Privacy Policy

1. Introduction

This privacy notice provides you with details of how we collect and process your personal data through your use of our site www.lowe-maintenance.co.uk

By providing us with your data, you warrant to us that you are over 13 years of age.

Demelza Lowe and Phillip Lowe trading as Lowe Maintenance, are the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

We have appointed a Data Protection Officer who is in charge of privacy related matters for us. If you have any questions about this privacy notice, please contact the Data Protection Officer using the details set out below.

Contact Details

Our full details are:

Full name of legal entity: Lowe Maintenance

Data Protection Officer: Demelza Lowe

Email address: info@lowe-maintenance.co.uk

Postal address: 18 Duke Street, Settle, North Yorkshire, BD24 9DN

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@lowe-maintenance.co.uk or click here to update your details within the portal https://portal.lowe-maintenance.co.uk

2. What data do we collect about you, for what purpose and on what ground we process it

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process the following categories of personal data about you:

Communication Data

This includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Customer Data

This includes data relating to any purchases of goods and/or services such as your name, title, billing address, delivery address, email address, phone number, contact details, purchase details, date of birth, photograph ID, head and shoulders candidate image, and training records. We process this data to supply the goods and/or services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

We use a third-party payment processor, Stripe, to handle online payment transactions. We do not store or have access to your credit or debit card details. For more information on how Stripe processes your payment information, please refer their privacy policy.

User Data

This includes data about how you use our website and any online services together with any data that you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and/or databases and to enable publication and administration of our website, other online services and business. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

We collect the following types of User Data, name, email address, contact details, health information, training progress, completion records, assessment and certification records. Of which it is stored within our systems and on the candidate training portal.

We process this data for the purposes of providing access to training materials, tracking progress, and communicating important updates related to the training. The lawful basis for processing this data is contractual necessity.

We take appropriate security measures to protect your User Data and will retain it for as long as you wish to maintain access to the portal inline with our terms and conditions. You have the right to request access to your data at any time, and you can request the deletion of your data if you no longer wish to use the portal.

We will periodically review the data we hold and will inform you of any changes to your access rights or data retention policies. If you choose to withdraw your access to the poral, we will delete your personal data in accordance with our data retention policy, unless we are required to retain it for legal or regulatory purposes.

Technical Data

This includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is from our analytics tracking system. We process this data to analyse your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business and to grow our business and to decide our marketing strategy.

We may share certain technical data with freelancers who have limited access to this information as necessary from them to perform their roles and provide services to us. This sharing of data will only occur when it is essential for the completion of specific tasks or projects.

We ensure that any data shared with freelancers is done in compliance with applicable data protection laws and regulations. We take appropriate measures to safeguard your data, including confidentiality agreements or data processing agreements, to ensure that your information is handled securely and responsibly.

Marketing Data

This includes data about your preferences in receiving marketing from us and our third parties and your communication preferences. We process this data to enable you to partake in our promotions such as competitions, prize draws and free give-aways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is either consent, contract or our legitimate interests which in this case are to study how customers use our products/services, to develop them, to grow our business and to decide our marketing strategy.

We may use Customer Data, User Data, Technical Data, Marketing Data and Media Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely to grow our business or for direct marketing).

We may process your reviews, recommendations and testimonial comments (including written, images and video) that include data about experiences on our courses or product purchases. We process this data under the lawful ground of legitimate interest to aid our marketing and sales on social media platforms such as Facebook, Instagram, LinkedIn, Google and YouTube and other display advertising.

We believe that you would reasonably expect your feedback to be used in this way, and we take care to ensure that your rights and freedoms are respected. If you do not wish for your reviews or testimonials to be used for marketing purposes, please let us know, and we will respect your request.

We may also use Communications Data, Customer Data, User Data, Technical Data and Marketing Data for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to establish, pursue or defend legal claims.

Health Related Data

We collect specific health-related information as part of the candidate registration process. This includes details about your health status, any medical conditions, disabilities, or learning difficulties that may affect your ability to participate in our courses. This data is essential for ensuring your safety and well-being during training and assessments, and to provide any necessary accommodations to support your learning experience.

In addition to the above, we may process your health-related data in the event of a safety or emergency situation that may occur during one of our training courses. This processing is necessary to protect your vital interests and ensure your safety, as well as the safety of other participants. Relevant staff within Lowe Maintenance will be informed of any health concerns to ensure that appropriate measures are taken for the safety of all involved.

The lawful basis for processing this health data is contractual necessity, as it is essential for fulfilling our obligations to provide a safe and supportive training environment. We are committed to ensuring that your health information is handled with the utmost care and confidentiality.

We implement appropriate technical and organisational measures to protect your health data from unauthorised access, loss or misuse and will only share it with relevant personnel in emergency situations to ensure your safety.

This includes the data being stored in the candidate portal, where only you and the staff within Lowe Maintenance who need to know have access to that information. Your health data may also be securely forwarded to the assessment centre as part of the registration process, in compliance with data protection regulations.

You have the right to access your health data, request corrections, and withdraw your consent at any time. If you have any concerns or questions about how we handle your health data, please contact us at info@lowe-maintenance.co.uk. We take your privacy seriously and are dedicated to safeguarding your personal information.

