Privacy Policy & Cookie Notice

Our organisation works globally and includes the following legal entities:

• Luminate Foundation Inc;
• Luminate Holdings LLC;
• Luminate Fund LLC;
• Luminate US Services LLC;
• Luminate US Services Limited;
• Luminate Projects Limited; and
• Luminate Strategic Initiatives.

Any references to “Luminate”, “we”, “us” or “our” in this privacy and cookie policy refer to all of the entities above. 

If you want to know more about this notice and how we approach data protection and your privacy, please email [email protected]. 

When we use the term personal information, we mean any information which identifies you or which could be used to identify you. At its simplest this could be your name and/or email address. Personal information also includes information about your expertise in a particular area as well as contributions you may make (for example, when we ask you to contribute to reports or we conduct surveys to evaluate our impact). 

We occasionally anonymise personal information, which means that we remove all ability to connect you to the information (and anonymised information is not personal information that is subject to this policy or data protection law). For example, when we collect personal information for the purposes of research and evaluation, we will anonymise responses wherever possible. Where this is not possible, we will inform respondents accordingly.  

We try not to collect information from children, and if we find this information in a dataset, we will permanently delete this information.  

Certain types of personal information are sensitive and merit more protection. For example, information about your race or ethnic origins, political opinions, sex life or sexual orientation, religious beliefs, health information, biometric and genetic data. Criminal information (information about convictions or allegations about convictions) also merits additional protection and special consideration. Financial information (bank details, identity documents, etc) can also cause harm when misused, so we endeavour to treat these as sensitive, as well.  

We collect and use personal information about people with whom we work, people interested in Luminate’s work, and people we believe could be helpful to our work. These include:  

• Contacts at partners (and potential partners). By partners, we are referring to organisations that we fund.  
• Experts in our areas of work and regions of focus 
• Stakeholders (for example, public sector figures, contacts at other foundations, and potential co-investors) 
• Contacts at co-funders
• Advisors to Luminate (members of our Advisory Group and others) 
• Attendees of our events  
• Vendors with whom we work (and who are recommended to us) 
• Visitors to our website (and people who engage with us on social media) 
• Applicants for jobs at Luminate 

If you are a staff member of Luminate, we have a separate Employee Privacy Notice (which can be requested from our People Operations team).  

For job applicants, see section 8 for more information.

We collect your information from three types of sources: 

• Directly from you: For example, if you sign up for an event with us.  
• Indirectly from another source: For example, if a potential partner provides information about its board of trustees as part of due diligence.  
• When it is available publicly: For example, if you write an article about an area in which we are interested or engage with us on social media.  

The information we collect depends upon your relationship with us, and so we have set out below the types of information we collect and from whom we collect it.  

• Name (all) 
• Contact details (all) 
• Information you provide to us (all) 
• Records of our communication with you (all) 
• Role & associated organisations (partners*, experts, stakeholders, co-funders, advisors, attendees, vendors) 
• Records of our relationship with you - for example: reports, contracts, funding disbursements (partners, experts, stakeholders, co-funders, advisors, vendors) 
• References from other relevant people (partners, advisors, vendors) 
• Information about staff and beneficiaries – for example: collected during due diligence and portfolio management (partners) 

*Note that where we refer to “partners”, we also mean “potential partners” who are undergoing the due diligence process.  

We do not usually collect sensitive personal information about you. We will only process these types of personal information about you if we have a valid reason for doing so and only if the law allows us to do so.  

There are two key exceptions:  

• First, if you are a partner or potential partner, we may collect sensitive personal information as part of the due diligence process (for example, race or ethnic origins to understand the diversity of your organisation). We may also collect sensitive personal information during the course of our relationship with you (for example, health information if there’s a crisis which requires emergency support).  
• Second, if you are a job applicant, we may collect sensitive personal information as part of the application process. See section 8 for more information.  

Please note that if you fail to provide us with the relevant details that we request, we will not be able to consider you for funding or appoint you to provide services. 

