Privacy Policy

1. WHO DOES THIS PRIVACY NOTICE APPLY TO?

This privacy notice applies to individuals who:

• Engage Luna Software by purchasing our services.
• Agree to receive marketing communications from us.
• Access our website.
• Visit our offices.
• Apply to work for use

2. WHO ARE WE?

“Luna Software” (referred to in this policy as “we”, “us”, “our”) is:

Luna Software Ltd
Quayside Studio
Prince Albert Gardens
Grimsby
North East Lincolnshire
DN31 3AG

ICO Registration Number: ZB962616

3. HOW TO CONTACT US

We have appointed a Data Protection Officer (DPO), who can be contacted in the following ways should you have any questions or feedback about the way your data is processed:

Email: hello@luna.software

Mail: Data Protection Officer

Luna Software
Quayside Studio
Prince Albert Gardens
Grimsby
North East Lincolnshire
DN31 3AG

4. WHERE WE COLLECT YOUR PERSONAL DATA FROM

We get information about you from the following sources:

• When you request a proposal from us in respect of the services we provide;
• When you engage us to provide our services;
• When we are performing our services;
• When you contact us by email, telephone, post or social media, or
• Where we receive information from third parties and/or publicly available resources (for example, from your employer or from Companies House).

5. WHAT DATA DO WE COLLECT AND HOW DO WE USE IT?

We collect, use, store and process the following information, which we have categorised and grouped as follows:

PROVIDING YOU WITH AND IMPROVING OUR SERVICES

We collect or use the following information to provide and improve our products and services:

• Your personal details (such as your full name, date of birth, nationality, address, national insurance number and bank account details)
• Details of any services you have received from us
• Details of contact we have had with you in relation to the provision, or the proposed provision, of our services
• Our correspondence and communications with you
• Information from research, surveys, and marketing activities;
• Information relating to compliments and complaints
• Usage data (how you interact with and use our website, products and services)
• Transaction data (details about payments and details of products and services)
• Website user account information and access
• Website user journeys and experiences
• Information we receive from other sources, such as publicly available information.

Applicable lawful basis:

• Performance of a contract
• Legal/ regulatory obligation
• Legitimate Interest: To ensure the security of our websites and systems, to improve and enhance our products and services, to provide a personalised service and to understand the usage of our website and services.

DEALING WITH QUERIES, COMPLAINTS OR CLAIMS

We collect or use the following personal information for dealing with queries, complaints or claims:

• Names and contact details (address, telephone number or email address)
• Engagement information
• Relevant information from previous service reviews
• Correspondence
• Any other personal data relevant to the query, complaint or claim.

Applicable lawful basis:

• Performance of a contract
• Legal/ regulatory obligation
• Legitimate Interest: To improve and enhance our services and to provide a personalised service.

MARKETING, RESEARCH AND SURVEYS

We collect or use the following personal information for information updates, marketing, and research purposes:

• Name and contact details (address, telephone number or email address)
• Marketing preferences
• Profile information
• Survey responses
• Feedback questionnaires

Applicable lawful basis:

• Consent
• Legitimate Interest: To improve and enhance our products and services, to provide a personalised service, and to promote our products and services via direct marketing. To determine the effectiveness of promotional campaigns.

PREVENTION OR DETECTION OF CRIME

We collect or use the following information for the prevention, detection, investigation and prosecution of crimes (e.g., fraud):

• Names and contact details (address, telephone number or email address)
• Account information
• Purchase or service history
• Relevant information from investigations or reviews
• Financial transaction information
• Correspondence
• Any other personal data relevant to the prevention or detection of crime.

RECRUITMENT

We collect or use the following personal information for recruitment purposes:

• Names and contact details (address, telephone number or email address)
• Curriculum Vitae (CV)
• Employment history (e.g., job application and employment references)
• Education history (e.g., qualifications)
• Right to Work Information

Applicable lawful basis:

• Performance of a contract.
• Legal/ regulatory obligation.

WHEN VISITING OUR OFFICES

We collect or use the following personal information for physical security purposes when you visit our offices:

• • CCTV footage.
  • Names and contact details (e.g., name, car registration, contact number, etc.)

Applicable lawful basis:

• Performance of a contract.
• Legal/ regulatory obligation.
• Legitimate Interest – For the safety and security of our people, visitors and assets.

