Privacy
Privacy notice
This notice explains what personal information Luma Fibre Limited collects, why we use it, the legal grounds we rely on, who we share it with, how long we keep it, and your rights.
1. Who we are
Luma Fibre Limited is the controller for the personal information described in this notice. We are registered in England and Wales under company number 17275056, and our registered office is 238A Telegraph Road, Heswall, Wirral, CH60 0AL.
We are registering with the Information Commissioner's Office (ICO) as a data controller. Our registration number will be shown here once it is confirmed.
You can reach us using any of the methods on our Contact page.
2. Information we collect
- Contact details you give us: name, email address, telephone number, address and postcode.
- Information about your current broadband: provider, package, monthly price, advertised speed and contract status.
- Any broadband bill you choose to upload for a comparison, and the details we take from it.
- Enquiry and questionnaire answers you submit through our forms, including our flats registration form.
- Account, billing and service data if you become a customer.
- Records of complaints and correspondence.
- Your cookie choice, and where you accept them, website analytics information.
We do not ask for bank details, payment card details or account numbers through this website. Please remove or cover those sections before uploading a bill.
3. Why we use it, and our lawful basis
We only use personal information where we have a lawful basis to do so under UK data protection law. The table below summarises our main processing activities.
| Purpose | Data used | Likely lawful basis |
|---|---|---|
| Broadband enquiry | Name, contact details, address, postcode | Steps taken at your request before entering a contract; legitimate interests in responding to enquiries |
| Customer broadband service | Account, contract, address, service and technical data | Performance of a contract with you |
| Billing | Billing address, charges, payment status | Performance of a contract; legal obligation (tax and accounting records) |
| Complaints | Complaint details, account information, correspondence | Legitimate interests in resolving complaints; legal obligation under communications regulation |
| Bill comparison | Uploaded bill, extracted provider/package/price/speed/contract details | Steps taken at your request; consent to upload and process the document |
| Marketing | Contact details, marketing preferences | Consent, which you can withdraw at any time |
| Analytics & cookies | Cookie identifiers, usage data | Consent, where the technology is non-essential |
4. Legitimate interests
Where we rely on legitimate interests, these include: responding to enquiries and availability checks, administering customer accounts, managing billing and fault resolution, handling complaints, keeping our website secure, and improving our services. We balance these interests against your rights and only proceed where they are not overridden by your interests or fundamental rights.
5. How uploaded bills are reviewed, including by AI
When you upload a bill, the file is stored in a private area of our file storage platform that is not publicly accessible. Our own server then sends it to an artificial intelligence (AI) document-processing service, which reads the document and extracts the provider, package, monthly price, advertised speed and contract status.
Automated extraction is not always accurate, so the details are always shown back to you on screen. You can correct anything that is wrong before you send your comparison request to us. A member of our team reviews your request when it reaches us, but the on-screen comparison itself is produced automatically.
Uploaded bills are not used to train AI models.
6. Website security
We use technical measures to protect this website and the information submitted through it, including secure transmission, access controls on our systems and monitoring for misuse. See our Cookie policy for how cookies fit into this.
7. Who we share information with
We share personal information with suppliers and partners who process it on our instructions, or who are separately involved in delivering our service. These may include:
- Our website hosting provider.
- Our database and file storage platform.
- Pipedrive, used to manage submissions from our flats registration form.
- Our email service provider.
- Network and wholesale partners involved in delivering your connection.
- Installation contractors carrying out site surveys and installations.
- eero/Amazon, where relevant to equipment supplied with your service.
- An AI document-processing provider used to read uploaded bills.
- Analytics providers, only where you have given cookie consent.
- A payment provider, once online ordering and payment collection are live.
We do not sell your information. We may share information with a regulator, an ADR scheme, or where the law requires it.
8. International transfers
Where any supplier listed above processes information outside the UK, we require appropriate safeguards to be in place, such as an adequacy decision or standard contractual clauses, before information is transferred.
9. How long we keep information
The periods below reflect our approach to retention. Deletion of uploaded bills is currently carried out by our team rather than automatically, so if you want your uploaded bill removed sooner, please ask us and we will delete it.
- Uploaded bills: kept in private storage while we prepare and discuss your comparison, and deleted on request or within 30 days of your comparison being completed.
- Enquiries that do not convert to a customer: kept for 12 months after the last meaningful contact.
- Customer contract and account records: kept for up to six years after the relationship ends.
- Financial and tax records: kept for the statutory period required by law.
- Complaint records: kept for at least 12 months after the complaint is closed.
- Marketing suppression records (records that you asked not to be contacted): kept for as long as needed to honour that request.
- Cookie choices: stored in your own browser until you change your choice or clear your browser data. There is no automatic expiry.
10. Your rights
- Ask for a copy of the information we hold about you.
- Ask us to correct information that is wrong.
- Ask us to delete information, including an uploaded bill.
- Withdraw marketing consent at any time.
- Object to, or ask us to restrict, how we use your information.
- Ask us to move certain information to another provider (data portability), where that right applies.
- Complain to the Information Commissioner's Office (ICO) if you are unhappy with how we have handled your information.
To exercise any of these rights, or to ask us to delete your information, contact us and tell us what you would like us to do. We will respond within the timescales the law allows.
11. Cookies
Non-essential analytics and marketing technologies are only loaded if you accept them. You can change your choice at any time using the "Cookie settings" link in the footer. See our Cookie policy for detail.
