PRIVACY NOTICE
ABOUT US AND THE PURPOSE OF THIS NOTICE
The Lumen Collective Limited (“TLC”, “we”, “us”, “our” and “ours”) is a finance consultancy and advisory firm. We are registered in England and Wales as a limited company under number: 16682576 and our registered office is at 71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ.
This notice will tell you how we look after your personal data, about your privacy rights, and about our compliance with and your protections under Data Protection Legislation.
In this notice “Data Protection Legislation” means any applicable law relating to the processing, privacy, and use of Personal Data, including the Data Protection Act 2018 and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended by The Data Protection, Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations 2020 and the Data (Use and Access) Act 2025.
For the purpose of the Data Protection Legislation and this notice, we are the ‘data controller’. This means that we are responsible for deciding how we hold and use personal data about you. We are required under the Data Protection Legislation to notify you of the information contained in this privacy notice.
We have appointed a Data Protection Officer. Our Data Protection Officer is our Data Protection Point of Contact and is responsible for assisting with enquiries in relation to this privacy notice or our treatment of your personal data.
Should you wish to contact our Data Protection Point of Contact you can do so using the contact details noted at the section, Contact Us, below.
THE KIND OF INFORMATION WE HOLD ABOUT YOU
The information we hold about you may include the following:
• your personal details (such as your name and/or address);
• details of contact we have had with you in relation to the provision, or the proposed provision, of our services;
• details of any services you have received from us;
• our correspondence and communications with you;
• information about any complaints and enquiries you make to us;
• information from research, surveys, and marketing activities; and
• financial data, accounting records, tax information and management information provided by you or generated through the provision of our services, which may be processed on third-party technology platforms used by us to deliver our services.
HOW WE MAY COLLECT YOUR PERSONAL DATA
We obtain your personal data directly from you when:
• you request a proposal from us in respect of the services we provide;
• you engage us to provide our services and also during the provision of those services; and
• you contact us by email, telephone, post or social media (for example when you have a query about our services).
We also collect certain information automatically when you visit our website through the use of privacy-focused analytics software. This information does not identify you personally and is processed in aggregate form only. It may include details such as the pages you visit, the referring website, and general information about your device or location. This helps us understand how our website is used and to improve its performance and content.
We may also obtain your personal data indirectly:
• from our client when it engages us to provide services and also during the provision of those services; and
• from third parties and/or publicly available resources (for example, from your employer or from Companies House); and
• from your accounting systems, financial systems and other data sources that you authorise us to connect to and integrate with the Chasq Platform. Where the services involve access to your bank account information, that data is obtained through an authorised account information service provider to whom you give separate consent when connecting.
HOW WE USE PERSONAL DATA WE HOLD ABOUT YOU
We may process your personal data for purposes necessary for the performance of our contract with you, your employer, our clients and to comply with our legal obligations. This may include processing your personal data where you are an employee, subcontractor, supplier or customer of our client.
We may also process your personal data for the purposes of our own legitimate interests provided that those interests do not override any of your own interests, rights and freedoms which require the protection of personal data. This includes processing for marketing, business development, statistical and management purposes.
Please note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.
Situations in which we will use your personal data
We may use your personal data in order to:
• carry out our obligations arising from any agreements entered into between you and us (which will most usually be for the provision of our services);
• carry out our obligations arising from any agreements entered into between our clients and us (which will most usually be for the provision of our services) where you may be a subcontractor, supplier or customer of our client;
• provide you with information related to our services and our events or seek your thoughts and opinions on the services we provide;
• notify you about any changes to our services; and
• monitor and analyse website usage through website analytics software to help us understand how visitors interact with our site and to improve user experience. This data is collected and processed in a fully anonymised, aggregated form and does not include personal identifiers.
In some circumstances we may anonymise or pseudonymise the personal data so that it can no longer be associated with you, in which case we may use it without further notice to you.
We may also process your personal data without your knowledge or consent, in accordance with this notice, where we are legally required or permitted to do so.
Data retention
We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is collected. When assessing what retention period is appropriate for your personal data, we take into consideration the requirements of our business and the services provided, any statutory or legal obligations and the purposes for which we originally collected the personal data.
In particular, where your personal data is processed on the Chasq Platform in connection with the services we deliver to you (see Technology Platform Processing below), the following retention periods apply on termination of our engagement with you:
• Operational handover (90 days). We will retain your data on the platform for at least 90 days following termination to enable export and handover to you or your successor advisors.
• Legal claims and regulatory retention (6 years). We and Chasquis Limited may retain your data in identifiable form for a further period of up to six years (or such longer period as may be required by law) for the purposes of defending or pursuing legal claims, complying with our regulatory and statutory obligations (including the Limitation Act 1980, anti-money laundering regulations, and tax and accounting record-keeping obligations). Access during this period will be restricted to those personnel with a legitimate need to access it for these purposes.
• Anonymised data (indefinite). Subject to your right to opt out, Chasquis Limited may retain and use your data in anonymised form indefinitely for the purposes of platform improvement, statistical analysis, benchmarking and the development of new products or features. Anonymised data is data from which all identifiers have been irreversibly removed such that you cannot be identified, and is no longer personal data for the purposes of the Data Protection Legislation. The legal basis for the anonymisation processing itself is legitimate interests (Chasquis Limited’s interest in platform improvement and benchmark development for use by professional services firms), and we have considered this against your interests, rights and freedoms.
