Privacy Policy

enlighten – Privacy Policy

 


We are enlighten (referred to as we, us and our in this Privacy Policy), a company incorporated in England and Wales under company name Nolton Limited, company registration number 1337289 and whose registered office address is 27 Old Gloucester Street, London, England, WC1N 3AX.

The information set out in this Privacy Policy is provided to individuals whose personal data we process (you or your) as data controller, in compliance with our obligations under the Data Protection Act 2018 and the UK GDPR (as defined in the as defined in the Data Protection, Privacy and Electronic Communications Privacy and Electronic Communications (Amendments etc) (EU Exit) Regulations SI 2019/419) (GDPR). 

This Privacy Policy includes:

1.    Data controller details

2.    How we collect your information

3.    Information we collect and purpose for processing

4.    Sharing your information

5.    International transfers

6.    Retention of personal data

7.    Your rights in respect of your personal data

8.    Automatic decision making

9.    Security

10.  Changes to this Privacy Policy

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1.           Data controller details

1.1              We are the data controller in relation to the processing of the personal information that you provide to us. Our contact details are as follows:

1.1.1             Address: 27 Old Gloucester Street, London, England, WC1N 3AX.

1.1.2             Email address: hello@enlighten-me.co.uk (please include “Personal Data Request” in your subject heading to ensure it receives the correct attention).

2.          How we collect your information

2.1              We provide provides services and content via our site (including any website or any web applications, mobile applications or similar devices, channels, platforms, service applications, or other applications operated by or on behalf of us (site)) to provide assistance and guidance to individuals going through a divorce or other family-related proceedings (Proceedings). How we collect your information will depend on the relationship we have with you, as further set out below.

Clients and visitors of our site

2.2              If you are a visitor of our site or a user of our services and/or online content via our site (Client), generally, the information we hold about you comes from the way that you engage with us, for example by doing any of the following:

2.2.1             through engaging with us or accessing services/content via our site;

2.2.2             providing us with information in the course of registering with us or any newsletters we may operate from time to time, or uploading information or content to your account;

2.2.3             contacting us offline, for example by telephone, SMS, email or by post; and/or

2.2.4             interacting with us using social media.  

         Proxy Users

2.3              In the course of using our site and services, our Clients may upload or input information via our site in connection with the Proceedings, including as part of the litigation process. This may include personal data of or about “Proxy Users” including individuals such as:

2.3.1             ex-partners, children, family members or other individuals with a significant relationship to the Client; and

2.3.2             professionals engaged by our Clients or other parties to the Proceedings such as solicitors, barristers, accountants and/or other relevant consultants advisers and suppliers.

Suppliers

2.4              Where we engage suppliers in connection with our business (Suppliers), we may obtain information about you in the course of carrying out due diligence, entering into negotiations and liaising with you in connection with our contractual arrangements. This information will usually be obtained directly from or by you, however, we may also obtain information from publicly available sources including public databases, registers and records (such as Companies House).

3.          Information we collect and purpose for processing

3.1              The types of personal data that we may collect, use, store and transfer about you will depend on the relationship we have with you (i.e. whether you are a Client or visitor or our site, Proxy User or Supplier). We have set out below the types of information collected together with the purpose and legal grounds for processing.

3.2              Please note that Special Categories of Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.

Clients

Personal data

We may use your information for the following purposes, based on the following legal grounds:

·       Contact details such as your name, home/work addresses, email address or landline/mobile phone numbers.

·       Date of birth

·       If it is necessary for the performance of our contract or for the purposes of entering into a contract: for the purpose of registering your account with us and to create your individual customer profile and/or in connection with the provision of our services and content to you e.g. by auto-filling data into forms and letters where necessary.

·       If it is in our legitimate business interests to do so: for internal record keeping for administration purposes, in order to verify your account, to communicate with you regarding our service and fees (e.g. re any changes to our website or services); for dealing with any complaints or issues raised by you; for insight purposes (e.g. to analyse market trends and demographics, to develop the service which we offer to you or other individuals in the future) and to send information to you about products and services which we think may be of interest to you for marketing purposes. You may at any time unsubscribe from receiving marketing communications from us (see further below).

·       Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.

·       Payment information such as bank details.

·       If it is necessary for the performance of our contract:for the purpose of issuing/receiving payments in connection with your account and in the course of providing our services and content to you.

