Last updated: January 2026
1. Introduction
LupaSoft Ltd ("we", "us", "our") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website or use our services.
We are the data controller responsible for your personal data. We are registered in England and Wales under company number 16943875, with our registered office at The Dolls House, 62 Chipstead Lane, Sevenoaks, TN13 2AG.
2. Information We Collect
2.1 Information You Provide
We collect information you voluntarily provide to us, including:
- Contact Form Data: When you submit our contact form, we collect your name, email address, and any message content you provide.
- Email Correspondence: When you contact us via email, we retain your email address and correspondence.
- Business Information: If you engage our services, we may collect company name, billing address, and other information necessary for our business relationship.
2.2 Information Collected Automatically
When you visit our website, we automatically collect certain information through cookies and similar technologies:
- Device Information: Browser type, operating system, device type
- Usage Data: Pages visited, time spent on pages, click patterns
- Location Data: Approximate location based on IP address
- Referral Data: How you arrived at our website
For more details about cookies, please see our Cookie Policy.
3. How We Use Your Information
We use your personal data for the following purposes:
- To respond to enquiries: Processing and responding to your contact form submissions and emails
- To provide services: Delivering software development and design services you have requested
- To improve our website: Analysing how visitors use our website to improve user experience
- To comply with legal obligations: Meeting our legal and regulatory requirements
- To protect our interests: Enforcing our terms and protecting against fraud
4. Legal Basis for Processing
We process your personal data on the following legal bases:
- Consent: Where you have given clear consent for us to process your personal data (e.g., marketing communications, non-essential cookies)
- Contract: Where processing is necessary for the performance of a contract with you
- Legitimate Interests: Where processing is necessary for our legitimate business interests, such as improving our services and website
- Legal Obligation: Where processing is necessary to comply with a legal obligation
5. Analytics and Tracking
5.1 Google Analytics 4 (GA4)
We use Google Analytics 4 to understand how visitors interact with our website. GA4 collects data such as:
- Pages you visit and how long you spend on them
- How you arrived at our website
- Your approximate geographic location
- Device and browser information
Google Analytics uses cookies to collect this information. The data is processed by Google LLC in accordance with their privacy policy. We have configured GA4 to anonymise IP addresses where possible.
5.2 Google Tag Manager
We use Google Tag Manager to manage and deploy tracking scripts on our website. Google Tag Manager itself does not collect personal data, but it facilitates the deployment of other services that may collect data.
6. Data Sharing
We may share your personal data with:
- Service Providers: Third parties who provide services on our behalf, such as hosting, analytics, and email services
- Professional Advisors: Lawyers, accountants, and other professional advisors as necessary
- Legal Requirements: Where required by law, court order, or governmental authority
- Business Transfers: In connection with any merger, sale, or acquisition of our business
We do not sell your personal data to third parties.
7. International Transfers
Some of our service providers (including Google) may process your data outside the UK and European Economic Area. Where this occurs, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the UK Information Commissioner's Office.
8. Data Retention
We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:
- Contact form submissions: 2 years from submission
- Client project data: 6 years after project completion (for legal and accounting purposes)
- Analytics data: 14 months (GA4 default retention)
- Marketing preferences: Until you withdraw consent
9. Your Rights
Under UK data protection law, you have the following rights:
- Right of Access: Request a copy of the personal data we hold about you
- Right to Rectification: Request correction of inaccurate or incomplete data
- Right to Erasure: Request deletion of your personal data in certain circumstances
- Right to Restrict Processing: Request limitation of how we use your data
- Right to Data Portability: Request transfer of your data to another organisation
- Right to Object: Object to processing based on legitimate interests
- Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
To exercise any of these rights, please contact us at hi@lupasoft.co.uk.
10. Data Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:
- Encryption of data in transit (HTTPS)
- Secure hosting with reputable providers
- Regular security assessments
- Limited access to personal data on a need-to-know basis
11. Children's Privacy
Our website and services are not directed at children under 16 years of age. We do not knowingly collect personal data from children. If you believe we have collected data from a child, please contact us immediately.
12. Links to Other Websites
Our website may contain links to third-party websites. We are not responsible for the privacy practices of these websites. We encourage you to read the privacy policies of any linked websites you visit.
13. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of any significant changes by posting the new policy on this page and updating the "Last updated" date. We encourage you to review this policy periodically.
14. Complaints
If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with the Information Commissioner's Office (ICO):
We would appreciate the opportunity to address your concerns before you approach the ICO, so please contact us first.
15. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us: