Privacy Policy

1. Who we are

LuxeLegs Ltd (“LuxeLegs”, “we”, “us”) is a company registered in England and Wales under company number 17418419, with its registered office at 128 City Road, London, United Kingdom, EC1V 2NX. We operate the marketing website at luxe-legs.com. For the purposes of UK data protection law, LuxeLegs Ltd is the data controller for the personal data described in this policy.

LuxeLegs is a marketplace concept for chauffeur dead legs, the repositioning journeys that a chauffeur or fleet is already making. The product is currently pre-launch. This policy describes only the marketing website; a separate policy will apply to the LuxeLegs application when it opens to users.

2. Scope of this policy

This policy applies to visitors of luxe-legs.com and its sub-pages for travellers, operators and the user guide. It does not cover third-party sites we link to, such as the LuxeLegs application at luxe-legs.app or the demo environment, each of which will carry its own terms and privacy information.

3. What we collect

We deliberately collect as little as possible. On this website we process:

Data	What it is	How
Page views and clicks	Which pages are viewed and which buttons or download links are used, plus the page path and referring site.	First-party analytics beacon
Approximate location	Country, region and city, plus a coarse latitude and longitude, derived from your connection at our CDN edge.	Edge-derived, never from a stored IP
Device type	Whether the view was on mobile, tablet or desktop, and a browser user-agent string.	Sent by your browser
Aggregate page-view counts	Anonymised visit totals with no cross-site tracking.	Cloudflare Web Analytics
Feedback you send	Your name, email and message, only if you choose to submit the feedback form.	You give it to us directly

We do not collect or store your IP address, we do not use advertising or cross-site tracking cookies, and we do not attempt to identify individual visitors from analytics data.

Usage analytics in the LuxeLegs app

The LuxeLegs app, on the web at luxe-legs.app and in the iOS and Android apps, records how the app is used so we can see which screens and steps work and where people get stuck. It uses Matomo, which we host ourselves on infrastructure we control, so the data is not shared with an analytics company.

• What is recorded: the screens you open, with any booking, journey or account numbers removed from the address; the type of action you complete, such as signing in or making an offer, but never what you typed; the type of account (for example traveller or operator); your device type, language and approximate location; and which version of the app you are using.
• What is not recorded: your name, email address, phone number, account id, payment details or the content of anything you enter. There is no session recording or heatmap in the app.
• No cookies and no tracking across visits: nothing is stored on your device for analytics, and each time you open the app it starts with a new random id, so separate visits are not linked together.
• Your IP address is used to work out an approximate location and is shortened before it is stored, so the stored value cannot identify your connection.
• Opting out: if your browser or device sends a Do Not Track or Global Privacy Control signal, the app records nothing.

Crash and error reports

When the app or our server hits a fault, a technical report is sent to Sentry, an error reporting service, hosted in the European Union (Frankfurt). It holds the error, the screen or route where it happened with any booking, journey or account numbers removed, the app version and your device type. It does not include your name, email address, phone number, account id, payment details or anything you have typed, and there is no screen recording. Reports are kept for up to 30 days and are used only to find and fix faults.

Journey checks in the LuxeLegs app

Each dead leg is offered for the journey the operator listed, so the app checks that a booked journey matches it.

• Your pickup and drop-off: before you book or make an offer, you confirm where you will be picked up and dropped off. We look these up with Google Maps to measure the journey and compare it with the listing. Your confirmed pickup and drop-off are shared with the operator and driver so they can carry out the journey.
• Driver location at the start and end of a ride: when a driver taps Start ride or Finish ride, we record the phone’s location once at that moment, with its accuracy and the time. We do not track location at any other time, and never in the background. Travellers and operators cannot see these locations; only LuxeLegs administrators can, when reviewing a journey.
• Why: to confirm that the journey carried out matches the booking and to investigate misuse of the marketplace. We rely on our legitimate interest in preventing fraud and keeping the marketplace fair. A mismatch is reviewed by a person; it does not trigger any automatic decision.
• How long: start and finish locations are kept for 12 months after the booking ends, then deleted.

4. Location without storing your IP address

When your browser requests a page, our content delivery network (Amazon CloudFront) determines an approximate location from the network request and passes only the resulting country, region, city and a coarse latitude and longitude to us. Your IP address is used momentarily in transit to route the request and to derive that location; it is never written to our records. What we store is the approximate place, not the address that produced it. This lets us understand which regions are interested in LuxeLegs without holding data that identifies you.

5. Cookies

This website does not set analytics, advertising or tracking cookies. Our first-party analytics and Cloudflare Web Analytics are both cookieless. Your browser may hold a purely local preference, such as your light or dark theme choice, on your own device; this is not sent to us and is not used to track you. Because we do not use non-essential cookies, we do not show a cookie consent banner.

6. Why we process this data

• To understand how the site is used and which pages and calls to action are useful, so we can improve them.
• To see, at a country and city level, where interest in LuxeLegs is coming from as we prepare to launch.
• To keep the site secure and reliable, and to detect abuse.
• To respond to you if you contact us through the feedback form.

7. Legal basis

Under the UK GDPR we rely on the following legal bases:

• Legitimate interests for cookieless analytics, approximate location and security, namely our interest in understanding and improving a pre-launch product. Because the data is not tied to your identity and no tracking cookies are used, the impact on you is minimal.
• Consent where you actively submit the feedback form or opt in to hear from us; you can withdraw at any time.

8. Who we share it with

We do not sell your data. We use a small number of trusted service providers who process data on our behalf:

• Amazon Web Services (hosting, content delivery and edge location) in the UK and EU regions.
• Cloudflare for privacy-friendly, cookieless page-view analytics.
• Resend for sending email, such as delivering feedback you submit to our team.
• Google Maps Platform for looking up and measuring journeys in the LuxeLegs app. It receives the place names you enter, not your name or account details.

Each acts under contract and only on our instructions. We may also disclose data if required by law.

9. How long we keep it

Analytics events, including the approximate location, are automatically deleted after 90 days. Feedback you send is kept only for as long as needed to deal with your message and any follow-up, and is then removed. In the LuxeLegs app, driver locations recorded at the start and end of a ride are kept for 12 months after the booking ends.

10. International transfers

We aim to process data in the UK and the European Economic Area. Where a provider processes data outside the UK or EEA, we rely on appropriate safeguards such as UK International Data Transfer Agreements or Standard Contractual Clauses.

11. Your rights

Under UK data protection law you have the right to access, correct, delete or restrict processing of your personal data, to object to processing based on legitimate interests, and to data portability where it applies. Because our analytics data is not linked to your identity and holds no IP address, we usually cannot connect an individual analytics record to you, which limits what we can retrieve for such requests. For any data you have given us directly, such as feedback, you can exercise these rights by contacting us. You also have the right to complain to the Information Commissioner’s Office at ico.org.uk.

12. Changes to this policy

We may update this policy as the product develops. The date at the top shows when it was last changed. Material changes will be reflected on this page.

13. Contact

For any privacy question or to exercise your rights, contact us at info@luxe-legs.com, or write to us at LuxeLegs Ltd, 128 City Road, London, United Kingdom, EC1V 2NX.