Last updated: 14 July 2026
On this page
- Introduction
- Who we are
- Information we collect
- How we use your information
- Services and technology providers
- Cookies
- Your rights
- Complaints
- Contact us
1. Introduction
Lugira Accounting respects your privacy and is committed to protecting your personal information.
This Privacy Notice explains how we collect, use, store, share and protect personal information when you:
- visit our website;
- contact us through our website, by email or by telephone;
- book a consultation;
- subscribe to our newsletter;
- request information about our services; or
- become a client of Lugira Accounting.
This Privacy Notice has been prepared with reference to the UK General Data Protection Regulation, the Data Protection Act 2018 and the Privacy and Electronic Communications Regulations.
2. Who we are
The data controller responsible for your personal information is:
Irina Lugovskaya
Trading as Lugira Accounting
Address:
75 Gilpin Crescent
Twickenham
London
TW2 7BP
United Kingdom
Email: mail@lugiraaccounting.co.uk
In this Privacy Notice, “Lugira Accounting”, “we”, “us” and “our” refer to Irina Lugovskaya trading as Lugira Accounting.
We determine the purposes for which personal information is used and the way in which it is processed.
3. Personal information we collect
The personal information we collect depends on how you interact with us and which services you request.
Information you provide directly
We may collect:
- your name;
- business or trading name;
- email address;
- telephone number;
- postal or business address;
- details entered into our contact or consultation forms;
- information contained in emails and other correspondence;
- information about the accounting, bookkeeping, payroll or tax services you require;
- information provided when you subscribe to our newsletter;
- information required to establish and manage a client relationship.
If you become a client, we may also collect:
- date of birth;
- National Insurance number;
- Unique Taxpayer Reference;
- company number;
- VAT registration number;
- PAYE reference numbers;
- identification documents;
- proof of address;
- bank and payment information;
- income and expense records;
- invoices, receipts and bank statements;
- payroll and employment information;
- pension information;
- accounting records;
- tax returns and tax calculations;
- information concerning directors, shareholders, employees, customers and suppliers;
- correspondence with HM Revenue & Customs or Companies House;
- other information necessary to provide the agreed services.
Please do not send passports, bank statements, tax records or other sensitive documents through the general website contact form. Where such information is required, we will provide instructions for sending it by an appropriate method.
4. Information collected automatically
When you visit our website, certain technical information may be collected automatically, including:
- your IP address;
- browser type and version;
- device type;
- operating system;
- referring website;
- pages viewed;
- time and date of your visit;
- approximate geographical location derived from your IP address;
- website interaction and performance information;
- cookie identifiers and consent preferences.
Essential technical information may be processed where necessary to operate and secure the website.
Analytics information will only be collected after you have consented to analytics cookies, where consent is required.
5. How we collect personal information
We may collect personal information:
- directly from you;
- through our website contact form;
- when you book a consultation;
- when you subscribe to our newsletter;
- through email or telephone correspondence;
- from documents you provide;
- from publicly available sources such as Companies House;
- from HM Revenue & Customs, where authorised;
- from your employer, business, previous accountant or adviser;
- from another person whom you have authorised to communicate with us;
- from accounting, payroll and cloud software used to provide our services;
- through cookies and similar website technologies.
Where we receive personal information from someone other than you, we will provide appropriate privacy information where required by law.
6. How we use your personal information
We may use personal information for the following purposes.
Responding to enquiries
We use your contact details and the information contained in your enquiry to:
- respond to your questions;
- arrange a consultation;
- understand which services you require;
- provide information about our services;
- prepare a proposal, quotation or engagement letter;
- take steps at your request before entering into a contract.
Lawful basis: taking steps before entering into a contract and our legitimate interests in responding to business enquiries.
Providing accounting and related services
We may use your personal information to:
- provide bookkeeping services;
- prepare accounts;
- prepare and submit VAT returns;
- administer payroll;
- prepare Self Assessment tax returns;
- prepare Corporation Tax returns;
- provide management accounting and business support;
- communicate with HM Revenue & Customs or Companies House where authorised;
- maintain accounting and tax records;
- provide professional advice;
- manage our relationship with you.
Lawful basis: performance of a contract, taking steps before entering into a contract and compliance with legal obligations.
Client identification and compliance checks
We may process personal information to:
- verify your identity;
- verify your address;
- carry out client due diligence;
- comply with anti-money laundering requirements;
- assess whether we can accept or continue an engagement;
- comply with legal and professional obligations;
- prevent fraud and financial crime.
Lawful basis: compliance with a legal obligation and our legitimate interests in protecting our business and preventing unlawful activity.
