Lumorus CoSec Retainer, CoSec Hub and Governance Knowledge Centres Consumer Protection and Fair Use Policy
Effective date: 16 June 2026 Last Updated: 16 June 2026
Effective date: 16 June 2026
Last Updated: 16 June 2026
- Purpose of this Policy
This Consumer Protection and Fair Use Policy explains how Lumorus seeks to treat clients fairly, communicate transparently, and operate the CoSec Retainer, CoSec Hub and Governance Knowledge Centres in a responsible, commercially fair and legally compliant way.
This Policy covers:
- the CoSec Retainer service;
- access to and use of the CoSec Hub;
- service delivery through the Governance Knowledge Centres;
- free month, trial, introductory or promotional offers;
- pricing, billing, renewals, cancellation and refunds;
- service limits, fair usage and client responsibilities;
- complaints and service concerns;
- marketing claims and sales communications.
Lumorus is based in the United Kingdom and its client contracts may be governed by the laws of England and Wales, unless otherwise agreed in writing. However, Lumorus works with clients globally. Where mandatory consumer protection, fair trading, electronic commerce, digital services, subscription, cancellation, data protection or similar laws apply in a client’s location, Lumorus will take reasonable steps to comply with those applicable requirements.
Nothing in this Policy is intended to exclude, restrict or limit any statutory rights that cannot lawfully be excluded under applicable law.
- Who this Policy applies to
This Policy applies to:
- clients and prospective clients of the CoSec Retainer;
- authorised users of the CoSec Hub;
- clients receiving services through the Governance Knowledge Centres;
- individuals, founders, sole traders, small businesses, SMEs, companies, charities, funds, investment vehicles and other organisations that engage Lumorus;
- client representatives, directors, officers, employees, advisers and authorised contacts who interact with Lumorus services.
Different legal protections may apply depending on whether the client is acting as a consumer, a sole trader, a business, a company, a charity, a fund, a public body or another type of organisation.
Where a client is acting for business or organisational purposes, consumer protection laws may not apply in the same way as they apply to individual consumers. However, Lumorus will still apply the core principles of fairness, transparency and good faith in its dealings with clients.
- Key definitions
In this Policy:
CoSec Retainer means the packaged company secretary and governance support service provided by Lumorus on a retainer, subscription or recurring service basis.
CoSec Hub means Lumorus’ digital platform, portal or technology environment used to support company secretary services, governance workflows, client communications, records, tasks, filings, calendars, documents, reporting and related service delivery.
Governance Knowledge Centres means the Lumorus service delivery centres, expert teams, operating hubs, knowledge systems and specialist workspaces through which company secretaries and other Lumorus experts support clients. The Governance Knowledge Centres are not intended to be a general public download library or open digital marketplace for downloadable content unless Lumorus expressly states otherwise
Client means the person or organisation that enters into an agreement with Lumorus.
Authorised User means a person approved by the client or Lumorus to access the CoSec Hub or interact with Lumorus systems for the purposes of receiving or supporting the services.
Applicable law means the law that applies to the relevant client, service, contract, transaction, jurisdiction, user, marketing activity or platform use.
- Our fairness principles
Lumorus aims to ensure that:
- clients understand what they are buying before they commit;
- prices, fees and material charges are presented clearly;
- free month, trial, promotional and “risk-free” offers are explained accurately;
- important limitations and exclusions are not hidden;
- cancellation and renewal terms are clear;
- additional charges are explained before they are incurred where reasonably possible;
- service descriptions are honest and not misleading;
- clients are not pressured through artificial urgency, misleading scarcity or unclear pricing;
- complaints are handled fairly;
- platform access and service usage are managed reasonably;
- global clients are treated consistently, while recognising that local laws may differ.
- Relationship with local laws
Lumorus may contract under English law, notwithstanding that its clients may be located in different jurisdictions. Some countries have mandatory laws that may apply regardless of the governing law stated in a contract.
