history and references

2.2 Information We Collect Automatically

When you use our Platform, we automatically collect:
- IP address and device information
- Browser type and version
- Operating system
- Pages visited and time spent on pages
- Referring website
- Location data (with your consent)
- Cookies and similar tracking technologies

2.3 Information From Third Parties

We may receive information from:
- Payment processors (Stripe) - transaction confirmation and fraud prevention
- Identity verification services - for Service Provider vetting
- DBS checking services - criminal record checks for Service Providers
- Social media (if you choose to link accounts)

3. HOW WE USE YOUR INFORMATION

3.1 Legal Basis for Processing

We process your personal data under the following legal bases:

CONTRACT PERFORMANCE:
- Processing bookings and facilitating services
- Payment processing
- Communicating with Clients and Service Providers
- Managing accounts

LEGITIMATE INTERESTS:
- Platform security and fraud prevention
- Customer service and support
- Improving our Platform and services
- Marketing (where not requiring consent)
- Business analytics

LEGAL OBLIGATION:
- Tax compliance and financial reporting
- Responding to legal requests
- Regulatory compliance

CONSENT:
- Marketing emails (where legally required)
- Optional cookies
- Location tracking

3.2 Specific Uses

FOR CLIENTS, WE USE YOUR DATA TO:
- Create and manage your account
- Process booking requests
- Match you with appropriate Service Providers
- Share your details with assigned Service Provider (name, address, contact info, property details)
- Process payments
- Send booking confirmations and reminders
- Enable communication with Service Providers
- Handle complaints and disputes
- Improve service quality through reviews
- Send relevant service updates
- Prevent fraud and ensure Platform security

FOR SERVICE PROVIDERS, WE USE YOUR DATA TO:
- Verify identity and right to work
- Conduct background checks
- Create and manage your professional profile
- Send you available job opportunities
- Share your profile with potential Clients
- Process payments (80% of booking value)
- Track performance and ratings
- Communicate Platform updates
- Ensure compliance with terms
- Prevent fraud

4. DATA SHARING AND DISCLOSURE

4.1 Who We Share Data With

We share personal data only as necessary:

BETWEEN USERS:
- Client details shared with assigned Service Provider (name, address, contact info, property details, special requirements)
- Service Provider profile shared with Client (name, photo, ratings, reviews - NOT full address)

SERVICE PROVIDERS:
- Stripe (payment processing) - financial data
- AWS/Cloud hosting - encrypted data storage
- Email service providers - for communications
- SMS providers - for booking confirmations
- DBS checking services - for Service Provider vetting
- Identity verification services

LEGAL REQUIREMENTS:
- Law enforcement or regulatory authorities when legally required
- To enforce our Terms and Conditions
- To protect rights, property, or safety
- In connection with legal proceedings

BUSINESS TRANSFERS:
- In the event of merger, acquisition, or sale of assets

4.2 What We DON'T Share

We NEVER:
- Sell your personal data to third parties
- Share your data for third-party marketing without explicit consent
- Share Client's full details with Service Providers before booking confirmation
- Share Service Provider's home address with Clients

5. INTERNATIONAL DATA TRANSFERS

Our primary servers are located in the UK/EEA. If data is transferred outside the UK/EEA, we ensure:
- Adequate protection mechanisms (Standard Contractual Clauses)
- Compliance with UK GDPR requirements
- Necessary safeguards are in place

Stripe may process payment data internationally - see Stripe's privacy policy for details.

6. DATA RETENTION

We retain personal data only as long as necessary:

CLIENTS:
- Active accounts: Duration of account + 7 years (tax/legal requirements)
- Inactive accounts: 3 years after last login, then deleted
- Booking history: 7 years (financial/tax compliance)
- Communications: 3 years

SERVICE PROVIDERS:
- Active contractors: Duration of relationship + 7 years
- After termination: 7 years (tax/employment/legal requirements)
- DBS checks: As required by law
- Financial records: 7 years

GENERAL:
- Marketing opt-outs: Permanently (to prevent re-contact)
- Deleted accounts: 30 days (in case of accidental deletion)
- Aggregated anonymous data: May be retained indefinitely

7. YOUR RIGHTS UNDER UK GDPR

You have the following rights:

7.1 Right of Access
Request a copy of your personal data we hold 

7.2 Right to Rectification
Correct inaccurate or incomplete data

7.3 Right to Erasure ("Right to be Forgotten")
Request deletion of your data in certain circumstances

7.4 Right to Restriction
Limit how we use your data in certain situations

7.5 Right to Data Portability
Receive your data in a structured, commonly used format

7.6 Right to Object
Object to processing based on legitimate interests or direct marketing

7.7 Rights Related to Automated Decision Making
We do not use fully automated decision-making with legal effects

TO EXERCISE YOUR RIGHTS:
Email: info@lumierecleaning.co.uk
Subject: "Data Subject Request"
Include: Full name, account email, specific request

We will respond within 30 days (may extend to 60 days for complex requests).

