LUX24 PRIVACY POLICY

1. Introduction

This Privacy Policy explains how KEY24 INC., operating under the brand name “LUX24 Limo” (“LUX24,” “we,” “us,” or “our”), collects, uses, discloses, stores, retains, and protects Personal Information.

This Privacy Policy applies to customers, passengers, guests, Corporate Customers, website visitors, mobile application users, Chauffeurs, Fleet Operators, Transportation Providers, applicants, authorized fleet staff, and other persons who interact with LUX24.

It applies when you visit the LUX24 website; use a LUX24 mobile application; create or use an Account; request, reserve, manage, receive, or pay for Transportation Services; travel as a passenger or Guest; make a Booking for another person; use a corporate or business account; apply to become a Chauffeur, Fleet Operator, or Transportation Provider; provide Transportation Services through the LUX24 Platform; communicate with LUX24; participate in a promotion, referral program, or survey; or otherwise interact with LUX24 or the Platform.

By accessing or using the Platform, submitting information to LUX24, creating an Account, or requesting Transportation Services, you acknowledge that you have read and understood this Privacy Policy. Where applicable law requires consent, LUX24 will obtain an appropriate form of consent before collecting, using, or disclosing Personal Information.

2. Who We Are

LUX24 Limo is a technology platform operated by KEY24 INC., a federally incorporated Canadian corporation. LUX24 enables customers to discover, request, reserve, manage, track, and pay for premium passenger transportation and chauffeur services.

The Platform may provide online and mobile Booking, advance reservations, on-demand or scheduled transportation requests, pricing and fare estimates, vehicle and service-class selection, dispatch and trip-management technology, customer and Chauffeur communications, location and status information, payment facilitation, corporate travel tools, safety and support features, flight and travel monitoring, and customer-service assistance.

Transportation Services available through the Platform are generally performed by independent Transportation Providers, including independent Chauffeurs, Fleet Operators, limousine companies, vehicle-for-hire operators, and other licensed transportation businesses. Unless LUX24 expressly identifies itself as the direct Transportation Provider for a particular Booking, LUX24 acts as a technology, Booking, dispatch, payment-facilitation, communication, and service-management platform.

LUX24 does not necessarily own, operate, lease, maintain, control, employ, or insure every vehicle or Chauffeur made available through the Platform. Each Transportation Provider is independently responsible for its own business operations, licences and permits, commercial automobile insurance, vehicle registration and inspections, safe vehicle condition, legal compliance, tax and business-registration requirements, availability, accepted Booking decisions, vehicles and equipment, operating expenses, personnel or subcontractors, privacy and safety requirements, and accepted Transportation Services.

Nothing in this Privacy Policy is intended to create an employment relationship, partnership, joint venture, franchise, fiduciary relationship, or general agency relationship between LUX24 and a Transportation Provider. The legal status of any relationship is determined by applicable law and the actual circumstances of that relationship, not solely by terminology used in this Policy or another agreement. Service, vehicle, safety, customer-experience, Platform, brand, and quality-control standards protect customers and support lawful Platform operations; they are not intended by themselves to create an employment relationship.

Where a Fleet Operator provides or manages Chauffeurs, the Fleet Operator is independently responsible for its relationship with those Chauffeurs, including any employment, contractor, payroll, tax, insurance, workplace-safety, or labour obligations.

3. Scope of This Privacy Policy

This Privacy Policy applies to Personal Information processed through the LUX24 website, customer and Chauffeur applications, customer, passenger, Chauffeur, Fleet Operator and corporate portals, Booking and reservation forms, pricing, dispatch, trip-management, payment and invoicing systems, location and trip-tracking tools, email, telephone, SMS, chat, push-notification and messaging services, support systems, driver and vehicle onboarding, identity, licence, insurance and document verification, safety and incident reporting, lost-property processes, marketing and referral programs, and other LUX24 features that refer to this Privacy Policy.