We use your personal information to help Luminate operate. This includes: 

• Promoting our work and values, for example through case studies in blogs and speaking engagements 
• Assessing how and where we distribute our funding 
• Further developing and refining our work  
• Evaluating our impact and identifying areas for improvement 
• Administering our funding (for example, receiving reports and making further disbursements) 
• Amplifying our partners’ work through our website and social media 
• Running and participating in events (for example, partner convenings and conferences) 
• Handling any concerns or queries which arise within the course of our work 
• Procuring services and advice from you (whether there’s a vendor and/or advisor relationship) 
• Operating Luminate (for example, making financial payments or participating in annual audits) 
• Ensuring the proper governance and stewardship of our funding

Our lawful bases

We can only use your personal information if we have a valid reason. In Europe, this is known as a lawful basis of processing. Below we explain the lawful bases which we think apply to our use of personal information. 

Legitimate interests is a flexible lawful basis which allows us to use your personal information provided that: 

• We have a good reason to do so. For example, to evaluate whether we should invest in a potential partner. 
• You can reasonably expect that we would use your personal information in this way. In other words, our use of your personal information shouldn’t be a surprise. 
• It fits with your rights and it doesn’t affect you unfairly. Your rights are explained in section 14.  

When we rely upon legitimate interests as a lawful basis, our use of your personal information must be fair and balanced, and we need to consider the points above.

Consent is when we ask for your permission to use your personal information for a specific purpose. For example, if we ask to use a quote from you to promote our work. You always have the right to withdraw your consent. Just send us an email or contact us using the details set out in section 1.  

We may also need to process your personal information to comply with a legal obligation on us. For example, to run checks on your identity prior to disbursing funding. 

We may also need to process personal information in order to perform our contract with you. For example, where you provide us with your bank details for payment.  

In the limited cases where we collect sensitive personal information, we will rely on one of the following conditions: 

• Consent
• The processing of the data is necessary for reasons of substantial public interest, including for purposes of equality of opportunities monitoring
• In some very limited circumstances, we might need to process this information to protect your vital interests, for example in an emergency situation. 

The table in Schedule 1 sets out when we might use different types of personal information for different purposes, as well as the appropriate lawful bases in each case.

We may contact you when you give us your contact details or when we believe that you may wish to hear from us. Some of these communications may be administrative (for example, to respond to a query or request from you) and some may be promotional (for example, a newsletter with updates about our work).   

We’ll only contact you when we’re allowed to do so. And you can request that we cease contacting you with promotional material at any time. Though please note that we may still send you administrative communications (for example, if you’re a contact at a partner, we will contact you about your funding).

We handle personal information of those who apply to work with us slightly differently than we have discussed above, so we’ve included a dedicated section. 

When you apply to work at Luminate, we will collect and use your information for the purposes of evaluating your application as part of our recruitment process.  

We will collect the following types of personal information: 

• Information you provide on your CV or resumé and any associated covering letter or email. 
• Information you provide during the course of the recruitment process (for example, during the interview phase). 
• Information provided by third parties about you, including former employers and named references. 
• Information recorded in our notes and records.  

We will use the personal information we collect about you to: 

• Assess your skills, qualifications, and suitability for the role. 
• Carry out background checks and reference checks (where applicable). 
• Communicate with you about the recruitment process. 
• Keep records about our recruitment process. 
• Comply with other legal and regulatory requirements.  
• If successful, enter into a contract of employment with you.  

It is in our legitimate interests to decide whether to appoint you to the role, since it would be beneficial to Luminate to appoint a qualified and appropriate person to the role.  

Please note that if you fail to provide us with the relevant details that we request, we will not be able to process your application. 

If you are successful in your application, we will transfer the personal information collected as part of your recruitment process to your employment record. We will also provide you with a staff specific privacy notice.  

If you are unsuccessful with your application we usually retain your personal information for two years after we communicated the decision to you, unless otherwise required to do so by law (for example, where immigration regulations require the retention of recruitment notes). 

As mentioned above, Luminate operates through several legal entities (listed above). These entities share systems, and so your personal information will be shared among these entities.  

We also use vendors to help us operate. For example, we have a database management provider and communications consultants. We have written agreements with our vendors that require them to help keep your personal information safe.  