These may include laws relating to:
- consumer protection;
- unfair contract terms;
- e-commerce and online contracting;
- distance selling;
- subscription renewals;
- cancellation and cooling-off rights;
- transparent pricing;
- digital services;
- marketing and advertising;
- complaints handling;
- data protection and privacy.
Where local mandatory rights apply, Lumorus will honour those rights to the extent required by applicable law.
Where there is uncertainty about which local laws apply, Lumorus may take legal advice, amend service terms for a particular jurisdiction, restrict availability of certain services, or require additional jurisdiction-specific terms.
- Scope of the CoSec Retainer
The CoSec Retainer may include a combination of:
- company secretary services;
- statutory record support;
- board, committee and shareholder meeting support;
- compliance calendar support;
- governance advisory support;
- access to the CoSec Hub;
- service delivery through the Governance Knowledge Centres;
- account management;
- filings support;
- governance documentation support;
- policy and compliance support;
- reporting and reminders;
- other services agreed in the applicable order form, proposal, statement of work or client agreement.
The exact scope, limits, fees and exclusions of the CoSec Retainer will be set out in the applicable client agreement, order form, proposal, onboarding confirmation or service schedule.
Nothing in this Policy expands the agreed service scope or creates an unlimited service obligation.
- CoSecHub access
Where a client receives access to the CoSec Hub, that access is provided to support the delivery, management and administration of Lumorus services.
CoSec Hub access may be used for:
- client onboarding;
- entity information;
- statutory records;
- governance calendars;
- filing and compliance tasks;
- meeting records;
- document exchange;
- service requests;
- client communications;
- workflow tracking;
- governance reporting;
- access to relevant records and service information.
Access is subject to:
- the client agreement;
- the Platform Terms of Use;
- user permissions;
- security controls;
- fair usage limits;
- applicable data protection requirements;
- any service-specific restrictions communicated to the client.
The CoSec Hub may be developed, improved, modified or upgraded over time. Lumorus may add, remove, replace or change features where reasonably required for service improvement, security, compliance, technical reasons, supplier changes or business development. Where a material change significantly affects a paid service, Lumorus will aim to provide reasonable notice where practical.
- Governance Knowledge Centres
The Governance Knowledge Centres are Lumorus’ specialist service delivery environments. They are where Lumorus company secretaries, governance professionals and other experts collaborate, manage knowledge, apply professional judgement and deliver support to clients.
The Governance Knowledge Centres may include:
- internal knowledge systems;
- expert teams;
- service delivery workflows;
- governance methodologies;
- playbooks and operating procedures;
- jurisdictional know-how;
- quality assurance processes;
- specialist support from company secretaries and other professionals.
Unless Lumorus expressly agrees otherwise, the Governance Knowledge Centres are not a self-service download platform for clients and do not provide unrestricted access to Lumorus’ internal know-how, templates, methodologies, training materials or proprietary content.
Any materials, templates, guidance notes, summaries, outputs, documents or recommendations shared with clients are provided within the scope of the agreed services and subject to the applicable client agreement, intellectual property terms and usage restrictions.
- Nature of guidance and professional support
Lumorus provides governance and company secretary support. Depending on the agreed scope, this may include practical guidance, governance advice, document support, meeting support, compliance coordination and related services.
Unless expressly agreed in writing, Lumorus does not provide regulated legal, tax, investment, audit, accounting, financial, immigration or other regulated professional advice. Clients remain responsible for obtaining specialist advice where required.
Governance guidance, compliance reminders, platform workflows and Knowledge Centre support are intended to assist client decision-making. They do not replace the responsibility of the client, its board, officers, directors, shareholders, advisers or management to make final decisions and comply with applicable law.
- Free month, trial and promotional offers
Where Lumorus offers a free month, trial, introductory offer, promotional rate, discounted package or “risk-free” offer, the terms of that offer will be explained before the client commits or during onboarding.
The offer terms should state, where applicable:
- who is eligible;
- what is included;
- what is excluded;
- when the offer starts;
- when the offer ends;
- whether onboarding approval is required;
- whether payment details are required;
- when paid charges begin;
- whether the service converts to a paid retainer automatically;
- how to cancel before paid charges begin;
- whether fair usage limits apply;
- whether third-party costs, filing fees, disbursements or out-of-scope work are excluded.
