This Privacy Policy is provided by LuxDirect Limited, a company registered in England and Wales under company number 16544799 with registered office at 85 Great Portland Street, London, England, W1W 7LT ("we", "our" or "us") for use of our products and services, including our marketing website at luxdirect.ai (the "Website"), our platform at app.luxdirect.co.uk (the "Platform"), and any related services we provide under your subscription such as AI visibility audits, reports, and support (together, the "Services").
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
Important: LuxDirect is designed to operate without collecting or storing guest personal data. We provide hotel-level analysis and recommendations using publicly available content and business identifiers. You must not upload guest personal data to the Platform unless we have a separate written agreement in place that requires us to process it.
This privacy policy relates to your use of the Services only.
The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites or services, please consult their privacy policies as appropriate. For more information see the section "Who we share your personal data with" below.
The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:
| Category of Data | In More Detail |
|---|---|
| Data collected when you use our platform | Your name and email address |
| Data collected when you use specific functions in the Services | Data you store or generate through the Services such as account settings, usage preferences, audit configuration inputs and platform activity history. Some of this information may not be personal data under UK GDPR, but where it relates to an identified or identifiable individual we will treat it as personal data and handle it in accordance with this policy. |
| Data collected when you provide goods or services to us under contract |
|
| Data collected when you request a free AI audit | Your hotel name, hotel location, hotel website URL, and business email address. This data is used solely to deliver your audit results and to follow up regarding LuxDirect's paid services. It is retained for up to 12 months and then automatically deleted. |
| Data collected when you make an enquiry with us | Your name and email address |
If you do not provide personal data we ask for where it is required, it may prevent us from providing services and/or the Services to you.
We collect and use this personal data for the purposes described in the section "How and why we use your personal data" below.
Our Services do not collect, store or process personal data about customers or clients of our users in the ordinary course of providing the Services. We do not collect, and you must not supply us with, third-party data (i.e. data of another person, such as guest personal data, booking or payment details, Property Management System or Online Travel Agency data) unless we have a contractual agreement in place to process such data.
For clarity, you must not upload guest personal data to the Platform, including guest names, contact details, booking references, stay details, payment information, or private communications, unless we have agreed in writing to process that data under a separate data processing arrangement.
LuxDirect acts as a data controller only in relation to personal data of its own users (for example, account holders and platform administrators). LuxDirect does not act as a data processor of guest personal data unless separately agreed in writing under a dedicated data processing agreement.
As part of the Services, LuxDirect may analyse publicly available hotel-related content, including reviews, editorial mentions, and social commentary published in public online forums, and treats such content as hotel-level, publicly available material, not as data about identifiable individuals.
In practice:
While some public reviews may incidentally contain personal identifiers (such as a username), LuxDirect does not process that content for the purpose of identifying individuals, and does not attempt to enrich, link, or profile reviewers in any way.
Where public reviews contain personal data, we process such data only to provide aggregated analysis at hotel or brand level and do not attempt to identify or contact the reviewer.
LuxDirect does not track individual guests, travellers, or reviewers across platforms, and does not combine publicly available content with external datasets to identify or profile individuals.
When providing advisory or concierge guidance, LuxDirect communicates at the level of response principles and themes, not individual guests. For example, we advise on how hotels should respond to common types of feedback in a way that improves guest perception and AI summaries, rather than instructing responses to specific reviewers.
As part of the Services, LuxDirect may query or observe third-party AI platforms using hotel names or other non-personal business identifiers only, to understand how hotels are described publicly. We do not transmit personal data to those platforms, and we do not control how they process data or generate outputs. Our Services remain limited to monitoring, analysis, scoring, and advisory reporting based on publicly available hotel-related information and business identifiers, and do not require the collection or storage of guest personal data.
Sensitive personal data (also known as special category data) means information related to personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data (where used for identification purposes), data concerning health, data concerning a person's sex life, and data concerning a person's sexual orientation.
Please note that we do not knowingly or intentionally collect sensitive personal data or information about criminal convictions from individuals. You should not submit sensitive data to us.
If we become aware that sensitive personal data has been submitted to us, we may remove it and may suspend or terminate access to the Services. If we collect sensitive personal data unintentionally, we will take reasonable steps to delete it unless we are required to retain it by law.
We collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.
We also collect personal data using cookies and similar technologies. Details are set out in our Cookie Policy at luxdirect.ai/cookies.
We obtain personal data from the following sources:
We do not purchase personal data from data brokers or enrich your personal data using third-party profiling services.
Under data protection law, we can only use your personal data if we have a proper reason, for example:
A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see "How to contact us" below).
