Governance & Compliance
Welcome to Lumina Strategies. By accessing and using our website, you agree to the following terms and conditions:
1. Use of Website
This website is intended for information about our services, resources, and events. You agree to use the site only for lawful purposes and in a way that does not infringe on the rights of others.
2. Intellectual Property
All content, logos, frameworks, and materials published on this site are the property of Lumina Strategies, unless otherwise credited. You may not reproduce, copy, or distribute materials without prior written consent.
3. Information Accuracy
While we aim to keep content accurate and up to date, Lumina Strategies makes no guarantees regarding completeness or reliability. Information provided is for general use and not professional advice.
4. Third-Party Links
Our site may contain links to external websites. We are not responsible for the content, practices, or policies of those sites.
5. Limitation of Liability
Lumina Strategies will not be liable for any direct, indirect, or consequential damages arising from use of our website, resources, or services accessed through it.
6. Service Availability
We reserve the right to update, suspend, or withdraw parts of the website or services without notice.
7. User-Generated Content
If interactive features (e.g. comments, forms) are introduced, users must not post unlawful, offensive, or misleading content. Lumina Strategies reserves the right to remove such material.
8. Payments and Refunds
- Payments for workshops, courses, or services booked via this website must be made in full at the time of booking.
- Unless otherwise stated in writing, all fees are non-refundable.
- If Lumina Strategies cancels an event or service, you will be offered a transfer to another date or a full refund.
9. Digital Products and Cooling-Off Period
- If we begin to offer digital downloads or online toolkits for purchase, UK law gives consumers a 14-day cooling-off period from the date of purchase.
- By downloading or accessing the digital product immediately, customers agree to waive their right to this cooling-off period.
- This does not affect statutory rights.
10. Governing Law
These Terms are governed by the laws of England and Wales. Any disputes will fall under the exclusive jurisdiction of the English courts.
11. Changes to Terms
We may update these Terms and Conditions at any time. The revised version will be published on this page.
12. Contact Us
For questions about these Terms, please contact us at: hello@luminastrategies.org
Lumina Strategies CIC is a community interest company registered in England & Wales and regulated by the CIC Regulator. We exist to deliver social impact alongside sustainable business practice. Our purpose is to develop people, drive strategy, and deliver growth, with profits reinvested into community benefit.
We are guided by our Articles of Association and Community Interest Statement, ensuring all activities align with our mission and values. Our governance is supported by directors and independent advisors. We are committed to diversity, equity, and inclusion in all our work.
Purpose
We want everyone connected with Lumina Strategies to feel confident raising concerns about serious wrongdoing. This policy explains how to do that safely and how we will respond.
What Counts as Whistleblowing?
- Fraud or misuse of funds
- Breach of law or regulation
- Harassment, discrimination, or unethical behaviour
- Attempts to conceal wrongdoing
This does not cover personal complaints, which should be addressed separately.
Our Promise
- Concerns raised in good faith will be taken seriously.
- All disclosures will be handled fairly, sensitively, and, wherever possible, confidentially.
How to Raise a Concern
- Email: hello@luminastrategies.org
- Post: Lumina Strategies CIC, 128 City Road, London, EC1V 2NX
External Reporting
If you prefer, you can go directly to:
- CIC Regulator
Review
We will review this policy each year to ensure it remains current and effective.
1. Purpose
We take complaints seriously. This policy explains how you can raise a concern with us and how we will respond.
2. Who It’s For
Anyone who engages with us – clients, partners, funders, collaborators, or the wider public – can use this process.
3. Our Principles
We aim to:
- Handle complaints fairly, respectfully, and consistently.
- Respond promptly, aiming for resolution and learning.
- Keep all complaints confidential and protect personal data under GDPR.
- Use feedback to strengthen our services and build trust.
4. How to File a Complaint
You can contact us via:
- Email: hello@luminastrategies.org
- Post: Lumina Strategies CIC, 128 City Road, London, EC1V 2NX
- Form: Website contact form
Include:
- Your name and contact details
- What your complaint is about
- When it happened
- What outcome you are seeking
5. What Happens Next
- Acknowledgement: Within 5 working days
- Response: Full reply within 28 working days
- Delays: If we need longer, we will explain why and give a new date
6. If You’re Not Satisfied
Ask for a review by a senior member of our team.
7. Accessibility
If you need this policy in another format – for example, large print or simplified English – please let us know.
