Privacy Policy

Effective Date: December 20, 2023.

This privacy policy (“Privacy Policy”) describes what personal data Luxy Limited (“Luxy”, “we”, “us”, or “our”) collects, the purposes for collecting this personal data, who we may share personal data with, and what rights you may have under applicable data privacy law. This Privacy Policy applies to our website www.onluxy.com (the “Website”), the Android and iOS mobile applications “Luxy” and “Luxy Pro” (the “Mobile Applications”), and their associated services, features, and functionalities (collectively, together with the Website and the Mobile Applications, the “Services”).


1. Contact

Luxy is the controller of your personal data in connection with the Services. If you would like to contact us (including our data protection officer), please contact: support@onluxy.com


2. Changes to Luxy’s Privacy Policy

Luxy may update or modify this Privacy Policy at any time effective upon posting the revised Privacy Policy with an updated “Effective Date” above, on the Services. We may give notice of such updates or modifications by any reasonable means, including by posting a revised version of this Privacy Policy on the Services.


3. Categories of Personal Data


A. Overview

To provide the Services, Luxy collects certain personal data from you. Luxy collects your personal data from the following sources:

The provision of your personal data is necessary in order to access and use the Services. If you do not want Luxy to process your personal data, please do not access or use our Services.


B. When you access our Services

Each time you access our Services, we and our third party service providers may collect certain usage data. This data includes:

The following usage data is stored in the so-called login data records every time the Luxy member logs into the Services:

For more information on the use of cookies and other tracking technologies on our Services, please see the “Cookies & Tracking” and “Online Analytics” sections of our Privacy Policy, below.


C. When you register for or use the Services

Minimum information for registration process and Basic Membership

When initially registering for the Service free of charge (the “Basic Membership”), you are asked to provide certain minimum information without which the registration cannot be completed. The mandatory data required for registration is:


When registering via phone number

Luxy offers the option of specifying the mobile phone number for a mobile phone login. You may sign up for the Services using your mobile phone number. To fully function, you have to agree to receive text messages (SMS) from Luxy. A confirmation code will be sent to the mobile phone number you use after you have given your consent to receive text messages. Luxy may send to this phone number important messages regarding your Luxy account and its promotions and services. If you do not want to sign-up with your mobile phone number, you should choose a different sign-up method on the Services.


Further information obtained during registration process and membership
While registering for the Services or otherwise using the Services, we may collect the following data:


Luxy Pro business networking mode
Luxy offers on its app for iOS ‘Luxy Pro’ a Business Networking mode. Mandatory data for the Business Networking mode includes:


Further, we may collect the following data:


Picture verification data

You may voluntarily verify your profile pictures via the Services. Luxy may also require a mandatory picture verification if we determine your profile on the Services is high-risk in our sole discretion or if we suspect your profile on the Services is involved in suspicious activities, including, but not limited to, frequent IP address changes or mismatch between the location transmitted via IP address and the geo-data of your device.

A picture or video is being used in the process of picture verification. This won’t be shown publicly on the Services.

Luxy may collect your face geometry data via facial recognition or similar technology, which may be considered biometric data or biometric information in some jurisdictions. The purpose of the use of this data is for verification and security purposes, including, but not limited to, keeping our community safe from fake profiles and possible dangerous activity.

Using facial recognition technology, we compare your face in a real-time selfie to your photos in your profile. We delete your facial recognition data once the verification is complete, which takes up to 7 days. To execute the photo verification process, we process your facial geometry information and screenshots via our server.

When Luxy deletes the biometric data or biometric information following the completion of the profile picture verification process, it is permanently deleted from our systems and can no longer be retrieved.

When you consent to the collection and use of the picture verification feature, you acknowledge and agree that Luxy may share biometric data or biometric information with its service providers for verification and security purposes.


Income verification
On the Website and Android app, you are able to verify your income. In doing so, proof of income or assets need to be voluntarily provided by you in connection with a copy of an ID or government-issued identifier. If you don’t want to provide a copy of your ID or government-issued identifier or proof of income or assets, please don’t verify your income on Luxy. You are able to use the Services without doing so.


