Privacy Policy
Lightwork Holding Ltd
Company Number 15027977
83 Victoria Street, London, SW1H 0HW, United Kingdom
28 Jul, 2026
1.
Introduction
1.1
1.1
1.2
1.2
1.3
1.2
1.4
1.2
2.
Legal basis for data collection
2.1
2.1
“Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:
Profile/Identity Data: This is data relating to your first name, last name, gender, date of birth.
Contact Data: This is data relating to your phone number, addresses, email addresses, phone numbers.
Marketing and Communications Data: This is your preferences in receiving marketing information and other information from us.
Billing Data: This is information relating to your debit and credit card information such as the name attached to your payment details and your billing address.
Financial Data: These are your banking details e.g. your account number and sort code.
Transactional Data: This is information of details and records of all payments you have made for our services or products.
Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
Customer Support Data: This includes feedback and survey responses.
Usage Data: information about how you use our website, products and services.
We also collect and share Aggregated Data for analytics, research, and business reporting. Aggregated Data is information that has been combined with data from other users and de-identified so that it does not identify you or any individual. We use this data to understand usage patterns, measure performance, and generate statistical insights. When we share Aggregated Data with partners, service providers, or the public, it is presented in a summary form that cannot reasonably be used to identify you. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.
We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.
In our capacity as Data Controller (for example, for website visitors, marketing contacts, business contacts and account holders) we do not seek to collect Special Categories of Personal Data (such as race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, and genetic and biometric data) or information about criminal convictions and offences. Where we act as a Data Processor providing the Services on behalf of a customer (see section 1.3), the Services may incidentally receive Special Category data that individuals disclose through unstructured communications. We do not solicit such data, we apply access controls to it, and the customer (as Data Controller) is responsible for the Article 9 UK GDPR lawful basis, as set out in the applicable Data Processing Agreement.
2.2
2.2
There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:
“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
“Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.
Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
2.3
Cookies and Analytics
2.3
We use cookies and similar tracking technologies on our website and platform.
We use analytics cookies to collect information about how users interact with our website and Services. These cookies help us understand usage patterns, measure performance, and improve functionality.
The information collected may include IP address, browser type, device information, pages visited, and interaction data. This information is used in aggregated form and does not directly identify you.
Analytics cookies are not strictly necessary for the operation of the website. Where required under the Privacy and Electronic Communications Regulations 2003 (PECR), we obtain your consent before placing non-essential cookies on your device.
You can control or disable cookies through your browser settings. Disabling certain cookies may affect the functionality of the website.
3.
How We Use Your Personal Data
3.1
Our Data Uses
3.1
We will only use your Personal Data when the law allows us to.
Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.
Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.
3.1
Activity | Type of data | Legal Justification | Lawful basis for processing data |
|---|---|---|---|
When a customer creates an account, uses our services, makes a purchase, contacts support, or opts in to receive marketing communications. | Profile/Identity Data; Contact Data; Marketing and Communications Data; Billing Data; Financial Data; Transactional Data; Technical Data; Customer Support Data; Usage Data | Consent; Contractual Obligations; Legal Compliance; Legitimate Interest | We process Personal Data to perform our contract with you, including providing access to our services, managing accounts, processing payments, and delivering customer support. We process certain data to comply with legal obligations, including tax, accounting, and regulatory requirements. We rely on legitimate interests to operate, secure, and improve our services, prevent fraud, and communicate with customers about relevant updates. Where required by law, we rely on your consent, particularly for marketing communications and the use of certain cookies or tracking technologies. |
Using de-identified customer data to evaluate and improve the Services. We do not train or fine-tune AI models on customer data, including Google Workspace and Gmail data. | Transactional Data; Technical Data; Customer Support Data; Usage Data; Other Data | Contractual Obligations; Legitimate Interest | We use de-identified data to improve the functionality, accuracy, and performance of the Services. This processing is necessary for our legitimate interest in developing and maintaining high-quality services and is permitted under our Terms and Conditions and Data Processing Agreement. We have completed a legitimate interests assessment for this processing (our AI Evaluation and Product Improvement DPIA). |
Processing Personal Data received through tenant, contractor, landlord, or customer communications with the Services. | Profile/Identity Data; Contact Data; Transactional Data; Customer Support Data; Other Data | Contractual Obligations; Legitimate Interest | We process this data to deliver the Service, automate workflows, and facilitate property management communications. This processing is necessary to perform our contract with the customer and to operate the platform efficiently. |
Accessing and processing data from customer property management system integrations to provide the Services. | Profile/Identity Data; Contact Data; Financial Data; Transactional Data; Technical Data | Contractual Obligations; Legitimate Interest | We process this data to integrate with the customer’s systems and deliver the agreed functionality. This processing is necessary for contractual performance and for our legitimate interest in ensuring interoperability and automation. |
Monitoring system activity, detecting threats, and responding to security incidents. | Profile/Identity Data; Technical Data; Usage Data | Contractual Obligations; Legal Compliance; Legitimate Interest | We process certain data to protect our systems, prevent fraud, investigate incidents, and comply with legal obligations under applicable data protection laws. This supports our legitimate interest in maintaining secure services. |
Complying with tax, accounting, audit, and regulatory requirements. | Profile/Identity Data; Billing Data; Financial Data; Transactional Data | Contractual Obligations; Legal Compliance; Legitimate Interest | We process Personal Data where required to comply with applicable legal obligations, including tax, financial reporting, and regulatory compliance. |
Responding to data subject access requests, deletion requests, or regulatory enquiries. | Profile/Identity Data; Contact Data; Transactional Data; Usage Data | Contractual Obligations; Legal Compliance; Legitimate Interest | We process Personal Data to comply with obligations under the UK GDPR and Data Protection Act 2018, including fulfilling data subject rights and cooperating with supervisory authorities. |
3.2
Marketing and content updates
3.1
You will receive marketing and new content communications from us if you have created an account and chosen to opt into receiving those communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.
