Last updated: 3rd September 2026

The Luxe Nomad Limited (“we”, “us”, or “TLN”) is committed to protecting your personal data. This Policy explains how we collect, use, disclose, and protect personal data in connection with theluxenomad.com and our services, in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”).

This Policy applies to personal data we hold or control, including personal data held by organisations we have engaged to process personal data on our behalf.

ARTICLE 1 (BUSINESS OPERATOR INFORMATION)

ARTICLE 2 (CATEGORIES OF PERSONAL DATA COLLECTED)

We collect the following personal data, by context.

1. Bookings and Reservations: Name, name as it appears on travel documents, date of birth, nationality, contact details (email, phone), passport information and copy (where required for your stay), payment information, information on accompanying guests, arrival/departure details, stay history, special requests, and emergency contact information.
2. Enquiries (Website, Email, WhatsApp, and Other Messaging Channels): Name, contact details, and the content of your enquiry.
3. Guest Services (Activities, Transfers, Dining, and Similar Arrangements): Name, contact details, number of participants, timing, and information reasonably necessary to arrange the service (for example, sizing information for equipment rental).
4. Health and Safety-Related Information: Where you disclose it to us, we may collect information about allergies, dietary requirements, medical conditions, or accessibility needs, to the extent necessary to arrange your stay or guest services safely. We collect this only based on your own disclosure and with your consent, and use it solely for that purpose.
5. Marketing and Newsletter Sign-Up: Email address, name, country of residence, and areas of interest.
6. Website Use: Cookies, IP address, device and browser information, browsing behaviour, and referrer information (see Article 6).
7. Property Owner and Management Enquiries: Name or company name, contact details, and information relevant to the property management relationship.

ARTICLE 3 (PURPOSES OF USE)

We use your personal data for the following purposes.

1. Purposes Relating to Bookings and Guest Services:
   1. accepting, confirming, changing, and cancelling bookings;
   2. arranging and providing guest services;
   3. billing and payment processing;
   4. responding to enquiries, requests, and complaints; and
   5. contact in the event of an emergency during your stay.
2. Purposes Relating to Marketing:
   1. sending marketing communications, where you have consented; and
   2. analysing usage to improve our services and website.
3. Purposes Relating to Legal and Administrative Matters:
   1. complying with legal and regulatory obligations; and
   2. exercising or defending legal rights.

ARTICLE 4 (CONSENT AND MARKETING)

1. Where required, we obtain your consent separately for marketing communications and for any use of your personal data beyond what is necessary to respond to your enquiry or fulfil your booking. Accepting our Booking Terms and Conditions is not treated as consent to receive marketing - these are always handled as a separate, distinct step. Where local law requires an explicit opt-in for marketing consent (this currently applies to guests in mainland China), we obtain that consent through an unbundled, standalone step, not combined with booking acceptance.
2. You may withdraw your consent to marketing at any time by using the unsubscribe link in our emails or contacting us using the details in Article 1.

ARTICLE 5 (OUTSOURCING AND DISCLOSURE OF PERSONAL DATA)

1. We may disclose personal data to the following categories of service providers, engaged to help us operate our business:
   1. providers of booking, property management, and channel management systems;
   2. online travel agencies and other booking intermediaries;
   3. payment processing providers;
   4. cloud hosting and server providers;
   5. CRM and email delivery service providers;
   6. customer support and call centre providers;
   7. marketing and advertising service providers; and
   8. professional service providers (accounting, legal, and similar).
2. We select service providers using appropriate criteria, require them to protect personal data to a standard consistent with this Policy, and exercise appropriate oversight of their handling of personal data. We do not sell personal data to third parties.
3. We may also disclose personal data to other Luxe Nomad group companies, and to regulatory or governmental authorities where required by law.
4. Where necessary to fulfil a booking, we may share a guest’s name, contact details, and stay information with the relevant property owner or their representative, for purposes such as check-in coordination and on-site guest services.

ARTICLE 6 (COOKIES AND SIMILAR TECHNOLOGIES)

1. Our website uses cookies and similar technologies to operate the site, remember your preferences, analyse usage, and, where applicable, support advertising. You can manage cookie preferences through your browser settings; disabling certain cookies may affect site functionality.
2. The main tools and providers we use are as follows.

ARTICLE 7 (CROSS-BORDER TRANSFER OF PERSONAL DATA)

1. Personal data may be transferred to and processed by group companies and service providers located outside Hong Kong. We take appropriate steps to protect personal data transferred in this way.
2. The recipients and countries to which personal data is provided are as follows.

3. In addition, where a property owner or their representative is located outside Hong Kong, we take the same protective steps described in this Article when sharing guest information with them for check-in coordination and on-site guest services.

ARTICLE 8 (DATA SECURITY)

1. To protect personal data against unauthorised access, loss, or disclosure, we implement measures across the following areas:
   1. organisational measures: a designated person responsible for personal data handling, and internal reporting procedures for security concerns;
   2. personnel measures: confidentiality obligations for staff, and training on data handling;
   3. physical measures: controls on access to areas and devices where personal data is handled; and
   4. technical measures: access controls, authentication, and safeguards against unauthorised system access.

ARTICLE 9 (DATA RETENTION)

1. We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by law, after which it is deleted or anonymised.
2. The principal retention periods are as follows.

ARTICLE 10 (YOUR RIGHTS)

1. Under the PDPO, you have the right to request access to, and correction of, personal data we hold about you. Requests should be made in writing to the contact details in Article 1, together with sufficient information to verify your identity.
2. We will respond within forty (40) days, as required under the PDPO.
3. We may charge a reasonable fee for access requests, which we will confirm before processing your request.

ARTICLE 11 (COMPLAINTS)

1. If you have concerns about how we handle your personal data, please contact us using the details in Article 1.
2. You may also lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD).

ARTICLE 12 (CHANGES TO THIS POLICY)

1. We may update this Policy from time to time. The “last updated” date at the top of this page will reflect the most recent revision.
2. Where a change is material, we will provide reasonable notice before it takes effect.

ARTICLE 13 (GOVERNING LAW)

1. This Policy is governed by the laws of Hong Kong.

Effective date: 3rd September 2026
Last updated: 3rd September 2026
The Luxe Nomad Limited