There are other circumstances where we may need to share your personal information, for example: 

• If we spin out our operation or part of our operation to another organisation; 
• With co-funders and co-investors to help our portfolio grow; 
• With our professional advisors such as lawyers or accountants; 
• If we’re under any legal or regulatory obligation to do so; and  
• In connection with any legal proceedings or prospective legal proceedings, in order to establish, exercise, or defend our legal rights.  

If we share your information with any other third party, we will let you know in advance where possible.  

We will not sell your information.  

Our website includes links to other websites. This notice only covers how Luminate uses personal information and does not cover these other websites. We encourage you to read the privacy notices on other websites you visit.  

The success of Luminate depends in part on people amplifying our messages, and we have provided social media plugins to allow you to easily share content from our website with your networks. In doing so your personal information will be disclosed to these social media platforms. When you share content using these buttons, a new page will pop up from the relevant social media platform. If you’re already logged into your account on that social media platform, then you will probably be automatically logged into this pop-up page.  

We have no control over how social media platforms use your personal information. We encourage you to read the privacy notices on the various social media platforms you use (and engage with their privacy tools).  

Find out more about how these social media platforms use your personal information:  

• YouTube
• LinkedIn

It’s our job to keep your personal information safe and secure. We have security measures in place to protect your personal information, like encrypted messaging and secure systems.  

We also provide training to our staff on how to keep your information safe.  

While we seek to use appropriate organisational, technical and administrative measures to protect personal information within our organisation, unfortunately no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us using the details set out at Section 1 above.

As we mentioned, Luminate is a global foundation.  We also have staff and vendors working around the world in our key regions. This means we transfer your personal information to these various locations.  

Even as your information goes around the world, we are under an obligation to make sure that your information remains safe and secure. We implement appropriate safeguards accordingly, including by vetting our suppliers and putting in place strict contracts that cover the transfer of personal information to other countries and incorporate standard contractual clauses approved by the European Commission and/or UK Government (as appropriate) to protect your personal information.

We keep your personal information for as long as we reasonably need to use it for the purposes set out in section 6 and section 8 (for job applicants). Once the relevant retention period has expired, the information will be routinely deleted, as long as it is no longer necessary for another ongoing purpose, such as the fulfillment of a contract, the initiation of a contract or to protect or defend our position or that of a third party.

We have set out below a few examples of the periods of time we retain personal information. For full details contact us for a copy of our retention schedule.  

• Partner records: 12 years following the end of our funding 
• Unsuccessful potential partners: retained only for as long as necessary, and typically up to 3 years from our decision not to fund 
• Unsuccessful job applicants: 2 years from the communication of our decision 
• Research and evaluation information: retained on a long term or permenant basis where it forms part of formal programme evaluation or learning outputs, and otherwise only for as long as necessary. depending on the nature of the record.

You are in control of your personal information. When we use your personal information you have the right to: 

• Ask for a copy of the personal information we hold about you. We may ask you for proof of your identity. We will give you a copy of your personal information unless we consider that an exemption applies. If we withhold any of your personal information, we’ll explain why.  
• Ask that we erase the personal information we hold about you. We may not be able to erase your information (for example, we may be legally obliged to keep your personal information), but we will consider and respond to your request. 
• Ask that we correct any personal information that we hold about you that you believe to be incorrect.  
• Ask that we restrict the use of your personal information if you believe the information we hold is incorrect, or if we don’t have a valid reason for using your personal information.  
• Change your mind when you have provided your consent and withdraw that consent.  
• Ask us to stop using your personal information, if we are relying on legitimate interests as our lawful basis.  
• Make a complaint to us about our handling of your personal data.

To exercise these rights, contact us via details set out in Section 1 above. Please be aware that we may be unable to provide these rights to you under certain circumstances, for example if we are legally prevented from doing so or can rely on exemptions.

Other rights may apply under various legal regimes, which will not obviously apply to the way in which we use your personal information. For example, European data protection law allows you to port (or transfer) your personal information to a third party in certain circumstances.  

If you have any concerns about the way we are handling your personal information, or if you’ve raised a question or a complaint that we haven’t dealt with, you can (in certain cases) contact your data protection regulator directly. For example, the Information Commissioner’s Office in the UK. If you are based in the EU, you can find out more information about your local data protection authority here.