3.3
Change of purpose
3.1
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
3.4
How LightWork AI uses Google user data
3.1
When you connect a Google (Gmail or Google Workspace) account, LightWork AI accesses your Google data only to run the assistant: to read incoming email and reply from your mailbox, to label and mark messages read, and to read and manage your Google Calendar to show your schedule and to book, update or cancel appointments. Our use of data received from Google APIs follows the Google API Services User Data Policy, including the Limited Use requirements. We do not sell Google user data, use it for advertising, or use it to train AI models, and humans do not read it except with your consent, for security, or where the law requires. We do not use Google user data for the de-identified improvement analysis described in section 3.1.
3.5
Automated decision-making and profiling
3.1
The Services use artificial intelligence to process communications and to take certain actions automatically on behalf of our customers. We do not carry out automated decision-making that produces legal effects concerning you, or similarly significantly affects you, based solely on automated processing without meaningful human involvement. Where the Services act automatically on behalf of a customer, that customer, as Data Controller, determines and remains responsible for those actions and any associated decision-making. If our position changes, we will update this policy and provide the information required under Articles 13 and 14 UK GDPR.
4.
Your Rights and How You Are Protected By Us
4.1
Your legal rights
4.1
Under certain circumstances, you have the following rights under data protection laws in relation to your personal data
Right to be informed: You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.
Right of access: This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request"). See section 4.5 below for more details on how you can make a data subject access request.
Right to rectification: You have a right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Right to erasure: You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to object: You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right and it only applies in certain circumstances, for example:
a) Where we are processing your personal data for direct marketing purposes.
b) 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 ground as you feel it impacts on your fundamental rights and freedoms.
c) In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedomsRight to restrict processing: You have the right to request the restriction or suppression of their personal data. Note that this is not an absolute right and it only applies in certain circumstances.
a) If you want us to establish the data's accuracy.
b) Where our use of the data is unlawful but you do not want us to erase it.
c) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
d) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.Right to data portability: You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Right to withdraw consent. Where our processing of your personal data is based on your consent, you may withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
Right to complain. You have the right to lodge a complaint at any time with the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to address your concerns before you approach the ICO, so please contact us first.
If you wish to make a request under any of these rights, please contact us at contact@lightwork.co.
If you wish to make a request under any of these rights, please contact us at privacy@lightwork.co.Where we act as a Data Processor on behalf of a customer, we will assist the customer in responding to data subject requests in accordance with our Data Processing Agreement, but we may be required to redirect your request to the relevant customer as the Data Controller.
4.2
Your control over LightWork Holding Ltd’s use of your Personal Data
4.3
You may delete your account at any time – this will remove your account page from our systems and our related software. We will delete or anonymise Personal Data associated with your account in accordance with our retention policies and legal obligations.
You can access information associated with your account by logging into your account you created with us.
Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.
4.3
How LightWork Holding Ltd protects customers' Personal Data
4.3
We are concerned with keeping your data secure and protecting it from inappropriate disclosure. We implement a variety of security measures to ensure the security of your Personal Data on our systems, including:
encryption of data in transit using secure protocols;
encryption of sensitive data at rest;
access controls based on the principle of least privilege;
multi-factor authentication for administrative access;
regular security monitoring and vulnerability testing; and
the use of reputable cybersecurity software and infrastructure providers.
Our information security program aligns with ISO 27001 standards and the SOC 2 Trust Services Criteria. We maintain policies, procedures, and controls designed to meet the requirements of these frameworks.
We also restrict access to Personal Data to authorized personnel who require it for legitimate business purposes and require them to maintain confidentiality. Any Personal Data collected by us is only accessible by a limited number of employees who have special access rights to such systems and are bound by obligations of confidentiality. If and when we use subcontractors to store your data, we will not relinquish control of your Personal Data or expose it to security risks that would not have arisen had the data remained in our possession. However, unfortunately no transmission of data over the internet is guaranteed to be completely secure. It may be possible for third parties not under the control of LightWork Holding Ltd to intercept or access transmissions or private communications unlawfully. While we strive to protect your Personal Data, we cannot ensure or warrant the security of any Personal Data you transmit to us. Any such transmission is done at your own risk. If you believe that your interaction with us is no longer secure, please contact us.
