1. Introduction
This Privacy Policy explains how Lupe (“we”, “us”, “our”) collects, uses, and protects your personal data.
Lupe is a software company owned and operated by Transparent Digital Services Limited, a company registered in England and Wales. We are committed to protecting your privacy and handling your personal data in a transparent, lawful, and secure manner.
This policy applies to visitors to our website, users of our software, and anyone who interacts with us.
2. Company Information
Company Name: Transparent Digital Services Limited
Trading As: Lupe
Company Number: 10377347
Registered Office Address:
303 The Pill Box
115 Coventry Road
London
England
E2 6GH
Contact Email: contact@transparentdigitalservices.com
For the purposes of UK data protection law (including the UK GDPR and the Data Protection Act 2018), Transparent Digital Services Limited is the data controller unless otherwise stated.
3. What Personal Data We Collect
We may collect and process the following categories of personal data:
Information You Provide Directly
- Name
- Email address
- Company name
- Account login details
- Information submitted via contact forms or support enquiries
Technical and Usage Data
Collected automatically when you use our website or software:
- IP address
- Browser type and version
- Device type and operating system
- Pages visited and time spent
- Referring URLs
- Interaction and event data
Account and Platform Data
Where users connect advertising platforms or related services to Lupe, we may process:
- Advertising account IDs
- Campaign-level performance data
- Conversion and event data
- Tracking and measurement data
4. How We Collect Data
We collect data:
- Directly from you when you create an account, submit forms, or contact us
- Automatically through cookies and similar tracking technologies
- Via Google Tag Manager for analytics and advertising measurement purposes
We use Google Tag Manager to manage tracking scripts and event measurement. Data collected via this method is used strictly for analytics, performance monitoring, and advertising effectiveness relating to Lupe.
5. How We Use Your Data
We process personal data in order to:
- Provide and operate the Lupe software
- Deliver contracted services
- Improve system performance and functionality
- Monitor usage and troubleshoot issues
- Measure and optimise advertising campaigns
- Communicate service updates or support responses
- Comply with legal and regulatory obligations
We rely on the following lawful bases under UK GDPR:
- Performance of a contract
- Legitimate interests
- Legal obligation
- Consent (where required for non-essential cookies or marketing)
6. Data Sharing and Advertising
We do not sell personal data.
We do not share personal data with unrelated third parties for independent marketing purposes.
We may transmit tracking and event data to advertising platforms used by Lupe strictly for campaign measurement, attribution, and optimisation.
Data is only sent to advertising accounts used and controlled by Lupe.
Where we use service providers (such as hosting providers), they process data solely on our instructions and under appropriate contractual safeguards.
7. Cookies and Tracking Technologies
We use cookies and similar technologies to:
- Operate and secure our website
- Analyse traffic and user behaviour
- Improve user experience
- Support advertising measurement
Where legally required, we obtain consent before placing non-essential cookies. You can manage or disable cookies via your browser settings.
For further information, please refer to our Cookie Policy.
8. Data Retention
We retain personal data only for as long as necessary to:
- Provide our services
- Fulfil contractual obligations
- Comply with legal requirements
- Resolve disputes and enforce agreements
Retention periods vary depending on the nature of the data and applicable legal requirements.
9. Data Security
We implement appropriate technical and organisational measures to safeguard personal data against:
- Unauthorised access
- Accidental loss
- Alteration
- Disclosure
- Misuse
While we take reasonable steps to protect data, no system can guarantee absolute security.
10. International Data Transfers
Where personal data is transferred outside the United Kingdom, we ensure appropriate safeguards are in place, including:
- Adequacy decisions
- Standard Contractual Clauses
- Other legally approved transfer mechanisms
11. Your Rights
Under UK GDPR, you have the right to:
- Request access to your personal data
- Request correction of inaccurate or incomplete data
- Request erasure of your personal data
- Restrict or object to processing
- Request data portability
- Withdraw consent where processing is based on consent
To exercise your rights, please contact:
contact@transparentdigitalservices.com
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO).
12. Third-Party Links
Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites.
13. Children’s Privacy
Lupe is not intended for individuals under the age of 18. We do not knowingly collect personal data from children.
14. Changes to This Policy
We may update this Privacy Policy from time to time. Any updates will be published on this page with a revised “Last updated” date.
15. Contact Us
If you have any questions about this Privacy Policy or how we process personal data, please contact:
Transparent Digital Services Limited
303 The Pill Box
115 Coventry Road
London
England
E2 6GH