UK GDPR • Data Protection Act 2018 • ICO Registered

Privacy Policy & Data Protection

Official data governance and privacy policy for lucasmalec.com, operated by Mind Reflection LTD.

Document Version: 2.1 • Effective Date: September 2026 • Governing Law: United Kingdom (Northern Ireland)

1. Statutory Company & Data Controller Information

Operating Legal Entity Mind Reflection LTD (Company No: NI626017)
Incorporated in Northern Ireland, UK
ICO Data Protection Reference ZA317530
Verified on UK ICO Register ↗
Registered Office Unit 869A, Moat House
54 Bloomfield Avenue, Belfast BT5 5AD
Data Protection Officer Lucas Malec (Managing Director)
sayhi@lucasmalec.com

2. Scope of This Policy

This policy applies to all business communications, IT advisory services, technical solutions, and web interactions conducted via lucasmalec.com.

lucasmalec.com functions as a professional portfolio and commercial trading presence for the IT consulting, cloud architecture, and systems engineering operations of Mind Reflection LTD.

3. Our Technical Data Commitments (Privacy by Architecture)

  • Zero Invasive Tracking: We deploy no advertising cookies, no Meta Pixels, and no third-party behavioral profiling tools.
  • Data Minimisation: We collect only the data strictly necessary to respond to client inquiries, fulfill service level agreements (SLAs), and secure our infrastructure.
  • Enterprise Security: All data in transit is encrypted using modern TLS 1.3 ciphers, hardened server firewalls, and isolated Linux environments.

4. Categories of Personal Data Processed

  • Client Inquiry Data: Name, business email, telephone number, company name, and project scope submitted through our contact channels.
  • Contractual & Billing Data: Service agreements, company registration details, VAT numbers, invoice records, and payment logs.
  • Server Access Logs: IP address, browser user-agent, timestamp, requested resource, and HTTP status code strictly utilized for DDoS mitigation, intrusion detection, and fail2ban firewalls.

5. Lawful Basis for Processing (UK GDPR Art. 6)

  • Contract Performance (Art. 6(1)(b)): To prepare technical proposals, manage IT deployments, and deliver enterprise SLAs.
  • Legal Obligation (Art. 6(1)(c)): To maintain mandatory corporate, accounting, and tax records under the UK Companies Act 2006 and HMRC regulations (6+1 years).
  • Legitimate Interests (Art. 6(1)(f)): To maintain 100% server availability, prevent unauthorized brute-force attempts, and protect digital assets.

6. Your Statutory Rights Under UK GDPR

You have full statutory rights regarding your personal information:

  • Right of access to your data (Subject Access Request).
  • Right to rectification of incomplete or inaccurate records.
  • Right to erasure (Right to be Forgotten), subject to statutory tax and accounting retention rules.
  • Right to restrict or object to processing based on legitimate interests.
  • Right to data portability in a machine-readable format.

To exercise your rights, email the Data Protection Officer directly at sayhi@lucasmalec.com. We respond within 30 days without fee.

7. Regulatory Authority & Complaints

You have the right to lodge a complaint with the UK supervisory authority:

Information Commissioner’s Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Helpline: 0303 123 1113 • Website: ico.org.uk
Mind Reflection LTD Registration Reference: ZA317530