Privacy Policy
Your trust is our top priority. This Privacy Policy explains, in plain English, what personal and financial data we collect, why we need it, and how we use, store, and protect it. We are committed to protecting your privacy and handling your data in accordance with UK data protection laws, including the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. We have built our platform with "Privacy by Design" as a core principle.
1. Who We Are
Illora ("we", "us", "our") is the "data controller" responsible for your personal data.
- Legal Entity: Illora Limited
- Registered Office: 195-197 Whiteladies Road, Bristol, BS8 2SB
- Privacy Contact: legal@illora.co.uk
If you have any questions about this policy or our data practices, please contact our Data Protection representative at the email address above.
2. Eligibility and Age Restrictions
Illora is for individuals aged 18 and over residing in the United Kingdom. We do not knowingly collect data from children. If we discover a user is under 18, we will immediately delete their personal data. Contact us at privacy@illora.co.uk if you suspect a minor is using the service.
3. What Personal Data We Collect & How We Collect It
We only collect the minimum data needed to manage our pre-launch waitlist and website. This includes:
Identity & Contact Data: Your name and email address when you voluntarily join our waitlist or subscribe to updates. We also collect basic sign-up metadata, like the time and date you registered.
Technical & Usage Data: Information like your IP address (which we anonymise), device type, browser, and how you interact with our website and quick-read articles. We use this to secure our platform and improve our content.
Website Calculators: Our site features interactive educational calculators. All calculations happen locally in your web browser. The financial numbers you type in are never sent to our servers, never stored by us, and are never linked to your waitlist profile.
4. How and Why We Use Your Personal Data
We only use your data when the law allows us to. The table below sets out the purposes for which we use your pre-launch data, the data types involved, and the legal bases we rely on:
| Purpose / Activity | Lawful Basis | Data Type(s) Used |
|---|---|---|
| To administer the waitlist: Managing your entry and keeping you informed of your position. | Legitimate Interests | Identity & Contact Data |
| To deliver interactive calculators: Processing technical inputs to run mathematical formulas in your browser. | Contractual Necessity | Technical Data |
| To maintain website security: Protecting our landing page from cyber-attacks and automated bots. | Legitimate Interests | Technical Data |
| To send newsletters and marketing: Sending company updates and product announcements. | Explicit Consent | Identity & Contact Data |
Note: Where we rely on your consent for marketing, you have the right to withdraw this consent at any time.
5. How We Use Artificial Intelligence (AI)
During this pre-launch phase, we use Artificial Intelligence in the background to improve our business operations. Specifically, we use it to analyse general waitlist trends and help draft our educational content.
No Profiling or Automated Decisions: We do not use AI to analyse your personal financial situation, create profiles about you, or make automated decisions that have a legal or significant effect on you. Our AI tools operate strictly on an aggregated, administrative level under the lawful basis of our "Legitimate Interests" to improve our future product.
6. Who We Share Your Data With (Third-Party Processors)
We do not sell, rent, or trade your personal data to third parties.
To run our platform securely and efficiently, we partner with specialized technology providers. We only share the minimum data necessary for these partners to perform their specific functions. These categories of partners include:
- Cloud Hosting & Database Providers: To securely store your data and host our website/app.
- Communication Platforms: To send you waitlist updates, newsletters, and essential service emails.
- AI & Coaching Engine Partners: To power our financial modeling and AI coaching features.
- Analytics & Marketing Providers: To help us understand website traffic and measure the effectiveness of our campaigns.
How We Protect Your Data With Partners: We have legally binding Data Processing Agreements (DPAs) in place with every partner. They act strictly under our instructions and cannot use your data for their own independent purposes.
Our AI "No-Training" Promise: We have specifically configured our agreements with AI providers to disable the training of their models on your personal data.
7. Where Your Data is Stored & International Data Transfers
Illora is based in the UK, and we store your data on secure UK or European servers whenever possible. However, some of our specialized technology partners (like our email or cloud providers) are based in the United States.
When we transfer your data outside the UK, we ensure it receives the exact same level of legal protection by relying on approved safeguards, such as the UK-US Data Bridge or Standard Contractual Clauses (SCCs) mandated by the Information Commissioner's Office (ICO).
8. How Long We Keep Your Data
We only keep your personal data for as long as necessary to manage our waitlist, run our platform, and respect your communication preferences.
Waitlist Data: We will hold your contact details until we officially launch the Illora platform. If you decide not to convert your waitlist spot into a full account at launch, we will automatically delete your waitlist data within 12 months of the launch date.
Marketing & Newsletters: If you explicitly opt in to receive our marketing and updates, we will retain your email for this purpose until you unsubscribe. If you opt out, we will immediately stop sending you marketing, but we will securely hold your email address on a "suppression list" simply to ensure we never accidentally email you again.
Database Hygiene: If emails to you consistently bounce, or if you do not open any of our communications for 12 months, we will automatically remove you from our active mailing lists to keep our database secure and clean.
9. Your Legal Rights
Under the UK GDPR, you have strong legal rights over your personal data. You have the right to:
- Request Access: Ask us for a copy of the personal data we hold about you.
- Request Correction: Ask us to fix any inaccurate or incomplete data.
- Request Erasure (Right to be Forgotten): Ask us to delete your data when we no longer have a legal reason to keep it.
- Object to Processing: Object to us using your data, particularly for direct marketing or AI profiling.
- Withdraw Consent: If you consented to our newsletter or marketing, you can withdraw this at any time by clicking "unsubscribe" in any email.
- Request Portability: Ask us to transfer your data to another service provider.
How to exercise these rights: Please email us at privacy@illora.co.uk. We will respond to all legitimate requests within 30 days, free of charge.
10. Cookies and Tracker Management
Our website uses cookies and similar tracking technologies to make our platform work and to understand how users interact with it.
Essential & Performance Cookies (Automatic): We automatically use necessary cookies to keep our website secure. We also use basic analytics to count website visits and see which pages are popular. This data is aggregated, completely anonymous, and helps us improve our service. (You can opt out of these performance analytics at any time via our cookie manager).
Advertising & Marketing (Consent Required): We use tools and pixels from third parties (like Google and Meta) to show you relevant Illora ads on other platforms. We will never activate these tracking pixels without your explicit consent via our cookie banner.
You can change your mind, opt out of analytics, or update your advertising preferences at any time by clicking the link in our website footer.
11. Updates to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our services or legal requirements. We will notify you of any significant changes by sending an email to the address you provided or by placing a prominent notice on our website.
12. How to Contact Us or Lodge a Complaint
If you have any questions, concerns, or feedback regarding how we handle your personal data during this pre-launch phase, please get in touch with us at privacy@illora.co.uk so we can resolve the issue for you directly.
If you believe we have not handled your personal data in accordance with UK law, you have the statutory right to lodge a formal complaint with the Information Commissioner's Office (ICO), the UK's independent supervisory authority for data protection:
- ICO Helpline: 0303 123 1113
- ICO Website: https://ico.org.uk