Privacy Policy
We take your privacy seriously. This policy explains what personal information The Luminari Club collects, how we use it, who we share it with, and the rights you have over it.
1. Who we are
The Luminari Club is a trading name of Luminari Travel Ltd, a company registered in England and Wales (company number 17254177), with its registered office at 24 Haines House, 10 Charles Clowes Walk, London SW11 7AH, United Kingdom ("we", "us", "our").
For the purposes of the UK GDPR and the Data Protection Act 2018, Luminari Travel Ltd is the data controller responsible for your personal information. You can reach us at contact@luminariclub.com.
When we arrange travel for you, your booking is made through Simplexity Travel Management Ltd, of which we are an independent travel consultant. Simplexity acts as a separate data controller for the information needed to fulfil and protect your booking. See our Financial protection page.
2. What information we collect
Information you give us
When you apply for membership, complete your Guest Passport, contact your concierge or otherwise interact with us, we collect information such as: your name and title; contact details (email and telephone); the people in your household who travel with you; your travel preferences and the small things that matter to your stays; occasions and dates; loyalty programme memberships; and the content of your messages to us.
Special category information
To look after you well, you may choose to share information that data protection law treats as more sensitive, for example dietary needs, accessibility or mobility requirements, or health-related preferences relevant to a stay. We only collect this where you provide it, use it solely to arrange and personalise your travel, and rely on your explicit consent to do so. You can withdraw that consent at any time.
Information we collect automatically
When you use our websites we collect limited technical information using our own first-party, privacy-friendly analytics, such as pages viewed and approximate, non-identifying usage patterns. We do not use third-party advertising or cross-site tracking. See Cookies below.
Information from others
If you were introduced by an existing member or a partner, we may receive your name and contact details from them. If you give us information about another person (for example a fellow traveller), you confirm you have their permission to do so.
3. How we use your information
- To consider your membership application and manage your membership.
- To build and maintain your Guest Passport so hotels are briefed before you arrive.
- To arrange, coordinate and support your travel through Simplexity and the relevant suppliers.
- To communicate with you, including your concierge correspondence and service messages.
- To send you our members' newsletter and recommendations, where you have not opted out.
- To improve our service, keep our systems secure, and prevent fraud.
- To meet our legal and regulatory obligations.
4. Our legal bases for using your information
We rely on the following legal bases under the UK GDPR:
- Contract, to manage your membership and arrange the travel you ask us to.
- Consent, for any special category information you choose to share, and for email marketing where consent is required. You can withdraw consent at any time.
- Legitimate interests, to run and improve the club, keep members informed, and protect our service, balanced against your rights.
- Legal obligation, where we must keep records or respond to lawful requests.
5. Who we share your information with
We share your information only where needed to look after you, and never sell, rent or trade it. We may share it with:
- Simplexity Travel Management Ltd, through whom your bookings are made and financially protected.
- Travel suppliers such as hotels, airlines and transfer providers, so they can deliver and prepare for your stay.
- Our service providers, for example secure hosting, database and email infrastructure, who act on our instructions under data processing terms.
- Authorities or advisers, where we are required to by law or to establish or defend legal rights.
6. International transfers
Your information is primarily held in the UK and the European Economic Area. Because travel is global, we may need to pass your information to suppliers outside the UK or EEA so you can enjoy what you have booked, for example a hotel in your destination. Where we transfer personal data to a country without a UK adequacy decision, we use appropriate safeguards such as the UK International Data Transfer Agreement or Standard Contractual Clauses.
7. How long we keep your information
We keep your information only for as long as we need it. While you are a member we keep your Guest Passport so we do not have to ask you the same things twice. If you leave the club or ask us to erase your data, we delete or anonymise it, except where we must keep certain records (for example booking and financial records, typically for up to seven years to meet UK tax and legal requirements).
8. Keeping your information secure
We apply appropriate technical and organisational measures to protect your information, including encryption in transit, access controls and least-privilege access to our systems. No transmission over the internet is ever completely secure, but we work to protect your information and to limit who can see it.
9. Your rights
Under UK data protection law you have the right to: access a copy of your information; correct it if it is wrong; ask us to erase it; restrict or object to how we use it; receive it in a portable format; and withdraw consent where we rely on it. You can also ask us to stop sending you marketing at any time.
To exercise any of these, email contact@luminariclub.com. Members can also update much of their information, or request deletion, directly in the Members Zone. We will respond within one month.
10. Cookies
We keep cookies to a minimum. Our analytics are first-party and privacy-friendly, and do not track you across other websites, so we do not show an intrusive cookie banner. For detail, see our Cookie notice.
11. Children
Membership and our services are intended for adults. We do not knowingly collect information from anyone under 18 except details of children travelling within a member's household, which a responsible adult provides on their behalf.
12. Changes to this policy
We may update this policy from time to time. We will change the date at the top, and where changes are significant we will let members know.
13. Contact and complaints
If you have any question about this policy or your information, please contact us at contact@luminariclub.com or write to Luminari Travel Ltd, 24 Haines House, 10 Charles Clowes Walk, London SW11 7AH.
If you are not satisfied, you have the right to complain to the Information Commissioner's Office (ICO), Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, telephone 0303 123 1113, ico.org.uk. We would, though, appreciate the chance to put things right first.