Privacy Policy Effective Date: 01-11-2023

Luxsevita, located at Staringstraat 28 H, 1054VR Amsterdam, is committed to protecting the privacy of our clients and users. This Privacy Policy explains how we collect, use, and protect your personal data, as well as your rights under the General Data Protection Regulation (GDPR) and Dutch data protection laws.

By using our services, including concierge memberships, app purchases, Expat Accelerator plans, and a la carte items, you consent to the practices described below. If you have concerns or questions, please contact us at +31 06 29025960 or via email at team@luxsevita.com.

1. Who We Are

Luxsevita is responsible for the processing of personal data as outlined in this Privacy Policy. Our contact details are as follows:

• Address: Staringstraat 28 H, 1054VR Amsterdam
• Phone: +31 06 29025960
• Email: team@luxsevita.com

2. Personal Data We Process

Luxsevita processes your personal data because you use our services or provide this information directly. Below is an overview of the personal data we may collect and process:

• First and last name
• Address details
• Telephone number
• Email address
• Bank account details
• Other personal data actively provided (e.g., creating a profile, correspondence, or phone calls)
• Location data
• Information about your activities on our website
• Surfing behavior across websites, including through advertising networks
• List of customer contacts via app use
• Internet browser and device type

2.1 Special and/or Sensitive Personal Data

We do not intentionally collect data on website visitors who are under the age of 16 without parental consent. If you believe that we have inadvertently collected personal data about a minor, please contact us at team@luxsevita.com so we can delete this information.

3. Purpose and Legal Basis for Processing Personal Data

Luxsevita processes your data for the following purposes:

• To handle your payments (processed securely through Stripe).
• To send our newsletter and/or promotional offers (with your consent).
• To contact you by phone or email to perform or update our services.
• To inform you of changes to products and services.
• To enable you to create and manage an account.
• To deliver goods and services to you.
• To analyze website behavior and optimize our offerings (via Google Analytics).
• To tailor products and services to your preferences based on web browsing activity.

The legal basis for processing your personal data includes the performance of a contract, compliance with legal obligations, and consent where necessary.

4. Automated Decision-Making

Luxsevita makes use of automated decision-making systems for operational efficiency. These systems may affect users in the following ways:

• System Used: Pixpa (for website and app management)
  • Purpose: Improved customer experience, automated workflows for account handling.
• System Used: Stripe (for payment security and fraud detection).
  • Purpose: Ensuring secure payment transactions and detecting fraudulent activity.
• System Used: Google Analytics (for behavior analysis).
  • Purpose: Analyzing visitor trends to optimize user experience and services.

These systems operate based on input data and algorithms without human involvement. If you feel that the decisions made negatively impact you, you may contact us at team@luxsevita.com for an explanation or to contest the decision.

5. Retention of Personal Data

We retain your personal data only for as long as strictly necessary to fulfill the purposes listed or to comply with regulatory requirements. Retention periods are as follows:

• Financial data (e.g., invoices, payment details): 7 years, as required by Dutch tax laws.
• Account and profile data (e.g., login credentials, preferences): 2 years after your last activity on our platform.
• Cookies and tracking data (via Pixpa and Google Analytics): 6 months after collection.

After the retention period expires, your data will be deleted or anonymized unless required by law to retain it.

6. Sharing Personal Data with Third Parties

Luxsevita does not sell your personal data to third parties. We share data only as needed for the following purposes:

1. Payment Processing:
   • We use Stripe to securely process transactions. Data shared includes billing information and payment details.
2. Website and App Management:
   • We use Pixpa to host and manage our website and app and for service delivery.
3. Analytics and Performance Monitoring:
   • We use Google Analytics to analyze website usage and improve our services.

All third-party processors are bound by data processing agreements that require them to comply with GDPR standards and ensure the security of your data.

7. Cookies and Tracking Technologies

Luxsevita uses cookies to enhance your experience and monitor website performance. These include:

• Essential Cookies: Ensure the proper functioning of our website and services.
• Analytical Cookies: Monitor website traffic and usage trends via Google Analytics.
• Marketing Cookies: Tailor ads and promotional offers to your preferences.

You may adjust your browser settings to block cookies or delete previously stored cookies. For further details, see our Cookie Policy.

8. Your Data Protection Rights

Under GDPR, you have the following rights regarding your personal data:

• Access: Request a copy of the data we hold about you.
• Correction: Correct inaccurate or incomplete data.
• Deletion (“Right to Be Forgotten”): Request the deletion of your data under specific legal conditions.
• Restriction: Limit our use of your data in certain circumstances.
• Portability: Request a transfer of your data to another organization.
• Objection: Object to the processing of your data for marketing or other purposes.
• Withdraw Consent: Revoke your consent at any time where processing was based on consent.

To submit a request, email team@luxsevita.com. For data access requests, include proof of identity with sensitive information (e.g., BSN number, passport photo) blacked out for security.

We will respond to your request within 4 weeks. If you believe we have not handled your data appropriately, you may file a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

9. How We Protect Your Data

Luxsevita takes appropriate measures to protect your personal data from unauthorized access, misuse, or loss:

• Use of industry-standard encryption (e.g., SSL) for online transactions.
• Restricted access to personal data based on job role and necessity.
• Regular security assessments of our systems and processing methods.
• Ensuring third-party compliance with strict data protection standards.

If you suspect any misuse of your data, please notify us immediately via team@luxsevita.com.

10. Changes to This Privacy Policy

We may update this Privacy Policy to reflect enhancements to our services or legal changes. Significant updates will be announced via email or on our website. Continued use of our services constitutes your acknowledgment of these updates.

Thank you for trusting Luxsevita with your data.
For any questions about this policy, reach out to us at +31 06 29025960 or team@luxsevita.com.