Privacy notice — Lustriq Automation Agency

This notice explains how we use personal data under UK GDPR Articles 13 and 14.

Who we are

Lustriq Automation Agency is a trading name of Lustriq Facilities Limited, registered in England and Wales (company number 17092690). Registered office: Suite A, 82 James Carter Road, Mildenhall, IP28 7DE, United Kingdom.

Controller contact: hello@lustriqfacilities.com. We have not appointed a data protection officer. ICO registration: [ICO REG NO. — pending]. We will add the number once it is issued and will not describe ourselves as ICO-registered until then.

Controller and processor

We build lead-to-quote-to-booking automation for UK cleaning firms. We are the controller for data about our prospects, clients, and people who contact us.

We are a processor when we handle a client firm’s customer enquiries to run the service. The client remains the controller of that data. We use it only on the client’s instructions, under a written contract, and only as needed to reply and quote. If you are a customer of one of those firms, see that firm’s privacy notice, or email us.

Personal data we use

This website is static: no cookies, no analytics and no live forms. The video is served from this website, which is hosted on Cloudflare Pages, and contact is by email only. When you visit, Cloudflare, which hosts this website, processes your IP address and request metadata (request logs) to deliver the site (see Who we share data with). We do not use cookies, analytics or tracking. [Update this notice before any live form collects data.]

We use:

• from your emails: your name, email address, message and any other details you include;
• for prospects: name, job title, work email, and the company’s name and number;
• for clients: contact and billing details needed for the contract [CLIENT DATA — SUGGESTED: name, work email, phone, job title, company address, invoices];
• as a processor: a customer’s name, contact details, message, and quote or booking information, only as needed to run the service.

We do not seek special category data, and we do not make solely automated decisions with legal or similarly significant effects. If you include special category data in an email, we use it only to deal with that message and delete it where we can. To become a client we need the details required for the contract.

Where the data comes from

From you, if you email us or become a client. For prospects, from Companies House and company websites (publicly accessible sources). [OTHER PROSPECT SOURCES — TBC: none at present.]

Purposes and lawful bases

For emails to UK cleaning limited companies about our service we rely on legitimate interests (Article 6(1)(f)): promoting a service designed for those firms. We only email limited companies (corporate subscribers). The Privacy and Electronic Communications Regulations 2003 (PECR) do not require consent for those emails (regulation 22). Every marketing email identifies us and includes a valid opt-out (regulation 23). We do not email sole traders or partnerships. [LIA ON FILE? — TBC]

For enquiries: legitimate interests, or steps towards a contract (Article 6(1)(b)) if you may become a client. For client work, billing and the contract: contract (Article 6(1)(b)). For records we must keep, such as tax records: legal obligation (Article 6(1)(c)). As a processor, the client must have a lawful basis; we follow their instructions.

Who we share data with

We use Hetzner to host n8n in the EU, and Zoho Mail (EU data centre) for email. We may also share data with professional advisers (for example an accountant) and, where required, bodies such as HMRC. [Twilio, for SMS, if adopted — TBC] We use Cloudflare, Inc. (a US company) to host this website on Cloudflare Pages, served through its global network. Cloudflare acts as our processor and processes visitors' IP addresses and request metadata to deliver the site. [TBC — how long Cloudflare keeps Pages request logs] We do not sell personal data.

International transfers

Hetzner and Zoho Mail are used in the EU (part of the EEA). UK adequacy regulations cover all EEA countries, so transfers from the UK to those countries can be made on that basis. [RESIDUAL ACCESS — TBC] [Twilio US transfers — TBC] Cloudflare, which hosts this website, is a US company with a global network, so visitor data may be processed in the United States and other countries. Cloudflare's data processing addendum includes the UK Addendum and the EU-US Data Privacy Framework (DPF). [TBC — which of these we rely on for UK transfers, whether Cloudflare is certified under the UK Extension to the DPF, and how to obtain a copy of the safeguard] We do not otherwise intend to transfer personal data outside the UK, except to those EEA processors and Cloudflare as described above. If that changes, we will update this notice first.

Retention

These periods are suggestions, not decided policy.

• Prospects: until you opt out, or [SUGGESTED: 12 months] after last contact. We keep an opt-out record so we do not contact you again [SUGGESTED: until you ask us to remove it, if we can still honour the opt-out].
• Unsuccessful enquiries: [SUGGESTED: 12 months] after correspondence ends.
• Client contract, billing and tax records: [SUGGESTED: 6 years] after the contract ends.
• Processor data: as the client instructs; deleted or returned when the contract ends, unless the law requires otherwise.

Right to object to direct marketing

You have an absolute right to object to direct marketing, including related profiling. If you object, we will stop. Opt out via any marketing email, or by emailing hello@lustriqfacilities.com. You do not need to give a reason.

Your other rights

You can ask us to access, correct, delete or restrict your data, object where we rely on legitimate interests, or obtain a portable copy where we rely on contract and the processing is automated. These rights are not always absolute; we will explain if an exception applies. Email hello@lustriqfacilities.com, in writing or verbally. We will respond within one month. We do not rely on consent for the processing in this notice, so there is no consent to withdraw. You can still opt out of marketing as set out above.

Complaints

If you are unhappy with how we have used your personal data, please email us first. You also have the right to complain to the Information Commissioner’s Office (ICO) at https://ico.org.uk/make-a-complaint/data-protection-complaints/ or on 0303 123 1113.

Cookies

This website does not use cookies, similar technologies or analytics, so there is no cookie banner. If that changes, we will update this notice and, where required, ask for consent before setting non-essential cookies.

Changes

We will update this notice if our processing changes. Version 0.4, 14 November 2026.