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Privacy Policy

Last updated: 31 May 2026  ·  Effective: 31 May 2026  ·  Applicable Law: Swiss FADP (nDSG) & GDPR

Table of Contents

  1. Who We Are
  2. Data We Collect
  3. How We Use Your Data
  4. Legal Basis for Processing (GDPR)
  5. Data Sharing & Third Parties
  6. International Data Transfers
  7. Data Retention
  8. Your Rights — EU / EEA (GDPR)
  9. Your Rights — California Residents (CCPA / CPRA)
  10. Your Rights — Other Regions
  11. Cookies & Tracking
  12. Security
  13. Children's Privacy
  14. Changes to This Policy
  15. Contact & Data Controller
Plain-language summary: Priveluxe collects only the information necessary to design and deliver your private luxury experience. We do not sell your personal data. You have the right to access, correct, or delete your data at any time by contacting us at info@priveluxe.ch.

1. Who We Are

This Privacy Policy applies to Priveluxe ("we", "us", "our"), a luxury travel concierge service operating between Lake Como (Italy) and Canton Ticino (Switzerland). We are the data controller responsible for your personal information.

Data Controller:
Priveluxe
Canton Ticino, Switzerland
Email: info@priveluxe.ch
WhatsApp: +41 76 366 18 22

We are subject to the Swiss Federal Act on Data Protection (FADP / nDSG), in force since 1 September 2023, and where applicable to EU/EEA residents, the EU General Data Protection Regulation (GDPR). Where our services are accessed from other jurisdictions, we also comply with applicable local data protection laws.

2. Data We Collect

2.1 Information You Provide Directly

When you contact us or request a luxury experience, you may provide:

  • Identity data: full name, title
  • Contact data: email address, phone number, WhatsApp number
  • Travel preferences: travel dates, number of guests, destination preferences, accommodation preferences, dietary requirements, special requests
  • Financial data: invoicing details (name, address, VAT number where applicable). Note: payment processing is handled directly by our banking partners — we do not store full card details.
  • Communications: content of emails, WhatsApp messages, or form submissions you send us

2.2 Information Collected Automatically

When you visit our website, we may automatically collect:

  • Technical data: IP address (anonymised after 24 hours), browser type and version, operating system, device type
  • Usage data: pages visited, time on site, referral URL, scroll depth
  • Cookie data: see our Cookie Policy for full details

2.3 Information from Third Parties

We may receive limited information when you contact us via:

  • Social media platforms (Instagram, Facebook, TikTok, Telegram) — only what you voluntarily share in messages
  • Referral partners — only your name and contact detail, with your prior consent

2.4 Special Categories of Data

We may collect special category data (as defined by GDPR Art. 9) only when strictly necessary to deliver your experience — for example, dietary requirements that may reveal health or religious information. We collect this only with your explicit consent and store it only for the duration required to fulfil your booking.

3. How We Use Your Data

Purpose Data Used Legal Basis
Design and deliver your private experience Identity, contact, travel preferences Contract performance (GDPR Art. 6(1)(b))
Process invoicing and payments Identity, financial data Contract performance; Legal obligation
Respond to enquiries Identity, contact, communications Legitimate interest (Art. 6(1)(f))
Improve our website and services Technical data, usage data Legitimate interest (anonymous/aggregated)
Send updates on new experiences (newsletter) Name, email Consent (Art. 6(1)(a)); opt-out anytime
Legal compliance (accounting, tax records) Identity, financial data Legal obligation (Art. 6(1)(c))
Fraud prevention and security Technical data, IP address Legitimate interest

4. Legal Basis for Processing (GDPR)

For residents of the EU/EEA, we rely on the following legal bases under GDPR Article 6:

  • Art. 6(1)(a) — Consent: where you have freely given explicit consent (e.g. marketing communications, non-essential cookies)
  • Art. 6(1)(b) — Contract: where processing is necessary to perform a contract with you or to take steps at your request before entering a contract
  • Art. 6(1)(c) — Legal obligation: where processing is required under Swiss or EU law (e.g. tax records)
  • Art. 6(1)(f) — Legitimate interests: where processing is in our legitimate business interests, provided those interests are not overridden by your rights (e.g. responding to enquiries, website analytics, fraud prevention)

Where we rely on consent, you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.

5. Data Sharing & Third Parties

We do not sell, rent, or trade your personal data to third parties.

We share your data only in limited, necessary circumstances:

5.1 Service Partners

To deliver your experience, we may share relevant details (name, contact, preferences) with carefully selected partners such as hotels, private transfer companies, boat charter operators, restaurant partners, and experience providers in Italy and Switzerland. All partners are bound by confidentiality agreements and may only use your data to fulfil the services you have requested.

5.2 Technology Providers

ProviderPurposeData SharedSafeguards
Google Fonts (Google LLC) Font delivery IP address, browser headers Google Privacy Policy; EU SCCs
Web hosting provider Website hosting Server logs (IP, access data) Processor agreement (DPA)
Email service provider Sending contact form responses Name, email, message content Processor agreement (DPA)

5.3 Legal Requirements

We may disclose your data if required by applicable law, court order, or governmental authority in Switzerland, Italy, or another jurisdiction where we operate.

6. International Data Transfers

Priveluxe operates between Switzerland and Italy. Switzerland is recognised by the European Commission as providing adequate protection for personal data (adequacy decision under GDPR Art. 45). As such, transfers between Switzerland and the EU/EEA do not require additional safeguards.

Where data is transferred to countries outside the EU/EEA/Switzerland (e.g. to technology providers in the United States), we ensure appropriate safeguards are in place, including:

  • EU Standard Contractual Clauses (SCCs) where applicable
  • Adequacy decisions by the European Commission
  • The EU-U.S. Data Privacy Framework (where providers are certified)

7. Data Retention

Data TypeRetention PeriodReason
Booking and contract data 10 years from booking date Swiss/Italian legal accounting obligation
Financial records 10 years Swiss Code of Obligations; Italian law
Marketing communications consent 3 years from last interaction, or until opt-out Legitimate interest / consent
Enquiries / contact form data (no booking) 2 years from last contact Legitimate interest (follow-up)
Website analytics data 14 months (aggregated/anonymised) Service improvement
Cookie consent records 13 months GDPR compliance evidence

After the applicable retention period, data is securely deleted or anonymised.

8. Your Rights — EU / EEA Residents (GDPR)

Under the General Data Protection Regulation (GDPR), you have the following rights:

Right of Access

Request a copy of the personal data we hold about you (Art. 15)

Right to Rectification

Request correction of inaccurate or incomplete data (Art. 16)

Right to Erasure

"Right to be forgotten" — request deletion of your data where there is no compelling reason to continue processing (Art. 17)

Right to Restriction

Request that we limit how we use your data in certain circumstances (Art. 18)

Right to Portability

Receive your data in a structured, machine-readable format and transfer it to another controller (Art. 20)

Right to Object

Object to processing based on legitimate interest, including direct marketing (Art. 21)

Right to Withdraw Consent

Withdraw consent at any time where processing is consent-based, without affecting past processing

Right to Lodge a Complaint

File a complaint with a supervisory authority, particularly in your EU Member State of residence

To exercise any of these rights, contact us at info@priveluxe.ch. We will respond within 30 days. For complex requests, we may extend this to 60 days with prior notice.

You may also contact the relevant supervisory authority:

  • Switzerland: Federal Data Protection and Information Commissioner (FDPIC) — edoeb.admin.ch
  • Italy: Garante per la protezione dei dati personali — garanteprivacy.it
  • EU (general): Supervisory authority of your country of residence

9. Your Rights — California Residents (CCPA / CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants you the following rights:

  • Right to Know: request disclosure of the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the categories of third parties with whom we share it
  • Right to Delete: request deletion of personal information we have collected from you, subject to certain exceptions
  • Right to Correct: request correction of inaccurate personal information
  • Right to Opt-Out of Sale or Sharing: We do not sell or share your personal information for cross-context behavioral advertising. No opt-out is required, but you may still contact us to confirm this
  • Right to Limit Use of Sensitive Personal Information: limit our use of sensitive personal information to that necessary for providing services
  • Right to Non-Discrimination: we will not discriminate against you for exercising your privacy rights
Do Not Sell or Share My Personal Information: Priveluxe does not sell or share personal information for cross-context behavioural advertising. To confirm this or to exercise any California rights, contact info@priveluxe.ch with the subject line "California Privacy Rights Request".

