Privacy Policy

Last Updated: 03/10/2025

Background

LightWork Holding Limited understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of everyone who visits this website, www.lightwork.co (“Our Site”) and our product, app.lightwork.blue, and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of Our Privacy Policy is deemed to occur upon your first use of Our Site and You will be required to read and accept this Privacy Policy when signing up for an Account. If you do not accept and agree with this Privacy Policy, you must stop using Our Site immediately.

1. Definitions and Interpretation

In this Policy, the following terms shall have the following meanings:

Account

Means an account required to access and/or use certain areas and features of Our Site.

Cookie

Some of our Site pages utilise cookies and other tracking technologies. A cookie is a small text file that may be used, for example, to collect information about Site activity. Some cookies and other technologies may serve to recall Personal Information previously indicated by a Web user. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser, but please note that if you choose to erase or block your cookies, you will need to re‑enter your original user ID and password to gain access to certain parts of the Site. Our use of cookies and other tracking technologies allows us to improve our Site and web experience.

Cookie Law

Means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.

Personal Data

Means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Site. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 1998 and the EU Regulation 2016/679 – the General Data Protection Regulation (“GDPR”).

We/Us/Our

Means LightWork Holding Limited, a limited company registered in England under company number 15027977, whose registered address is 83 Victoria Street, London, SW1H 0HW (“LightWork AI”).

2. Information about Us

2.1 Our Site is owned and operated by LightWork Holding Limited, a limited company registered in England under company number 15027977, whose registered address is 83 Victoria Street, London, SW1H 0HW (“LightWork AI”).

2.2 Our VAT number is GB488579216.

2.3 Our Data Protection Officer (DPO) is currently James Wilson, and can be contacted by email at james@lightwork.co or by post at 83 Victoria Street, London, SW1H 0HW.

3. What does this policy cover?

3.1 This Privacy Policy applies only to your use of Our Site. Our Site may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

4. Your Rights

You have the following rights under the UK GDPR: to be informed; access; rectification; erasure; restriction; portability; objection; rights relating to automated decision-making and profiling lightwork.co.

Complaints: You may contact us (Section 14). You also have the right to complain to the Information Commissioner’s Office (ICO)lightwork.co.
How to exercise your rights: Email contact@lightwork.co or write to the address in Section 2. We will respond within 30 days of receiving your request (extendable in limited circumstances permitted by law).

* The right to be informed about Our collection and use of personal data;

* The right of access to the personal data We hold about you[1];

* The right to rectification if any personal data We hold about you is inaccurate or incomplete[2];

* The right to be forgotten (i.e. the right to ask Us to delete any personal data We hold about you)[3];

* The right to restrict processing (i.e. prevent Us from processing your personal data)[4];

* The right to data portability (obtaining a copy of your personal data to re‑use with another service or organisation)[5];

* The right to object to Us using your personal data for particular purposes[6]; and

* Rights with respect to automated decision making and profiling[7].

4.2 If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in section 14 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office[8].

4.3 For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.

Exercising Your Rights

4.4 To exercise any of the rights set out above, please contact our Data Protection Officer by email at contact@lightwork.blue or by post at the registered office set out in section 2. When making a request please provide sufficient information to identify yourself and the data to which your request relates. We will acknowledge receipt of your request promptly and respond within one month of receiving it, in accordance with applicable data protection laws. Where your request is particularly complex or you have made multiple requests, we may extend this period by up to two further months; we will inform you of any such extension.

4.5 If you are dissatisfied with the way we handle your request or believe we are not processing your data lawfully, you have the right to lodge a complaint with the Information Commissioner’s Office. More information is available at ico.org.uk.

5. What Data do We collect?

Depending upon your use of Our Site, We may collect some or all of the following personal and non‑personal data (please also see section 13 on Our use of Cookies and similar technologies:

* name;

* date of birth;

* gender;

* business/company name;

* job title;

* profession;

* contact information such as email addresses and telephone numbers;

* demographic information such as postcode, preferences, and interests;

* financial information such as credit/debit card numbers;

* IP address;

* web browser type and version; and

* operating system.

6. How do We use your data?

6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times. For more details on security see section 7, below[9].

6.2 Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes[10]:

* Providing and managing your Account;

* Providing and managing your access to Our Site;

* Personalising and tailoring your experience on Our Site;

* Supplying Our services to you, including facilitating property operations and logistics (please note that We require your personal data in order to enter

into a contract with you);

* Personalising and tailoring Our services for you;

* Replying to emails from you;

* Supplying you with emails that you have opted into (you may unsubscribe or opt‑out at any time by clicking on unsubscribe at the footer of the email);

* Market research; and

* Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.

6.2.10 Where we use external software tools to manage administrative tasks for contracts and service management including AI, we may input personal data and analyse resulting outputs for the purposes of improving output accuracy where applicable.

6.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email and/or telephone with information, news and offers on Our products and/or services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.

6.4 Third parties whose content appears on Our Site may use third party Cookies, as detailed below in section 13. Please refer to section 13 for more information on controlling Cookies. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties[11].

6.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it[12].