This Policy does not govern the independent privacy practices of third parties that collect or process information for their own purposes, including banks, card networks, payment processors, insurers, government authorities, municipal licensing bodies, law enforcement, airports, airlines, hotels, travel agencies, app stores, mapping providers, social networks, identity-verification providers, and independent Transportation Providers. Those organizations may have their own privacy policies and independent legal obligations.

4. Definitions

“Account” means an account created by a customer, passenger, Chauffeur, Fleet Operator, Corporate Customer, administrator, employee, contractor, or other authorized user.

“Booking” means a request, reservation, order, or confirmed arrangement for Transportation Services or related services.

“Chauffeur” means a driver who provides or may provide Transportation Services requested through the LUX24 Platform.

“Corporate Customer” means a company, hotel, travel agency, event organizer, government body, aviation operator, professional firm, or other organization that uses LUX24 for business transportation.

“Fleet Operator” means a vehicle owner, limousine company, transportation company, vehicle-for-hire operator, or other organization that provides vehicles or Chauffeurs.

“Guest” means a passenger for whom another person or organization makes a Booking.

“Personal Information” means information about an identifiable individual or information that can reasonably be linked to an identifiable individual.

“Platform” means the LUX24 website, applications, portals, software, APIs, dispatch systems, payment tools, communications systems, tracking services, and related technologies.

“Transportation Provider” means an independent Chauffeur, Fleet Operator, limousine company, vehicle-for-hire operator, or other person or organization that accepts or performs Transportation Services arranged through the Platform.

“Transportation Services” means passenger transportation, chauffeur, airport-transfer, hourly, point-to-point, event, corporate, or related services requested through the Platform.

5. Information We Collect

The information LUX24 collects depends on how you interact with LUX24, the services you request, your role on the Platform, the features you use, permissions granted through your device, information required to perform a Booking, and applicable legal and regulatory requirements.

We may collect information directly from you; automatically through the Platform; from another person making a Booking for you; from Corporate Customers, Transportation Providers and service providers; and from legally authorized public or government sources. LUX24 seeks to limit collection to information reasonably necessary for identified business, safety, contractual, or legal purposes.

6. Information You Provide Directly

You may provide LUX24 with your name, preferred name, title, telephone number, email address, home, business and billing addresses, username and password, authentication information, profile photograph, language and communication preferences, accessibility preferences, emergency-contact information, employer, company, department and job title, passenger and travel information, payment and billing information, Booking instructions, vehicle preferences, passenger and luggage counts, child-seat, mobility, accessibility and service-animal information, promotional and referral information, ratings, reviews, surveys, support requests, complaints, incident and lost-property reports, photographs, videos, documents, identity-verification information, and other information you voluntarily provide.

You should not provide Personal Information that is unnecessary for the requested service.

7. Booking and Trip Information

When a Booking is requested, managed, or performed, we may collect the Booking number, customer identifier, passenger or Guest name, requested pickup date and time, pickup address, destination and additional stops, service type, vehicle class, airport, terminal, airline and flight information, train, cruise, hotel, event or private-aviation information, estimated and actual pickup, arrival and completion times, estimated and actual route, duration and distance, passenger and luggage counts, accessibility requirements, special instructions, assigned Chauffeur, vehicle and Fleet Operator, dispatch history, trip status, waiting time, route changes, delays, cancellations, no-show records, charges, payment status, tips, refunds, credits, ratings, reviews, complaints, safety reports, and related communications.

Flight, train, cruise, or other travel information may be used to monitor expected arrival times, delays, cancellations, or terminal changes and to adjust pickup arrangements where reasonably possible. Third-party travel information may be delayed, inaccurate, incomplete, or unavailable. LUX24 does not guarantee its accuracy.

8. Bookings Made for Other People

A customer, employer, hotel, travel agency, assistant, family member, or other authorized person may make a Booking for another passenger. When you provide another person’s information, you represent that you are authorized to make the Booking and provide the information, that it is accurate, that the person has been appropriately informed, and that you will not provide unnecessary or excessively sensitive information. We may provide Booking information directly to the passenger or Guest and share necessary information with the assigned Transportation Provider.