Business administration
We may use personal information to:
- maintain client records;
- issue invoices;
- process and record payments;
- administer contracts;
- manage complaints;
- maintain insurance and professional records;
- obtain legal, technical or professional advice;
- protect our legal rights;
- manage the security of our website and systems.
Lawful basis: performance of a contract, compliance with legal obligations and our legitimate interests in operating and protecting our business.
Website analytics
Subject to your cookie preferences, we may use Google Analytics to understand:
- how visitors find our website;
- which pages they visit;
- how visitors use the website;
- which devices and browsers are used;
- how the website can be improved.
Lawful basis: consent.
Google Analytics must remain disabled until the visitor has accepted analytics cookies.
Newsletter and marketing communications
Where you have subscribed to our newsletter, we may use your name and email address to send:
- accounting and tax updates;
- information about changes in UK legislation;
- articles and guides;
- information about our services;
- occasional business news and announcements.
Lawful basis: consent or, where legally permitted, legitimate interests together with an applicable PECR exception.
You can unsubscribe at any time by:
- clicking the unsubscribe link in an email; or
- emailing mail@lugiraaccounting.co.uk.
Marketing emails must identify the sender and provide a valid way to opt out.
7. Our lawful bases
Depending on the circumstances, we may rely on the following lawful bases:
Contract
Processing is necessary to enter into or perform a contract with you.
Legal obligation
Processing is necessary to comply with tax, accounting, anti-money laundering, regulatory or other legal obligations.
Legitimate interests
Processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms.
Our legitimate interests may include:
- responding to business enquiries;
- operating and improving our services;
- maintaining accurate business records;
- protecting our website and systems;
- preventing fraud and misuse;
- recovering debts;
- establishing, exercising or defending legal claims.
Consent
We may rely on your consent for:
- non-essential website cookies;
- Google Analytics;
- newsletter subscriptions;
- certain marketing activities.
Where we rely on consent, you may withdraw it at any time.
8. Special category information
Some accounting, payroll or tax records may contain special category information, such as information concerning:
- health;
- trade union membership;
- religious beliefs;
- racial or ethnic origin;
- other legally protected categories of information.
We will only process this information where it is genuinely necessary and where an appropriate lawful basis and additional legal condition apply.
We ask clients not to provide special category information unless it is relevant to the service being provided.
9. Criminal offence information
In limited circumstances, client due diligence or professional work may involve information concerning criminal convictions or offences.
We will only process such information where permitted by law and where appropriate safeguards are in place.
10. Services and technology providers we use
We use third-party providers to operate our website, communicate with clients and provide accounting services.
These providers may process limited personal information on our behalf or as independent data controllers, depending on the service involved.
Krystal Hosting
Our website is hosted using services provided by Krystal Hosting.
Krystal may process:
- website files;
- server logs;
- IP addresses;
- technical security information;
- website backups;
- limited information submitted through the website.
Krystal is used for website hosting, server management, backups, performance and security.
WordPress
Our website is built using WordPress.
WordPress is used to:
- publish website pages and articles;
- manage website content;
- operate plugins and website functionality;
- process contact and newsletter forms;
- manage administrator accounts.
WordPress itself is a website platform. Additional data processing may occur through the plugins and services connected to it.
Fluent Forms
We intend to use the free version of Fluent Forms for our website contact and consultation forms.
Fluent Forms may process:
- name;
- email address;
- telephone number;
- business name;
- enquiry details;
- consent confirmation;
- date and time of submission;
- IP address, where enabled;
- technical anti-spam information.
Form submissions may be stored temporarily or permanently in the WordPress database and may also be sent to us by email.
We will configure the forms to collect only the information reasonably necessary for the enquiry.
The free version provides contact-form creation, notifications, spam-protection options and submission management.
Microsoft Outlook
We use Microsoft Outlook or associated Microsoft email services to send, receive and store business emails.
Microsoft may process:
- email addresses;
- email content;
- attachments;
- correspondence metadata;
- contact information.
Users should avoid sending highly sensitive information by ordinary email unless specifically requested.
Google Drive
We may use Google Drive as a cloud storage and document-sharing service.
Google Drive may be used to store or share:
- accounting records;
- spreadsheets;
- correspondence;
- client documents;
- working papers;
- reports and supporting information.
Access will be restricted to authorised persons.
Where practical, particularly sensitive information should be shared through restricted folders and protected using suitable access controls.
Google Analytics
We may use Google Analytics to measure website traffic and performance.
Depending on the configuration and your consent, Google Analytics may process:
- cookie identifiers;
- device and browser information;
- IP-related technical data;
- approximate location;
- page views;
- interactions with the website;
- referral information.
Google Analytics will only be activated after consent has been given through our cookie banner.
