LUNARRÁPerformance Return to Lunarrá
Legal · Data Protection

Privacy Notice

We ask people to tell us the truth about the conditions they work in. That only works if they can see exactly what happens to what they tell us.

Version1.1
In effect19 August 2026
Next review19 August 2027

This notice explains what personal data LUNARRÁ collects, why we hold it, who we share it with, how long we keep it and what you can ask us to do about it. It covers this website, the Performance Architecture Assessment™, and everyone who contacts us or works with us.

Section 01Who we are

LUNARRÁ is the trading name of LUNARRÁ Group Ltd, a company registered in England and Wales, company number 16881159, registered office 71-75 Shelton Street, Covent Garden, London, WC2H 9JQ.

We are the data controller for the personal data described in this notice. That means we decide what is collected and why, and we are accountable for it.

When your employer commissions an assessment

Two different things are happening, and the difference is the reason you can answer honestly.

Your organisation decides to run the assessment and gives us the list of people to invite. For that list, your organisation is the controller and we act on its instructions.

For your answers, and for everything we build from them, we are the controller. We set the questions, the scoring and the thresholds, and we decide what the report is able to say. Your organisation cannot instruct us to hand over your individual answers, because they are not its data to demand. There is no instruction it could give us that would work.

We are independent controllers rather than joint controllers. Each of us answers for our own part.

We are registered with the Information Commissioner's Office under registration number ZC216954.

For anything to do with your data, write to info@lunarra.co.uk. Data protection is the personal responsibility of the director, Ramón Wright. There is no separate Data Protection Officer, because we are not required to appoint one.

Section 02What we collect, and why

If you complete the assessment

The Performance Architecture Assessment™ is the main way we collect personal data. When you complete it we record:

We use this to build your Pressure Architecture Map™ and your organisation's Performance Architecture Report™, and to contact you about the results and about our work.

Be clear about this one

The assessment asks how well you recover, how sustainable your workload is, and where pressure sits. Those are questions about working conditions, not about your health. We do not ask for, and do not want, medical information.

But we recognise that answers about recovery and sustained pressure can say something personal about you. So we treat them as sensitive by choice: your individual answers are never shown to your employer. Everything your organisation sees is combined with other people's answers, and no view is released to an organisation until enough people at that level have responded for individuals not to be identifiable.

If you contact us or book a briefing

Your name, email address, organisation, and whatever you choose to tell us. If you book through our online scheduling page we also receive the time you chose and any notes you added.

If we meet online

We use an automated notetaker on some client and partner calls. It records, transcribes and summarises the meeting. We tell you before it starts, and we turn it off if you ask. Recordings of your meeting are not shared outside LUNARRÁ without your agreement.

If you work with us or for us

Staff, partners and contractors are covered by a separate staff privacy notice, issued directly. Suppliers and clients: we hold the contact and billing details needed to run the relationship.

What we do not do

Section 03Our lawful basis

UK data protection law requires a lawful basis for every use of personal data. Ours are these.

What we doOur basisWhy it applies
Produce and send you your assessment resultContract, or steps taken at your requestYou asked us for the result. We cannot produce it without your answers.
Combine responses into an organisation's reportLegitimate interestsIt is the service the organisation engaged us for, and individuals are protected by aggregation.
Follow up with you about your result and our workLegitimate interestsYou are a business contact who came to us. You can stop it with one reply.
Run the business: invoices, records, taxLegal obligationCompany and tax law requires us to keep these.
Record meetings with a notetakerLegitimate interestsAccurate notes serve the work. You may ask that recording is not used, and alternative note-taking arrangements will be considered. Refusal costs you nothing.

Where we rely on legitimate interests we have weighed our interest against yours and concluded it does not override your rights. You can ask us for that assessment and we will send it to you.

Section 04Who else touches your data

We are a small firm and we use established suppliers to run the service. Each one acts on our instructions only. We do not give any of them permission to use your data for their own purposes.

SupplierWhat it does for usWhat it sees
NetlifyHosts the websiteTechnical request data
SupabaseStores assessment responsesEverything in Section 02
Web3FormsRelays completion notices to our inboxYour email, organisation and scores
EmailJSSends you the link to your own resultYour name, email and link
Namecheap Private EmailOur mailboxesAnything you email us
CalendlyBriefing bookingsYour name, email, booking
FathomMeeting notes and transcriptsWhat is said in the meeting
Revolut BusinessInvoicing and paymentsBilling contact details
Google Fonts, jsDelivrServe fonts and code to your browserYour IP address, as any web request requires
ClearbitFetches your organisation's logo for your reportYour organisation's website domain only, never your email

We will also disclose data where the law requires it, and to our professional advisers where necessary.

Data outside the UK

Some of these suppliers are based outside the UK, principally in the United States. Where data is transferred, we rely on the safeguards approved under UK law, which is normally the International Data Transfer Addendum to the European Commission's standard contractual clauses. The specific safeguard for each supplier is recorded in our processor register. You can ask us which safeguard applies to a particular supplier.

Section 05How long we keep it

RecordKept forThen
Assessment responses, where the organisation became a clientDuration of the engagement plus 6 yearsDeleted
Assessment responses, where no engagement followed24 months from completionDeleted, or reduced to anonymous statistics
Enquiries and briefing bookings that went nowhere12 monthsDeleted
Meeting recordings and transcripts12 monthsDeleted, notes retained
Invoices, contracts and financial records6 years after the end of the financial yearDeleted
Saved assessment progress in your own browser21 daysExpires automatically

Anonymous statistics, meaning figures that can no longer be traced to a person or an organisation, may be kept indefinitely. Once data is genuinely anonymous it stops being personal data.

Section 06Cookies and browser storage

This site sets no advertising cookies, no analytics cookies and no third-party tracking cookies.

The assessment saves your progress in your browser's local storage so that closing the tab does not lose your work, and passes your result to the Pressure Architecture Map™ through session storage. Both are strictly necessary for the function you asked for, both stay on your device, and clearing your browser data removes them.

Fonts and code libraries are loaded from Google Fonts and jsDelivr. Those requests reveal your IP address to those providers, as every web request does.

Section 07Your rights

You have the right to:

Ask by emailing info@lunarra.co.uk. We answer within one month. We do not charge. We may ask you to confirm who you are first, so that we do not hand your data to somebody else.

Section 08Keeping it safe

Section 09Complaints

If you are unhappy with how we have handled your data, tell us first. We would rather fix it than have it escalate, and we will take it seriously.

You also have the right to complain to the Information Commissioner's Office, the UK regulator, at any time. Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. Helpline 0303 123 1113. ico.org.uk/make-a-complaint.

Section 10Changes

If we change this notice we update the version and date at the top of the page. If a change materially affects how we use data you have already given us, we tell the people affected directly rather than expecting them to notice.

In closing

The conditions we ask about are the conditions we hold ourselves to.

Questions about any of this go to info@lunarra.co.uk and reach a person, not a queue.