Purchase of Premium Membership
If you decide to use a paid service from Luxy via the Services (a “Premium Membership”), Luxy does not collect or store any further data. Information collected as a part of the Premium Membership, including the credit card or bank data, name and addresses are collected and stored by Luxy’s payment provider only.


Communication between users of the Services
When using the Services, you may have the option of communicating with other users via text messages and video chat. Luxy uses your IP address and an anonymous identifier when using the video chat. Furthermore, the time and duration of the chat are stored. Luxy does not store any video and audio content is not stored from the video chat on the Services. To use the video chat on the Services, Luxy requires access to the camera and microphone of your device. If you do not want other users to be able to reach you via video chat on the Services, you should not use the video chat function which can be turned off in the privacy settings of your user profile.


Messages, emails and text messages about Luxy
During registration of your Luxy membership to the Services, you provide your e-mail address or cell phone number. This e-mail address, or cell phone number or any new e-mail addresses and phone number you may subsequently provide may be used to send informational or marketing materials about the Services. If you no longer wish to receive these information or marketing materials, you have the option to turn off this option at any time in the settings of your profile on the Services.


Push notifications

If you allow on your mobile device Luxy to send you messages, you may receive push notifications from us as part of using the Services. These push notifications may include information regarding the Services or other information or marketing materials. You can modify or prevent the receipt of push messages at any time via the device settings of your mobile device or in the Mobile Applications.

D. When you contact us

Luxy may also collect any other personal data you may provide us when you choose to contact us. For example, you may provide us personal data when we are providing you with customer support.

Additionally, for example, on the Services, you can subscribe to a free newsletter and updates of promotional content for the Luxy platform by clicking on a checkbox. When registering for the newsletter, the data from the input mask is used. In addition, you may choose to use the Services to share information with other users, including your phone contacts. If you allow us to do so, the Services may access your device’s address book solely to add your contacts so you can invite friends to join Luxy and send an invitation link via the Services.


4. Personal data processing purposes

Luxy processes your personal data for the following purposes:


5. Legal basis for the processing of personal data

Luxy’s legal basis for processing your personal data will depend on the personal data collected and the specific context for which we collect it. We process your personal data:


6. Disclosure of Personal Data to Third Parties

With other users: You may disclose personal data with other users of the Services when you voluntarily disclose information on the Service (including through your profile).

With service providers: Luxy uses service providers to help us operate, distribute, market, and improve our Services. Service providers receive from Luxy only the personal data that they need for their specific activity. Luxy uses, among other things, service providers for sending emails, newsletters or text messages to their members. Service providers also provide the Luxy server capacity. Luxy uses service providers to process and store your data securely. External payment services and service providers in connection with debt collection support Luxy in processing payments. Depending on which payment method you select in the ordering process, payment providers collect your data independently to process payments (e.g., bank details or credit card details). Luxy also offers video calls in cooperation with our service providers.

With law enforcement / when required by law: In addition, personal data can be transmitted to third parties if Luxy should be obliged to do so by law, legal process, or by enforceable administrative or judicial order, or to assist in the prevention or detection of a crime, or to protect the safety of any person.

To enforce legal rights: We may also disclose personal data to third parties: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.

With corporate transactions: We may disclose your personal data if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control.

With your consent: We may ask for your consent to share your personal data with third parties. In any such case, we will make it clear why we want to share the personal data.


7. Personal data retention

We store your personal data for as long as necessary to provide our Services and as permitted by applicable law.

If you decide to stop using our Services, you can delete your account. Following account deletion, we implement a safety and security window of thirty (30) days following the account deletion. Following an account ban, we also implement a safety and security window of thirty (30) days following the ban. During this period, your data will be retained but it won’t be visible anymore to others.

