Privacy Policy

Policy version: Version 2.0

Last updated on 20th October 2025

Introduction

This Privacy Policy is provided by Larry Mann, a sole trader trading as LSMann, with principal place of business at 133 Macpherson Way, Ardeseir, IV2 7BQ for use of our website, being www.lsmann.com (Website). We offer professional heating and plumbing services including installation, maintenance, repairs, and emergency callouts for residential properties.

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share your personal information when you use our heating and plumbing services or interact with our website (your personal data).

It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).

We are the controller of personal data obtained via the Website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.

What this policy applies to

This privacy policy relates to your use of the Website, booking our heating and plumbing services through the Website, and the provision of these services at your property.

The Website may link to other websites owned and operated by us or by certain trusted third parties. These other websites may gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other websites, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.

Personal data we collect about you

The personal data we collect about you is primarily gathered during property assessments, service callouts, through our booking forms and service agreements. We also collect limited information through our Website. This includes:

Category of data

In more detail

Data collected when you use specific functions in the Website

Data you store online with us using the Website including your usage history (while such data may not always be personal data as defined at law in all cases, we will assume it is and treat it in accordance with this policy as if it were)

Other data the Website collects automatically when you use it

Your activities on, and use of, the Website which reveal your preferences, interests or manner of use of the Website and the times of use
Tracking information such as IP Address, Cookies, User Agent, Device Fingerprinting (which includes MAC address), Session IDs, Referral URLs, Tracking Pixels and Scripts Geolocation Data

Data collected when you make an enquiry with us

Your name, email address, contact details, property address, preferred appointment times, details about your heating and plumbing systems, property type, any specific access requirements, and information about the services you require. We may also collect information about your property's heating system specifications, plumbing configuration, and any historical maintenance records you provide.

Marketing and communications data

Your preferences in receiving marketing emails from us and our third parties and your communication preferences

We also collect, use and share aggregated and anonymised data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate service data and website usage patterns to analyse trends and improve our service offerings. This might include information about common heating system issues in specific areas, peak service request times, or how users interact with our online booking system.

We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.

Sensitive Data

Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; genetic data; biometric data (where used for identification purposes); data concerning health; data concerning a person’s sex life; and data concerning a person’s sexual orientation.

While we generally do not collect sensitive personal data, we may need to record information about specific access requirements or health conditions that could affect our ability to safely provide heating and plumbing services at your property. This information is only collected when necessary and with your explicit consent. We handle any such data with enhanced security measures, including encryption, restricted access protocols, and secure storage, in accordance with UK GDPR requirements. We do not collect information about criminal convictions.

If, however you do submit sensitive data to us, such as if you make this sensitive data available to other users of the Website (such as by publishing it through any forum feature, we may make available from time to time) we will assume that you have purposefully made any such sensitive data manifestly public.

How your personal data is collected

We use different methods to collect data from and about you including through:

Your interaction with us: We collect personal data from you directly when you sign up to the Website, subscribe to our communications, request for marketing emails to be sent to you, contact us directly or reach out to us via social media, make submissions via the Website when a forum element is available, or indirectly, such as your activity while using the Website, participate in any feedback or survey.
Automated technologies or interactions: As you interact with the Website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
How and WHY, we use your personal data

Under data protection law, we can only use your personal data if we have a proper reason, e.g.:

where you have given consent
to comply with our legal and regulatory obligations
for the performance of a contract with you or to take steps at your request before entering into a contract, or
for our legitimate interests or those of a third party

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).

The table below explains what we use your personal data for and why.

What we use your personal data for

Our reasons

Create and manage your account with us

To perform our contract with you or to take steps at your request before entering into a contract

Providing services and/or the functionalities of the Website to you

Depending on the circumstances, to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Website)

To enforce legal rights or defend or undertake legal proceedings

Depending on the circumstances:

to comply with our legal and regulatory obligations
in other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of others

Sending relevant marketing communications and for making personalised suggestions about our heating and plumbing services that may benefit your property, based on your property's requirements and service history

For our legitimate interests, to carry out direct marketing, develop our services and grow our business and having obtained your consent to receive direct marketing communications.

Carry out market research through your voluntary participation in surveys

Necessary for our legitimate interests to study how customers use the products, use our Website and to help us improve and develop our Website and products and services offered through the Website.

Communications with you not related to marketing, including about updates concerning your upcoming service appointments, maintenance schedules, emergency callouts, or other important notices

Depending on the circumstances:

to comply with our legal and regulatory obligations
to keep you updated on your service schedule and maintenance requirements
in other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you

Protect the security of systems and data

To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us

Operational reasons, such as improving efficiency, training, and quality control or to provide support to you

For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you

Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures

For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app

Updating and enhancing user records

Depending on the circumstances:

to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Website)
to comply with our legal and regulatory obligations
where neither of the above apply, for our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Website and the products and services offered through the Website

To comply with our legal and regulatory obligations

Depending on the circumstances:

to perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Website)
to comply with our legal and regulatory obligations

where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Website

To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency.

In such cases information will be anonymised where possible and only shared where necessary

Depending on the circumstances:

to comply with our legal and regulatory obligations
in other cases, for our legitimate interests or those of a third party, i.e., to protect, realise or grow the value in our business and assets

See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.

Marketing
- contacting us at accounts@lsmann.com

We may send you communications to inform you about our heating and plumbing services, maintenance reminders, energy efficiency tips, special offers, and emergency contact information. Our communications may include educational content about energy efficiency, boiler maintenance, plumbing best practices, heating system optimisation, and home safety tips. We ensure all communications are professional, relevant to our services, and aligned with principles.

We will always ask you for your consent before sending you marketing communications, except where you have explicitly opted-in to receiving email marketing from us in the past or except where you were given the option to opt-out of email marketing when you initially signed up for your account with us and you did not do so.

