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Privacy Policy

At Lusso Circle Ltd (“we,” “us,” or “our”), your privacy is extremely important to us. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our website, submit enquiries, or interact with our services. We are committed to safeguarding your personal data and ensuring transparency about how it is handled.

By using our website [www.lussocircle.co.uk] or any of our services, you agree to the terms outlined in this policy.

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1. Who We Are

Lusso Circle Ltd is a lifestyle concierge company based in the United Kingdom, offering luxury coordination services including but not limited to vehicle hire, private jet charters, yacht charters, and bespoke travel arrangements through trusted third-party partners.

Our registered office is located in the UK.
If you have any questions about this Privacy Policy, you can contact us at:
Email: enquiries@lussocircle.co.uk

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2. What Information We Collect

We may collect and process the following personal data:

a. Information You Provide Directly:
   •    Name
   •    Email address
   •    Telephone number
   •    Location (departure/arrival)
   •    Travel details and preferences
   •    Any additional information you provide in enquiry forms, messages, or WhatsApp communications

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b. Information We Collect Automatically:
   •    IP address
   •    Browser type and version
   •    Device type
   •    Operating system
   •    Referring website URLs
   •    Usage data (pages visited, time on site, etc.)

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c. Cookies and Tracking:
We use cookies and similar tracking technologies to monitor website traffic and enhance user experience. You can manage cookie preferences through your browser settings.

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3. How We Use Your Information

We use your data to:
   •    Respond to your enquiries and provide requested services
   •    Communicate with you via email, phone, or WhatsApp
   •    Coordinate quotes and bookings with third-party providers
   •    Improve our website functionality and content
   •    Maintain internal records and client files
   •    Comply with legal obligations and regulations

We do not sell your personal information.

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4. Legal Basis for Processing

Under the UK GDPR, we rely on the following lawful bases to process your personal data:
   •    Consent: When you voluntarily submit information through forms or messages
   •    Legitimate Interests: To provide and improve our services and respond to your enquiries
   •    Contractual Necessity: When coordinating services you’ve requested
   •    Legal Obligation: To comply with applicable laws and regulations

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5. Sharing Your Information

We may share your personal data with:
   •    Trusted third-party service providers (e.g. vehicle rental, aviation, or yacht partners) to fulfil your request
   •    Professional service providers (e.g. IT support, legal, accounting)
   •    Regulators or law enforcement where legally required

All third-party partners are expected to maintain appropriate levels of data protection.

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6. International Transfers

As part of our service offering, your data may be transferred outside the UK (e.g. to service providers in the EU, UAE, or other regions). In such cases, we ensure appropriate safeguards are in place to protect your data, such as Standard Contractual Clauses or equivalent mechanisms.

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7. Data Retention

We retain personal information only as long as necessary to fulfil the purpose for which it was collected, including legal, accounting, or reporting obligations. Typically:
   •    Enquiries: retained for up to 12 months
   •    Bookings: retained for up to 6 years
   •    Marketing opt-ins: until you unsubscribe

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8. Your Rights Under UK GDPR

You have the right to:
   •    Access your personal data
   •    Correct inaccurate or incomplete data
   •    Request deletion of your data (“right to be forgotten”)
   •    Restrict or object to processing
   •    Withdraw consent at any time
   •    Lodge a complaint with the Information Commissioner’s Office (ICO)

To exercise your rights, email us at enquiries@lussocircle.co.uk.

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9. Security of Your Data

We take reasonable steps to secure your information through encryption, access controls, and secure servers. However, please note that no method of internet transmission is 100% secure.

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10. Third-Party Links

Our website may contain links to other websites. We are not responsible for the content or privacy practices of those sites. We encourage you to read their policies before submitting personal data.

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11. Children’s Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect data from children. If we become aware of such data being collected, we will take steps to delete it.

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12. Changes to This Policy

We may update this Privacy Policy periodically. Any changes will be posted on this page with an updated “Effective Date.” Continued use of our services after changes indicates your acceptance.

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