9. Information Received From Third Parties

We may receive information about you from another person making a Booking, your employer, a Corporate Customer, family member, assistant, hotel, travel agency, airline, private aviation operator, event organizer, Fleet Operator, Chauffeur, payment processor, financial institution, card network, insurer, insurance broker, identity or background-verification provider, fraud-prevention provider, vehicle-information provider, licensing authority, government agency, public records, social-login provider, or another source you authorize. Where permitted by law, this information may be combined with information already held by LUX24.

10. Location and GPS Information

10.1 Customer and Passenger Location

With your device permission, LUX24 may collect precise or approximate location information to identify your pickup location, suggest nearby addresses or points of interest, identify airports, hotels, terminals or venues, calculate routes, distance, travel time and pricing, help a Chauffeur locate a passenger, display vehicle progress and estimated arrival time, support safety, respond to emergencies, prevent fraud, detect misuse, and improve Platform accuracy. You may manage location permissions through browser or device settings. Certain features may not function correctly if location access is disabled.

10.2 Chauffeur and Vehicle Location

LUX24 may collect precise or approximate Chauffeur and vehicle location only when reasonably necessary to operate the Platform, offer or perform Transportation Services, support safety, or comply with legal obligations.

Precise GPS location may be collected while a Chauffeur is signed in and marked Available; actively willing to receive Booking opportunities; reviewing or responding to an opportunity; travelling to a pickup; waiting for a passenger; performing an active trip; travelling between stops in an active Booking; completing an active trip; or completing a directly related safety, payment, or trip-status process.

Location information may include precise GPS coordinates, approximate location, travel direction, route, speed or movement information, time and date, distance from pickup or destination, estimated arrival time, availability status, Booking status, and location-update status.

LUX24 does not intentionally collect precise background GPS location to monitor a Chauffeur’s private activities when the Chauffeur is Offline, Off Duty, unavailable for Bookings, signed out, not responding to a Booking, and not providing or preparing to provide Transportation Services. The Platform may retain the last known operational location for a limited period to confirm a trip end, investigate an incident or payment dispute, detect manipulation, protect safety, prevent fraud, or comply with law. If a mobile operating system sends a background update during an active Booking or availability session, LUX24 will use it only for legitimate Platform, safety, dispatch, fraud-prevention, or trip-completion purposes.

Chauffeurs must not falsify, manipulate, spoof, disable, or interfere with required location information while Available or performing Transportation Services.

10.3 Location Accuracy

Location information may be affected by device limitations, satellite availability, coverage, connectivity, map-provider errors, incorrect addresses, traffic, construction, weather, or technical failures. LUX24 does not guarantee that displayed vehicle location, route, travel time, or estimated arrival time will always be exact.

11. Payment and Financial Information

LUX24 and authorized payment providers may collect and process information needed to authorize, complete, record, refund, or dispute payments, including cardholder name, billing address, payment type and token, limited card details and expiry information, transaction identifier and result, payment amount, currency, taxes, fees, tips, credits, promotional balances, gift cards, refunds, chargebacks, bank-transfer and e-transfer records, corporate billing, invoices, fraud indicators, and accounting and tax records.

Full payment-card numbers are generally submitted directly to an authorized payment processor. LUX24 does not intend to store complete payment-card numbers on its own systems. LUX24 may retain payment tokens, transaction identifiers, limited card information, payment status, receipts, invoices, refunds, and transaction history. Payment providers, financial institutions, and card networks may process information under their own policies and legal requirements.

12. Chauffeur, Fleet, Applicant, and Vehicle Information

If you apply to become or operate as a Chauffeur, Fleet Operator, Transportation Provider, vehicle owner, or authorized fleet staff member, we may collect legal name, date of birth, photograph, contact and address details, identification, driver’s licence information and images, proof of work eligibility, driving records, violations, suspensions or restrictions, legally permitted criminal-record or judicial-matters check information, transportation permits, vehicle registration, ownership or lease documents, vehicle specifications, licence plate, VIN, photographs, inspection and safety records, commercial automobile insurance information, business registration and tax information, banking and payout information, onboarding and training records, compliance and verification history, application and approval records, suspension or deactivation records, Booking and earnings records, ratings, complaints, device information, and Platform-related location information.