Media Data

We collect images, videos, and testimonials from candidates not only throughout the training and at the end of assessments but also at other relevant moments during your participation. Furthermore, we may collect other information that helps us enhance our services. This media data is collected under a contractual basis for the purpose of marketing our courses and services.

The content produced may be shared on various social media platforms, including but not limited to Facebook, Instagram, LinkedIn, Google and YouTube, to promote our offerings and showcase candidate experiences.

By providing us with your images, videos, and testimonials, you consent to the use of this media data for marketing purposes. You have the right to withdraw your consent at any time. If you wish to opt out of having your media data used for marketing purposes, please contact us at info@lowe-maintenance.co.uk

Please note that once your media data has been published in printed materials, it cannot be removed or withdrawn from those materials. We will make reasonable efforts to ensure that your media data is used appropriately and in a manner that respects your privacy.

We take your privacy seriously and are committed to safeguarding your personal information. We will retain your media data only as long as necessary for the stated purposes.

Required Processing

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

Purposes of Processing

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at info@lowe-maintenance.co.uk.  

We may also process your personal data, including but not limited to contact information and health-related data, in the event of an emergency or safety situation that requires immediate action. This processing is necessary to ensure the safety and well-being of all participants and to facilitate effective communication during such incidents. We will take appropriate measures to safeguard your personal data during these situations and ensure that it is only shared with relevant personnel who are involved in the emergency response. Our commitment to protecting your personal data remains paramount, and we will handle all information with the utmost care and confidentiality.

Sensitive Data, Criminal Conviction Data and Automated Processing

We collect certain categories of personal data that are classified as sensitive under the UK GDPR. As part of the registration process, we will collect sensitive data, including your health information, disability status, learning difficulties, and photographs (including photo ID). We require your explicit consent to process this sensitive data to ensure your safety and well-being during our training courses.

This includes:

• Health Data: Information regarding your health status, medical conditions, and any disabilities that may affect your ability to participate in our courses.
• Disability Information: Details about any disabilities you may have, which may require accommodations during training.
• Learning Difficulties: Information about any learning difficulties that may affect your training experience.
• Photographs: Images of candidates, including photographs for identification purposes (e.g., photo ID).

We do not collect or process any criminal conviction and offences data.

The collection of this sensitive data is essential for ensuring your safety and well-being during training and assessments, as well as for providing necessary accommodations to support your learning experience.

The lawful basis for processing this sensitive data is contractual necessity, as it is required to fulfil our obligations to provide a safe and supportive training environment. We are committed to handling your sensitive data with the utmost care and confidentiality, implementing appropriate technical and organisational measures to protect it from unauthorised access, loss, or misuse.

While we require your photo ID for registration purposes, you have the right to withdraw consent for the processing of your sensitive data, such as health information. Your photo ID will still be processed for identity verification purposes, even if you do not consent to the processing of other sensitive data.

You have the right to access your sensitive data, request corrections, and withdraw your consent at any time. We will retain your sensitive data only for as long as necessary to fulfil the purposes for which it was collected. If you have any concerns or questions about how we handle your sensitive data, please contact us at info@lowe-maintenance.co.uk. We take your privacy seriously and are dedicated to safeguarding your personal information.

Automated decision making

We do not carry out automated decision making or any type of automated profiling.

Automated Decision-Making (Non-Significant Decisions)

We may use automated processes to assist us in making certain decisions about you. This means that we may use systems or tools to analyse your personal data in order to help us operate our business more efficiently.

These automated processes are used for purposes such as:

• improving our services
• analysing trends or preferences
• managing administrative processes

These decisions do not have a legal or similarly significant effect on you. They are used to support our internal processes and do not materially affect your rights, opportunities or access to services. Where appropriate, we ensure that human oversight is applied to these processes.

Automated Decision-Making (Significant Decisions)

We do not engage in automated decision-making that produces significant effects on individuals. All decisions regarding your personal data are made by our staff, ensuring that you receive a fair and transparent process.

3. How we collect your personal data
   We may collect data about you in the following ways:

1. Directly from You: You provide us with personal data directly when you fill in forms on our site, send us emails, or register for our courses. This will include your name, phone number, and email address as a minimum.
2. From Employers: We may also collect personal data, such as names, phone numbers, and email addresses, from employers when they book employees onto our courses.
3. Automatically: We may automatically collect certain data from you as you use our website by using cookies and similar technologies. Please see our cookie policy for more details about this https://lowe-maintenance.co.uk/cookie-policy/.
4. From Third Parties: We do not collect personal data from other bodies and companies. However, we may receive data from third parties such as analytics providers (e.g., Google) based outside the UK and/or the EU, advertising networks (e.g., Facebook) based outside the UK and/or the EU, search information providers (e.g., Google) based outside the UK and/or the EU, and providers of technical, payment, and delivery services.

We may also receive data from publicly available sources such as Companies House and the Electoral Register based inside or outside the UK and/or the EU.

4. Marketing communications

Our lawful ground of processing your personal data to send you marketing communications is either your consent, or our legitimate interests (namely to grow our business).