·       If it is in our legitimate business interests to do so: for internal record keeping for administration purposes, for the purpose of retaining evidence of payment transactions, for insight purposes (e.g. to analyse market trends and demographics in relation to our fees and to develop the service which we offer to you or other individuals in the future).

·       Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other relevant legal or regulatory requirements.

Information relating to or uploaded as part of the Proceedings which may include:

·       In addition to the information listed above, copies of passports/ID information, occupation, nationality, payment information and bank details.

·       Personal data submitted via Form E.

·       Special categories of personal data including racial/ethnic origin, details about sexual orientation/sex life, genetic data, medical details, religious beliefs and political opinions.

·       Criminal convictions data including details of allegations, convictions etc.  

·       If it is necessary for the performance of our contract: in the course of providing services to you, we may process information that is submitted to the digital platform and/or uploaded to our site and as part of the Proceedings. 

·       Special categories of personal data (Article 9(2)(f) GDPR): your special category data may be processed via our site in connection with the Proceedings (e.g. as part of evidence, declarations or witness statements), where necessary for the establishment, exercise or defence of legal claims. Note that certain types of special category data, e.g. sexual orientation, may not be explicitly stated anywhere, but may be implied and discerned due to the nature of the litigation and the individuals involved. 

·       Criminal convictions data (S.33, Schedule 1, Data Protection Act 2018): details of your criminal convictions history or allegations made against you may be processed via our site in connection with the Proceedings (e.g. as part of evidence, declarations or witness statements), for the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings), for the purpose of obtaining legal advice or as otherwise necessary for the purposes or establishing, exercising or defending legal rights.

Proxy Users (including ex-partners, children, family members or other individuals with a significant relationship to our Client)

Personal data

We may use your information for the following purposes, based on the following legal grounds:

Information relating to or uploaded as part of the Proceedings which may include:

·       Contact details such as your name, home/work addresses, email address or landline/mobile phone numbers.

·       Employment informationsuch as your position/title, employment history, professional specialisms and qualifications.

·       Copies of passports/ID information, occupation, nationality, payment information and bank details.

·       Personal data submitted via Form E.

·       Special categories of personal data including racial/ethnic origin, details about sexual orientation/sex life, genetic data, medical details, religious beliefs and political opinions.

·       Criminal convictions data including details of allegations, convictions etc.  

·       If it is necessary for the performance of our contract: in the course of providing services to our Client, we may process information about you that is submitted to the digital platform and/or uploaded to our site and as part of the Proceedings. 

·       Special categories of personal data (Article 9(2)(f) GDPR): your special category data may be uploaded to and/or processed via our site in connection with the Proceedings (e.g. as part of evidence, declarations or witness statements), where necessary for the establishment, exercise or defence of legal claims. Note that certain types of special category data, e.g. sexual orientation, may not be explicitly stated anywhere, but may be implied and discerned due to the nature of the litigation and the individuals involved. 

Criminal convictions data (S.33, Schedule 1, Data Protection Act 2018): details of your criminal convictions history or allegations made against you may be uploaded to and/or processed via our site in connection with the Proceedings (e.g. as part of evidence, declarations or witness statements), for the purpose of, or in connection with, any legal proceedings (including prospective legal proceedings), for the purpose of obtaining legal advice or as otherwise necessary for the purposes or establishing, exercising or defending legal rights.

Proxy Users (including professionals engaged by our Client or other parties to the Proceedings such as solicitors, barristers, accountants and/or other relevant consultants advisers and suppliers)

Personal data

We may use your information for the following purposes, based on the following legal grounds:

·       Contact details such as your name, home/work addresses, email address, landline/mobile phone or fax numbers.

·       Employment informationsuch as your position/title, employment history, professional specialisms and qualifications.

·       If it is necessary for the performance of our contract: your information may be uploaded to and/or processed via our site in the course of providing services to our Client and as part of the Proceedings. 

·       If it is in our legitimate business interests to do so: for internal record keeping for administration purposes.

 

Suppliers

Personal data

We may use your information for the following purposes, based on the following legal grounds:

·       Contact details such as your name, home/work addresses, email address, landline/mobile phone or fax numbers.

·       Employment informationsuch as your position/title, employment history, professional specialisms and qualifications.

