1. Introduction

Lurvo Digital Ltd ("we", "us", "our") is committed to protecting your privacy and handling your personal data responsibly. This Privacy Policy explains how we collect, use, store, and protect personal data when you visit our website or use our services.

Lurvo Digital Ltd is the data controller. Company number 16288427. Registered office: Amtri House, Hulley Road, Macclesfield, England, SK10 2NE.

2. What Data We Collect

We may collect the following types of personal data:

Data from website visitors

  • IP address and browser/device information (collected automatically via cookies and analytics tools)
  • Pages visited, time on site, and referral source
  • Any information you voluntarily provide through contact forms (name, email address, phone number, company name, message)

Data from consumer enquiries

Through our lead generation websites, consumers may submit personal information including:

  • Full name, email address, and phone number
  • Property details, financial circumstances, and insurance requirements (depending on the enquiry type)
  • Consent records and SMS verification status

Data from business clients

  • Business name, contact name, email address, and phone number
  • Billing and payment information
  • Lead delivery preferences and CRM integration details

3. How We Use Your Data

We use personal data for the following purposes:

  • Lead delivery: To deliver consumer enquiries to our business clients in real-time, as consented to by the consumer at the point of enquiry.
  • Service provision: To set up and manage your lead supply account, process payments, and provide customer support.
  • Communication: To respond to enquiries submitted through our contact forms and to send service-related communications.
  • Website improvement: To analyse how visitors use our website and improve its content, functionality, and performance.
  • Legal compliance: To comply with our legal obligations, including GDPR, UK data protection law, and PECR.

4. Legal Basis for Processing

We process personal data on the following legal bases under UK GDPR:

  • Consent: Where consumers have given explicit consent for their enquiry to be passed to a financial services professional. Consumers can withdraw consent at any time.
  • Contractual necessity: Where processing is necessary to fulfil our contractual obligations to business clients.
  • Legitimate interests: Where processing is necessary for our legitimate business interests (e.g., website analytics, fraud prevention), provided these do not override your rights and freedoms.
  • Legal obligation: Where we are required to process data to comply with the law.

5. SMS Verification

As part of our lead generation process, we send a one-time SMS verification message to consumers who submit an enquiry. This verifies that the phone number provided is correct and that the consumer is expecting contact. We do not use phone numbers for marketing purposes.

6. Data Sharing

We share personal data only in the following circumstances:

  • Lead delivery: Consumer enquiry data is shared with a single, named business client (e.g., a mortgage broker or insurance adviser) as consented to by the consumer. Each lead is exclusive — we never sell the same lead to multiple parties.
  • Service providers: We use third-party service providers for hosting, analytics, email delivery, and payment processing. These providers act as data processors on our behalf and are contractually required to protect your data.
  • Legal requirements: We may disclose data where required by law, regulation, or court order.

We do not sell, rent, or trade personal data to third parties for marketing purposes.

7. Cookies

Our website uses cookies to improve your experience and analyse site usage. Cookies are small text files stored on your device. We use:

  • Essential cookies: Required for the website to function correctly.
  • Analytics cookies: Used to understand how visitors interact with our website (e.g., Google Analytics). These collect anonymised data.

You can manage your cookie preferences through your browser settings. Disabling cookies may affect the functionality of our website.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected:

  • Consumer enquiry data: Retained for up to 24 months from the date of the enquiry, then securely deleted.
  • Business client data: Retained for the duration of the business relationship plus 6 years for accounting and legal compliance purposes.
  • Website analytics data: Retained in anonymised form and not linked to identifiable individuals.

9. Data Security

We take appropriate technical and organisational measures to protect personal data from unauthorised access, alteration, disclosure, or destruction. These measures include encrypted data transmission (SSL/TLS), secure server infrastructure, access controls, and regular security reviews.

10. Your Rights

Under UK GDPR, you have the following rights regarding your personal data:

  • Right of access: You can request a copy of the personal data we hold about you.
  • Right to rectification: You can request that we correct any inaccurate or incomplete data.
  • Right to erasure: You can request that we delete your personal data, subject to our legal obligations.
  • Right to restrict processing: You can request that we limit how we use your data.
  • Right to data portability: You can request your data in a structured, commonly used format.
  • Right to object: You can object to processing based on legitimate interests.
  • Right to withdraw consent: Where processing is based on consent, you can withdraw it at any time.

To exercise any of these rights, please contact us using the details below. We will respond within 30 days.

11. Complaints

If you are unhappy with how we handle your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Information Commissioner's Office
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Website: ico.org.uk
Helpline: 0303 123 1113

12. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated revision date. We encourage you to review this policy periodically.

13. Contact

If you have any questions about this Privacy Policy or how we handle your data, please contact us: