Privacy Policy

Last updated: 15 January 2026

Data Controller Information

The data controller responsible for your personal data is:

• Company: clearvertexis.top SARL
• Address: Boulevard de la Pétrusse 105, 4162 Esch-sur-Alzette, Luxembourg
• Registration Number: RCSB932871
• VAT Number: LU93648257
• Email: [email protected]
• Phone: +352 26264745

Data Collection

We collect different types of personal data depending on how you interact with our website and services. The data we collect includes information you provide directly to us and information we collect automatically when you use our website.

Information You Provide

When you contact us through our website forms, request information, or engage our services, we may collect:

• Name and contact details (email address, phone number)
• Business information (company name, number of locations, business goals)
• Communication preferences and enquiry details
• Any other information you choose to provide in your messages

Information We Collect Automatically

When you visit our website, we may automatically collect:

• IP address and browser information
• Device type and operating system
• Pages visited and time spent on our website
• Referral sources and website navigation patterns
• Cookie and tracking technology data (see our Cookie Policy for details)

How We Use Your Information

We use your personal data for the following purposes, based on legitimate business interests and your consent where required:

Service Provision

• To respond to your enquiries and provide requested information
• To deliver our beauty salon scaling consultation services
• To communicate with you about our services and your projects
• To process and fulfil service agreements

Business Operations

• To improve our website and service offerings
• To analyse website usage and optimise user experience
• To comply with legal obligations and regulatory requirements
• To protect our business interests and prevent fraud

Marketing and Communications

With your consent, we may use your information to:

• Send you information about our services and industry insights
• Provide personalised recommendations based on your business needs
• Invite you to relevant events or webinars

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 the cookies we use and how to manage them, please see our Cookie Policy.

Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

• Consent: Where you have given clear consent for specific processing activities
• Contract: To perform our contractual obligations when you engage our services
• Legitimate Interests: For our business operations, website improvement, and direct marketing (where not overridden by your rights)
• Legal Obligation: To comply with applicable laws and regulations

Data Sharing and Third Parties

We do not sell your personal data to third parties. We may share your information in the following circumstances:

• Service Providers: With trusted third-party service providers who assist us in operating our website and delivering our services (such as hosting providers, analytics services)
• Legal Requirements: When required by law, regulation, or legal process
• Business Transfers: In connection with a merger, acquisition, or sale of business assets
• Protection: To protect our rights, property, or safety, or that of our clients or others

International Data Transfers

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

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected and to comply with legal obligations. Our typical data retention periods are:

• Enquiry Data: 3 years from last contact
• Client Data: 7 years after service completion (for legal and tax purposes)
• Website Analytics: 26 months (Google Analytics default)
• Marketing Data: Until you withdraw consent or 3 years of inactivity

Your Rights

Under GDPR and other 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 process your data
• Right to Data Portability: Request transfer of your data to another service provider
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw consent for processing where consent is the legal basis

To exercise any of these rights, please contact us using the details provided below.

Data Security

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

• Secure data transmission using SSL/TLS encryption
• Regular security assessments and updates
• Access controls and authentication measures
• Staff training on data protection principles
• Incident response procedures

Children's Privacy

Our services are not directed to individuals under the age of 16, and we do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without appropriate consent, we will take steps to delete such information.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. 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 policy periodically.

Contact Us

If you have questions about this Privacy Policy, wish to exercise your rights, or need to contact us regarding data protection matters, please reach out to us:

• Email: [email protected]
• Phone: +352 26264745
• Post: clearvertexis.top SARL, Boulevard de la Pétrusse 105, 4162 Esch-sur-Alzette, Luxembourg

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with the Luxembourg National Commission for Data Protection (CNPD) or your local data protection authority.