·       If it is necessary for the performance of our contract or for the purposes of entering into a contract: for the purpose of negotiating and entering into contractual agreements with you, in the course of receiving services from you e.g. contacting individuals where we need to do so to provide instructions and discuss work involved.

·       If it is in our legitimate business interests to do so: for internal record keeping for administration purposes, for the purpose of communications in relation to establishing a supplier relationship, obtaining evidence of identity of our suppliers, communications regarding the service and fees.

·       Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.

·       Payment information such as bank details and transaction history.

·       If it is necessary for the performance of our contract: for the purpose of making or receiving payments in the course of receiving services.

·       If it is in our legitimate business interests to do so: for the purpose of enquiring, requesting or purchasing goods or services, for internal record keeping for administration purposes, for the purpose of retaining evidence of payment transactions and for insight purposes (e.g. to analyse market trends and demographics in relation to our suppliers’ fees).

·       Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.

·       Identification informationcontained in or provided to us as part of our supplier ID checks. This includes details included in copy personal photo and residential ID documents we receive. 

·       Compliance with a legal obligation: in order to prevent fraud or money laundering or to comply with any other legal or regulatory requirements.

Visitors of our site

Personal data

We may use your information for the following purposes, based on the following legal grounds:

·       Technical and device information/ social networks

·       If it is in our legitimate business interests to do so: we may use certain technical log data (such as your IP address) for research or statistical purposes; to analyse user traffic and for ensuring the proper administration of our site; for analytics and insight purposes e.g. to monitor market trends and demographics and to improve the user experience within our site; and to ensure that content from our site is presented in the most effective manner for you and for your computer or other device from which you access our site and/or the services we offer through the site.

·       Cookies (and other web-tracking technology)

·       We may use “cookies” and other anonymous web tracking technologies (such as “web beacon” and “pixel tags”) implemented by us or by third party service providers. A cookie is a small file of letters and numbers that is sent to your device when you visit our site, allowing our site to recognise your browser if you revisit it. Cookies may store your online preferences and other information about the interaction you make in the site.

·       Where we collect “essential” cookies we will rely on the legitimate interest ground. We will only collect and process “non-essential” cookies where your consent has been obtained. Please refer to our Cookie Policy [INSERT HYPERLINK] for more information about the type of cookies used and how we use cookies/tracking technologies within our site.


4.          Sharing your information

4.1              Please note that personal information we are holding about you may be shared with and processed by:

4.1.1             any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;

4.1.2             the relevant court, Client and/or Proxy Users involved in connection with the Proceedings;

4.1.3             regulators, fraud prevention agencies or other third parties for the purposes of monitoring and/or enforcing our compliance with any legal and regulatory obligations, including statutory or regulatory reporting or the detection or prevention of unlawful acts;

4.1.4             any third party in the context of actual or threatened legal proceedings against us, provided we can do so lawfully (for example in response to a court order);

4.1.5             other parties and/or their professional advisers involved in a matter where required as part of the conduct of the services; 

4.1.6             our own professional advisers and auditors (e.g. accountants, solicitors and consultants) for the purpose of seeking professional advice or to meet our audit responsibilities;

4.1.7             our service providers and agents (including their subcontractors) or third parties which process information on our behalf (e.g. internet service and data/cloud storage and security platform providers (including Amazon Web Services), our bank, payment processing providers and those organisations we engage to help us send communications to you) so that they may help us to provide you with the applications, products, services and information you have requested; and

4.1.8             another organisation to whom we may transfer our agreement with you or if we sell or buy (or negotiate to sell or buy) our business or any of our assets (provided that adequate protections and safeguards are in place).

4.2              Please note that we may include links within our site to third party social media providers such as Facebook and Twitter, but we will not share your information with such providers without your consent.

5.          International transfers

We will not transfer personal data relating to you to a country which is outside the UK unless:

5.1              the country or recipient is covered by an adequacy decision of the Commission under GDPR Article 45;

5.2              appropriate safeguards have been put in place which meet the requirements of GDPR Article 46 (for example using the approved Standard Model Clauses for transfers of personal data outside the UK); or

5.3              one of the derogations for specific situations under GDPR Article 49 is applicable to the transfer.  These include (in summary):

5.3.1             the transfer is necessary to perform, or to form, a contract to which we are a party:

5.3.1.1           with you; or

5.3.1.2           with a third party where the contract is in your interests;

5.3.2             the transfer is necessary for the establishment, exercise or defence of legal claims;

5.3.3             you have provided your explicit consent to the transfer; or

5.3.4             the transfer is of a limited nature, and is necessary for the purpose of our compelling legitimate interests.