We may update this notice from time to time. If we update this notice in a way that significantly changes how we use your personal information we will bring these changes to your attention where reasonably possible. Otherwise, you can access the latest version on our website.  

Version: 2

Dated:  April 2026

© April 2026 Luminate. All rights reserved.

Cookies are small files that are placed on your computer or mobile deice by a website when you visit it. They contain details of your browsing history on that website and distinguish you from other users. Cookies send data back to the originating website on each subsequent visit or allow another website to recognise that user’s device and, for instance, remember your preferences and generally improve your online user experience. Like most websites, our website uses cookies.  

Although this notice refers to the general term cookie, it also applies to similar tracking technologies that we use (such as web beacons, clear GIFs and pixel tags).  

You can find out more about cookies at www.allaboutcookies.org.

1. To let you do things on the website. For example, to fill in application forms or view content.  
2. To collect statistics. This enables us to improve the website through analysis of usage figures and patterns. For example, it’s useful to us to understand our most popular content, and the way in which users interact with our website.  
3. To improve your experience with the website. For example, to ensure that users can find what they’re looking for quickly. 
4. To keep our website secure. For example, we take steps to make sure that personal information you give us does not fall into the wrong hands. 

Our websites use the following types of cookies and storage objects:

1. Our websites use transient cookies, which will be deleted once you close your browser. Session cookies, which fall into the category of transient cookies, enable our website(s) to identify different requests from your browser during the same session. Your device can be recognized once you return to our website(s). Session cookies will be deleted once you log out of your account on our website(s) and/or close your browser.
2. Our websites use persistent cookies. Persistent cookies expire or get automatically deleted after a set period; the duration differs depending on the specific cookie).

Cookies can be first-party, which means that they’re owned by Luminate.

Alternatively, cookies can be third-party. This means they’re not owned by the website which sets them and that the relevant information may be accessible to third parties. 

We differentiate between cookies that are necessary for our websites’ technical features (also known as necessary cookies) and optional cookies. To enable you to select your cookie preferences when you visit our websites, we provide you with the option to reject the use of cookies which do not fall under the “Necessary”, or “Essential” category using the cookie banner on our website. Please note that you cannot opt-out of our use of Necessary cookies, since these are necessary for the functioning of our websites.

We use the following type of non-essential cookies: 

• Functional cookies – Functional cookies help us to improve your experience on our websites through enhanced functionality. The cookies may be set by us or by third party providers whose services we use. If you do not allow these cookies then some or all of these services may not function properly.
• Analytics cookies – Analytics cookies (also known as ‘performance’ or ‘statistics’ cookies’) help us to know which pages are the most and least popular and see how visitors move around our websites. These are non-essential cookies that are used to better our platform. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance. 

The table in Schedule 2 provides more information about the cookies we use and why.

By clicking ‘Allow all cookies’ or the relevant accept tab on our cookie banner when you visit the website, you consent to our use of cookies as updated from time to time. In particular, you consent to cookies being stored on your computer or mobile device (unless rejected or disabled by your browser). You also have the option to ‘Disable tracking cookies’ so that you can reject non-essential cookies, [and to ‘Customise Settings’, so that you can provide your consent to some types of cookies, but not others, by toggling the relevant options as appropriate. You can change your preferences at any time.]

Most browsers also let you turn off either all or at least third-party cookies. What you can do depends upon which browser you are using. If you do not accept our use of cookies as described above, you can configure your browser to reject cookies. However, please be aware that this may impair or limit your ability to use the website. If you are attempting to reject cookies which are strictly necessary for the performance of the website. The ability to do this is usually found in the options, settings, or preferences menu of your browser or mobile device (and we include links for common browsers below).  

Click on the links below to find out how to change your cookies session in the relevant browsers and/or operating systems:

• Firefox
• Chrome
• Safari
• iPad/iPhone
• Samsung
• Brave

There is also software available which enables you to use settings that allow you to choose which cookies are set on your computer or mobile device, such as the Ghostery App.

We may update this notice from time to time and so we recommend you check this notice regularly. We aim to notify you if there are any significant changes by a notice on this website or by contacting you directly.   

Version: 2

Dated:  April 2026

© April 2026 Luminate. All rights reserved.