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Lucid Cognition
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GDPR Compliance Statement

Last updated: May 11, 2026

Our Commitment to Data Protection

Lucid Cognition Ltd is committed to complying with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We take our data protection responsibilities seriously and have implemented appropriate measures to ensure your personal data is processed lawfully, fairly, and transparently.

Data Controller Information

Lucid Cognition Ltd is the data controller responsible for your personal data.

Registered Office:
42 Finsbury Square
London EC2A 1AD
United Kingdom

Contact Email: [email protected]

Lawful Basis for Processing

We process personal data under the following lawful bases:

Consent

Where you have provided explicit consent for us to process your data for specific purposes, such as marketing communications or initial consultations.

Contractual Necessity

When processing is necessary to perform our pension advisory services under a contract with you, or to take steps at your request before entering into a contract.

Legal Obligation

When we must process your data to comply with legal requirements, including:

  • Financial Conduct Authority (FCA) regulations
  • Anti-money laundering requirements
  • Tax reporting obligations
  • Record-keeping requirements for financial services

Legitimate Interests

When processing is necessary for our legitimate business interests, such as:

  • Fraud prevention and security
  • Network and information security
  • Internal business administration
  • Improving our services

We balance our legitimate interests against your rights and only process data where our interests do not override your fundamental rights.

Data Protection Principles

We adhere to the following data protection principles:

Lawfulness, Fairness, and Transparency

We process personal data lawfully, fairly, and in a transparent manner. We provide clear information about how and why we use your data.

Purpose Limitation

We collect personal data for specified, explicit, and legitimate purposes and do not process it in ways incompatible with those purposes.

Data Minimization

We only collect personal data that is adequate, relevant, and limited to what is necessary for the purposes for which it is processed.

Accuracy

We take reasonable steps to ensure personal data is accurate and kept up to date. Inaccurate data is corrected or deleted without delay.

Storage Limitation

We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law.

Integrity and Confidentiality

We process personal data securely using appropriate technical and organizational measures to protect against unauthorized or unlawful processing and accidental loss, destruction, or damage.

Accountability

We are responsible for demonstrating compliance with GDPR principles through documentation, policies, and procedures.

Your Rights Under UK GDPR

Right of Access

You have the right to request a copy of the personal data we hold about you. We will provide this information within one month of your request, free of charge.

Right to Rectification

You can request correction of inaccurate or incomplete personal data. We will update your information within one month.

Right to Erasure (Right to be Forgotten)

You may request deletion of your personal data in certain circumstances, such as when data is no longer necessary for the purpose it was collected. However, we may need to retain certain data to comply with legal obligations.

Right to Restrict Processing

You can request that we restrict processing of your personal data in certain situations, such as when you contest the accuracy of the data.

Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and transmit it to another controller.

Right to Object

You can object to processing based on legitimate interests or for direct marketing purposes. We will stop processing unless we have compelling legitimate grounds.

Rights Related to Automated Decision-Making

You have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal or similarly significant effects. We do not currently use automated decision-making in our pension advisory services.

Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw that consent at any time. This does not affect the lawfulness of processing before consent was withdrawn.

How to Exercise Your Rights

To exercise any of your data protection rights, please contact us:

Email: [email protected]
Post: Lucid Cognition Ltd, 42 Finsbury Square, London EC2A 1AD

We will respond to your request within one month. In complex cases, this may be extended by up to two months, and we will inform you of any delay.

Data Security Measures

We implement appropriate technical and organizational measures to protect personal data, including:

  • Encryption of data in transit and at rest
  • Access controls and authentication
  • Regular security assessments and updates
  • Staff training on data protection
  • Secure disposal of physical and electronic records
  • Business continuity and disaster recovery planning

Data Breach Notification

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the Information Commissioner's Office (ICO) within 72 hours of becoming aware of the breach. If the breach poses a high risk to you, we will also notify you directly without undue delay.

International Data Transfers

We primarily store and process data within the United Kingdom. If we transfer personal data outside the UK, we ensure appropriate safeguards are in place, such as:

  • Adequacy decisions by the UK government
  • Standard contractual clauses approved by the ICO
  • Binding corporate rules

Data Protection Officer

While we are not currently required to appoint a Data Protection Officer, our senior management team is responsible for overseeing GDPR compliance. Questions about data protection can be directed to [email protected].

Complaints and Regulatory Authority

If you are dissatisfied 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
Telephone: 0303 123 1113
Website: lucid-cognition.com

Updates to This Statement

We may update this GDPR Compliance Statement from time to time to reflect changes in our practices or legal requirements. Material changes will be communicated through our website.

Lucid Cognition

Expert pension planning and retirement advisory services across the United Kingdom.

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