Privacy Policy

Last Updated: 1st January 2026

This Privacy Policy describes how luxentiora.top Ltd ("we", "us", or "our") collects, uses, and protects your personal information when you visit our website at luxentiora.top or use our services. We are committed to protecting your privacy and handling your personal data in accordance with the General Data Protection Regulation (GDPR) and applicable data protection laws.

Data Controller Information

luxentiora.top Ltd is the data controller responsible for your personal data. Our company is registered in Cyprus with Registration Number HE965874 and VAT Number CY96351428X. Our registered office is located at Stasikratous Street 116, Larnaca 6092, Cyprus.

Data We Collect

We may collect and process the following types of personal data when you interact with our website and services:

• Contact Information: Name, email address, phone number, company name, and job title when you contact us or request our services
• Technical Information: IP address, browser type, device information, operating system, and website usage data
• Communication Data: Records of correspondence, enquiries, and support requests
• Marketing Data: Your preferences for receiving marketing communications and information about our services
• Cookie Data: Information collected through cookies and similar tracking technologies as described in our Cookie Policy

How We Use Your Information

We use your personal data for the following purposes based on legitimate business interests and legal obligations:

• To provide and deliver our IT infrastructure planning and consulting services
• To respond to your enquiries and provide customer support
• To improve our website functionality and user experience
• To send you relevant information about our services (with your consent)
• To comply with legal obligations and regulatory requirements
• To protect our legitimate business interests and prevent fraud
• To analyse website usage and optimise our digital marketing efforts

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner. For detailed information about our use of cookies, please refer to our Cookie Policy.

Data Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your data only in the following circumstances:

• With trusted service providers who assist us in operating our website and delivering our services
• When required by law, court order, or regulatory authority
• To protect our rights, property, or safety, or that of our users
• In connection with a business transfer, merger, or acquisition (with appropriate safeguards)

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Contact information is typically retained for up to 7 years after our last interaction, while website analytics data is retained for up to 26 months. Marketing consent records are maintained until you withdraw consent or we determine the data is no longer needed.

Your Rights

Under GDPR and applicable data protection laws, you have the following rights regarding your personal data:

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data in certain circumstances
• Right to Restrict Processing: Request limitation of how we use your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for marketing purposes
• Right to Withdraw Consent: Withdraw consent for data processing where consent is the legal basis

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, access controls, secure data transmission, and regular security assessments. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

International Data Transfers

As we operate within the European Union, your personal data is primarily processed within the EU/EEA. If we transfer data outside the EU/EEA, we ensure appropriate safeguards are in place, such as adequacy decisions or standard contractual clauses approved by the European Commission.

Contact Information

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us using the following details:

Complaints

If you believe we have not handled your personal data in accordance with this Privacy Policy or applicable data protection laws, you have the right to lodge a complaint with the relevant supervisory authority. In Cyprus, this is the Commissioner for Personal Data Protection (www.dataprotection.gov.cy).

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. We will notify you of any material changes by posting the updated policy on our website and updating the "Last Updated" date. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.

Legal Basis for Processing

We process your personal data based on the following legal grounds under GDPR: (a) Consent for marketing communications and cookies, (b) Legitimate interests for website analytics and business operations, (c) Contract performance for service delivery, and (d) Legal obligations for regulatory compliance and record-keeping requirements.