English
Arabic
1. Who are we?
Luxurio Club LLC, a limited liability company in Cairo, Egypt (hereinafter "LUXURIO CLUB”) is the controller of your data in Egypt for the purpose of the provision of our services through the website Luxurio Club.com.eg, related sites and the mobile application of the platform (collectively, the "Website") according to our Terms of Use, (hereinafter collectively referred to as “LUXURIO CLUB”, “we”, “us” or “our” in this privacy statement). Relevant contact details are set out in section 13.
2. What data do we collect about you?
2.1. Data provided through direct interactions
Registration and other account information
When you register to use our Services, we may collect the following information about you:
· if you register using your Google account: first name, last name, and email address;
· if you register using your Facebook account: we collect your first name and last name as appeared on your Facebook account and Facebook IDs. In the event you have provided permission to Facebook through their in-app privacy option (which appears just before you register on our Platform), we may collect your gender, age, or email id depending on the permissions granted by you; and
· if you register using your mobile number: mobile number.
Depending on the choices you make during the log-in to our Services or during the process of engaging our Services, you may opt to give the following additional personal data:
· your name;
· e-mail address;
· mobile number; and/or
· your credit card details in case you want to purchase our paid services as defined in our Terms of Use.
Communication through the chat feature on our Platform
When you use our chat feature to communicate with other users, we collect information that you choose to provide to other users through this feature.
2.2. Data we collect automatically when you use our Services
When you interact with our Platform or use our Services, we automatically collect the following information about you:
Device Information
· We collect device-specific information such as operating system versions and unique identifiers. For example, the name of the mobile network that you are using. We associate the device identifiers with your LUXURIO CLUB account.
Location information
· Depending on your device permissions, if you post an item on our Platform, we automatically collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, Wi-Fi access points, and mobile towers. Your location data allows you to see user items near you and helps you in posting items within your location.
Client and Log data
· Technical details, including the Internet Protocol (IP) address of your device, time zone, and operating system. We will also store your login information (registration date, date of last password change, date of last successful login), type, and version of your browser.
Clickstream data
· We collect information about your activity on our Platform which includes the sites from which you accessed our Platform, date and time stamp of each visit, searches you have performed, listings or advertisement banners you clicked, your interaction with such advertisements or listings, duration of your visit and the order in which you visit the content on our Platform.
Cookies and Similar Technologies
· We use cookies to manage our users’ sessions, to store the language of your preferred selection and deliver you relevant advertisements. "Cookies" are small text files transferred by a web server to the hard drive of your device. Cookies may be used to collect the date and time of your visit, your browsing history, your preferences, and your username. You can set your browser to refuse all or some cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Services/Platform may become inaccessible or not function properly. For more information on the cookies we use, please see our Policy on Cookies and Similar Technologies, the terms of which are incorporated into, and form part of, this Privacy Statement by reference.
2.3. Data from third parties or publicly available sources.
We may receive personal data about you from various third parties and public sources. If you would like more information about this, please contact us using the relevant contact details set out in section 13.
3. Do we collect data from children?
Our Services are not intended for children under 18 and we do not knowingly collect data from anyone under 18. If we become aware that a person under 18 has provided us with personal data, we will delete it immediately.
If you are resident in Egypt and under 18, we are not permitted to contract with you directly. If you are a resident in Egypt and under 18 then, by agreeing to this Privacy Statement, you acknowledge and agree that your guardian has read and consented to its terms on your behalf. If we seek your consent to process your personal data for a specific purpose in accordance with this Privacy Statement, consent must be granted on your behalf by your guardian.
4. Why do we process your personal information?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the contract, we are about to enter into or have entered into with you.
· Where it is necessary for our legitimate interests to improve our Services and to provide you a safe and secure Platform.
· Where we need to comply with a legal or regulatory obligation.
In certain circumstances, we may also process your personal data based on your consent. If we do this, we will let you know the purpose and the category of personal data to be processed at the time we seek your consent.
We have set out below a description of the ways we use your personal data.
4.1. For providing access and delivering Services through our Platform
· If you log in using your mobile number or email id, we use your first name and last name, mobile number, and/or e-mail address to identify you as a user and provide access to our Platform.
· If you log in using your Facebook account, we use your first name and last name from your Facebook profile and the Facebook e-mail address to identify you as a user on our Platform and to provide you access to our Platform.
