Last updated: 01/12/2025
Introduction
This privacy policy describes how Luma Black Ltd, trading as LUMA (“LUMA”, “we”, “us” or “our”) collects, processes and protects your personal data.
The term “you” or “your” refers to the person who books, receives or participates in an experience through LUMA.
Personal data is information, or a combination of pieces of information, that could reasonably allow you to be identified.
1. PERSONAL DATA WE PROCESS
LUMA only processes information that it needs to provide services to you or fulfil its legal obligations. The categories of data that we may process are:
Identity Data — including first name, last name, and date of birth (where relevant for age-restricted experiences or venues).
Contact Data — including your email address, telephone number and postal address. When using the “book for another person” feature, you may also give us permission to access the contact details of the person you are booking for.
Financial Data — bank account and payment card details (including expiration date and CVV) in order to process payments. We only use the CVV to confirm the validity of payment card details and do not store it after payment is confirmed.
Transaction Data — details about payments to and from you, and details of experiences you have booked, including:
- Collection and destination addresses
- Dates and times
- Distance travelled
- Amount charged
- Journey itinerary and schedule
- Preferences and requirements (dietary, accessibility, etc.)
- Any special requests or arrangements
Technical Data — including internet protocol (IP) address, browser type and version, time zone setting and location, device information such as device ID, and other technology on the devices you use to access our website.
Preference Data — including your preferences for provisions (champagne, wine, etc.), special requirements, accessibility needs, allergies, and feedback.
Usage Data — including information about how you use our website and services.
Marketing and Communications Data — including your preferences in receiving marketing from us and reminders for occasions such as birthdays, anniversaries, or events.
Experience Ratings — you may be asked to rate your chauffeur’s performance and provide feedback through our internal review system or via third-party platforms such as Trustpilot.
Business Account Data — if you are booking through a corporate or business account, we may collect business contact details, credit information, and billing details for the account holder.
Booking for Others — when you book an experience for another person, we collect that person’s name, contact details, preferences, allergies, and any other information necessary to deliver the experience safely and appropriately.
Information we collect using automated technologies
As you interact with our website, we may automatically collect the data described above using cookies, server logs and similar technologies. See Section 4 (Cookies) below for detailed information.
2. HOW WE USE YOUR INFORMATION
We will only process your data where we have a lawful basis to do so. Generally, this will be to fulfil our contractual obligations to you or where there is a legitimate interest in doing so.
We use your personal data:
- To provide and personalise our services — including assigning a chauffeur, arranging your experience, providing complimentary provisions tailored to your preferences, and handling reservations, tickets or other arrangements.
- To manage your booking — including confirming collection times and locations, sharing your itinerary with your assigned chauffeur, and handling any changes or adjustments to your plans.
- To communicate with you — including responding to enquiries, providing customer support, and enabling you to communicate directly with your chauffeur on the day of your experience if needed.
- To process payments — including charging for services, managing business accounts, and handling refunds or disputes.
- To comply with legal obligations — including retaining journey records as required by Private Hire Vehicle (PHV) licensing regulations (minimum 1 year), cooperating with regulators and law enforcement, and conducting anti-money laundering checks where required.
- To improve our services — including analysing how our services are used, understanding customer preferences, and developing new experiences.
- For safety and security — including conducting enhanced DBS checks on all chauffeurs, verifying RoSPA advanced driving accreditation, and using fraud detection tools provided by our payment processor.
- To ask for feedback — including requesting ratings and reviews to help us understand how you feel about our services.
- For marketing purposes — including contacting you (where you have opted in) with reminders about occasions such as birthdays, anniversaries, or events that may be relevant to you.
Legal Basis for Processing
We process your data on the following legal bases:
Performance of a contract — to provide the services you have booked with us.
Legal obligations — including PHV licensing requirements, record retention, anti-money laundering checks, and cooperation with authorities.
Legitimate interests — including improving our services, fraud prevention, safety and security, and understanding customer needs. When we process data for legitimate interests, we ensure robust safeguards are in place to protect your privacy.
Consent — where we ask for your explicit consent (for example, to send you marketing communications), you may withdraw consent at any time by contacting us.
3. HOW WE SHARE YOUR INFORMATION
We may share your personal information with third parties under the following circumstances:
Information shared with your assigned chauffeur
Your assigned chauffeur will receive:
- Your name and, if provided, your photograph
- Collection address and time
- Destination(s) and itinerary
- Relevant preferences and requirements (e.g., accessibility needs, allergies)
- Any special instructions necessary to deliver your experience
This information is provided so that your chauffeur can deliver your experience safely and to the standard you expect.
Information shared when booking for others
If you book an experience for another person, we will share the necessary details with that person to enable them to receive the service. We may also share journey details with you as the booker.
Information shared with business account holders
If you are travelling under a corporate or business account, the account holder may have access to journey details including dates, times, locations, and amounts charged.
Information shared with service providers
We share your information with trusted service providers who help us deliver our services, including:
- Payment processors (including Stripe) to handle transactions and detect fraud
- Analytics providers (including Google Analytics) to understand how our website is used
- Our bespoke CRM system to manage bookings and customer support
- Review platforms (potentially including Trustpilot) if you choose to leave a review
- Professional advisors including lawyers, accountants, auditors, and insurers
These providers are contractually obligated to protect your data and use it only for the purposes we specify.