We will use available privacy controls, including appropriate data-retention settings and IP-related protections where available.
QuickBooks
We may use QuickBooks to provide accounting, bookkeeping and financial administration services.
Information processed in QuickBooks may include:
- customer and supplier details;
- invoices;
- bank transactions;
- expenses;
- financial reports;
- VAT information;
- payroll or payment information where applicable.
Xero
We may use Xero for bookkeeping, accounting, bank reconciliation, VAT reporting and related client services.
Information processed in Xero may include:
- contact details;
- bank transactions;
- sales and purchase invoices;
- expenses;
- accounting records;
- VAT records;
- payroll information where applicable.
Sage
We may use Sage for accounting, bookkeeping, payroll and reporting services.
Information processed may include:
- client and employee details;
- payroll records;
- financial transactions;
- invoices;
- VAT records;
- accounting reports.
We will normally use only the accounting platform relevant to the particular client. Client information will not automatically be entered into all three systems.
MailPoet
We intend to use MailPoet for newsletter subscriptions and email marketing.
MailPoet may process:
- name;
- email address;
- subscription status;
- consent date and time;
- email delivery status;
- email opens and link clicks, where tracking is enabled;
- unsubscribe records.
MailPoet integrates directly with WordPress and offers a free plan suitable for a small initial subscriber list.
We recommend enabling double opt-in so that subscribers must confirm their email address before joining the mailing list.
Yoast SEO
We use or may use Yoast SEO to manage:
- page titles;
- meta descriptions;
- search-engine indexing instructions;
- XML sitemaps;
- website metadata.
Yoast SEO is not used by us as a client database or as a contact-form service.
However, technical information may be processed if optional Yoast integrations, usage tracking or connections to external webmaster tools are enabled.
We recommend disabling optional usage tracking unless it is genuinely needed.
Complianz
We recommend using the free version of Complianz – GDPR/CCPA Cookie Consent to manage:
- the cookie banner;
- cookie categories;
- consent choices;
- blocking of non-essential cookies;
- cookie scanning;
- the Cookie Policy;
- records of visitor consent where supported.
Complianz provides a conditional cookie banner and cookie-policy functionality based on its cookie scan.
11. Who we may share personal information with
Where necessary and lawful, we may share personal information with:
- HM Revenue & Customs;
- Companies House;
- banks and payment providers;
- pension providers;
- professional advisers;
- insurers;
- software and cloud providers;
- website hosting and technical support providers;
- payroll and accounting platforms;
- identity-verification providers;
- regulatory and law-enforcement authorities;
- courts and legal representatives;
- subcontractors or consultants assisting with the agreed services;
- a successor to our business in the event of a sale, transfer or reorganisation.
We do not sell or rent personal information.
We only disclose information where:
- it is necessary to provide an agreed service;
- you have authorised us to do so;
- it is necessary to comply with the law;
- it is necessary to protect legal rights; or
- another lawful basis applies.
12. Acting as your agent
Where you authorise us to act on your behalf, we may disclose relevant information to:
- HM Revenue & Customs;
- Companies House;
- pension providers;
- payroll bodies;
- previous accountants;
- banks;
- software providers;
- other persons specifically authorised by you.
We will only act within the scope of the authority provided.
13. International transfers
Some of the technology providers we use may store or process information outside the United Kingdom.
Where personal information is transferred internationally, we will take reasonable steps to ensure that an appropriate legal transfer mechanism is used.
This may include:
- UK adequacy regulations;
- the UK International Data Transfer Agreement;
- the UK Addendum to the EU Standard Contractual Clauses;
- another mechanism permitted under UK data protection law.
The location of processing may depend on the provider, account configuration and service selected.
14. How long we retain personal information
We retain information only for as long as reasonably necessary for the purpose for which it was collected and to comply with legal, tax, accounting, professional and insurance obligations.
Our usual retention periods are:
| Type of information | Usual retention period |
|---|---|
| General enquiries that do not become clients | Up to 12 months |
| Consultation requests | Up to 12 months |
| Newsletter subscription records | While subscribed and for a reasonable period afterwards to record consent or an opt-out |
| Contact-form submissions | Up to 12 months unless required for an ongoing engagement |
| Client engagement and identification records | Normally at least 5 years after the business relationship ends |
| Anti-money laundering records | Normally 5 years after the business relationship or relevant transaction ends |
| Accounting and tax records | Normally at least 6 years after the relevant accounting period |
| Contracts, invoices and payment records | Normally 6 years after the relationship or transaction ends |
| Payroll information | Normally at least 6 years after the relevant tax year |
| Website security logs | Normally up to 12 months unless needed for an investigation |
| Analytics information | In accordance with our configured Google Analytics retention period |
| Records relating to legal claims | For as long as reasonably necessary to establish, exercise or defend the claim |
We may retain information for longer where:
- required by law;
- required by HM Revenue & Customs;
- an enquiry, investigation or dispute is ongoing;
- legal proceedings are anticipated;
- professional or insurance requirements apply.
