1. Introduction

Truly Luxe is committed to protecting the privacy and confidentiality of our clients, partners, and website visitors. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you interact with us, whether via our website, direct contact, or as part of our bespoke lifestyle and travel services.

2. What Information We Collect

We may collect and process the following types of personal data:

a) Personal Identification Information

• Full name
• Date of birth
• Nationality
• Passport or ID details (when required for bookings)

b) Contact Information

• Email address
• Phone number
• Physical/billing address

c) Travel & Lifestyle Preferences

• Dietary requirements
• Accommodation and travel preferences
• Special requests or lifestyle interests
• Loyalty programme or frequent flyer numbers (if relevant)

d) Financial Information

• Payment details (for processing invoices or bookings)
• Billing history

e) Usage Data (Website & Email)

• IP address
• Browser type and device
• Pages visited
• Referral source
• Email open/click behavior (for newsletters or service updates)

3. How We Use Your Information

We use your personal data to:

• Provide you with tailored concierge, travel, and lifestyle management services
• Process bookings and manage third-party supplier arrangements
• Communicate relevant updates, confirmations, and itineraries
• Maintain our client relationship records
• Improve our services and client experience
• Comply with legal and regulatory obligations

4. Legal Basis for Processing

We process your personal data based on the following lawful grounds:

• Performance of a contract (e.g., managing your travel or service requests)
• Legitimate interest (e.g., enhancing client experiences, preventing fraud)
• Consent (e.g., marketing communications – always optional)
• Legal obligation (e.g., compliance with tax or regulatory requirements)

5. Sharing Your Information

We only share your data when necessary and always with discretion:

• Trusted suppliers (e.g., airlines, hotels, chauffeurs, event coordinators) to fulfil your requests
• Professional advisors (e.g., legal, tax, or IT support)
• Regulatory bodies if required by law

We never sell your data to third parties.

6. International Transfers

Due to the global nature of our business and that of our third party suppliers who process your personal data on our behalf, personal information we collect from you may be transferred, processed and stored overseas including (where applicable) outside the jurisdiction where the personal information is collected.

Although the data protection laws of these other countries may not be as comprehensive as those in your own, we will take all necessary steps to ensure that your personal information is treated securely, and in accordance with this Privacy Charter and any applicable laws.

In addition, personal information that you submit for publication on the website will be published on the internet and may be available, via the internet, around the world. Lux cannot prevent the use of such information by others. By submitting your personal data, you expressly agree to these transfers, storing, processing and publishing.

However, any such transfer of information does not change any of our commitments to safeguard your privacy and the information remains subject to existing confidentiality obligations.

7. Data Retention

We retain your information only for as long as necessary to provide services, fulfil legal obligations, or maintain our business relationship. Data is securely deleted or anonymised when no longer required.

8. Your Data Rights

You have the right to:

• Access the personal data we hold about you
• Request correction of inaccurate or incomplete data
• Request deletion of your data (subject to legal limitations)
• Withdraw consent for marketing or specific processing
• Object to processing based on legitimate interest
• Request restriction of processing
• Request data portability

To exercise these rights, please contact: hello@trulyluxe.world

9. Data Security

We take data security seriously and implement strict controls to protect your information, including encryption, secure storage, and restricted access protocols.

10. Cookies

Our website uses cookies to improve your browsing experience and gather usage analytics. You can manage your cookie preferences in your browser settings. For details, see our [Cookie Policy] (link).

11. Marketing Communications

We may contact you with tailored content, updates, and exclusive offers. You can opt out at any time via the unsubscribe link in emails or by contacting us.

12. Third-Party Links

Our website may include links to other websites. We are not responsible for the privacy practices or content of these external sites.