You will have the right to opt out of receiving marketing communications at any time by:

using the ‘unsubscribe’ link included in all marketing emails you may receive from us

We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.

For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.

Who we share your personal data with

We maintain strict confidentiality of your personal data in running our heating and plumbing business. We use secure storage systems to protect your service records, property information, and maintenance history. We work with trusted third-party payment processors to handle transactions securely. Access to your personal information is strictly limited to authorised staff members who are directly involved in providing our services, and service providers necessary for secure record-keeping and service delivery. We only share the minimum necessary information with each provider. All sharing of personal data is conducted with appropriate safeguards, including encryption and detailed data processing agreements that ensure GDPR and UK data protection compliance.

We only allow service providers to handle your personal data if we are satisfied, they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.

We or the third parties mentioned above may occasionally also need to share your personal data with:

external auditors, e.g. in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations

If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).

We will not share your personal data with any other third party.

How long your personal data will be kept

We will keep your personal data, including your service history, maintenance records, installation details, and customer correspondence, for as long as you are an active client and for a period of up to 6 years thereafter. This retention period is necessary to comply with record-keeping requirements, accounting obligations, and legal obligations, including warranty claims and the potential pursuit or defence of legal claims. Your payment information is only retained for as long as necessary to process payments and handle any payment-related disputes. After you cease being an active client, we will secure your personal data in a separate protected storage system so that only authorised staff members have access to such data on a ‘need to know basis’.

Following the end of the aforementioned retention period, we will delete or anonymise your personal data, including all service records, installation details, and maintenance history, in accordance with applicable data protection requirements.

Transferring your personal data out of the UK

At this point in time, we do not transfer your personal data outside of the UK. If this changes, we would comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with the section on ‘Changes to this privacy policy’ below.

Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to:

The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
Any country located outside the UK/EEA: we would rely on an appropriate safeguard under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements with our service providers.

In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.

Your rights

Before exercising your rights outlined below, please note that we process your personal data to: (1) fulfil our contractual obligations under our heating and plumbing service agreements; (2) process and record payments for our services; (3) provide you with our heating and plumbing services including installations, repairs, maintenance, and emergency call-outs; and (4) maintain appropriate records of your property’s heating and plumbing systems, service history, and warranty information. Some of this processing is required by law and professional standards, particularly regarding safety certificates, warranties, and compliance with building regulations.

You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.

Access to a copy of your personal data

The right to be provided with a copy of your personal data.

Correction (also known as rectification)

The right to require us to correct any mistakes in your personal data.

Erasure (also known as the right to be forgotten)

The right to require us to delete your personal data—in certain situations.

Restriction of use

The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data.

Data portability

The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.

To object to use

The right to object:

at any time to your personal data being used for direct marketing (including profiling)
in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests.
- provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and

Not to be subject to decisions without human involvement

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.

If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:

let us know which right(s) you want to exercise and the information to which your request relates

Keeping your personal data secure

We have appropriate security measures to protect your personal data, including your property information and service history. We implement strict security protocols for all client records, including property assessments, installation details, and maintenance records. Access to your personal data is strictly limited to authorised staff members who need it to provide our heating and plumbing services. All our staff are bound by professional confidentiality obligations regarding your personal and property information.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

How to complain

Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.

You also have the right to lodge a complaint with the Information Commissioner.

The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.

Website Usage Notice

We provide heating and plumbing services throughout our service area and maintain www.lsmann.com for both informational purposes and service bookings. Any personal information you provide through our website contact forms is used to respond to your inquiries and process service requests.

Cookies help us to recognise you and your device and allow us to store some information about your preferences or past actions, such as your preferred heating system types or previous service appointments, and remember these preferences next time you visit www.lsmann.com.

For example, we may monitor how many times you visit our Website, which heating and plumbing services you view, and which service areas you browse. This information helps us understand how our users interact with the Website. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies, please see below.

For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

Consent to use cookies and changing settings

We will ask for your consent to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested (e.g. to maintain your login status while booking heating services or to remember your location preferences for service area checking).

You can withdraw any consent to the use of cookies or manage any other cookie preferences by using the tool made available to you within the Website itself. You can then adjust sliders or untick boxes as appropriate to reflect your choice. It may be necessary to refresh or restart the Website for the updated settings to take effect.

Our use of cookies

We use the following cookies:

Strictly necessary cookies: These are cookies that are required for the operation of our Website. These essential cookies are always enabled because the Website will not work properly without them. You can switch off these cookies in your browser settings but then you may not be able to access all or parts of our Website.
Analytical or performance cookies: These allow us to recognise and count the number of visitors and to see how visitors navigate our Website. This helps us improve the Website's functionality, for example, by ensuring customers can easily find information about our heating and plumbing services and make service bookings efficiently.
Functionality cookies: These are used to recognise when you return to the Website. This enables us to personalise our content for you, greet you by name, remember your service preferences (such as preferred appointment times or heating system types), and maintain your logged-in status for booking services.
Targeting cookies: These cookies record your visit to the Website, including which heating and plumbing services you've viewed and the service areas you've checked. We will use this information to make the Website and our service recommendations more relevant to your needs.
How to turn off all cookies and consequences of doing so

If you do not want to accept any cookies, you may be able to change your device settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of the Website. For further information about cookies and how to disable them, please go to the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

Changes to this policy

We may change this privacy policy from time to time to reflect updates in our heating and plumbing services, service offerings, or regulatory requirements. When we make significant changes, we will take steps to inform you via email, through our website www.lsmann.com, or through written notice provided during our next service visit.

How to contact us

You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

LSMann, 133 Macpherson Way, Ardeseir, IV2 7BQ
accounts@lsmann.com
01667303666