Privacy Policy

Last updated: 1st January 2026

Introduction

velqorixantemula.top SARL ("we", "our", or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and protect your personal information when you use our website and services.

Data Controller Information

The data controller responsible for your personal information is velqorixantemula.top SARL, registered in Luxembourg with registration number RCSB486251, located at Grand-Rue 100, 4143 Esch-sur-Alzette, Luxembourg.

Data We Collect

We collect and process the following types of personal data when you interact with our services:

• Contact Information: Name, email address, phone number, and postal address
• Membership Data: Membership preferences, treatment history, and booking information
• Communication Records: Records of correspondence and enquiries you send to us
• Website Usage Data: IP address, browser type, pages visited, and time spent on our website
• Payment Information: Billing address and payment method details (processed securely by our payment providers)

How We Use Your Information

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

• Providing spa membership services and processing bookings
• Communicating with you about your membership and appointments
• Processing payments and managing billing
• Improving our services and website functionality
• Sending marketing communications (with your consent)
• Complying with legal obligations and resolving disputes

Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds: performance of a contract, legitimate interests, legal compliance, and your explicit consent for marketing communications and optional services.

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 our use of cookies, please see our Cookie Policy.

Data Sharing

We may share your personal information with:

• Service providers who assist us in operating our business (payment processors, booking systems)
• Professional advisers such as lawyers, accountants, and consultants
• Regulatory authorities when required by law
• Third parties in connection with a business transfer or acquisition

Data Retention

We retain your personal data for as long as necessary to provide our services and comply with legal obligations. Membership data is retained for the duration of your membership plus 7 years for accounting and legal purposes. Marketing communications data is retained until you withdraw consent. Website analytics data is typically retained for 26 months.

Your Rights

Under GDPR, you have the following rights regarding your personal data:

• Right of access: Request copies of your personal data
• Right to rectification: Request correction of inaccurate data
• Right to erasure: Request deletion of your data in certain circumstances
• Right to restrict processing: Request limitation of how we use your data
• Right to data portability: Request transfer of your data to another service
• Right to object: Object to processing based on legitimate interests
• Right to withdraw consent: Withdraw consent for marketing communications

International Data Transfers

Some of our service providers may be located outside the European Economic Area (EEA). When we transfer your data internationally, we ensure appropriate safeguards are in place, such as adequacy decisions, standard contractual clauses, or certification schemes.

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. This includes encryption, access controls, regular security assessments, and staff training on data protection.

Contact Information

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us:

Complaints

If you believe we have not handled your personal data in accordance with this policy, you have the right to lodge a complaint with the Luxembourg National Commission for Data Protection (CNPD) or your local supervisory authority.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of significant changes by posting the updated policy on our website with a new effective date.