Privacy Policy
Last updated:
This Privacy Policy explains how Holborn Wellness Ltd ("we", "us", "our"), registered in England and Wales (Company No. 09847312), of 74 Holborn Viaduct, London, EC1A 2FD, processes personal data collected through this website in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Information We Collect
We may collect the following categories of personal data:
- Contact form data: name, email address and message content when you submit our contact form.
- Order request data: name and telephone number submitted via our order form.
- Technical data: IP address, browser type, operating system, pages visited and time of visit, collected automatically via server logs and analytics cookies (subject to your consent).
- Cookie data: your cookie consent preferences stored in local storage.
2. How We Use Your Information
- To process and confirm your order by telephone and arrange delivery.
- To respond to enquiries submitted through the contact form.
- To comply with our legal obligations.
- With your consent: to measure website traffic (analytics) and to show relevant advertisements (marketing).
3. Legal Basis for Processing
We process your data under the following legal bases set out in Article 6 UK GDPR:
- Contract performance (Art. 6(1)(b)): processing your order request and arranging delivery.
- Legitimate interests (Art. 6(1)(f)): responding to general enquiries, basic website security.
- Legal obligation (Art. 6(1)(c)): retaining records as required by UK law.
- Consent (Art. 6(1)(a)): analytics and marketing cookies, where you have given consent via our cookie banner.
4. Sharing and Disclosure
We do not sell your personal data. We may share it with:
- Delivery couriers (name, address, phone) to fulfil your order.
- Google LLC for analytics and advertising services (see section 10).
- Regulators and law enforcement where we are legally required to do so.
5. Data Security
We use appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure or destruction, including HTTPS encryption and restricted staff access.
6. Your Rights
Under UK GDPR, you have the right to:
- Access the personal data we hold about you.
- Rectify inaccurate data.
- Request erasure ("right to be forgotten"), subject to legal retention requirements.
- Object to processing based on legitimate interests.
- Request restriction of processing.
- Data portability (where processing is automated and based on consent or contract).
- Withdraw consent at any time (without affecting prior processing).
- Lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or by post to Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
To exercise your rights, contact us at info@luminousboneclea.world.
7. International Data Transfers
Google LLC is based in the United States. Where your data is transferred outside the UK, we rely on adequacy decisions or Standard Contractual Clauses approved by the ICO to ensure an adequate level of protection.
8. Retention Periods
- Order and contact data: retained for up to 3 years for operational and legal purposes, then deleted.
- Analytics data: retained in accordance with Google Analytics default retention settings.
- Cookie consent records: retained for 12 months in your browser's local storage.
9. Children's Privacy
This website is not directed at children under the age of 18. We do not knowingly collect personal data from anyone under 18. If you believe we have inadvertently collected such data, please contact us and we will delete it promptly.
10. Third-Party Services
We use the following third-party services:
- Google Analytics (subject to your consent): measures site visits using cookies
_ga,_gid,_gat. Data is processed by Google LLC. See Google's Privacy Policy at policies.google.com. - Google Ads Conversion Tracking & Remarketing (subject to your consent): cookies
_gcl_au,_gcl_aw. We implement Consent Mode v2 to ensure signals are only transmitted with your consent. - Google Maps Embed API (Contact page): displays a map of our registered address. Your IP address is transmitted to Google when you view the map. No consent-dependent cookies are set by the embed itself.
11. Cookies
We use cookies as described in our Cookie Policy. You can manage your preferences at any time via the cookie settings button in the footer.
12. Policy Updates
We may update this policy from time to time. The "Last updated" date at the top of this page reflects the most recent revision. Significant changes will be notified via a banner on the site.
13. Contact
Data Controller: Holborn Wellness Ltd, 74 Holborn Viaduct, London, EC1A 2FD.
Email: info@luminousboneclea.world
Phone: +44 20 3947 8162