At the end of the applicable retention period, information will be securely deleted, destroyed or anonymised.
15. Information security
We use appropriate technical and organisational measures to protect personal information.
These may include:
- password-protected accounts;
- multifactor authentication;
- restricted user access;
- encrypted connections;
- secure cloud storage;
- software and security updates;
- backups;
- malware and firewall protection;
- confidentiality obligations;
- access reviews;
- secure deletion procedures.
Access to client information is limited to persons and providers who need it for a legitimate business purpose.
No internet, email or electronic storage system can be guaranteed to be completely secure. Visitors and clients should not send highly sensitive documents through an unsecured form or ordinary email unless specifically instructed.
16. Cookies
Our website uses cookies and similar technologies.
Cookies may be categorised as follows.
Necessary cookies
These cookies are required for:
- website security;
- basic website operation;
- remembering consent choices;
- maintaining technical functionality.
Necessary cookies may be used without consent where they are strictly necessary.
Analytics cookies
Analytics cookies help us understand how visitors use the website.
We may use Google Analytics for this purpose.
Analytics cookies will only be placed after you have selected Accept analytics or Accept all in the cookie banner.
Functional cookies
Functional cookies may support optional website features, embedded content or user preferences.
Where consent is required, these cookies will remain disabled until consent is given.
Marketing cookies
We do not currently intend to use advertising or behavioural marketing cookies.
Should this change, the cookie banner and Cookie Policy will be updated before such cookies are enabled.
You can change or withdraw your cookie consent at any time by selecting the Manage Cookie Preferences link in the website footer.
Further information is available in our separate Cookie Policy.
17. Newsletter consent
Subscription to our newsletter is optional.
The newsletter subscription form should contain an unticked consent box or clear subscription button explaining that the person is signing up to receive marketing and accounting updates.
We recommend using double opt-in.
We will keep a record of:
- the email address submitted;
- the date and time of subscription;
- the consent wording shown at the time;
- confirmation of the subscription;
- any subsequent unsubscribe request.
Unsubscribing from marketing will not prevent us from sending administrative or service-related communications to current clients.
18. Links to third-party websites
Our website may contain links to third-party websites.
We are not responsible for:
- their content;
- their security;
- their privacy practices;
- the way they use personal information.
You should review the privacy notice of the relevant third-party website before providing information.
19. Your data protection rights
Depending on the circumstances, you may have the right to:
- be informed about how your information is used;
- request access to your personal information;
- request correction of inaccurate information;
- request completion of incomplete information;
- request deletion of your information;
- request restriction of processing;
- object to processing based on legitimate interests;
- object to direct marketing;
- request transfer of certain information;
- withdraw consent;
- complain about the use of your information;
- obtain safeguards relating to certain automated decisions.
These rights are not absolute, and legal exemptions may apply.
You will not normally be required to pay a fee to exercise your rights.
We may ask for information necessary to verify your identity before responding.
To exercise your rights, contact:
Email: mail@lugiraaccounting.co.uk
Postal address:
Irina Lugovskaya
Lugira Accounting
75 Gilpin Crescent
Twickenham
London
TW2 7BP
United Kingdom
The privacy notice should explain the individual’s rights, including withdrawal of consent and how to complain.
20. Automated decision-making
We do not currently make decisions about individuals based solely on automated processing where those decisions produce legal or similarly significant effects.
Should this change, we will update this Privacy Notice and provide the information required by law.
21. Children’s information
Our website and services are intended for adults and businesses.
We do not knowingly collect personal information from children through this website.
If you believe a child has provided information to us, please contact us so that we can investigate and take appropriate action.
22. Complaints
Please contact us first if you have concerns about the way we use your personal information.
Email: mail@lugiraaccounting.co.uk
You also have the right to complain to the Information Commissioner’s Office.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
United Kingdom
Telephone: 0303 123 1113
23. Changes to this Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in:
- our services;
- the software we use;
- our data-processing activities;
- legal or regulatory requirements;
- website functionality.
The current version will always be published on this page.
The date at the top of the page will show when it was last updated.
24. Contact us
For questions about this Privacy Notice or the way we process personal information, contact:
Irina Lugovskaya
Trading as Lugira Accounting
75 Gilpin Crescent
Twickenham
London
TW2 7BP
United Kingdom
Email: mail@lugiraaccounting.co.uk