If you do not wish your data to be anonymised and used for the purposes set out above, you may opt out by notifying us in writing at contact@thelumencollective.co. Opting out will not affect the services we provide to you and there is no fee for opting out.
Change of purpose
Where we need to use your personal data for a reason, other than the purpose for which we originally collected it, we will only use your personal data where that reason is compatible with the original purpose. If we need to use your data for a new purpose, we will notify you and communicate our legal basis for this new processing.
DATA SHARING
We will share your personal data with third parties where we are required by law, where it is necessary to administer the relationship between us, or where we have another legitimate interest in doing so. This may include sharing your personal data with a regulator or to otherwise comply with the law.
“Third parties” includes third-party service providers. The following activities are carried out by third-party service providers: technology platform services (including the Chasq Platform, operated by Chasquis Limited, which we use to deliver financial analysis and advisory services), professional advisory services, administration services, marketing services and banking services. We only permit our third-party service providers to process your personal data for specified purposes and in accordance with our instructions.
We may share your personal data with other third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law.
Technology Platform Processing
In the course of providing our professional services, we use the Chasq Platform, a technology platform operated by Chasquis Limited (company number 17027569). Chasquis Limited is a connected party to this firm. The principal of The Lumen Collective Limited, Ben Leadbetter, is also the founder and sole director of Chasquis Limited.
Your data, which may include personal data, is uploaded to and processed on this platform to enable us to deliver financial analysis, advisory and other professional services to you. Chasquis Limited acts as our data processor in respect of any personal data processed on the Chasq Platform under the terms of our agreement with Chasquis Limited, which contains the data processing protections required by the Data Protection Legislation, including obligations regarding security, sub-processing, breach notification and data subject rights.
The Chasq Platform automatically generates reports, analyses, insights and other outputs (“Platform Outputs”) based on data uploaded to it. Platform Outputs are produced by Chasquis Limited.
The Chasq Platform may use artificial intelligence capabilities as part of its analytical functions. We review Platform Outputs as part of delivering our professional services to you, and we remain responsible to you for the professional services we provide. Platform Outputs do not themselves constitute professional advice.
Further details about Chasquis Limited’s own data practices, including its retention practices and use of anonymised data, can be found in their privacy notice at https://www.chasq.com/privacy.
TRANSFERRING PERSONAL DATA OUTSIDE THE UNITED KINGDOM (UK)
Personal data processed in the course of providing our services is processed and stored on servers located within the United Kingdom or the European Economic Area. The UK has adequacy regulations in place recognising the EEA as providing an adequate level of protection for personal data under the Data Protection Act 2018. Personal data processed within the EEA is therefore treated as offering equivalent safeguards to UK data protection standards. We will not transfer your personal data outside the United Kingdom or the European Economic Area without appropriate safeguards being in place.
Our website analytics provider is also based in the European Union and is covered by the same adequacy regulations.
In the event that we transfer personal data to a country that does not benefit from an adequacy decision, we will ensure that appropriate safeguards are implemented, such as standard contractual clauses approved by the Information Commissioner’s Office (ICO), to ensure your personal data is protected.
Further details about adequacy regulations can be found on the ICO’s website at https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/international-transfers/a-brief-guide-to-international-transfers/.
If you would like further information about the countries to which we may transfer personal data or the safeguards we use, please contact us using the details provided in the section, Contact Us.
DATA SECURITY
We have put in place commercially reasonable and appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
Our third-party technology platform provider, Chasquis Limited, has undertaken to us that it will maintain appropriate technical and organisational security measures to protect personal data processed on the Chasq Platform and to notify us without undue delay of any actual or suspected data security breach affecting your personal data.
We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION
Your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Should your personal information change, please notify us of any changes of which we need to be made aware by contacting us, using the contact details below.
Your rights in connection with personal data
Under certain circumstances, by law you have the right to:
• Request access to your personal data. This enables you to receive details of the personal data we hold about you and to check that we are processing it lawfully.
• Request correction of the personal data that we hold about you.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this basis. You also have the right to object where we are processing your personal information for direct marketing purposes, or for the anonymisation use case described above (see Data retention, Anonymised data).
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to you or another data controller if the processing is based on consent, carried out by automated means and this is technically feasible.
If you want to exercise any of the above rights, please email our Data Protection Point of Contact at contact@thelumencollective.co or visit https://thelumencollective.co/contact.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee for the administrative costs of complying with the request if your request for access is manifestly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
RIGHT TO WITHDRAW CONSENT
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose (for example, in relation to direct marketing that you have indicated you would like to receive from us), you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please email our Data Protection Point of Contact at contact@thelumencollective.co or visit https://thelumencollective.co/contact.
Once we have received notification that you have withdrawn your consent, we will no longer process your personal information (personal data) for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
CHANGES TO THIS NOTICE
Any changes we may make to our privacy notice in the future will be provided to you via an updated privacy policy on our website.
This privacy notice was last updated on 15 June 2026.
CONTACT US
If you have any questions regarding this notice or if you would like to speak to us about the manner in which we process your personal data, please email our Data Protection Point of Contact at contact@thelumencollective.co.
You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues, at any time. The ICO’s contact details are as follows:
https://ico.org.uk/global/contact-us/contact-us-public/public-advice/
Telephone: 0303 123 1113
The ICO’s normal opening hours are Monday to Friday between 9am and 5pm (excluding bank holidays).
Website: https://ico.org.uk/make-a-complaint/data-protection-complaints/