4.4
Opting out of marketing promotions
4.3
You can ask us to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, we will continue to retain other Personal Data provided to us as a result of interactions with us not related to your marketing preferences.
4.5
How to request your data and the process for obtaining it
4.3
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, we could refuse to comply with your request.
We may need to request specific information from you to help us confirm your identity and ensure you have the 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.
5.
Your Data and Third Parties
5.1
Sharing your data with third parties
4.1
We may share non-Personal Data with third parties. We may share your Personal Data with the following categories of recipients, subject to confidentiality obligations and our instructions:
(a) cloud hosting and infrastructure providers;
(b) third-party AI and foundational-model providers;
(c) communications providers (email, SMS, messaging and telephony);
(d) analytics and security providers; and
(e) our professional advisers.
A current list of our sub-processors is available at www.lightwork.co/legal/security-measures-and-sub-processors.
We may also share Personal Data with interested parties in the event that LightWork Holding Ltd anticipates a change in control or the acquisition of all or part of our business or assets or with interested parties in connection with the licensing of our technology.
If LightWork Holding Ltd is sold or makes a sale or transfer, we may, in our sole discretion, transfer, sell or assign your Personal Data to a third party as part of or in connection with that transaction. Upon such transfer, the Privacy Policy of the acquiring entity may govern the further use of your Personal Data. In all other situations your data will still remain protected in accordance with this Privacy Policy (as amended from time to time).
We may share your Personal Data at any time if required for legal reasons or in order to enforce our terms or this Privacy Policy.
5.2
Third-Party Links
4.1
This Site 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 Site, we encourage you to read the privacy policy of every website you visit.
6.
How Long We Retain Your Data
4.1
We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, accounting, or reporting requirements.
When determining retention periods, we consider:
The nature, sensitivity, and volume of the Personal Data;
The purposes for which we process the data;
Legal and regulatory requirements;
The potential risk of harm from unauthorised use or disclosure.
Different types of Personal Data may be retained for different periods. We periodically review the data we hold and securely delete or anonymise Personal Data when it is no longer required.
In certain circumstances, we may retain Personal Data for longer periods where required for legal claims, regulatory investigations, or compliance with applicable law.
7.
International Transfer of Data
4.1
Your Personal Data may be transferred to and processed in countries outside the United Kingdom.
Where we transfer Personal Data outside the UK, we ensure appropriate safeguards are in place in accordance with UK GDPR requirements. These safeguards may include:
Transfers to countries recognised as providing adequate protection;
The use of UK International Data Transfer Agreements (IDTAs);
Standard Contractual Clauses approved by the UK Information Commissioner’s Office;
Implementation of appropriate supplementary technical and organisational measures.
All international transfers are conducted securely and lawfully. You can request a copy of the relevant safeguards, or information about where your Personal Data is transferred, by contacting us at privacy@lightwork.co.
8.
Notification of Changes and Acceptance Of Policy
4.1
We keep our Privacy Policy under review and will place any updates here. This version is dated 21 July 2026.
By using LightWork Holding Ltd, you acknowledge the collection and use of data by us as set out in this Privacy Policy. Continued access or use of LightWork Holding Ltd will constitute your express acceptance of any modifications to this Privacy Policy.
9.
Interpretation
8.1
All uses of the word "including" mean "including but not limited to" and the enumerated examples are not intended to in any way limit the term which they serve to illustrate. Any email addresses set out in this policy may be used solely for the purpose for which they are stated to be provided, and any unrelated correspondence will be ignored. Unless otherwise required by law, we reserve the right to not respond to emails, even if they relate to a legitimate subject matter for which we have provided an email address. You are more likely to get a reply if your request or question is polite, reasonable and there is no relatively obvious other way to deal with or answer your concern or question (e.g. FAQs, other areas of our website, etc.).
Our staff are not authorised to contract on behalf of LightWork Holding Ltd, waive rights or make representations (whether contractual or otherwise). If anything contained in an email from a LightWork Holding Ltd address contradicts anything in this policy, our terms or any official public announcement on our website, or is inconsistent with or amounts to a waiver of any LightWork Holding Ltd rights, the email content will be read down to grant precedence to the latter. The only exception to this is genuine correspondence expressed to be from the LightWork Holding Ltd legal department.
10.
Terms of Use
9.1
Please also see our Terms of Use (https://www.lightwork.co/legal/terms-and-conditions) which set out the terms, disclaimers, and limitations of liability governing your use of LightWork Holding Ltd.
11.
Contacting Us
11.1
If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at privacy@lightwork.co, or write to us at 83 Victoria Street, London, SW1H 0HW, United Kingdom.