Information shared with law enforcement or regulators
We may share your information with courts, regulators, government authorities, or law enforcement where we believe this is necessary to comply with legal obligations or to protect our rights or those of third parties.
Information shared in the event of business transfer
If LUMA is acquired or merged with another company, we may share your information with the acquiring party. We will notify you of any such change and ensure your data continues to be protected.
4. COOKIES AND SIMILAR TECHNOLOGIES
What are cookies?
Cookies are small text files that are placed on your device (computer, tablet, or mobile) when you visit a website. They are widely used to make websites work more efficiently and to provide information to the website owners.
How we use cookies
We use cookies and similar technologies to:
- Recognise you when you visit our website
- Remember your preferences and settings
- Understand how you use our website
- Improve your experience on our website
- Analyse website traffic and performance
- Deliver relevant content and advertising
Types of cookies we use
Cookie Type | Purpose |
Strictly Necessary | These cookies are essential for our website to function. They enable basic functions like page navigation and access to secure areas. The website cannot function properly without these cookies. |
Performance Cookies | These cookies collect information about how visitors use our website, such as which pages are visited most often. This helps us improve how our website works. |
Functionality Cookies | These cookies allow our website to remember choices you make (such as your preferences) and provide enhanced, more personal features. |
Analytics Cookies | We use Google Analytics to understand how visitors interact with our website. This helps us improve our services and user experience. Google Analytics uses cookies to collect information anonymously and report website trends. |
Third-party cookies
Some cookies are placed by third-party services that appear on our pages. We use:
Google Analytics — to analyse website usage and improve our services. For more information about how Google uses data, please visit: https://policies.google.com/technologies/partner-sites
Stripe — to process payments securely. Stripe may use cookies for fraud detection and security purposes. For more information, please visit: https://stripe.com/privacy
Managing cookies
Most web browsers allow you to control cookies through their settings. You can set your browser to:
- Block all cookies
- Block third-party cookies only
- Delete cookies when you close your browser
- Alert you when a website tries to place a cookie
To find out how to manage cookies on popular browsers:
- Google Chrome: https://support.google.com/chrome/answer/95647
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
- Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac
- Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
Please note: If you disable or refuse cookies, some parts of our website may become inaccessible or not function properly.
Opting out of Google Analytics
If you would like to opt out of Google Analytics tracking, you can install the Google Analytics Opt-out Browser Add-on available at: https://tools.google.com/dlpage/gaoptout
Changes to our cookie policy
We may update this cookie policy from time to time. Any changes will be posted on this page with an updated revision date.
5. INFORMATION SECURITY AND STORAGE
We implement technical and organisational measures to ensure your personal information is secure, including:
- Encryption of sensitive data
- Access controls and authentication
- Regular security reviews
- Secure data storage on UK-based servers
We evaluate these measures regularly to ensure they remain effective.
How long we keep your data
We will keep your personal information for as long as we have a relationship with you. Once our relationship ends, we will retain your personal information for a period that enables us to:
- Maintain business records for operational purposes
- Comply with PHV licensing requirements (minimum 1 year for journey records)
- Comply with other legal record retention requirements
- Defend or bring any existing or potential legal claims
- Deal with any complaints or disputes
We will delete your personal information when it is no longer required for these purposes. If there is information we are unable to delete entirely for technical reasons, we will put in place measures to prevent any further processing or use of the data.
6. INTERNATIONAL DATA TRANSFERS
LUMA operates exclusively in the United Kingdom and stores all data on UK-based servers. Your personal information is not transferred outside the UK.
7. YOUR RIGHTS OVER YOUR PERSONAL INFORMATION
You have the following rights regarding your personal information, subject to UK law:
Right to access — you can request a copy of the personal information we hold about you.
Right to rectification — you can ask us to correct inaccurate or incomplete information.
Right to erasure — you can request that we delete your personal information in certain circumstances.
Right to restrict processing — you can ask us to limit how we use your information.
Right to object — you can object to our processing of your information, particularly for marketing purposes.
Right to data portability — you can receive your personal information in a usable format to transfer to another service provider.
Right to withdraw consent — where we rely on your consent to process your data, you can withdraw that consent at any time.
Right to lodge a complaint — you can complain to the Information Commissioner’s Office (ICO) if you believe we have not handled your data properly.
Marketing communications
You can opt out of marketing communications at any time by:
- Following the unsubscribe link in any marketing email
- Contacting us directly using the details below
Deleting your account
You may request deletion of your account at any time by contacting us. Please note that you will not be able to delete your account if you have any outstanding payments or pending bookings.
8. CONTACT US
Luma Black Ltd (trading as LUMA) is the data controller responsible for the personal information we collect and process.
If you have questions or concerns about how your personal information has been used, please contact us:
Company Name: Luma Black Ltd (trading as LUMA)
Company number: 16834345
Email: concierge@luma.black
Phone: 0333 333 3333
Registered Office: 3rd Floor Suite, 207 Regent Street, London, W1B 3HH
We are committed to working with you to resolve any complaint or concern about privacy. If you believe we have not been able to assist with your concern, you have the right to make a complaint to the Information Commissioner’s Office (ICO) at https://ico.org.uk/
9. CHANGES TO THIS POLICY
We may modify or update this privacy policy from time to time to reflect changes in our practices or legal requirements.
If we make changes that will have a fundamental impact on the nature of our processing or that substantially affect you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (for example, to object to the processing).
You can request a copy of this privacy policy at any time by contacting us using the details above.