Under the Privacy and Electronic Communications Regulations (PECR), we may send you marketing communications from us if (i) you made a purchase or asked for information from us about our goods or services or (ii) you agreed to receive marketing communications and in each case you have not opted out of receiving such communications since. Under these regulations, if you are a limited company, we may send you marketing emails without your consent. However, you can still opt out of receiving marketing emails from us at any time.

We will never share your personal details with any third party for their own marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you at any time.

If you opt out of receiving marketing communications this opt-out does not apply to personal data provided as a result of other transactions, such as purchases, warranty registrations etc.

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below, who assist us in delivering our services, including:

• Service Providers: Including Parkhill Training & Assessment centre, City & Guilds for registration purposes.

• IT Support Providers: Such as 3CX, Microsoft 365, Outlook, WordPress, WooCommerce, SuiteDash CRM, IT and website freelancers who provide IT and system administration services.
• Marketing Providers: Including Mailerlite, marketing and social media freelancers, who assist us with marketing services.
• Payment Providers: Such as Stripe, who process payments on our behalf.
• Analytics Providers: Including Google Forms and Zapier, who help us gather insights and automate processes.

• Professional Advisers: We may share your personal data with professional advisers, including lawyers, bankers, auditors, accountants and insurers.
• Government Bodies: We may disclose your personal data to government bodies that require us to report processing activities.
• Funding Bodies: Such as Forestry Commission or Yorkshire Dales Millenium Trust, and others as necessary that require us to process funding packages.
• Other Third Parties: We may also share your personal data with other third parties as necessary, including those involved in fraud prevention and market research, if applicable.
• Business Transfers: We may share your personal data with third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We are subject to the provisions of the UK General Data Protection Regulations (UK GDPR) that protect your personal data. Where we transfer your data to third parties outside of the UK, we will ensure that certain safeguards are in place to ensure a similar degree of security for your personal data. As such:

• We may transfer your personal data to countries that the United Kingdom regulatory authorities have approved as providing an adequate level of protection for personal data; or
• If we use US-based providers that are part of the UK-US Data Bridge (the UK Extension to the EU-US Data Privacy Framework), we may transfer data to them, as they have equivalent safeguards in place; or
• Where we use certain service providers who are established outside of the UK, we may use specific contracts approved by the ICO (the International Data Transfer Agreement or the UK Addendum to the EU Standard Contractual Clauses), or codes of conduct or certification mechanisms approved by the UK government, which give personal data the same protection it has in the UK.

If none of the above safeguards are available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

7. Data security

We have put in place security measures to prevent your personal data from being accidentally lost, used, altered, disclosed, or accessed without authorisation. We also allow access to your personal data only to those employees and partners who have a business need to know such data. They will only process your personal data on our instructions, and they must keep it confidential.

We have procedures in place to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach if we are legally required to.

8. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

For tax purposes the law requires us to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they stop being customers.

In some circumstances we may anonymise your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to portability of data and (where the lawful ground of processing is consent) to withdraw consent.

If you are within the UK, you can see more about these rights at:

https://ico.org.uk/for-organisations/uk-gdpr-guidance-and-resources/individual-rights/

If you wish to exercise any of the rights set out above, please email us at info@lowe-maintenane.co.uk

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

When responding to a request to access your personal data, we are only required to carry out searches that are reasonable and proportionate in the circumstances (as now expressly recognised in the Data (Use and Access) Act 2025). This means we will take into account factors such as the nature of the information sought, the context in which it is held, any difficulty involved in locating it and the potential benefit to you of receiving it.

We try to respond to all legitimate requests within one month of receiving the request (or, where applicable, of receiving the identity verification information or clarification we have asked for – the response period is paused, or “stopped”, while we wait for that information, in line with the Data (Use and Access) Act 2025).

Occasionally it may take us longer than one month if your request is particularly complex or you have made a number of requests, in which case we may extend the response period by up to a further two months. We will notify you within one month of receiving your request if an extension is needed and explain why.

10. How to complain

If you have a complaint about how we handle your personal data, we ask that you contact us first so that we can try to resolve it for you.

You can submit a data protection complaint to us by:

• completing our online complaints form at https://lowe-maintenance.co.uk/data-protection-complaint-form/
• emailing us at info@lowe-maintenance.co.uk
• writing to us at Lowe Maintenance, 18 Duke Street, Settle, BD24 9DN

We will acknowledge your complaint within 5 working days of receiving it. We will investigate your complaint without undue delay, keep you informed of our progress, and communicate the outcome to you clearly with sufficient detail for you to understand how we reached our conclusion.

If you are within the UK and are not satisfied with our response, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).

11. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

12. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://lowe-maintenance.co.uk/cookie-policy/  

Document Control

Version: 3.0

Date: 17 June 2026

Changes: This Privacy Notice has been updated to reflect changes in data protection legislation, including the implementation of the Data (Use and Access) Act and amendments to the UK General Data Protection Regulation (UK GDPR). These updates ensure our compliance with current legal requirements and enhance transparency regarding how we collect, use, and protect your personal data.