6.          Retention of personal data

6.1              Unless we are required or permitted by law to hold on to your data for a specific retention period, we will hold your personal information within our systems for the following periods:

6.1.1             Clients: For the duration you hold an account with us, plus 6 years following closure of your account. If you have not logged into your account for a period of more than 12 months, we will email you to ask if you wish to close your account and upon confirmation by you, we will close your account (following which you will no longer be able to access or reopen the account).

6.1.2             Proxy Users: For the duration of the relevant Client’s account with us, plus 6 years following closure of that account.

6.1.3             Suppliers: For the duration of the relevant contractual arrangement between us, plus 6 years following the end of that arrangement.   

6.2              Where we no longer need your personal information, we will dispose of it in a secure manner.

6.3              In some circumstances you can ask us to delete your data: see your legal rights at paragraph 7 below for further information.

6.4              In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

7.          Your rights in respect of your personal data

Your rights

7.1              In respect of the personal data about you that we are processing and in accordance with the Data Protection Act 2018 and the GDPR, in certain circumstances (and provided that exemptions do not apply) you will have the following rights:

7.1.1             right to access: the right to request certain information about, access to and copies of the personal information about you that we are holding (please note that you are entitled to request one copy of the personal information that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs);

7.1.2             right to rectification: the right to have your personal information rectified if it is inaccurate or incomplete;

7.1.3             right to erasure/“right to be forgotten”: the right to withdraw your consent to our processing of the data (if the legal basis for processing is based on your consent) and the right to request that we delete or erase your personal information from our systems;

7.1.4             right to restriction of use of your information: the right to stop us from using your personal information or limit the way in which we can use it;

7.1.5             right to data portability: the right to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another company, where technically feasible; and

7.1.6             right to object: the right to object to our use of your personal information including where we use it for our legitimate interests or for marketing purposes.

          Please upload relevant content and material only

7.2              For Clients (including all individuals who hold an account with us): please note that in the event we receive a data subject request by a third party (e.g. a request to access their data in line with the rights outlined above), we will be required to disclose any information you upload about such third party if it is not relevant or necessary for the dominant purpose of the relevant litigation/Proceedings. 

7.3              Therefore, please ensure that you upload relevant and necessary information strictly for the purpose of the Proceedings only.  We will not be responsible in respect of any information or personal data uploaded that is subject to disclosure to a third party with regards to a data subject access/other request under data protection legislation.

Marketing communications

7.4              If you have subscribed to marketing communications from us, you have the right to unsubscribe from such communications at any time by following the link in the footer of the last email you received from one of our brands or by sending your request with detailed instructions to us (see contact details above).

Withdrawing consent

7.5              Please note that if you withdraw your consent to the use of your personal information (where we rely on consent as the basis for processing, as further set out above in this Privacy Policy), we may not be able to provide you with access to all or certain parts of our site.

Complaints to the ICO

7.6              If you consider our use of your personal information to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. Please see further information on their website: www.ico.org.uk. 

8.          Automatic decision making

We do not make decisions based solely on automated data processing, including profiling.

9.          Security

9.1              We keep your information protected by taking appropriate technical and organisational measures to guard against unauthorised or unlawful processing, accidental loss, destruction or damage. For example:

9.1.1             where appropriate, data is encrypted when transiting on our system or stored on our databases;

9.1.2             we have implemented safeguards in relation to access and confidentiality in order to protect the information held within our systems; and

9.1.3             we frequently carry out risk assessments and audits to monitor and review threats and vulnerabilities to our systems to prevent fraud.

9.2              However, while we will do our best to protect your personal information, we cannot guarantee the security of your information which is transmitted via an internet or similar connection. It is important that all details of any username, password and/or other identification information created to access our servers are kept confidential by you and should not be disclosed to or shared with anyone.

10.       Changes to this Privacy Policy

We may amend this Privacy Policy from time to time, for example to keep it up to date, to implement minor technical adjustments and improvements or to comply with legal requirements. We will always update this Privacy Policy on our site, so please try to read it when you visit the site (the “last updated” reference tells you when we last updated our Privacy Policy).

Last updated July 2025