Data Retention and Deletion Policy

6.6 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected[13]. Data will therefore be retained for the following periods, after which it will be securely deleted or anonymised:

* Customer account data (including account details and billing information): retained for the duration of your active contract with Us and for up to 12 months after termination in order to comply with our contractual and legal obligations and to facilitate reactivation, then securely deleted or anonymised.

* Tenant/property data (including tenancy agreements, property details and tenant contact information): retained for the duration of the tenancy and for up to six years after the tenancy ends, to comply with statutory limitation periods under English law, after which it will be deleted or anonymised.

* Marketing data (including your preferences for receiving marketing communications): retained until you withdraw your consent or opt out of marketing communications, at which point the data will be deleted or anonymised without undue delay.

* Support data (including communications with our support team and tickets): retained for up to two years after the issue has been resolved to allow us to improve our services and resolve any follow‑up queries, then deleted or anonymised.

* Other personal data collected via Our Site will be retained for the minimum period necessary to fulfil the purposes described in this Policy and will be periodically reviewed and deleted or anonymised when no longer needed.

6.7 When establishing and/or reviewing retention periods, We take into account the objectives and requirements of the Company, the type of personal data in question, the purpose(s) for which the data is collected, held and processed, our legal basis for processing that data and the categories of data subjects to whom the data relates[14].

6.8 If a precise retention period cannot be fixed for a particular type of data, criteria shall be established by which the retention of the data will be determined, thereby ensuring that the data in question, and the retention of that data, can be regularly reviewed against those criteria[15].

6.9 Notwithstanding the defined retention periods above, certain personal data may be deleted or otherwise disposed of prior to the expiry of its defined retention period where a decision is made within the Company to do so (whether in response to a request by a data subject or otherwise)[16]. In limited circumstances, it may also be necessary to retain personal data for longer periods where such retention is for archiving purposes that are in the public interest, for scientific or historical research purposes, or for statistical purposes. All such retention will be subject to the implementation of appropriate technical and organisational measures to protect the rights and freedoms of data subjects, as required by the GDPR[17].

6.10 Once data is no longer required, it will be securely destroyed or anonymised in accordance with our data destruction procedures.

6.11 In order for us to provide you with the Services, your Data may be transferred into various Artificial Intelligence large language models and operating systems that are created by and operated by third parties (as more detailed in clause 8) and you understand and consent to such transfer and processing as is necessary for us to deliver you the Services.

7. How and where do We store your data?

7.1 We only keep your personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it[18].

Hosting and Data Residency

7.2 We use reputable cloud infrastructure providers with primary data centres located in the United Kingdom and the European Economic Area (EEA). Accordingly, your data will normally be stored and processed in the UK or within the EEA. These providers offer robust physical and logical security controls, and we monitor compliance with recognised standards. If at any time we use data centres located outside the UK/EEA, we will ensure that appropriate safeguards are in place.

7.3 Where data is transferred outside the UK or EEA, we will ensure that any such transfer complies with applicable data protection laws. This may include:

* entering into the UK International Data Transfer Agreement (IDTA) or its successor with the recipient;

* implementing the European Commission’s Standard Contractual Clauses (SCCs) for data transfers to countries that have not been deemed to provide an adequate level of data protection; and

* conducting transfer impact assessments and implementing additional technical or organisational measures to ensure that your data is afforded a level of protection essentially equivalent to that provided within the UK and EEA.

7.4 You are deemed to accept and agree to such transfers by using Our Site and submitting information to Us. We will always take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the GDPR, including ensuring that appropriate technical and organisational measures are in place[19].

7.5 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site[20]. 

Steps We take to secure and protect your data include

Technical Data Security Measures:

7.6.1 All emails containing Personal Data must be marked ‘confidential’; 

7.6.2 Where personal data is to be sent by facsimile transmission the recipient should be informed in advance and should be waiting to receive it[21]; 

7.6.3 Where Personal Data is to be transferred in hardcopy form, it should be passed directly to the recipient in accordance with this Policy[22];

7.6.4 All Personal Data transferred physically should be transferred in a suitable container marked “confidential”[23];

7.6.5 No Personal Data may be shared informally and if access is required to any Personal Data, such access should be formally requested from the DPO[24];

7.6.6 All hardcopies of Personal Data, along with any electronic copies stored on physical media should be stored securely[25];

7.6.7 No Personal Data may be transferred to any agents, or other third parties, whether such parties are working on behalf of the Company or not, without authorisation[26];

7.6.8 Personal Data must be handled with care at all times and should not be left unattended or on view[27];

7.6.9 Computers used to view Personal Data must always be locked before being left unattended[28];

7.6.10 No Personal Data should be transferred to any device personally belonging to an employee and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the Company’s Data Protection Policy and the GDPR[29];

7.6.11 All Personal Data stored electronically should be backed up regularly and stored securely[30];

7.6.12 All passwords used to protect Personal Data should be changed regularly and must be secure[31];

7.6.13 Under no circumstances should any passwords be written down or shared. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords[32];

7.6.14 All software should be kept up‑to‑date. Security-related updates should be installed as soon as reasonably possible after becoming available[33];

7.6.15 Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of the DPO to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third‑party service such as the TPS[34].

