Privacy Policy

LUNA (“we”, “our” or “us”) is committed to protecting your personal information and respecting your privacy.

This Privacy Policy explains how we collect, use and protect your personal information when you interact with us, whether as a resident, prospective customer, partner, supplier or website visitor.

We take our responsibilities under UK data protection law, including the UK GDPR and Data Protection Act 2018, seriously. Your personal information will always be handled securely, fairly and transparently.

What is personal information?

Personal information means any information that relates to an identified or identifiable individual. This could include your name, contact details, identification information, online identifiers or any other information that can be linked to you.

The data we collect

We may collect and process the following types of personal information:

Contact details
Your name, address, email address, phone number and other contact information.

Booking and account information
Details relating to your booking, tenancy, payments, guarantor information and correspondence with us.

Identity and verification data
Identification documents, right to rent checks and other verification information where required.

Financial information
Payment details, bank information and transaction history where relevant.

Communication data
Emails, call recordings and messages between you and our team.

Usage and technical data
Information about how you use our website, including IP address, browser type and device data.

Safety and security data
CCTV footage, building access records and incident reports where applicable.

Sanctions compliance
As part of our legal obligations, we may carry out checks against UK sanctions lists, including OFSI, for tenants and guarantors, particularly where international payments are involved.

We only collect information that is necessary for the purposes set out in this policy.

Special category data

In limited circumstances, we may process sensitive personal information, such as health or accessibility requirements, where this is necessary to support your needs or comply with legal obligations.

This information is handled with additional care and only where there is a lawful basis to do so.

How we collect your data

We collect personal information in a number of ways:

Directly from you when you make an enquiry, booking or complete a form
Through your interactions with our website or systems
From third parties such as agents, partners, credit reference agencies or regulatory bodies
Through security systems such as CCTV and access control systems, where permitted by law

Where information is required to fulfil a contract or legal obligation, we will make this clear. If you choose not to provide certain information, we may not be able to provide our services.

How we use your data

We use your personal information to:

Manage bookings, tenancies and payments
Communicate with you and provide customer support
Verify your identity and carry out necessary checks
Maintain the safety and security of our buildings and residents
Improve our services, website and user experience
Meet our legal and regulatory obligations
Manage our business operations and reporting
Promote our services where you have consented or where permitted by law

Lawful basis for processing

We process your personal information under one or more of the following lawful bases:

Contract
Where processing is necessary to provide our services to you.

Legal obligation
Where we are required to comply with legal or regulatory requirements.

Legitimate interests
Where processing is necessary for our legitimate business interests, provided these do not override your rights.

Consent
Where you have given clear permission for us to process your data for a specific purpose.

Sharing your data

We may share your personal information with trusted third parties where necessary, including:

Payment providers and financial institutions
IT systems and service providers
Professional advisers such as legal and audit firms
Regulatory authorities and government bodies
Property management and operational partners

All third parties are required to handle your data securely and in line with applicable data protection laws.

International transfers

Where personal information is transferred outside of the UK, we ensure appropriate safeguards are in place, such as approved contractual clauses, to protect your data.

Data retention

We only keep your personal information for as long as necessary for the purposes it was collected, including to meet legal, accounting or reporting requirements.

Retention periods may vary depending on the type of data and our legal obligations.

Keeping your data secure

We have appropriate technical and organisational measures in place to protect your personal information from unauthorised access, loss or misuse.

Your rights

You have the following rights under data protection law:

The right to access your personal information
The right to correct inaccurate or incomplete data
The right to request deletion of your data
The right to restrict or object to processing
The right to data portability
The right to withdraw consent at any time

You also have the right to lodge a complaint with the Information Commissioner’s Office if you believe your data has been handled incorrectly.

Contact us

If you have any questions about this Privacy Policy or how we handle your data, please contact us via our website.

Updates to this policy

We may update this Privacy Policy from time to time to reflect changes in legislation or how we operate. Please check back regularly to stay informed.