A “free month” means the agreed monthly retainer fee is waived for the specified initial period, subject to the offer terms. It does not mean that every additional service, third-party charge, filing fee, regulatory fee, disbursement, premium request or out-of-scope matter is free unless Lumorus expressly states this in writing.
A “risk-free” offer means the client may cancel in accordance with the stated offer terms without paying the ongoing retainer fee for the remaining period. It does not remove obligations relating to unauthorised use, misuse, third-party charges, out-of-scope work, unpaid fees, confidentiality, data protection or breach of contract.
Lumorus should avoid using “no strings attached” unless the relevant offer has no material conditions. Where conditions apply, the conditions should be clearly stated.
- Pricing transparency
Lumorus will aim to present pricing in a clear, accurate and understandable way before the client commits.
Pricing information should include, where applicable:
- retainer fees;
- platform access fees;
- onboarding fees;
- billing frequency;
- VAT or other applicable taxes;
- currency;
- payment dates;
- additional user fees;
- additional entity fees;
- additional meeting fees;
- out-of-scope hourly or project rates;
- third-party charges;
- filing fees;
- regulatory fees;
- disbursements;
- renewal pricing;
- cancellation consequences.
Lumorus will not intentionally hide mandatory charges or present pricing in a way that is likely to mislead clients.
Where a price is described as “from”, “starting at”, “introductory”, “promotional”, “estimated” or “indicative”, Lumorus will aim to explain the conditions, assumptions or limitations that apply.
- Additional charges and out-of-scope services
Additional charges may apply where the client requests services beyond the agreed scope.
Examples may include:
- additional meetings;
- meetings exceeding included time limits;
- urgent or expedited turnaround;
- additional entities;
- additional users;
- additional jurisdictions;
- complex restructuring support;
- complex filings;
- support outside agreed service hours;
- legal drafting beyond the agreed governance scope;
- notarisation, apostille or legalisation;
- courier or postage costs;
- regulatory, registry or filing fees;
- third-party professional adviser costs;
- additional document reviews;
- bespoke governance projects;
- technology integrations or customisation.
Where reasonably possible, Lumorus will notify the client before carrying out work that will incur additional charges. In urgent cases, or where the client has already authorised a category of work, Lumorus may proceed in accordance with the client agreement or prior instructions.
- Subscriptions, renewals and billing
Where the CoSec Retainer is provided on a subscription, retainer or recurring basis, the client agreement or order form will state:
- the start date;
- the initial term;
- the billing cycle;
- the applicable fees;
- the renewal position;
- whether renewal is automatic or requires agreement;
- the cancellation process;
- any minimum term;
- payment due dates;
- consequences of late payment or non-payment.
Where automatic renewal applies, Lumorus will aim to explain this clearly before the client commits.
Different jurisdictions may impose different rules on subscription contracts, automatic renewals, renewal reminders, cancellation processes and consumer notifications. Where such rules apply, Lumorus will take reasonable steps to comply with applicable mandatory requirements.
- Cancellation
Cancellation rights depend on:
- the type of client;
- the client’s location;
- whether the client is acting as a consumer or business customer;
- whether the contract was entered into online, remotely, in person or after negotiation;
- whether services have already started;
- whether platform access has been provided;
- the applicable client agreement;
- the applicable law.
Where a client has a statutory cancellation right under applicable law, Lumorus will honour that right.
Where no statutory cancellation right applies, cancellation will be governed by the applicable client agreement, order form, service schedule or promotional offer terms.
Clients wishing to cancel should contact:
Email: [email protected]
Subject line: Cancellation Request – [Client Name]
Lumorus may ask for information to confirm the client account, the authorised person making the request and the effective cancellation date.
- Cooling-off rights
Cooling-off rights may apply where a client is acting as a consumer and enters into a qualifying distance, online or off-premises contract.