To submit a verifiable consumer request, contact us at info@priveluxe.ch. We will acknowledge within 10 business days and respond within 45 days (extendable by 45 further days where necessary).

You may also designate an authorised agent to make a request on your behalf.

10. Your Rights — Other Regions

United Kingdom (UK GDPR / Data Protection Act 2018)

UK residents have rights equivalent to EU GDPR rights listed in Section 8. The UK supervisory authority is the Information Commissioner's Office (ICO) — ico.org.uk.

Canada (PIPEDA / Law 25 — Quebec)

Canadian residents may request access to, or correction of, their personal information held by us. For Quebec residents, additional rights apply under Law 25. Contact us at info@priveluxe.ch.

Brazil (LGPD)

Brazilian residents have rights under the Lei Geral de Proteção de Dados (LGPD), including rights to access, correction, anonymisation, portability, deletion, and objection. Contact us at info@priveluxe.ch to exercise these rights.

Australia (Privacy Act 1988)

Australian residents may access personal information we hold and request correction of inaccuracies. Complaints may be directed to the Office of the Australian Information Commissioner (OAIC) — oaic.gov.au.

Gulf Region (UAE, Saudi Arabia, Qatar)

Residents of Gulf countries are protected by applicable local data protection legislation. We handle all guest data with the same standard of care regardless of geographic origin. For any enquiries, contact info@priveluxe.ch.

All Other Regions

Regardless of where you are located, you may contact us at any time to request access, correction, or deletion of your personal information. We treat all such requests with equal priority.

11. Cookies & Tracking Technologies

Our website uses cookies and similar technologies. For full details on the types of cookies we use, their purpose, and how to manage your preferences, please read our Cookie Policy.

In summary:

  • Strictly Necessary Cookies: required for the website to function — no consent needed
  • Functional Cookies: remember your language preference — require consent
  • Analytics Cookies: help us understand how visitors use the site — require consent
  • Marketing Cookies: used to deliver relevant content — require consent

You may update your cookie preferences at any time by clicking Manage Cookie Preferences.

12. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include:

  • SSL/TLS encryption for all data transmitted via our website and email
  • Access controls limiting data access to authorised personnel only
  • Confidentiality obligations for all staff and service partners handling personal data
  • Regular review of our data handling practices

No internet transmission or electronic storage is 100% secure. While we strive to protect your data, we cannot guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and the relevant supervisory authority as required by applicable law.

13. Children's Privacy

Our services are intended for adults aged 18 and over. We do not knowingly collect personal data from children under 16. If you believe we have inadvertently collected data from a minor, please contact us at info@priveluxe.ch and we will delete it promptly.

14. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

  • Update the "Last updated" date at the top of this page
  • Notify you by email if you have provided us with your email address
  • Display a notice on our website for a reasonable period

We encourage you to review this Policy periodically. Your continued use of our services after changes take effect constitutes acceptance of the revised Policy.

15. Contact & Data Controller

For any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact the data controller. All data protection, privacy, and legal enquiries should be sent to the same address:

Data Controller Priveluxe — Luxury Experiences in Switzerland & Italy
Responsible Person Sciary
Address Lugano, Canton Ticino, Switzerland
Email (all enquiries) info@priveluxe.ch
WhatsApp +41 76 366 18 22
Legal framework Swiss Federal Act on Data Protection (FADP / nDSG, in force since 1 Sept 2023) & EU GDPR where applicable
Response time Within 30 days for GDPR/FADP requests; within 45 days for CCPA requests
Important disclaimer: This Privacy Policy is provided as a good-faith effort to inform users of our data practices. It does not constitute legal advice. We recommend consulting a qualified legal professional for advice specific to your jurisdiction. Priveluxe reserves the right to update this policy at any time.

© 2026 Priveluxe. All rights reserved. Lake Como & Canton Ticino, Switzerland.

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