The above log-information data is also used by us to deliver our Services to you in accordance with our Terms of Use.
We use your e-mail address and mobile number (by SMS) to make suggestions and recommendations to you about our services or third-party services that may be of interest to you.
We process the above information for the adequate performance of our contract with you and on the basis of our legitimate interest in undertaking marketing activities to offer you any products or services that may be of your interest.
4.2. For improving your experience on the Platform
We use clickstream data to:
· offer you tailored content, such as giving you more relevant search results when using our Services;
· to determine how much time, you spend on our Platform and in what manner you navigate through our Platform in order to understand your interests and to improve our Services based on this data. For example, we may provide you with suggestions on content that you can visit based on the contents you have clicked; and
· to monitor and report the effectiveness of the campaign delivery to our business partners and for internal business analysis.
We use your location data for the following purposes:
· to compile anonymous and aggregated information about the characteristics and behavior of LUXURIO CLUB users, including for the purposes of business analysis, segmentation, and development of anonymous profiles;
· to enhance the performance of our Services and to personalize the content we direct towards you. For example - with the help of location data we display ad listings that are in your vicinity to improve your buying experience, and
· to measure and monitor your interaction with the third-party advertisements banners we place on our Platform.
With the help of your log-in information which includes your email id and phone number, we map the different devices (such as desktop, mobile, tablets) used by you to access our Platform. This allows us to associate your activity on our Platform across devices and helps us in providing you a seamless experience no matter which device you use.
We process the above information on the basis of our legitimate interest to improve your experience on our Platform and for the adequate performance of our contract with you.
4.3. To provide you a safe and secure Platform
1. We use your mobile number, log data, and unique device identifiers to administer and protect our Platform (including troubleshooting, data analysis, testing, fraud prevention, system maintenance, support, reporting, and hosting of data).
2. We analyze your communications done through our chat feature for fraud prevention and to promote safety by blocking spam or abusive messages that may have been sent to you by any other user.
We process the above information for the adequate performance of our contract with you, to improve our services and on the basis of our legitimate interest to prevent fraud.
5. How will we inform you about changes in our privacy statement?
We may amend this privacy statement from time to time. We will post changes on this page and will let you know by e-mail or through our Platform. If you or your guardian (as the case may be) do not agree with the changes, you may close your account by going to the account setting and select delete account.
6. Your rights
You have the following legal rights regarding your personal data depending on how we interact with you.:
· Right to request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
· Right to request correction of any of the data we have about you. This enables you to have any incomplete, inaccurate, outdated, or misleading data which we hold about you, or data which processing does not correspond with the declared purpose or which processing is prohibited, corrected completed, updated, or deleted, though we may need to verify the accuracy of the new data you provide to us.
· Right to object to the processing of your personal data at any time. Such objection is to be made for legitimate reasons. This does not affect the legality of any processing we have already carried out based on the consent given previously or to comply with the applicable law.
No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee for the cost of the provision of a copy of the data or if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.
7. Your rights - data deletion requests
To exercise your privacy rights and choices, if you do not want us to process your data, then you can use the Data Deletion Requests feature to issue a request for its removal. The option to request data deletion is visible under Account > View and edit profile> "Delete this account"
There may be situations where we cannot grant your request — for example, if you ask us to delete your transaction data and LUXURIO CLUB is legally obligated to keep a record of that transaction to comply with law.Note that a delete request will be processed within 90 days. If you wish to cancel this request you do so by logging in before the 90 days pass.
8. Communication and marketing
We will communicate with you by email, SMS, or in-app notification in connection with our Services/Platform to confirm your registration, to inform you in case your ad listing has become live/expired and for other transactional messages in relation to our Services. As it is imperative for us to provide you with such transactional messages you may not be able to opt out of such messages.
However, you can ask us to stop sending you marketing communication at any time by clicking on the opt-out link in the email or SMS sent to you or by reaching out to us through the Help Center
You may receive marketing communications from us if you:
· have requested such information from us;
· use our Platform or Services;
· provided us with your details when you entered a competition; or
· registered for a promotion.
9. Who do we share your data with?
We may have to share your personal data with the parties set out below for the purposes set out in section 4 above.