LUX24 may verify information through government registries, municipal licensing bodies, insurers, brokers, inspection facilities, identity and background-verification providers, vehicle databases, and other appropriate sources. Verification may reduce risk but does not guarantee future conduct, safety, reliability, or legal compliance.

13. Independent Transportation Provider Relationship

Transportation Providers operate independent businesses and are not employees of LUX24 unless a separate written agreement expressly states otherwise. Subject to applicable agreements and law, they may decide when to make themselves available, remain Offline or Off Duty, accept or decline opportunities, provide services through other platforms or directly to other customers, manage operating costs, use and maintain their own vehicles and equipment, employ or contract personnel where permitted, determine lawful methods for accepted services, bear business-loss risk, and benefit from efficient management.

LUX24 may establish eligibility, vehicle and document requirements, customer-service expectations, safety and privacy policies, service-quality and brand standards, and Platform-access rules to protect customers, support lawful operations, and preserve the Platform’s reputation. Nothing in this Policy alone determines employment or contractor status; the legal classification depends on actual facts and applicable law. LUX24 may enter separate Chauffeur, Fleet Partner, Transportation Provider, data-processing, or other agreements governing the relationship.

14. Corporate Account Information

For a corporate account, we may collect company and registration details, business address, corporate contacts, administrators, employee and traveller information, job titles, departments, cost centres, internal references, traveller profiles and preferred locations, billing contacts and invoices, payment arrangements, approval workflows, spending limits, permissions, Booking policies, trip and expense records, contracts, service-level information, and corporate communications. Authorized corporate administrators may view Booking information made through their corporate account, including traveller name, pickup, destination, date and time, trip status, price, receipt, invoice, and related activity. Corporate Customers may independently process this information under their own policies and legal obligations.

15. Communications and Customer Support

When you communicate with LUX24 or another Platform user, we may collect email, SMS, in-app and chat messages, WhatsApp communications, call information, voicemail, support tickets, contact forms, passenger-Chauffeur messages, dates, times, sender and recipient information, delivery status, attachments, screenshots, photographs, documents, recordings, and transcripts. Calls may be monitored or recorded where legally permitted and where appropriate notice or consent is provided.

Communications may be used to arrange Transportation Services, connect passengers and Chauffeurs, provide support, send Booking updates, investigate complaints and incidents, resolve disputes, protect safety, identify fraud, train support personnel, monitor service quality, and comply with legal obligations. LUX24 may use masked, temporary, or relayed numbers to reduce unnecessary disclosure of personal telephone numbers.

16. Device, Usage, and Technical Information

When you access the Platform, we may automatically collect IP address, browser type and version, device type, manufacturer and model, operating system, app version, device and advertising identifiers where permitted, language, time zone, regional settings, carrier and network information, screen size, pages or screens viewed, buttons and links selected, searches, session duration, navigation path, login and logout activity, authentication events, referring website, campaign information, crashes, error and diagnostic reports, performance data, security events, suspected unauthorized activity, cookie preferences, and dates and times of interactions. This information may be used to operate, secure, maintain, diagnose, analyze, and improve the Platform.

17. Cookies and Similar Technologies

LUX24 and authorized providers may use cookies, pixels, SDKs, tags, local storage, mobile identifiers, and similar technologies. Essential technologies authenticate users, maintain sessions, protect security, prevent fraud, remember language and privacy choices, retain Booking information, process payments, balance traffic, and provide required functions. Where permitted, analytics technologies measure use, identify errors, understand navigation, evaluate performance, and improve design and customer experience. Where permitted and, where required, with consent, advertising technologies measure campaigns, understand referrals, limit repeated advertisements, measure audiences, and provide relevant promotional information.

You may manage cookies through the LUX24 cookie-consent tool, where available, and browser or device settings. Disabling essential technologies may prevent some features from working properly.