If you refuse to provide us with certain information when requested, we may not be able to perform the contract we have entered into with you. Alternatively, we may be unable to comply with our legal or regulatory obligations.

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.

In some circumstances, we may anonymise 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.

6. CHANGE OF PURPOSE

Where we need to use your personal data for another reason, different to the original purpose it was collected for, we will only use your personal data where that reason is compatible with the original purpose.

Should it be necessary to use your personal data for a new purpose, we will notify you and communicate the legal basis which allows us to do so before starting any new processing.

7. YOUR DATA PROTECTION RIGHTS

The lawful basis we rely on may affect your data protection rights, which are, in brief, set out below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:

YOUR DATA PROTECTION RIGHTS

• Your right of access – You have the right to ask us for copies of your personal information. You can request other information, such as details about where we get personal information from and who we share personal information with. There are some exemptions, which means you may not receive all the information you ask for. You can read more about this right here.
• Your right to rectification – You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. You can read more about this right here.
• Your right to erasure – You have the right to ask us to delete your personal information. You can read more about this right here.
• Your right to restriction of processing – You have the right to ask us to limit how we can use your personal information. You can read more about this right here.
• Your right to object to processing – You have the right to object to the processing of your personal data. You can read more about this right here.
• Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. You can read more about this right here.
• Your right to withdraw consent – When we use consent as our lawful basis, you have the right to withdraw your consent at any time. You can read more about this right here.

If you make a request, we must respond to you without undue delay and in any event within one month.

To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.

Profiling and Automated Decision Making

We may use profiling to enable us to give you the best service across the Society, so that we can produce more relevant and tailored communications by having a deeper understanding of your behaviours, interests and personal preferences.

You have the right not to be subject to a decision based solely on automated processing, which has legal effects for you or affects you in any other significant way. We ensure that there are simple ways for you to request human intervention or challenge an automated decision. We also carry out regular checks to ensure that our systems and processes are working as intended.

8. DATA SHARING

We will only share your information 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, for example:

• To provide and support the services you have engaged us for.
• To verify your identity and check your details.
• To authorise payments and any other transactions.
• To prevent and detect fraud.
• To handle complaints and improve customer service.
• To provide or support marketing activities on our behalf.
• To perform our regulatory responsibilities.
• To provide us with professional advice and specialist support services.
• To provide us with IT support and maintenance.
• To provide us with IT systems and cloud hosting.
• To support the possible sale or restructuring of the business.

We’ll never make your personal data available to anyone outside Luna Software for them to use for their own marketing purposes without your prior consent.

9. INTERNATIONAL TRANSFERS

Your information is stored and processed within the UK and Europe.

In the future, should we transfer personal data overseas, we will ensure that we comply with UK data protection legislation, ensuring appropriate safeguards are in place and appropriate transparent notification is provided to you.

10. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

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.

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.

External Links

Please remember that if you use a link to go from our websites to another website, or you request a service from a third party, this privacy notice will no longer apply once you have left this website. Please note that your activity and interaction on any other website are subject to that website’s own rules and policies.

11. DATA RETENTION

We will only retain your personal data for as long as is necessary to fulfil the purposes for which it is processed.  When assessing what retention period is appropriate for your personal data, we take into consideration:

• Any statutory or legal obligations.
• The requirements of the business.
• The purposes for which we originally collected the personal data.
• The lawful grounds on which we based our processing.
• The types of personal data we have collected.
• The amount and categories of your personal data; and
• Whether the purpose of the processing could reasonably be fulfilled by other means.

After such time, we will securely delete or destroy your personal data.

12. WHAT TO DO IF YOU ARE NOT HAPPY

Please let us know if you are unhappy with how we have used your personal data by contacting the Data Protection Officer (details can be found in section 2).

You also have a right to complain to the Information Commissioner’s Office.  You can find their contact details at www.ico.org.uk.  We would be grateful for the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

13. DO YOU NEED A LITTLE EXTRA HELP?

If you would like this privacy notice in another format (for example: audio, large print or braille), please contact us (see the ’Who we are’ section above).

14. CHANGES TO THIS PRIVACY NOTICE

We will keep this privacy notice up to date and notify you of any significant changes to the way we process data.

Last updated September 2025.