Privacy Policy

Last updated: 15th January 2026

Introduction

CloudHub Novaes SARL ("we", "our", or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website cloudhubnovaes.pro or use our retail loyalty programme analytics services.

Data Controller Information

CloudHub Novaes SARL is the data controller responsible for your personal information. Our company details are:

  • Company Name: CloudHub Novaes SARL
  • Registration Number: RCSB965241
  • VAT Number: LU96748531
  • Address: Rue des Bains 68, 4897 Differdange, Esch-sur-Alzette, Luxembourg
  • Email: privacy@cloudhubnovaes.pro
  • Phone: +352 23562781

Data Collection

The data we collect includes personal information you provide directly to us and information automatically collected through your use of our website and services. We collect this information to provide our retail analytics services effectively and improve your experience with our platform.

Information You Provide

When you interact with our services, we may collect the following types of personal data:

  • Contact information (name, email address, phone number, company details)
  • Business information related to your retail operations and loyalty programmes
  • Communication preferences and correspondence history
  • Project requirements and analytical objectives
  • Financial information for billing and payment processing

Automatically Collected Information

When you visit our website, we automatically collect certain information including:

  • IP address and device information
  • Browser type and version
  • Pages visited and time spent on our website
  • Referring website information
  • Cookie and tracking technology data

How We Use Your Information

We use of your data is based on legitimate business interests, contractual necessity, and your consent where required. The specific ways we use your information include:

  • Providing retail loyalty programme analytics services and consultations
  • Communicating with you about our services and responding to enquiries
  • Processing payments and managing client accounts
  • Improving our website functionality and user experience
  • Conducting market research and business development activities
  • Complying with legal obligations and regulatory requirements
  • Protecting our business interests and preventing fraud

Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your personal data based on the following legal grounds:

  • Contract Performance: Processing necessary for performing our analytics services
  • Legitimate Interests: Business operations, customer service, and service improvement
  • Consent: Marketing communications and optional data processing activities
  • Legal Obligation: Compliance with applicable laws and regulations

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 cookie usage, please review our Cookie Policy.

Data Sharing and Disclosure

We do not sell, trade, or otherwise transfer your personal information to third parties except in the following circumstances:

  • With your explicit consent
  • To trusted service providers who assist in our business operations (under strict confidentiality agreements)
  • When required by law or legal process
  • To protect our rights, property, or safety, or that of our clients
  • In connection with a business merger, acquisition, or sale

International Data Transfers

As we operate within the European Union, your personal data is primarily processed within the EU. If we transfer data outside the EU, we ensure appropriate safeguards are in place, including adequacy decisions or standard contractual clauses approved by the European Commission.

Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes outlined in this privacy policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific data retention periods include:

  • Client project data: 7 years after project completion
  • Marketing communications: Until you unsubscribe or object
  • Website analytics data: 26 months
  • Financial records: As required by Luxembourg law

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 under certain circumstances
  • Right to Restrict Processing: Request limitation of data processing
  • Right to Data Portability: Request transfer of your data
  • Right to Object: Object to processing based on legitimate interests
  • Right to Withdraw Consent: Withdraw consent for consent-based processing

Data Security

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

Children's Privacy

Our services are not intended for individuals under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that we have collected personal data from a child under 16, we will take steps to delete such information promptly.

Changes to This Privacy 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. Continued use of our services after such changes constitutes acceptance of the updated policy.

Contact Information

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

Supervisory Authority

If you believe that our processing of your personal data violates GDPR, you have the right to lodge a complaint with the Luxembourg National Commission for Data Protection (CNPD) or your local supervisory authority.