01
What the site does
LUSSO has no user accounts, no checkout and no payment processing. Two forms collect personal data: the contact form, whose submissions are delivered to the LUSSO customer relationship system, and the newsletter form, whose submissions are delivered to the email service provider. The vehicle enquiry form on listing pages is not yet connected and sends nothing.
Every page loads two audience measurement services, and dealer profile pages embed a map. Both are described below, because they process data before you fill in anything.
02
Data that may be processed
- Technical logs
- The hosting provider processes an IP address, browser information, requested URL, timestamp and security events as part of ordinary server operation.
- Contact form data
- First name, last name, email address and the message you write.
- Newsletter data
- Email address and the language of the page you subscribed from.
- Enquiry data
- When vehicle enquiries are connected, the information entered may include a name, email address, telephone number, message and the public vehicle reference.
- Map requests
- Opening a dealer page containing an embedded Google map sends technical request data to Google.
- Analytics data
- Yandex.Metrica and Microsoft Clarity may process page URLs, referrers, device and browser details, IP-derived information, clicks, scrolling and other interaction or session data.
- Dealer data
- Public business identity, contact details and vehicle information supplied or authorised for marketplace presentation.
03
Why data is used
Data is processed to:
- operate, secure and troubleshoot the website;
- display authorised dealer and vehicle information;
- answer a message sent through the contact form;
- send the newsletter to people who asked for it;
- route a requested vehicle enquiry to the relevant dealer;
- measure visits, navigation and interaction with the website;
- respond to legal, privacy, rights or takedown requests;
- comply with applicable legal obligations.
Operating and securing the site, answering a message and routing an enquiry rest on the legitimate interest of running a marketplace and on the steps taken at your request. The newsletter rests on your consent, which you can withdraw from any newsletter email. Audience measurement rests on consent once the consent mechanism described above is in place.
04
Recipients and service providers
LUSSO does not sell personal data. The services below process data on behalf of LUSSO, except the dealer, who becomes an independent controller for the enquiry sent to them.
- OVH SAS
- Hosting. 2 rue Kellermann, 59100 Roubaix, France. Servers in the European Union.
- Brevo (Sendinblue SAS)
- Newsletter delivery and subscriber management. Paris, France.
- HubSpot
- Receives contact form submissions and the financing support requests sent from the finance calculator. Data may be transferred outside the European Economic Area under the transfer safeguards published by the provider.
- Salesforce
- Customer relationship system in which messages are handled. Data may be transferred outside the European Economic Area under the transfer safeguards published by the provider.
- The financing partner
- A financing partner selected by LUSSO receives the details and the scenario you submit through the finance calculator, and becomes responsible for its own use of them.
- Yandex
- Audience measurement through Yandex.Metrica, including session recording. Data may be processed outside the European Economic Area.
- Microsoft
- Audience measurement through Microsoft Clarity.
- Embedded map on dealer profile pages. Google Ireland Limited.
- The listing dealer
- Receives the vehicle enquiry you choose to send, and becomes an independent controller for it. The dealer is named on every listing.
05
Analytics
LUSSO uses Yandex.Metrica, including Webvisor session recording and click mapping, and Microsoft Clarity. These services can use cookies, local storage or similar technologies, and can produce session recordings and aggregated interaction reports.
Both currently load with the page, before any choice is offered. A consent mechanism is being introduced, and until it is in place you can refuse these technologies through your browser settings or the opt-out published by each provider. Data collected through Yandex.Metrica may be processed outside the European Economic Area.
06
Maps and cookies
Dealer profile pages embed a Google map. Opening such a page sends technical request data, including your IP address, to Google before you interact with the map.
Cookies and similar technologies are used by the analytics services and by the embedded map, under their own terms. LUSSO sets no advertising cookie and runs no advertising service.
07
Retention and security
Data is kept for the periods below, then deleted or anonymised. A longer period applies only where a legal obligation or the defence of a legal claim requires it.
- Server logs
- 6 months.
- Contact messages
- 24 months after the last exchange.
- Newsletter subscription
- Until you unsubscribe, then a further 3 years without any interaction.
- Vehicle enquiries
- 24 months, once enquiries are connected. The dealer applies its own retention to the copy it receives.
- Analytics cookies and data
- Cookies 13 months, collected data 25 months.
08
Your privacy rights
You have the right of access, correction, deletion, restriction, portability and objection, and the right to withdraw a consent you have given, at any time and without affecting what was done before.
You may also complain to a supervisory authority: the Andorran Data Protection Agency, where LUSSO is established, or the authority of your country of residence in the European Union.
Requests are answered at info@luxury.ad, and the Contact page carries the same address.
09
Controller details
The controller is LUXURY S.L., Edifici Montducal, AD500 Andorra la Vella, Principality of Andorra, which operates this marketplace under the LUSSO brand. Privacy requests go to info@luxury.ad.
LUSSO is established in Andorra and processes data under Andorran Law 29/2021. Because the marketplace addresses visitors in the European Union, the General Data Protection Regulation also applies to that processing.