For UK consumers, this may include a 14-day cancellation period under UK consumer contract rules. For clients outside the UK, similar, longer, shorter or different cancellation, cooling-off or consumer protection rights may apply under the laws of the country in which the client is located.
Lumorus will honour any statutory cancellation or cooling-off rights that apply under applicable law.
Business clients do not usually have statutory consumer cooling-off rights unless such rights are expressly stated in the applicable agreement or required by applicable law.
Where a consumer asks Lumorus to begin providing services during any applicable cooling-off period, the consumer may be required to pay for services already provided, where this is permitted by law and was properly explained before the service began.
Where platform access or service delivery begins during any applicable cancellation period, the effect on cancellation rights may depend on applicable law, the nature of the service, the client’s location, the client’s status and any consent or acknowledgement required before access begins.
Nothing in this section limits any statutory rights that a consumer may have under applicable law.
- Refunds
Refund eligibility will depend on:
- the applicable client agreement;
- the client’s status and location;
- applicable law;
- whether statutory cancellation rights apply;
- whether services have already been provided;
- whether platform access has been used;
- whether cancellation was made within a permitted period;
- whether third-party costs or disbursements have been incurred;
- whether out-of-scope services were authorised;
- whether there has been misuse, breach or non-payment.
Where a refund is due under applicable law or the client agreement, Lumorus will process it within a reasonable period and in accordance with applicable legal requirements.
Refunds will not usually be provided for:
- completed services;
- work already performed;
- third-party fees already incurred;
- regulatory filing fees;
- registry fees;
- disbursements;
- out-of-scope work authorised by the client;
- misuse of the platform or services;
- services used beyond the free, trial or promotional period;
- charges properly incurred before cancellation.
This does not affect any statutory rights that cannot lawfully be excluded.
- Fair usage
The CoSec Retainer is intended to provide fair and reasonable access to Lumorus services, the CoSec Hub and the support of Lumorus professionals through the Governance Knowledge Centres.
Fair usage protects:
- service quality;
- response times;
- staff capacity;
- platform stability;
- client confidentiality;
- security;
- equitable access for all clients.
Fair usage limits may apply to:
- number of authorised users;
- number of entities;
- number of jurisdictions;
- number of meetings;
- length of meetings;
- support requests;
- email or portal queries;
- document reviews;
- filings support;
- storage;
- workflows;
- governance consultation time;
- urgent requests;
- use of Lumorus expert time.
Where a client’s usage materially exceeds the agreed or reasonable level for the package, Lumorus may:
- discuss the usage with the client;
- recommend a different package;
- agree additional fees;
- prioritise urgent or contractual matters;
- limit excessive or unreasonable usage;
- suspend abusive or harmful usage;
- terminate access where permitted by the client agreement.
Lumorus will aim to act reasonably before restricting ordinary access, except where there is security risk, unlawful activity, non-payment, misuse, abuse, regulatory risk or breach of contract.
- Platform misuse
Clients and users must not misuse the CoSec Hub or Lumorus systems.
Prohibited conduct includes:
- sharing login details without permission;
- allowing unauthorised users to access the platform;
- uploading unlawful, harmful, misleading or infringing material;
- attempting to bypass security controls;
- scraping, copying or bulk extracting platform data without permission;
- reverse engineering the platform;
- using the platform to develop or support a competing service without authorisation;
- interfering with system operation;
- uploading malware or malicious code;
- using the platform for fraudulent, unlawful or abusive purposes;
- misrepresenting identity, authority or instructions;
- using Lumorus outputs outside the permitted scope.
Misuse may result in suspension, removal of content, restriction of access, termination, additional charges, reporting to appropriate authorities or other action under the client agreement and applicable law.
- Service availability and operational changes
Lumorus will use reasonable efforts to make the CoSec Hub and related service channels available, subject to:
- planned maintenance;
- emergency maintenance;
- security updates;
- technology provider outages;
- internet, hosting or infrastructure disruption;
- regulatory requirements;
- force majeure events;
- client-side technical issues;
- service development and improvement.
Lumorus may update service processes, platform features, user workflows, operating models and delivery arrangements from time to time.
