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Privacy Policy

Last updated: September 2026 — Lumio Pathways Ltd, Company No: 17255847

This is a working draft privacy policy. It will be reviewed by a qualified data protection practitioner before the platform launches. If you have questions about how we handle your data in the interim, please contact us at winifred@lumiopathways.co.uk.

Who we are

Lumio Pathways Ltd is a health technology company registered in England and Wales (Company No: 17255847) with its registered address in Manchester, United Kingdom. We are the data controller for personal data collected through this website and the Lumio Pathways platform.

We are registered with the Information Commissioner’s Office (ICO Registration: C2001425).

What data we collect

When you join our waitlist, we collect the following information:

When you use the Lumio Pathways platform (once launched), we will collect assessment responses, strengths and needs profile data and usage data. A full platform privacy policy will be published before launch.

How we use your data

We use the information you provide to:

We will never sell your data or share it with third parties for marketing purposes.

Legal basis for processing

We process your data on the basis of your consent, which you give when you join the waitlist. You can withdraw your consent and unsubscribe at any time by contacting us at winifred@lumiopathways.co.uk.

How long we keep your data

We will keep your waitlist data for up to 24 months from the date you join, or until you unsubscribe, whichever comes first.

Your rights

Under UK GDPR, you have the right to access, correct, delete or restrict the processing of your personal data. You also have the right to data portability and the right to object to processing. To exercise any of these rights, please contact us at winifred@lumiopathways.co.uk.

You also have the right to lodge a complaint with the ICO at ico.org.uk.

Cookies

This website does not currently use cookies or tracking technologies beyond those necessary to serve the website. We will update this policy before implementing any analytics or tracking.

Children’s data

Our platform is designed to be used by parents and carers on behalf of their children. We do not knowingly collect personal data directly from children. We are committed to full compliance with the UK Children’s Code (Age Appropriate Design Code).

Changes to this policy

We may update this policy as our platform develops. We will notify waitlist members of any material changes by email.

Questions about your data?

Contact our data controller directly at winifred@lumiopathways.co.uk
Lumio Pathways Ltd — Company No: 17255847 — ICO Registration: C2001425

© 2026 Lumio Pathways Ltd. All rights reserved.