Privacy & cookies policy

Last updated: February 2026

Lumen Later Life Living Pty Ltd respects your privacy. This Privacy & Cookies Policy explains how we collect, use, store and share personal data when you visit www.mypodplan.co.uk (“Our Site”) or use the Podplan platform.

We process personal data in accordance with:

  • UK General Data Protection Regulation (UK GDPR)
  • Data Protection Act 2018
  • Privacy and Electronic Communications Regulations (PECR)

1. Definitions and Interpretation

In this Policy:

Account means an account required to access certain areas of Our Site or platform.

Cookie means a small text file placed on your device when you visit Our Site.

Personal Data means information relating to an identified or identifiable individual.

Special Category Data means sensitive personal data as defined under UK GDPR (including health-related data).

We/Us/Our means Lumen Later Life Living Pty Ltd.

2. Information About Us

Our Site is owned and operated by Lumen Later Life Living Pty Ltd (Company No. 11355315).

Registered address:
92 Station Lane
Hornchurch
Essex RM12 6LX
United Kingdom

VAT No: 332 8025 26

We act as the data controller for personal data collected through Podplan.

Contact: support@mypodplan.co.uk

3. What Does This Policy Cover?

This Policy applies to:

  • Visitors to Our Site
  • Representatives of corporate organisations enquiring about Podplan
  • Members accessing Podplan through a corporate partner
  • Invited family members
  • Third-party partners contacting us

It does not apply to third-party websites linked from Our Site.

4. Your Rights

Under UK GDPR, you have the right to:

  • Be informed about how your data is used
  • Access your personal data
  • Request correction of inaccurate data
  • Request erasure (where applicable)
  • Restrict processing
  • Object to processing
  • Data portability
  • Withdraw consent (where consent is relied upon)

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO).

Requests may be submitted to support@mypodplan.co.uk. We respond within one month.

5. What Personal Data Do We Collect?

Depending on your interaction with Podplan, we may collect:

Identity and Contact Data

  • Name
  • Job title
  • Company name
  • Email address
  • Telephone number
  • Postal address

Technical Data

  • IP address
  • Browser type and version
  • Device information
  • Usage data

Account Data

  • Login details
  • Platform preferences
  • Interaction history

Special Category Data
Where voluntarily entered within planning tools (for example, health or later-life care information). This is processed only where an appropriate lawful basis applies.

Invite Family Member Feature

Where a member invites a family member to access Podplan, we collect:

  • First name
  • Last name
  • Relationship to the inviting member
  • Email address

This information is initially provided by the inviting member solely to send an invitation.

Lawful Basis

The initial processing of an invited individual’s contact details is based on our legitimate interests in facilitating platform access requested by an existing member.

Before any invited family member:

  • Activates their access
  • Receives ongoing communications
  • Shares information within the platform
  • Allows limited data sharing with the named adviser firm

they must provide explicit consent.

No further processing beyond sending the invitation email takes place unless consent is provided.

Adviser Firm Data Sharing

If explicit consent is given, we may share limited identifying information with the named adviser firm that originally provided Podplan access.

The information shared may include:

  • First name
  • Last name
  • Email address

This sharing occurs solely to enable the named firm to provide more relevant or personalised services.

We do not share planning information, platform content or Special Category Data with adviser firms without a separate lawful basis.

Withdrawal of Consent

Consent may be withdrawn at any time via account settings or by contacting us.

Withdrawal will:

  • Prevent future data sharing with the adviser firm
  • Not affect processing carried out prior to withdrawal

Where consent is withdrawn, we will cease further sharing and notify the relevant firm where applicable.

Third-Party Service Providers

We use service providers to operate Podplan, including:

These providers process personal data in accordance with their own privacy frameworks.

6. How Do We Use Your Personal Data?

We process personal data under the following lawful bases:

Contract
To provide access to the platform and premium subscriptions.

Legitimate Interests
To operate, secure and improve our services.

Consent
For marketing communications and Invite Family Member adviser data sharing.

Legal Obligation
Where required by law.

We use personal data to:

  • Create and manage accounts
  • Provide platform functionality
  • Process payments
  • Communicate with users
  • Conduct analytics
  • Improve services
  • Comply with legal obligations

You may withdraw consent at any time where consent is relied upon.

Data Retention

We retain personal data only as long as necessary.

As a general guideline:

  • Active account data: retained while in use
  • Inactive accounts: up to 36 months
  • Financial records: retained as required by law
  • Marketing data: retained until consent is withdrawn

7. How and Where Do We Store and/or Transfer Your Personal Data?

We implement appropriate technical and organisational security measures including:

  • Restricted access controls
  • Secure hosting infrastructure
  • Encryption where appropriate
  • Data breach response procedures

Some service providers may process data outside the United Kingdom. Such processing is subject to the safeguards and privacy frameworks of those providers.

8. Do We Share Your Personal Data?

We may share personal data:

  • With service providers supporting platform delivery
  • Within our corporate group (where applicable)
  • Where required by law
  • With a named adviser firm where explicit consent has been provided by an invited family member

We do not sell personal data.

9. What Happens If Our Business Changes Hands?

If our business is sold, restructured or transferred, personal data may transfer to the new owner under this Policy.

10. How Can You Control Your Personal Data?

You may:

  • Update your account information
  • Unsubscribe from marketing communications
  • Withdraw consent
  • Request deletion where legally permissible

11. Your Right to Withhold Information

You may browse parts of Our Site without providing personal data. However, certain features require personal information to function.

12. How Can You Access Your Personal Data?

You may request a copy of personal data we hold about you by contacting support@mypodplan.co.uk.

We do not charge a fee unless a request is manifestly unfounded or excessive.

13. Our Use of Cookies

We use cookies in accordance with PECR.

Cookies fall into the following categories:

Essential Cookies
Required for site functionality and security.

Analytics Cookies
Used to measure and improve performance.

Marketing Cookies
Used where applicable for communication and engagement tracking.

Non-essential cookies are placed only with your consent via our cookie banner.

You may withdraw or modify consent at any time.

14. Contacting Us

Email: support@mypodplan.co.uk

Post:
Lumen Later Life Living Pty Ltd
92 Station Lane
Hornchurch
Essex RM12 6LX
United Kingdom

15. Changes to Our Privacy Policy

We may update this Privacy & Cookies Policy from time to time. The latest version will always be available on Our Site.

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