18. How We Use Personal Information

LUX24 may use Personal Information to register, authenticate, secure, and recover Accounts; maintain preferences; receive and manage Bookings; calculate prices and estimates; identify available vehicles; present opportunities; match or assign Transportation Providers; dispatch services; provide pickup and destination information; connect Chauffeurs and passengers; track active trip progress; estimate arrival; process changes and cancellations; manage waiting time; track flights or trains; administer accessibility requests; support lost-property recovery; issue receipts and invoices; and maintain trip records.

We may also authorize and process payments, taxes, fees, tips, refunds, credits, gift cards, corporate billing and payouts; prevent fraud and respond to chargebacks; verify identity, qualifications, licences and insurance; investigate unsafe conduct, accidents, complaints, claims, emergencies, fraud, abuse, unauthorized access, and Platform-rule violations; provide communications and support; analyze performance, dispatch, mapping, routes, estimates, service quality, provider performance, safety, accessibility, and reliability; conduct research and create aggregated statistics; and comply with transportation, licensing, insurance, tax, accounting, and other legal requirements.

19. Consent and Legal Grounds

Depending on circumstances and applicable law, LUX24 may process Personal Information based on your knowledge and consent, performance of a contract, requested pre-contract steps, compliance with a legal obligation, protection of safety or vital interests, legitimate business interests, prevention of fraud and misuse, or another legally authorized basis. Where processing is based on consent, you may withdraw it subject to legal or contractual restrictions and reasonable notice. Withdrawal may affect our ability to provide services because necessary pickup, destination, passenger, communication, location, and payment information is ordinarily required to arrange Transportation Services.

20. Automated Processing and Artificial Intelligence

LUX24 may use rules-based software, algorithms, analytics, artificial intelligence, or automated systems to calculate fare estimates and upfront prices; identify available vehicles; present opportunities; match providers; estimate routes, distances, travel times and arrival times; detect unusual activity, duplicate or fraudulent Bookings, payment risk, and missing or expired documents; prioritize support and safety reports; summarize communications; suggest support responses; analyze service quality; and improve Platform features.

These tools may consider pickup, destination, service, vehicle class, provider availability and location, traffic, historical Booking patterns, Account and payment activity, device information, and fraud or security indicators. LUX24 does not intend to make decisions producing significant legal effects solely through automated processing where law requires human review, notice, consent, explanation, or another safeguard. You may contact LUX24 regarding a decision materially affecting your Account or Platform access.

21. How We Share Personal Information

LUX24 may disclose Personal Information only when reasonably necessary for the purposes in this Policy or as permitted or required by law.

21.1 Transportation Providers

We may provide a prospective or assigned Transportation Provider with passenger name, masked or direct contact information, pickup, destination and stops, date and time, flight, train, hotel or event information, passenger and luggage information, accessibility, child-seat and service-animal requirements, special instructions, Booking status, relevant payment status, safety information, and information needed to review, accept, prepare for, or perform a Booking.

21.2 Customers and Passengers

We may provide customers and passengers with Chauffeur name, profile photograph, contact information or a masked contact method, vehicle make, model, colour, class, licence plate, Fleet Operator identity, estimated arrival time, and current vehicle location relating to an active Booking.

21.3 Service Providers

We may disclose information to providers supporting cloud hosting and storage, payment and financial services, mapping, navigation, geolocation, travel and flight information, email, SMS, telephone, chat and push notifications, identity, background, licence, vehicle and insurance verification, analytics, cybersecurity, fraud prevention, support, electronic signatures, document storage, accounting, auditing, legal and tax services, and permitted marketing measurement. Providers are expected to process information only for authorized purposes and under appropriate contractual, confidentiality, privacy, and security obligations.

21.4 Corporate Customers, Insurers, and Business Transactions

When a Booking is made, paid for, approved, or managed through a Corporate Customer, LUX24 may disclose relevant trip and Account information to authorized administrators. Information may be disclosed to insurers, brokers, adjusters, legal representatives, Transportation Providers, vehicle owners, repair facilities, claimants, witnesses, and other parties to investigate or manage accidents, injuries, damage, claims, complaints, or disputes.

