Privacy Policy

 

1. INTRODUCTION

This privacy notice provides you with details of how we collect and process your personal data through your use of our site https://lighthouse.online, and through your use of any product, operating system or AI service we provide, including LuminaryOS, LeverageOS and The Lighthouse Suite.

 

By providing us with your data, you warrant to us that you are over 13 years of age.

 

The Lighthouse [trading as Gemma Went Ltd] is the data controller and we are responsible for your personal data (referred to as "we", "us" or "our" in this privacy notice).

Contact Details

 

Full name of legal entity: Gemma Went Limited Email address: hello@lighthouse.online Postal address: Office 1, Izabella House 24-26 Regent Place, City Centre Birmingham B1 3NJ

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at hello@lighthouse.online.

2. WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE AND ON WHAT GROUND WE PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

  • Communication Data that includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

 

  • Customer Data that includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details and your card details. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

 

  • User Data that includes data about how you use our website, our operating systems and any online services together with any data that you post for publication on our website or through other online services. Within LuminaryOS, LeverageOS and The Lighthouse Suite, User Data also includes the answers, business information and inputs you provide to the system and the outputs it generates for you. We process this data to operate our website and services, to deliver the product you have purchased, to ensure the security of our systems, to maintain back-ups and to enable publication and administration of our services. Our lawful ground for this processing is the performance of our contract with you and our legitimate interests in properly administering our website, systems and business.

 

  • Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

 

  • Marketing Data that includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

 

We may use Customer Data, User Data, Technical Data and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business). [NOTE SEE SECTION 4 BELOW]

 

Sensitive Data

 

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.

 

We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.

 

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don't provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

 

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at hello@lighthouse.online. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

 

We may process your personal data without your knowledge or consent where this is required or permitted by law.

 

We do not carry out automated decision making that produces legal or similarly significant effects about you without human review. Where our operating systems generate outputs, categorisations or recommendations for you, these are tools to support your judgement, they are subject to human review as described in our AI Transparency page, and they do not make final decisions about you.

3. HOW WE COLLECT YOUR PERSONAL DATA

We may collect data about you by you providing the data directly to us (for example by filling in forms on our site, by sending us emails, or by entering information into our operating systems). We may automatically collect certain data from you as you use our website by using cookies and similar technologies.

 

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, search information providers such as Google based outside the EU, providers of technical, payment and delivery services, and data brokers or aggregators.

 

We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4. MARKETING COMMUNICATIONS

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

 

Under the Privacy and Electronic Communications Regulations, we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However you can still opt out of receiving marketing emails from us at any time.

 

Before we share your personal data with any third party for their own marketing purposes we will get your express consent.

 

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at hello@lighthouse.online at any time.

 

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

5. USE OF ARTIFICIAL INTELLIGENCE

We use AI tools, including third-party AI models, to help us deliver and operate our services. This section explains what that means for your data. Our fuller, plain-English account lives on our AI Transparency page.

 

We use AI to support content creation, research, analysis and internal productivity, and to power our operating systems, LuminaryOS and LeverageOS, and the AI team within them.

 

The principles we apply to your data and AI are:

 

  • We do not use your personal data, or your clients' data, to train AI models.
  • We apply data minimisation, processing only what the work genuinely requires.
  • We will not knowingly input sensitive or personally identifying client data into public AI tools without a clear legal basis and appropriate safeguards.
  • AI-supported outputs that reach you or the public are subject to human review before use.
  • Where we rely on third-party AI platforms to run our systems, those platforms process data under their own terms, and we select them with data protection in mind.

 

Where our systems make clear that you are interacting with AI, this is part of how we work to the transparency principles of the EU AI Act. We build to the Act's standards by design, while not representing our systems as formally certified or "compliant" under it, since compliance is assessed by reference to specific systems and use cases.

6. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below:

 

  • Other companies in our group who provide services to us.
  • Service providers who provide IT, hosting, database, AI and system administration services that are necessary to run our website and operating systems.
  • Professional advisers including lawyers, bankers, auditors and insurers.
  • Government bodies that require us to report processing activities.
  • Third parties to whom we sell, transfer, or merge parts of our business or our assets.

 

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

7. INTERNATIONAL TRANSFERS

Countries outside the UK and the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so transfers of personal data outside the UK and EEA are restricted unless the transfer meets certain criteria.

 

Some of our third-party service providers may be based, or process data, outside the UK and EEA. Where we transfer your personal data outside the UK and EEA, we do our best to ensure a similar degree of protection by ensuring at least one of the following safeguards is in place:

 

  • We will only transfer your personal data to countries that have been recognised as providing an adequate level of protection for personal data; or
  • Where we use certain service providers, we may use specific contracts, such as the UK International Data Transfer Agreement or the appropriate Standard Contractual Clauses, which give personal data the same protection it has in the UK and Europe.

 

Where possible, we choose infrastructure that keeps your operating-system data hosted within the EEA. If none of the above safeguards is available, we may request your explicit consent to the specific transfer, and you will have the right to withdraw that consent at any time.

8. DATA SECURITY

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. Within our operating systems, this includes measures such as encrypted connections, individual account authentication, and separation of each member's data so that it is accessible only to them. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions and they must keep it confidential.

 

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

9. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

 

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

 

Operating-system and AI-service data on leaving. Where you hold an account in one of our operating systems, your data is yours. Before you cancel or leave, you may export all of your data. Once you cancel, your data will then be removed from that operating system entirely, save only for records we are required by law to retain, such as the basic transaction records described above.

 

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

10. YOUR LEGAL RIGHTS

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

 

You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

 

If you wish to exercise any of the rights set out above, please email us at hello@lighthouse.online

 

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 if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

 

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

11. THIRD-PARTY LINKS

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

12. COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

 

Last Updated: July 2026