8. Working Together
We ask that complainants are clear and constructive. In return, we commit to listen carefully, treat concerns respectfully, and act in good faith.
9. Continuous Improvement
- We log and review all complaints to identify themes.
- Findings are shared internally and used to strengthen our work.
- This policy is reviewed annually to stay aligned with best practice.
Data & Security
Lumina Strategies respects your privacy and is committed to protecting your personal data. This policy explains how we collect, use, and safeguard your information in line with UK GDPR and the Data Protection Act 2018.
1. Information We Collect
We may collect:
- Contact details when you book a call, sign up for newsletters, or attend an event (e.g. name, email, phone number).
- Organisation details if you register on behalf of a business or charity.
- Website usage data (via cookies, analytics, or similar tools).
2. How We Use Your Information
We process your data to:
- Deliver our services, workshops, and resources.
- Communicate with you (e.g. newsletters, updates, event invitations) – only where you have opted in.
- Improve our website, services, and user experience.
- Meet legal or regulatory obligations.
3. Sharing Your Information
- We do not sell your data.
- We may share data with trusted service providers (e.g. CRM, email platforms, hosting providers) under strict agreements.
- Data may be disclosed where required by law or regulation.
4. International Data Transfers
Some of our service providers may process or store data outside the UK. In these cases:
- We ensure that providers comply with UK GDPR standards through appropriate safeguards (such as Standard Contractual Clauses or UK adequacy regulations).
- By using our website and services, you acknowledge that your data may be transferred and processed internationally.
5. Data Retention
- Personal data is kept only as long as necessary for the purposes outlined above, or to comply with legal requirements.
- You can request deletion of your personal data at any time by contacting us.
6. Your Rights
Under UK GDPR you have the right to:
- Access, correct, or request deletion of your data.
- Withdraw consent to marketing at any time.
- Restrict or object to certain types of processing.
- Lodge a complaint with the Information Commissioner’s Office (ICO)
7. Cookies
Our website uses cookies for analytics and performance. You can manage or disable cookies through your browser settings. For more information, see our separate Cookie Policy.
8. Contact Us
For questions, or to exercise your data rights, contact us at: hello@luminastrategies.org
1. Purpose
This policy explains how long we keep different types of personal and business data, why we keep it, and when we securely delete it.
2. Principles
- We only keep data as long as it is needed for business, legal, or regulatory reasons.
- We minimise what we hold and review it annually.
- We delete or anonymise data once it is no longer required.
3. Retention Periods
- Client and project records: 6 years after the project ends (standard contract/tax requirement).
- Financial records: 6 years (HMRC requirement).
- Marketing data (e.g. newsletter sign-ups): until you unsubscribe or withdraw consent.
- Event registrations: up to 3 years, for reporting and learning.
- Supplier contracts: 6 years after the contract ends.
- Case studies/testimonials: held for up to 5 years, or until permission is withdrawn, whichever comes first.
- General enquiries: deleted within 12 months if no further engagement.
- Database backups: cleared on the same cycle as the original records.
4. Secure Storage and Deletion
- All data is stored securely using Google Workspace and other trusted platforms.
- When data reaches the end of its retention period, it is permanently deleted or anonymised.
- Backups are managed in line with these rules.
5. International Transfers
If data is transferred outside the UK or EEA (e.g. via Google), we rely on UK-approved safeguards such as Standard Contractual Clauses.
6. Your Rights
You can ask us to delete, correct, or update your data at any time. Contact us at hello@luminastrategies.org.
7. Annual Review
This policy and all retention periods are reviewed once a year by a director to ensure compliance and relevance.
1. Purpose
This policy sets out how Lumina Strategies protects its data, systems, and people from cyber threats. It applies to staff, associates, and contractors using our IT systems or handling our information.
2. Our Commitments
- Data protection – we comply with UK GDPR and handle all personal and business data responsibly.
- Secure access – all accounts are password protected and, where possible, use multi-factor authentication (MFA).
- Devices – laptops, mobiles, and other devices must be updated regularly and protected by antivirus software.
- Networks – staff must avoid using unsecured public Wi-Fi for sensitive work .
- Storage – all documents are stored securely in Google Workspace and access is controlled by role.
- Email security – staff are trained to recognise phishing, scams, and suspicious attachments.
- Software – only licensed and approved software is used.