After that, we will begin with the deletion of your data, provided that there is no legal retention requirement for this data. We may block deletion of that data on the basis of our legitimate interest (for example, to safeguard the community, to prevent or detect criminal actions, when involved in official investigations, litigation, or in a claim or dispute with Luxy, or it is otherwise necessary to retain data to comply with our legal obligations or as necessary in connection with a legal proceeding). We also keep records of consents users give us to evidence our compliance with applicable law.

Please note that if you choose to “deactivate your account”, your data won’t be deleted but your account is merely paused. During this time, your profile won’t be recommended to others, but your existing matches will still be able to view your profile.

The following applies to a Basic Membership: Luxy has the right to automatically delete personal profile data from basic members who are inactive for twenty-four (24) months.

The following applies to a Premium Membership: The personal data of Luxy premium members is stored for the duration of the contractual relationship. Once falling back to an active Basic Membership, your data is still being stored. However, Luxy may automatically delete personal profile data from basic members who are inactive for twenty-four (24) months.

Notwithstanding the foregoing, Luxy may delete any data from you (whether you have a Basic Membership or Premium Membership) in the event you have been blocked, removed, or suspended from our Services.


8. Your personal data rights and choices

We provide the following options and tools available to you in order to be in control of your data:

Depending on where you live, you may have certain rights under applicable data privacy law. These include:

You can exercise any of your rights listed above by writing an email to support@onluxy.com with the topic personal data inquiry. Before we can honor your request, we may confirm that you are the consumer whose personal data is sought, or a person authorized to act on your behalf. In addition, depending on the nature of your request, we may request verifying information from you, such as identifiers or service history already known to or collected by us.


9. Cross-border data transfers

If personal data is transferred outside of its country of origin, we take commercially reasonable efforts to protect such personal data, such as by entering into certain standard contractual clauses as approved by the European Commission or other approved data transfer mechanisms. In the event we transfer personal data outside of the European Union or the European Economic Area to a country which data protection laws have not been deemed adequate by the European Commission or other competent governmental body, we will use standard contractual clauses as approved by the European Commission or other approved data transfer mechanisms.


10. Automated decision-making

Luxy uses automated decision-making to help connect you with other users and to ensure your safety and security.

Luxy uses the following data to generate profile recommendations: the information you tell us about yourself in your profile and your intended match; whether you are a photo verified user; whether your existing activity on the Luxy app with this profile including your membership status; and your device coordinates, which are necessary to understand your proximity to other members. The legal basis for processing profile and proximity information is that this is necessary for the provision of our contractual services to you pursuant to Article 6(1)(b) GDPR.

Luxy uses automated decisions to prevent fraudulent activities as part of its anti-fraud procedures. In order to do this, our systems check various parameters that we indicated here in the Privacy Policy when using our Services (data we collect). If an activity meets a certain threshold, the relevant account may automatically be blocked.

Luxy uses automatic decision making for its price determination. The only criteria used here are the current users’ location and the purchase history of users on the Luxy app.


11. Children

Our Services are restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 to use our Services.


12. Third party registration

When registering via a third party login method, such as Facebook, through Facebook Plugin SDK, Google, LinkedIn, or Apple, we have no influence on the scope and purposes of personal data collected by such third party. If you do not want such third party to collect personal data about you in connection with our use of the Services, you should not use such third-party log-in feature. For more information on the scope and purposes of personal data collected by third parties, please review those third parties’ privacy policies and practices.


13. Cookies & Tracking

Our Services use cookies. Cookies are small text files that are sent when you visit a website and stored in the user’s browser or your device’s memory. If the corresponding website is called up again, the user’s browser sends back the content of the cookies and thus enables the user to be recognized. Certain cookies are automatically deleted after the end of the browser session (so-called session cookies), others are stored in the user’s browser for a specified time or permanently and then delete themselves (so-called temporary or permanent cookies).


What cookies does Luxy use?


Marketing cookies and third-party tracking

We allow other companies to collect data from our users using marketing cookies. This enables us and third parties to display interest-based marketing to the users of our Services, which is based on an analysis of their usage behavior (e.g., clicked advertising banners, visited sub-pages) overall and not limited to our Services.