Where a material change significantly affects a paid service, Lumorus will aim to provide reasonable notice, unless urgent change is required for security, compliance, legal, technical or operational reasons.
- Marketing claims and sales communications
Lumorus will aim to ensure that marketing, sales and onboarding communications are accurate, balanced and not misleading.
This applies to claims such as:
- “free month”;
- “risk-free”;
- “no long-term commitment”;
- “cancel anytime”;
- “24/7 access”;
- “global support”;
- “expert support”;
- “Governance Knowledge Centres”;
- “CoSec Hub”;
- “compliance support”;
- “company secretary services”;
- service turnaround times;
- platform features;
- client results;
- testimonials or case studies.
Material limitations should be stated clearly and close to the relevant claim.
For example, if “24/7 access” refers to access to the CoSec Hub rather than live adviser support at all hours, that distinction should be made clear.
If “global support” means Lumorus supports clients across multiple jurisdictions but does not provide local regulated legal advice in every jurisdiction, that distinction should be made clear.
- Reviews, testimonials and case studies
Lumorus will not knowingly publish fake, misleading or manipulated reviews, testimonials or case studies.
Where Lumorus uses a testimonial or case study, it will aim to ensure that:
- it is genuine;
- permission has been obtained where required;
- confidential information is protected;
- any material incentive is disclosed where required;
- the testimonial is not presented in a misleading way;
- the result is not presented as typical unless Lumorus can support that claim.
- Complaints
Clients may raise complaints about:
- pricing;
- billing;
- cancellation;
- refunds;
- service quality;
- CoSec Hub access;
- support experience;
- marketing claims;
- fair usage decisions;
- professional conduct;
- perceived unfair treatment.
Complaints should be sent to:
Email: [email protected]
Subject line: Complaint – [Client Name]
Lumorus will aim to:
- acknowledge complaints within 24-72 hours;
- investigate fairly;
- request further information where needed;
- identify whether the complaint concerns service delivery, billing, platform access, data protection, professional advice or another issue;
- provide a written response within [insert timeframe];
- explain any remedy offered;
- record complaint themes for service improvement.
Where a complaint relates to a regulated matter, legal issue, data protection issue or another specialist area, Lumorus may direct the complaint to the relevant internal lead, professional adviser, regulator, complaints route or contractual process.
- Client responsibilities
Clients are responsible for:
- providing accurate and complete information;
- ensuring their authorised users comply with the Platform Terms of Use;
- keeping login credentials secure;
- paying fees when due;
- reviewing service scope and package limits;
- identifying urgent deadlines clearly;
- providing documents, approvals and instructions on time;
- ensuring uploaded data is lawful, accurate and properly authorised;
- obtaining any required local legal, tax, regulatory or professional advice;
- ensuring they have authority to instruct Lumorus;
- using Lumorus outputs only within the agreed scope;
- complying with applicable laws in their own jurisdiction.
- No exclusion of mandatory rights
Nothing in this Policy excludes or limits any rights, remedies, obligations or protections that cannot lawfully be excluded under applicable law.
If any part of this Policy is found to be invalid, unlawful or unenforceable in a particular jurisdiction, that part will apply only to the extent permitted by law, and the remainder of the Policy will continue to apply.
- Relationship with other documents
This Policy should be read together with:
- the CoSec Retainer Terms and Conditions;
- the Platform Terms of Use;
- the Privacy Policy;
- the Data Processing Agreement;
- any order form, proposal or statement of work;
- any applicable service schedule;
- any jurisdiction-specific addendum.
If there is a conflict between this Policy and a signed client agreement, the signed client agreement will take priority, unless applicable mandatory law requires otherwise.
- Changes to this Policy
Lumorus may update this Policy from time to time to reflect changes in:
- services;
- platform functionality;
- pricing models;
- operational processes;
- applicable law;
- regulatory guidance;
- business structure;
- international service delivery.
The latest version will be made available on the Lumorus website, the CoSec Hub or by another appropriate method.
Where a material change affects existing clients, Lumorus will aim to provide reasonable notice where practical.