8. SECURITY MEASURES

We implement appropriate technical and organizational measures:

TECHNICAL MEASURES:
- SSL/TLS encryption for data transmission
- Encrypted data storage
- Secure password requirements (hashed and salted)
- Regular security testing and monitoring
- Firewall protection
- Access controls and authentication

ORGANIZATIONAL MEASURES:
- Staff training on data protection
- Confidentiality agreements
- Access on need-to-know basis
- Regular security audits
- Incident response procedures

PAYMENT SECURITY:
- PCI DSS compliant payment processing via Stripe
- We do not store full card details
- Tokenized payment information only

9. COOKIES AND TRACKING

9.1 What Are Cookies
Cookies are small text files stored on your device to remember your preferences and improve user experience.

9.2 Cookies We Use

STRICTLY NECESSARY (Always Active):
- Session management
- Authentication
- Security
- Load balancing

FUNCTIONAL COOKIES (Can Be Disabled):
- Language preferences
- Location preferences
- Remember login

ANALYTICS COOKIES (Can Be Disabled):
- Google Analytics - understand usage patterns
- Performance monitoring
- Feature effectiveness

MARKETING COOKIES (Opt-in Required):
- Facebook Pixel (if used)
- Google Ads tracking (if used)
- Retargeting pixels

9.3 Managing Cookies
You can control cookies through:
- Browser settings (block all or specific cookies)
- Our cookie consent banner (on first visit)
- Cookie preferences page (link in footer)

Note: Disabling essential cookies may affect Platform functionality.

10. MARKETING COMMUNICATIONS

10.1 What We Send

SERVICE MESSAGES (Cannot Opt-Out):
- Booking confirmations
- Service reminders
- Important account updates
- Security alerts

MARKETING MESSAGES (Can Opt-Out):
- Promotional offers and discounts
- Service updates and new features
- Tips and advice
- Newsletters

10.2 How to Opt-Out

You can unsubscribe from marketing at any time:
- Click "Unsubscribe" in any marketing email
- Update preferences in your account settings
- Email info@lumierecleaning.co.uk with "Unsubscribe"
- We will process within 48 hours

11. CHILDREN'S PRIVACY

Our Platform is not intended for children under 18. We do not knowingly collect data from children. If we become aware of such collection, we will delete it promptly.

Parents/guardians who believe their child provided data should contact us immediately.

12. THIRD-PARTY LINKS

Our Platform may contain links to third-party websites (e.g., social media, payment processors). We are not responsible for their privacy practices. Please review their privacy policies.

13. DATA BREACH NOTIFICATION

In the event of a data breach affecting your rights and freedoms:
- We will notify the ICO within 72 hours
- We will notify affected individuals without undue delay
- We will provide details of the breach and remedial actions

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time. Changes will be:
- Posted on this page with updated "Last Updated" date
- Notified to you via email for material changes
- Take effect immediately upon posting

Continued use after changes constitutes acceptance.

15. COMPLAINTS AND CONCERNS

15.1 Contact Us First

If you have concerns about how we handle your data:
Email: info@lumierecleaning.co.uk
Subject: "Privacy Concern"

We will investigate and respond within 30 days.

15.2 Supervisory Authority

If you're not satisfied with our response, you have the right to complain to:

Information Commissioner's Office (ICO)
Website: ico.org.uk
Phone: 0303 123 1113
Address: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

16. CONTACT INFORMATION

For any questions about this Privacy Policy or how we handle your data:

Lumiere Cleaning Ltd
Data Protection Queries

📧 Email: info@lumierecleaning.co.uk
📞 Phone: [Your business phone]
🌐 Website: www.lumierecleaning.co.uk

📍 Registered Office:
71-75 Shelton Street
London, England
WC2H 9JQ

Company Number: 16773397


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By using our Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal data as described herein.

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APPENDIX: KEY DEFINITIONS

Personal Data: Information relating to an identified or identifiable natural person
Processing: Any operation performed on personal data
Data Controller: Entity determining purposes and means of processing
Data Processor: Entity processing data on behalf of controller
Data Subject: Individual whose personal data is processed
UK GDPR: UK General Data Protection Regulation
ICO: Information Commissioner's Office (UK supervisory authority)

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END OF PRIVACY POLICY

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