Information may also be disclosed in connection with a proposed or completed financing, investment, restructuring, merger, acquisition, sale of assets, insolvency, or similar transaction, using appropriate confidentiality and legal safeguards where required. Information may be disclosed with your consent or direction, or where needed to provide a requested feature.

22. Transportation Provider Privacy Obligations

Transportation Providers may use Personal Information received through LUX24 only to review an opportunity, prepare for and perform an accepted Booking, contact the passenger for that Booking, locate pickup, complete an active Booking, respond to safety, complaints or lost-property matters, process an authorized payment or claim, or comply with law.

Transportation Providers are prohibited from selling passenger information, unrelated marketing, unauthorized personal or commercial contact, copying customer databases, unauthorized sharing, excessive retention, improperly bypassing LUX24, photographing passengers for personal, entertainment, publicity, or marketing purposes, unauthorized audio or video recording, publishing passenger information or communications, distributing trip information online, or otherwise misusing Personal Information. Violations may result in suspension, investigation, deactivation, termination, reporting, indemnification obligations, civil proceedings, and other available remedies.

23. Audio, Video, Dash Cameras, and Vehicle Systems

A Transportation Provider may use a dash camera, vehicle camera, telematics system, collision-detection system, or other safety technology only where permitted by applicable law. These systems may collect road-facing or exterior and interior video, legally permitted audio, speed, braking and acceleration information, GPS location, collision information, timestamps, and trip identifiers.

Recording systems may be used only for passenger and Chauffeur safety, accident investigation, insurance claims, dispute resolution, fraud prevention, legal compliance, law-enforcement requests, or protection of legal rights. Providers must provide any legally required notice and obtain any legally required consent before recording audio or video.

LUX24 does not authorize covert recording, unlawful surveillance, entertainment, personal content, social-media content, marketing recordings, or unauthorized publication or distribution. A Transportation Provider may not upload, publish, livestream, distribute, sell, repost, transmit, disclose, or otherwise make available passenger photographs, interior video, audio recordings, private conversations, trip information, or other recordings through social media, messaging services, blogs, podcasts, news or entertainment outlets, or any other public or private online service unless legally required or previously authorized in writing by both LUX24 and every identifiable affected person.

This prohibition applies even if a passenger’s name is not stated, a recording is viewed as humorous, the passenger is a public figure, the material is shared privately, deleted later, or was initially created for safety. Unauthorized recording or publication is a serious material violation and may lead to suspension, removal from active Bookings, deactivation, agreement termination, evidence preservation, passenger notification, reporting, civil action, indemnification, recovery of permitted costs, and other legal remedies.

24. Third-Party Services

The Platform may connect to or use third-party payment processors, banks and card networks, mapping and navigation providers, flight-information providers, application stores, social-login providers, email, SMS and messaging services, analytics, cloud and cybersecurity providers, spam-prevention services, social-media platforms, and external websites. Third parties may independently collect or process information under their own policies and terms. LUX24 is not responsible for a third party’s independent privacy practices except to the extent required by law.

25. Marketing Communications

Where permitted by law or with consent, LUX24 may send promotional offers, discounts, referral offers, loyalty communications, seasonal transportation offers, corporate-travel information, surveys, feedback requests, service announcements, and information about new features. You may unsubscribe from marketing emails using the link in the message or update available preferences or contact LUX24. Opting out does not prevent necessary communications concerning an active Booking, Account, payment, refund, safety, security, legal notices, or material service information.

26. Safety, Incidents, and Emergencies

We may collect, use, preserve, and disclose information reasonably necessary to prevent, identify, investigate, or respond to accidents, injuries, emergencies, threats, harassment, discrimination, violence, unsafe driving or vehicle conditions, fraud, theft, unauthorized payments, missing persons, lost property, insurance claims, licence or insurance concerns, cybersecurity incidents, Account compromise, privacy violations, unauthorized recordings, Platform-rule violations, and other threats to passengers, Chauffeurs, LUX24, or the public.