3. Responsibilities
- Staff and associates must protect login details, follow good password hygiene, and report any issues.
- Management ensures systems are secure, updated, and risks are reviewed annually.
4. Breaches
Any suspected cyber breach (e.g. data loss, hacking, phishing) must be reported immediately to:
hello@luminastrategies.org
We will investigate within 5 days
5. Continuous Improvement
Cybersecurity threats evolve. We commit to annual reviews and ongoing improvements
6. Review
Last reviewed: January 2026
Environmental & Operational
At Lumina Strategies, we are committed to making our website accessible to the widest possible audience, regardless of technology or ability.
1. Our Commitment
We aim to ensure that our digital services are inclusive, meeting the requirements of the Equality Act and following recognised accessibility standards such as the Web Content Accessibility Guidelines .
2. Accessibility Features
Our website has been designed to include:
- Clear and consistent navigation.
- Text that can be resized using standard browser tools.
- Alt text for images where relevant.
3. Browser and Device Compatibility
We aim to ensure functionality across desktop, tablet, and mobile devices.
4. Requesting Alternative Formats
If you need information in a different format (large print, easy read, audio, Braille, or another format), please contact us at:
- hello@luminastrategies.org
- Lumina Strategies CIC, 128 City Road, London, EC1V 2NX
We aim to respond to all requests promptly and will provide alternative formats within 7 working days whenever possible.
5. Reporting Accessibility Problems
If you experience any issues or believe we are not meeting accessibility requirements, please let us know.
- hello@luminastrategies.org
6. Feedback and Contact for Support
We are continuously working to improve accessibility and welcome feedback if you encounter any issues.
7. Ongoing Efforts
Accessibility is an ongoing process. We will review and update this statement as we develop our website and services further.
Equity & Inclusion
At Lumina Strategies, we believe AI can enhance skills, sharpen thinking, and make work more efficient and effective – but it should always serve people, not replace them. AI is a tool, never a substitute for empathy, creativity, or human connection.
This policy explains the principles that guide how we use AI, so that our clients and partners can trust its value for the long term.
1. Our Commitments
- Human first: AI supports our work, but people make the final decisions.
- Ethical use: We use AI responsibly, in line with values of fairness, transparency, and respect.
- Data responsibility: We safeguard the data we use, following UK GDPR and avoiding unsafe or non-compliant tools.
- Accountability: We are open about the role AI plays in our work, and take responsibility for outcomes.
- Continuous learning: AI evolves quickly. We keep learning and updating our practices to reflect new guidance and risks.
- Human layer: Every AI-assisted output is reviewed and refined by people before it is shared.
2. Grounded in UK & Global Standards
We align with:
- UK Government’s AI Regulation White Paper (2023) – focusing on safety, transparency, fairness, accountability, and contestability.
- OECD AI Principles.
- Ongoing research from the Alan Turing Institute – Responsible AI.
4. Always Evolving
We know AI will keep changing. Our promise is to keep people at the heart of every decision while adapting responsibly to new technologies.
Financial & Assurance
At Lumina Strategies, transparency matters to us. From time to time, we may recommend tools, services, or platforms that we believe can add value. Some of these links may be “affiliate links,” which means we may earn a small commission if you choose to buy through them – at no extra cost to you.
What This Means for You
- We only recommend products and services we trust, use ourselves, or genuinely believe will be useful.
- An affiliate relationship will never affect what we recommend or how we work.
- You are always free to choose alternatives.
Why We Do This
- Affiliate links help support our work and allow us to provide free resources, toolkits, and learning content.
- They allow us to reinvest in developing people, driving strategy, and delivering growth.
Our Promise
- We will always make it clear when a link is an affiliate link – either with the word affiliate or ad next to it.
- Some affiliate programmes use cookies to track referrals; you can read more in our Cookie Policy.
Lumina Strategies CIC does not carry out public fundraising or solicit individual donations.
Our financial sustainability is built through:
- Grants and foundations that support social impact and leadership development.
- Corporate partnerships and CSR collaborations that align with our mission.
- Contracts and commissioned work with charities, SMEs, and boards.
All funding we accept is reviewed to ensure it reflects our values and contributes to our stated community interest objectives. We are committed to transparency and accountability in how funds are used and reported.
This statement is provided for clarity to partners, funders, and clients. It is not a substitute for our full CIC Governance Statement.
