Lokhen House customer privacy notice
Registered name: Lokhen House Limited
We are the controller of your personal data.
For more information on controllers and their responsibilities please see our guidance on data protection principles, definitions, and key terms.
This privacy notice tells you what to expect us to do with your personal information.
· What information we collect, use, and why
· Lawful bases and data protection rights
· Where we get personal information from
· How long we keep information
· Who we share information with
· Sharing information outside the UK
Contact details
What information we collect, use, and why
We collect or use the following information to provide and improve products and services for clients:
· Names and contact details
· Transaction data (including details about payments to and from you and details of products and services you have purchased)
· Usage data (including information about how you interact with and use our website, products and services)
· Information relating to compliments or complaints
· Records of meetings and decisions
· Website user information
We collect or use the following personal information for information updates or marketing purposes:
· Names and contact details
We collect or use the following personal information to comply with legal requirements:
· Name
· Contact information
We collect or use the following personal information for dealing with queries, complaints or claims:
· Names and contact details
· Financial transaction information
Lawful bases and data protection rights
Under UK data protection law, we must have a “lawful basis” for collecting and using your personal information. There is a list of possible lawful bases in the UK GDPR. You can find out more about lawful bases on the ICO’s website.
Which lawful basis we rely on may affect your data protection rights which are set out in brief below. You can find out more about your data protection rights and the exemptions which may apply on the ICO’s website:
· Your right of access - You have the right to ask us for copies of your personal information. You can request other information such as details about where we get personal information from and who we share personal information with. There are some exemptions which means you may not receive all the information you ask for. Read more about the right of access.
· Your right to rectification - You have the right to ask us to correct or delete personal information you think is inaccurate or incomplete. Read more about the right to rectification.
· Your right to erasure - You have the right to ask us to delete your personal information. Read more about the right to erasure.
· Your right to restriction of processing - You have the right to ask us to limit how we can use your personal information. Read more about the right to restriction of processing.
· Your right to object to processing - You have the right to object to the processing of your personal data. Read more about the right to object to processing.
· Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you. Read more about the right to data portability.
· Your right to withdraw consent – When we use consent as our lawful basis you have the right to withdraw your consent at any time. Read more about the right to withdraw consent.
If you make a request, we must respond to you without undue delay and in any event within one month.
To make a data protection rights request, please contact us using the contact details at the top of this privacy notice.
Our lawful bases for the collection and use of your data
Our lawful bases for collecting or using personal information to provide and improve products and services for clients are:
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· We process limited personal information such as names, contact details and correspondence because it is necessary to understand enquiries, communicate with clients, and deliver or improve our professional services. This processing benefits both clients and our organisation by enabling clear communication, accurate record‑keeping, and effective service delivery. The information we use is minimal, non‑intrusive and provided directly by the individual, and we do not collect special category data. Our legitimate interest does not override people’s rights or freedoms, and the processing involved presents a very low risk to individuals.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Our lawful bases for collecting or using personal information for information updates or marketing purposes are:
· Consent - we have permission from you after we gave you all the relevant information. All of your data protection rights may apply, except the right to object. To be clear, you do have the right to withdraw your consent at any time.
Our lawful bases for collecting or using personal information to comply with legal requirements:
· Legal obligation – we have to collect or use your information so we can comply with the law. All of your data protection rights may apply, except the right to erasure, the right to object and the right to data portability.
Our lawful bases for collecting or using personal information for dealing with queries, complaints or claims are:
· Contract – we have to collect or use the information so we can enter into or carry out a contract with you. All of your data protection rights may apply except the right to object.
· Legitimate interests – we’re collecting or using your information because it benefits you, our organisation or someone else, without causing an undue risk of harm to anyone. All of your data protection rights may apply, except the right to portability. Our legitimate interests are:
· We process personal information such as names, contact details and correspondence so we can understand and respond to queries, complaints or claims raised by clients or other individuals. This processing is necessary to operate our business effectively, maintain accurate records, and resolve issues in a fair and timely manner. The information we use is minimal, directly provided by the individual, and handled in a way that presents very low risk. Our legitimate interest in managing and resolving queries or concerns does not override people’s rights or freedoms, and the processing involved is proportionate and expected in the context of professional services.
For more information on our use of legitimate interests as a lawful basis you can contact us using the contact details set out above.
Where we get personal information from
· Directly from you
· Publicly available sources
· Third parties:
· We may occasionally receive personal information from third parties when someone is copied into an email, introduced by a client or partner, or when contact details are shared as part of normal professional communication. This information is limited, incidental, and provided in the context of business correspondence. We do not receive personal information from formal third‑party sources or external data providers.
How long we keep information
We only keep personal information for as long as we need it. Different types of information are kept for different periods:
· Client work information (including contracts, deliverables, emails and project notes) is kept for 6 years. This is to meet our legal obligations and to respond to any contractual queries.
· Financial records (including invoices and payment information) are kept for 6 years to meet HMRC requirements.
· Enquiries and prospective client information (such as contact form submissions and emails) are kept for 12 months.
· Website analytics data is kept for 12 months.
· Legal or regulatory correspondence, if any, is kept for 6 years.
We delete or securely destroy information when we no longer need it.
We review our retention periods regularly to ensure they remain appropriate.
Who we share information with
Data processors
Website Hosting and form submission (Squarespace USA)
This data processor does the following activities for us: They host our website and process contact form submissions on our behalf, including storing and transmitting the information provided by individuals when they get in touch with us.
Online payment and invoicing provider - Stripe USA
This data processor does the following activities for us: They process payments and invoicing information on our behalf, including storing limited billing details and transmitting payment information securely.
Others we share personal information with
· Professional or legal advisors
· Organisations we’re legally obliged to share personal information with
· Third parties:
· Generic Accounting Provider - Cloud accounting and invoicing provider (various locations)., They process invoicing and billing information on our behalf, including storing client contact details, invoice records and payment status information.
Sharing information outside the UK
Where necessary, we may transfer personal information outside of the UK. When doing so, we comply with the UK GDPR, making sure appropriate safeguards are in place.
For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.
Organisation name: Microsoft
Category of recipient: Email infrastructure and storage
Country the personal information is sent to: USA
How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)
Organisation name: Stripe
Category of recipient: Online payment and invoicing provider
Country the personal information is sent to: USA
How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)
Organisation name: Generic Cloud Accounting and Invoice Provider
Category of recipient: Cloud accounting and invoicing provider (category)
Country the personal information is sent to: Various locations including USA
How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)
Where necessary, our data processors will share personal information outside of the UK. When doing so, they comply with the UK GDPR, making sure appropriate safeguards are in place.
For further information or to obtain a copy of the appropriate safeguard for any of the transfers below, please contact us using the contact information provided above.
Organisation name: Squarespace
Category of recipient: Website hosting and form submission provider
Country the personal information is sent to: USA
How the transfer complies with UK data protection law: Addendum to the EU Standard Contractual Clauses (SCCs)
How to complain
If you have any concerns about our use of your personal information, you can make a data protection complaint to us:
Email:hello@lokhenhouse.com
If you remain unhappy with how we’ve used your data after raising a complaint with us, you can also complain to the ICO.
The ICO’s address:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
Website: https://www.ico.org.uk/make-a-complaint