Relevant information may include Booking records, location information, communications, Account records, photographs, videos, recordings, documents, witness statements, vehicle information, payment information, device information, and third-party information. In an urgent emergency, contact local emergency services first and report the incident to LUX24 as soon as reasonably possible.

27. Legal and Government Disclosures

LUX24 may preserve, use, or disclose information where reasonably believed necessary to comply with law, licensing or regulatory requirements; respond to a court order, warrant, subpoena, or lawful demand; cooperate with law enforcement, regulators, or emergency services; protect safety or property; investigate fraud, abuse, or unlawful conduct; establish, exercise, or defend legal claims; enforce agreements and Platform rules; comply with insurance, tax, or accounting obligations; or report a privacy or cybersecurity incident where required.

LUX24 may reject, challenge, narrow, or seek clarification of a demand that appears invalid, unlawful, excessive, or inconsistent with applicable requirements.

28. International Data Processing

LUX24 is based in Canada. Personal Information may be processed or stored in Canada, the United States, or other countries where LUX24, Transportation Providers, or service providers operate. Information processed outside your province, territory, country, or region may be subject to laws of the jurisdiction where it is processed, including lawful access by courts, authorities, regulators, or law enforcement.

Where required, LUX24 will use appropriate safeguards for international transfers, including contractual privacy obligations, data-processing agreements, security requirements, transfer assessments, standard contractual clauses, statutory exceptions, or another recognized mechanism. When Transportation Services are requested in another jurisdiction, necessary Booking information may be transferred to a provider operating there.

29. Data Retention

LUX24 retains Personal Information only for as long as reasonably necessary for the purposes described in this Policy or as permitted or required by law. Retention depends on the relationship duration, Account activity, service needs, data sensitivity, tax, accounting, insurance and licensing requirements, limitation periods, fraud prevention, safety, security, complaints, disputes, chargebacks, claims, investigations, litigation, regulation, and contractual obligations.

Booking, invoice, payment, tax, and accounting records may be retained for required periods. Safety, incident, insurance, recording, and legal records may be retained until investigations, claims, proceedings, and limitation periods end. When information is no longer required, LUX24 may securely delete, destroy, anonymize, or de-identify it. Residual copies may remain temporarily in backups, archives, security logs, fraud-prevention records, or systems that cannot immediately remove individual records.

30. Information Security

LUX24 uses administrative, technical, physical, and organizational safeguards designed to protect Personal Information against loss, theft, misuse, unauthorized access, disclosure, copying, modification, and destruction. Safeguards may include encrypted transmission, password hashing, authentication controls, role-based permissions, restricted administrative access, server and network protections, logging and monitoring, suspicious-activity detection, specialized payment processors, backup and recovery procedures, document-access controls, confidentiality obligations, security reviews, software updates, vulnerability management, incident-response procedures, and limits on personnel access.

No electronic transmission, application, network, or storage system can guarantee absolute security. You are responsible for protecting your password and devices, not sharing credentials, signing out of shared devices, and promptly reporting suspected unauthorized access. Where a breach creates a real risk of significant harm or triggers another requirement, LUX24 will take steps required by applicable law, which may include notice to affected individuals, regulators, or other authorities.

31. Your Privacy Rights

Depending on location and applicable law, you may have the right to ask whether LUX24 holds Personal Information about you; request access, correction, completion, deletion, restriction, portability, or information about relevant automated processing; withdraw consent; object to certain processing; opt out of marketing; challenge LUX24’s compliance; and complain to an applicable privacy authority. These rights are subject to legal limitations and exceptions.

32. Privacy Requests

Submit privacy requests to privacy@lux24.limo. Include your full name, Account email address, telephone number where relevant, request type, relevant Account or Booking, information or date range concerned, and jurisdiction. LUX24 may request information reasonably necessary to verify identity. Do not send your Account password, a complete payment-card number, unnecessary identification documents, or unrelated sensitive information.

33. Authorized Representatives

Where permitted by law, an authorized representative may submit a request on your behalf. LUX24 may require written authorization, proof of the representative’s identity and authority, and direct confirmation from you.