Organisational Data Security Measures:

7.7.1 All employees and other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under the GDPR and under the Company’s GDPR Policy[35];

7.7.2 Only employees and other parties working on behalf of the Company that need access to, and use of, personal data in order to perform their work shall have access to personal data held by the Company[36];

7.7.3 All employees and other parties working on behalf of the Company handling Personal Data will be appropriately trained to do so and supervised[37];

7.7.4 All employees and other parties working on behalf of the Company handling Personal Data should exercise care and caution when discussing any work relating to Personal Data at all times[38];

7.7.5 Methods of collecting, holding, and processing Personal Data shall be regularly evaluated and reviewed[39];

7.7.6 The performance of those employees and other parties working on behalf of the Company handling Personal Data shall be regularly evaluated and reviewed[40];

7.7.7 All employees and other parties working on behalf of the Company handling Personal Data will be bound by contract to comply with the GDPR and the Company’s GDPR Policy[41];

7.7.8 All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all relevant employees are held to the same conditions as those relevant employees of the Company arising out of the GDPR and the Company’s GDPR Policy[42];

7.7.9 Where any agent, contractor or other party working on behalf of the Company handling Personal Data fails in their obligations under the GDPR and/or the Company GDPR Policy, that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure[43].

8. Do We share your data?

8.1 In order to provide our integrated services to you, We may be required to share your data with the third parties listed in 6.4 of this Policy[44].

8.2 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal obligations, a court order, or a governmental authority[45].

8.3 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law[46].

8.4 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law[47].

8.5 We may sometimes use third party data processors that are located outside of the EEA. Where We transfer any personal data outside the UK or EEA, We will ensure that appropriate safeguards (such as the UK IDTA or EU Standard Contractual Clauses) are in place and that the data is treated as safely and securely as it would be within the UK and under the GDPR[48].

8.6 These data processors may include (but are not limited to): Xero, Microsoft, JIRA, Google and ChatGPT Enterprise[49]. We have the same measures in place as those listed under clause 7.6 of this policy to ensure that data is kept and held securely if stored or transferred for any reason.

8.7 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority[50].

8.8 In some circumstances we may share your data with a member of our group, which means any subsidiaries, ultimate holding company and its subsidiaries, who may offer similar products or products we believe may be of interest to you[51].

9. What happens if Our business changes hands?

9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us[52].

9.2 In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller[53].

10. How can you control your data?

10.1 In addition to your rights under the GDPR, set out in section 4, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt‑out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account)[54].

10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving[55].

11. Your right to withhold information

11.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data[56].

11.2 You may restrict Our use of Cookies. For more information, see section 13.

12. How can you access your data?

You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details by raising a ticket at support.lightwork.blue or using the contact details below in section 14[57].

13. Our use of Cookies

13.1 Our Site may place and access certain first‑party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our products and/or services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all timeslightwork.co.

13.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site as per the list below. For more details, please refer to section 6, above, and to the marketing below. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to themlightwork.co.

13.3 All Cookies used by and on Our Site are used in accordance with current Cookie Lawlightwork.co.

13.4 Before Cookies are placed on your computer or device, you will be shown a pop‑up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the opportunity to allow only first party Cookies and block third party Cookieslightwork.co.

13.5 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 13.7, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing themlightwork.co.

13.6 Our Site uses analytics services provided by Google Analytics. Website analytics, also referred to as statistics, refers to a set of tools used to collect and analyse anonymous usage information, enabling Us to better understand how Our Site is used. This, in turn, enables Us to improve Our Site and the products and/or services offered through it. You do not have to allow Us to use these Cookies, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for youlightwork.co.

13.7 In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third‑party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your devicelightwork.co.

13.8 You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settingslightwork.co.

13.9 It is recommended that you keep your internet browser and operating system up‑to‑date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settingslightwork.co.

13.10 Cookie governance & compliance. We use dedicated cookie management software to maintain an up‑to‑date inventory of all cookies on our Site and to record your consent preferences. Under applicable data‑protection laws, failing to keep the cookie banner up to date or obtaining consent for non‑essential cookies can attract significant fines of up to 4 % of total global turnover or £20 million (whichever is smaller).

13.11  Cookie categories. Cookies used on our Site fall into four categories:

* Necessary (strictly necessary) Cookies: Essential for core site functionality such as session management and authentication.
* Performance (analytics) Cookies: Collect anonymous data about how users interact with the site so we can improve its performance and user experience.
* Functional (preference) Cookies: Remember choices such as language, region or currency to tailor the site for you.
* Marketing (targeting) Cookies: Used by advertising networks to track your browsing across different sites and deliver personalised ads.

13.12 Session vs persistent cookies. Session cookies exist only while your browser remains open and are deleted when you close it. Persistent cookies remain on your device for a specified period (see table below) to remember your preferences across visits.

13.13 Cookies we use. The following table lists the cookies currently active on Our Site. Our cookie management software updates this list automatically; the set of cookies and their durations may change over time.