Corporate affiliates – we may share your data with other LUXURIO CLUB group companies which are located within as well as outside Egypt and help us in providing business operation services such as product enhancements, customer support, fraud detection mechanisms, and marketing. Any sharing of personal data within the LUXURIO CLUB group of companies will always be subject to applicable legal safeguards or to a data transfer agreement that clearly defines the obligations of the parties and ensures appropriate technical and organizational measures to protect your data.
Third-Party Service Providers: We use third-party service providers to help us deliver certain aspects of our Services, for example, cloud storage facilities such as Amazon Web Services and Microsoft Azure, or payment service providers such as Checkout. Service providers may be located inside or outside of Egypt.
We conduct checks on our third-party service providers and require them to respect the security of your personal data and to treat it in accordance with the law. We do not allow them to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Marketing and data analytics providers: In order to improve our Services, we will sometimes share your non-identifiable information with analytics providers that help us analyze how people are using our Platform/Service. We share your information with them in a non-identifiable form for monitoring and reporting the effectiveness of the campaign delivery to our business partners and for internal business analysis. For further details about our analytics providers please refer to our Policy for Cookies and similar Technologies. We may share your contact information in the identifiable form with third-party service providers for the purposes of facilitating our marketing communications to you. Third-party service providers shall only process your information on behalf of and for the benefit of LUXURIO CLUB and in accordance with our instructions. They shall have no independent rights in relation to it. They will be bound to the terms of this Privacy Statement as well to data processing obligations in compliance with applicable data protection laws and/or a contractual obligation.
Law enforcement authorities, regulators, and others: We may disclose your personal data to law enforcement authorities, regulators, governmental or public bodies, and other relevant third parties to comply with any legal or regulatory requirements.
We may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy statement.
Publicly available information: When you post an item for sale using our Services, you may choose to make certain personal information visible to other LUXURIO CLUB users. This may include your first name, last name, your email address, your location, and your contact number. Please note, any information you provide to other users can always be shared by them with others so please exercise discretion in this respect.
10. International transfers
You agree that we may transfer your personal data to third parties inside and outside of Egypt.
Whenever we transfer your personal data out of Egypt, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
· The countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
· Adequate safeguards are put in place for personal data protection, such as specific contract clauses.
· Where we use service, providers based in the US, we may transfer data to them if they are part of the Privacy Shield.
You can receive a copy of relevant and implemented safeguards by contacting us through the Help Center.
11. Where do we store your data and for how long?
The data we collect about you may be stored and processed inside as well as outside Egypt in secure servers in order to provide the best possible user experience. For example – for fast website or mobile application build up.
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.
In case you have any queries in relation to the retention period of your data please contact us through the Help Center.
12. Technical and organizational measures and processing security
All the information we receive about you is stored on secure servers and we have implemented technical and organizational measures that are suitable and necessary to protect your personal data. LUXURIO CLUB continually evaluates the security of its network and adequacy of its internal information security program which is designed to (a) help secure your data against accidental or unlawful loss, access or disclosure, (b) identify reasonably foreseeable risks to the security of the LUXURIO CLUB network, and (c) minimize security risks, including through risk assessment and regular testing. In addition, we ensure that all payment data are encrypted using SSL technology.
Please note, despite the measures we have implemented to protect your data, the transfer of data through the Internet or other open networks is never completely secure and there is a risk that your personal data may be accessed by unauthorized third parties.
13. Links to third-party websites
Our Platform may contain links to third-party websites or apps. If you click on one of these links, please note that each one will have its own privacy policy. We do not control these websites/apps and are not responsible for those policies. When you leave our Platform, we encourage you to read the privacy notice of every website you visit.
14. Contact
For any privacy matters, exercising your rights or additional information, please check your account/privacy settings or contact our Privacy Officer through the Help Center.
Alternatively, you can contact our local company controlling your data for your local services by postal mail:
LUXURIO CLUB Egypt LLC
Heliopolis Cairo, Egypt
15. Changes to this Privacy Statement
We may amend this Privacy Statement from time to time to keep it up to date with legal requirements and the way we operate our business. Please regularly check this page for the latest version of this Privacy Statement. If we make material changes to this Privacy Statement, we will seek to inform you by notice on our website or application, or email ("Notice of Change").
Your continued use of our Services following any amendment or Notice of Change indicates your or your guardian's acceptance (as the case may be) of any changes.