34. Limits on Privacy Requests

Privacy rights are not absolute. LUX24 may refuse or limit a request where permitted or required by law, including where information cannot reliably be associated with the requester, contains another person’s information, is legally privileged, must be retained for tax, accounting, insurance, safety, licensing, fraud, security, investigation, dispute, or legal-claim purposes, cannot be disclosed without a serious safety risk, was created for formal dispute resolution, or is otherwise exempt. Where required, LUX24 will explain why a request was refused or limited.

35. Account Deletion

You may request deletion of a customer Account through an available Account feature or by contacting privacy@lux24.limo. Deleting an Account does not necessarily require immediate deletion of every record. LUX24 may retain records for completed or disputed Bookings, payments, refunds, chargebacks, tax and accounting, fraud prevention, safety investigations, insurance claims, legal obligations and proceedings, agreement enforcement, restricted or deactivated Account records, and other lawful purposes.

Chauffeur, Fleet Operator, and Transportation Provider information may be subject to additional retention requirements concerning licences, insurance, vehicles, completed trips, payouts, taxes, safety, and regulatory compliance.

36. Children and Minors

The LUX24 Platform is not directed to children who are legally unable to create an Account or enter into a binding agreement. A parent, legal guardian, or authorized adult may provide information about a minor when arranging lawful transportation. Information about a minor should be limited to what is reasonably necessary, such as passenger name, age range, child-seat requirements, accessibility needs, emergency contact, and trip instructions.

Transportation of an unaccompanied minor may be restricted or unavailable depending on law, LUX24 rules, Transportation Provider requirements, and the circumstances of the requested trip. Contact LUX24 if you believe a child has provided Personal Information without appropriate authorization.

37. Sale and Sharing of Personal Information

LUX24 does not sell Personal Information for money as part of its ordinary business model. LUX24 may use service providers, analytics technologies, and advertising tools as described in this Policy and the LUX24 Cookie Policy. Where law treats a particular analytics or advertising disclosure as a sale, sharing, or targeted advertising, LUX24 will provide any legally required notice, consent choice, or opt-out method.

38. Aggregated and De-Identified Information

LUX24 may create aggregated, anonymized, or de-identified information that does not reasonably identify an individual. This information may be used for analytics, business planning, service improvement, demand and safety analysis, research, reporting, Platform performance, and development of new services. LUX24 will not attempt to re-identify properly de-identified information except where permitted for security testing, legal compliance, or validation of de-identification.

39. Changes to This Privacy Policy

LUX24 may update this Privacy Policy to reflect changes in services, technology, information practices, Transportation Provider operations, third-party providers, legal obligations, regulatory guidance, or business operations. The updated version will be posted with a revised Last Updated date. Where required, LUX24 may provide additional notice or request renewed consent.

40. Contact LUX24

Questions, requests, complaints, or concerns regarding privacy may be directed to:

KEY24 INC., operating as LUX24 Limo
Registered Office:
5977 St. Mary’s Street
Niagara Falls, Ontario
Canada

Privacy: privacy@lux24.limo
Legal: legal@lux24.limo
Customer Support: support@lux24.limo
General Information: info@lux24.limo
Canada Telephone: +1 647-671-7588
United States Telephone: +1 817-632-7547

Please do not send complete payment-card numbers, passwords, or unnecessary identity documents through ordinary email.

41. Privacy Complaints

LUX24 takes privacy complaints seriously. We encourage you to contact LUX24 first so that we can investigate and attempt to resolve the concern. You may also have the right to complain to the Office of the Privacy Commissioner of Canada, an applicable provincial privacy commissioner, a European or United Kingdom data-protection authority, or another regulator with jurisdiction.

42. Related Policies

This Privacy Policy should be read together with the LUX24 Terms of Service, LUX24 Cookie Policy, applicable Chauffeur Agreement, applicable Fleet Partner Agreement, applicable Transportation Provider Agreement, applicable Corporate Agreement, if any, and any service-specific notice presented during registration or Booking.

© 2026 KEY24 INC. All rights reserved. LUX24 Limo is an operating brand of KEY24 INC.