The table below explains what we use your personal data for and why.
| What We Use Your Personal Data For | Our Reasons |
|---|---|
| Create and manage your account with us | To perform our contract with you or to take steps at your request before entering into a contract |
| Providing services and/or the functionalities of the Services to you | To perform our contract with you or to take steps at your request before entering into a contract |
| To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances: to comply with our legal and regulatory obligations, or for our legitimate interests or those of a third party (i.e. to protect our business, interests and rights or those of others) |
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or other important notices | Depending on the circumstances: to comply with our legal and regulatory obligations, or for our legitimate interests or those of a third party (i.e. to provide the best service to you) |
| Protect the security of systems and data | To comply with our legal and regulatory obligations. We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, in which case our reasons are for our legitimate interests or those of a third party (i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us) |
| Operational reasons, such as improving efficiency, staff training, and quality control or to provide support to you | For our legitimate interests or those of a third party (i.e. to be as efficient as we can so we can deliver the best service to you) |
| Statistical analysis to help us manage our business, e.g. in relation to our performance, customer base, platform and functionalities and offerings or other efficiency measures | For our legitimate interests or those of a third party (i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our Services) |
| Updating and enhancing user records | Depending on the circumstances: to perform our contract with you, to comply with our legal and regulatory obligations, or for our legitimate interests or those of a third party (e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services) |
| To comply with our legal and regulatory obligations | Depending on the circumstances: to perform our contract with you, to comply with our legal and regulatory obligations, or for our legitimate interests or those of a third party (e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services) |
| Delivering free AI audit results and following up with prospective clients | Consent (Article 6(1)(a)) - by submitting the free audit form and ticking the consent box, you consent to us storing your business email and hotel details to deliver your results and to contact you about LuxDirect's paid services. You may withdraw consent at any time by contacting support@luxdirect.co.uk. To share your personal data with members of our group and third parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymised where possible and only shared where necessary. | Depending on the circumstances: to comply with our legal and regulatory obligations, or for our legitimate interests or those of a third party (i.e. to protect, realise or grow the value in our business and assets) |
See "Who we share your personal data with" for further information on the steps we will take to protect your personal data where we need to share it with others.
We do not use personal data collected through the Services to train general-purpose AI models. Any AI analysis is conducted using solely publicly available, hotel-related content (including websites, public reviews, and public social posts), structured business metadata, and other non-personal or aggregated narrative signals.
As part of providing the Services, we do not collect, store, or process guest personal data, private communications, or interaction-level data between our clients and their customers or guests.
We may process publicly available reviews or social analysis as part of providing the Services, which may contain personal data. However, we use this solely to identify representation consistency and contradiction risk, not to profile individuals.
We may apply machine learning and analytical processes to anonymised and aggregated platform data to improve our services and develop industry benchmarks. This does not involve the use of personal data.
We may send you marketing communications about our services where you have:
You will have the right to opt out of receiving marketing communications at any time by:
We will always treat your personal data with the utmost respect and never sell or share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see "Your rights" below.
We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including developers, cloud storage and infrastructure providers, email marketing providers, payment providers and authentication providers.
We only allow service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with:
If you would like more information about who we share our data with and why, please contact us (see "How to contact us" below).
We will not sell your personal data and will not share it for third-party marketing purposes.
We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter if required to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims.
After you close your account, we will restrict access to your personal data and retain it only as necessary for legal, accounting, and dispute resolution purposes. Your personal data will not be used for product analytics or service improvement, except on an anonymised and aggregated basis.
Following the end of the aforementioned retention period, we will delete or anonymise your personal data.
Where you submit a free AI audit request via our website without creating an account, we will retain your name, email address, and audit results for up to 12 months from the date of submission. After this period your data will be deleted automatically. You may request earlier deletion at any time by contacting us at support@luxdirect.co.uk.
As LuxDirect does not collect or store guest personal data in the ordinary course of providing the Services, no retention period applies to such data.
We use data processors based within the United Kingdom and abroad, including companies located in the United States of America. Any updated destinations to which we send your personal data would be indicated in the present section and notified to you in accordance with the section on "Changes to this privacy policy" below.
Under UK data protection law, we can only transfer your personal data to a country outside the UK where there is an adequate level of protection for that data. We ensure this as follows:
If we could not or chose not to continue to rely on any of the above mechanisms, we would not transfer your personal data outside the UK unless we could do so on the basis of an alternative mechanism or exception provided by UK data protection law.
You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website.
| Right | Description |
|---|---|
| Access to a copy of your personal data | The right to be provided with a copy of your personal data. |
| Correction (rectification) | The right to require us to correct any mistakes in your personal data. |
| Erasure (right to be forgotten) | The right to require us to delete your personal data, in certain situations. |
| Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, e.g. if you contest the accuracy of the data. |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party, in certain situations. |
| To object to use | The right to object at any time to your personal data being used for direct marketing (including profiling), and in certain other situations to our continued use of your personal data, e.g. where we use your personal data for our legitimate interests. |
| Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you. We do not make any such decisions based on data collected by the Services. |
| Withdraw consent | Where we rely on your consent as our lawful basis for processing, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of any processing carried out before you withdraw your consent. |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see "How to contact us" below). You may also find it helpful to refer to the guidance from the UK's Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email or write to us (see below: "How to contact us"). When contacting us please:
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
Please contact us if you have any queries or concerns about our use of your information (see below "How to contact us"). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner. The Information Commissioner can be contacted at ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
We may change this privacy policy from time to time. When we make significant changes we will take steps to inform you, for example via the Services or by other means, such as email.
You can contact us via our website or by email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
For any data protection queries, please contact us at: support@luxdirect.co.uk