How can you control cookies?

You can control cookies by utilizing our cookie banner provided on the Services.
You can also control via your browser settings.
Please note, however, that our Services may not work or only function to a limited extent without cookies. We also recommend the website of www.YourOnlineChoices.com, where you can find information and assistance in connection with web tracking mechanisms.


14. Online Analytics

We collect statistical information about the use of our Services in order to make them more user-friendly, to measure reach, to be able to carry out market research and to display marketing and advertisements relevant to you. For this purpose, we work with various authorized service providers and use online analytics tools, which are described below.


Appsflyer Analytics

The Services use Appsflyer Analytics, a mobile app and web analytics service. Appsflyer uses cookies that are stored on your computer, tablet, or smartphone and that enable an analysis of your use of the Services. Luxy uses Appsflyer to monitor advertising campaigns and on-platform event tracking. Luxy and its service providers do not share the information obtained in this process with third parties.


Google Analytics

The Website uses Google Analytics, a web analytics service provided by Google. Google Analytics uses cookies that are stored on your computer, tablet or smartphone and that enable an analysis of your use of the Website. These are cookies from Google itself (Google Analytics cookies). Luxy uses Google Analytics with the additional function offered by Google for anonymizing IP addresses. Google will use this information to evaluate your use of the Website, to compile reports on Website activity and to provide other services related to Website and internet use, such as Google Analytics reports on performance based on demographic characteristics and interests. Google Analytics is being used on the Mobile Applications via the Firebase SDK, provided by Google.


Use of Google Ads Conversion Tracking

Luxy uses the online advertising program “Google Ads” and, as part of Google Ad Words, Google Conversion Tracking. Google Conversion Tracking is an analysis service provided by Google. If you click on an advertisement placed by Google, a cookie for the conversion tracking is placed on your computer. These cookies lose their validity after ninety (90) days. If you visit certain websites from our Services and the cookie has not yet expired, Google and we can recognize that you clicked on the advertisement and were forwarded to our Services. Every Google Ads customer receives a different cookie. The information obtained using the conversion cookie is used to create conversion statistics for ads customers who have opted for conversion tracking. Here, Luxy finds out the total number of users who have clicked on their advertisement and have been forwarded to a page provided with a conversion tracking tag.


Use of Meta Custom Audiences

Luxy wants to present “interest-based advertising” on Meta and limit the frequency with which certain advertisements are displayed. Meta collects HTTP header information (including IP address, information about the web browser, page storage location, document, URL of the website or the respectively accessed page and user agent of the web browser as well as day and time of use); and events (the user’s website visit to Luxy, registration, purchasing). If the Meta ID contained in the Meta cookie can be assigned to a Meta user, Meta will assign this user to a “custom audience” based on the rules we have defined, provided the criteria applicable to this are met. We use the information received in this way to display ads on Meta. However, ads are only displayed from a “Custom Audience” size of 20 different users - so no conclusions can be drawn about the properties of the individual users from the placement of the ads. The assignment to a “Custom Audience” takes place for a maximum of 180 days. This period starts again when you visit our Website again and there is a conformity with the same “Custom Audience” rules. Meta can assign your visit to our Website and your related activities to your Meta user account. We cannot do this. We only receive statistical information from Meta about the use of our Website through Audience Insights.


Social Plugins

The integration of social plugins regularly leads to the providers of the plugins storing cookies. In order to increase the protection of your data when visiting our Services, the plugins can be integrated into the page. Only when you activate the plugins will your internet browser or app establish a direct connection to the servers of the respective plugin provider. This gives the plugin provider the information that your internet browser has called up the corresponding page of our online offering, even if you do not have a user account with the provider or are not currently logged in. Log files (including the IP address) are transmitted from your Internet browser directly to a server of the respective plug-in provider and saved there if necessary. The plugins are independent extensions of the plugin providers. We therefore have no influence on the scope of the data collected and stored by the plugin providers via the plugins. If you do not want the plugin providers to receive the data collected via the Services, you should not use the respective plugins.