1. INTRODUCTION
At LUXORA, trust extends to the personal information entrusted to us. LUXORA AI SDN BHD ("LUXORA", "we", "us" or "our") is committed to handling personal data responsibly and securely.
This Privacy Policy explains how personal data is collected, used, stored, disclosed, transferred and protected in connection with www.myluxora.ai, the marketplace, AI services, Collector Profile, DealerOS SaaS, Dealer Exchange and applicable memberships.
It applies to website visitors, account holders, buyers, sellers, consignors, collectors, Commercial Dealers, Private Dealers and other individuals interacting with LUXORA. Processing is subject to Malaysian personal data protection laws, including the Personal Data Protection Act 2010 as amended.
2. SCOPE AND DATA PROTECTION ROLES
LUXORA generally acts as data controller for its marketplace accounts, dealer verification, transactions, customer service and other services it directly operates.
Where an independent dealer uses DealerOS to manage that dealer's own customer records, the dealer may be the controller and LUXORA may act as processor for the software service, depending on the specific processing and agreements.
DealerOS customer records are not automatically incorporated into LUXORA's own marketing database. Independent dealers and payment or delivery partners may act as separate controllers for information they independently collect.
3. PERSONAL DATA WE MAY COLLECT
Depending on the service, information may include:
- Identity and contact: name, email, telephone, postal address, account details and verification documents where needed.
- Account and membership: preferences, subscription status, saved searches, watchlists, wishlists and service records.
- Transactions and payments: purchases, sales, consignments, deposits, payment and refund status, delivery information and bank details when appropriate.
- Dealer certification: identity, business registration where applicable, authorized contacts, diligence and compliance records.
- DealerOS: CRM customer records, inventory, enquiries, quotations, invoices, orders, staff accounts, reports and subscription details.
- Dealer Exchange: participant details, listed goods, wanted requests, messages, offers and transaction records.
- Collector Profile: product photos, serial numbers, acquisition prices and dates, estimated values, supporting ownership records and sharing preferences.
- Authentication: inspection images, product details, expert findings, reports and certificates.
- AI interactions: messages to Clara, search queries, submitted images, valuations and related feedback.
- Technical information: IP address, device, browser, cookies, access logs and website use.
- Gallery visits: appointments, inquiries and CCTV where installed and appropriately notified.
Payment-card information may be processed directly by authorized payment providers under their own security and privacy arrangements.
4. SOURCES OF PERSONAL DATA
Data may be supplied directly by users, by authorized sellers and other transaction participants, by DealerOS business users, by service providers, from lawful verification sources or from permitted website technologies.
We take reasonable steps to maintain accuracy and relevance for material transactions and verification decisions.
5. PURPOSES OF PROCESSING
We may use personal data to:
1.Register and administer accounts and memberships.
2.Operate listings, enquiries and luxury marketplace transactions.
3.Verify stock, process deposits, balances, payments and refunds.
4.Coordinate consignments, sourcing, collection and delivery.
5.Verify Commercial Dealers, Private Dealers and sellers.
6.Deliver DealerOS SaaS, authorized CRM and business tools.
7.Support approved Dealer Exchange communications and trades.
8.Maintain Collector Profiles and private collection data.
9.Deliver Clara, AI screening, valuations and market information.
10.Arrange expert authentication and certification.
11.Prevent fraud, enforce security and maintain records.
12.Handle support, complaints and disputes.
13.Meet legal, regulatory, accounting and tax obligations.
14.Improve features using lawfully processed analytics.
15.Send marketing where permitted and subject to user preferences.
Personal data will not automatically be reused for unrelated purposes.
6. CONSENT AND USER CHOICES
Where consent is required for a processing purpose, LUXORA will seek the relevant consent. Certain information is necessary to deliver a requested service or comply with legal obligations.
Optional marketing or preference information may be managed using available controls. Users may withdraw consent where applicable, subject to lawful exceptions and obligations already in force.
7. DEALEROS DATA PROTECTION
DealerOS may contain confidential customer, inventory, sales and financial data belonging to subscribing dealers. Access is governed by role permissions, service controls and applicable contractual terms.
Dealers remain responsible for the lawfulness of their customer data and instructions. LUXORA may access or process dealer-controlled data only as authorized for the relevant software service or otherwise permitted by law.
Dealer customer information is not automatically available for LUXORA's own marketing. Data export, retention, deletion and termination arrangements will be described in the relevant DealerOS agreement.
8. DEALER EXCHANGE INFORMATION SHARING
Approved Dealer Exchange participants may receive information necessary for inventory discovery, wanted enquiries, offers, negotiations and transaction coordination.
Personal data and confidential trading details should be shared only with appropriate authorized participants and for legitimate service needs. Each participant remains responsible for its own lawful use of information received.
9. COLLECTOR PROFILE PRIVACY
Collector Profile may contain sensitive ownership and asset details, including product serial numbers, acquisition prices, valuation estimates and provenance documents.
Private collection data will not be published by default. Any sharing capability will be subject to clear user selections and available privacy controls. LUXORA may use aggregated or appropriately de-identified information for permitted analytics.
10. AI AGENT CLARA AND AI SERVICES
Clara, AI Authentication, AI Valuation and other intelligent tools may process user messages, images and supporting information using LUXORA systems and approved technology providers.
Outputs may be reviewed by authorized human specialists. Users should avoid sending unnecessary passwords, banking credentials or sensitive identity documents through general AI chat. Any secondary use of personal data, including model-improvement activities, must follow applicable notice, choice and legal requirements.
11. MARKET INTELLIGENCE AND ANALYTICS
LUXORA may analyze legally obtained listings, dealer quotes, market observations and permitted transaction records to develop indices and valuation tools.
We will not publish identifiable customer transactions, private collection information or confidential DealerOS CRM records merely because they are held on the platform. Aggregation or de-identification will be used where appropriate.
12. SHARING WITH THIRD PARTIES
Where appropriate and permitted, information may be shared with transaction counterparties, approved dealers, payment providers, delivery partners, authentication specialists, cloud/software/security providers, approved AI vendors, professional advisers and competent authorities.
Disclosures are limited to relevant purposes and subject to appropriate confidentiality, security and contractual safeguards. Independent parties may have their own privacy notices.
13. INTERNATIONAL DATA TRANSFERS
International suppliers, customers, dealer trading or technology partners may require data to be accessed or processed outside Malaysia.
Such transfers will be subject to applicable Malaysian data protection requirements and appropriate security and contractual safeguards.
14. COOKIES AND ONLINE TECHNOLOGIES
Cookies and similar technologies may support login sessions, essential functions, preferences, analytics, security and permitted advertising measurement.
Where required, optional tracking will be explained and relevant choices offered. Some preferences can be managed through the website or browser settings.
15. MARKETING COMMUNICATIONS
Where permitted, LUXORA may communicate product updates, market insights, event invitations, subscription information and promotions by email or other supported channels.
Users may opt out of direct marketing using offered mechanisms. Essential transaction, security and service notices may continue.
16. DATA RETENTION
Personal data is retained only for as long as reasonably necessary for the relevant purposes and legal obligations. Actual periods vary by category, including active accounts, transaction and tax records, authentication findings, dealer data, collection records and security logs.
Applicable electronic marketplace supplier information and transaction or advertising records will be maintained for the statutory periods, including relevant three-year recordkeeping requirements. When retention is no longer justified, data will be securely deleted, anonymized or disposed of, subject to lawful exceptions.
17. INFORMATION SECURITY
LUXORA will apply reasonable technical and organizational safeguards, which may include account controls, appropriate encryption, role-based permissions, monitoring, backups, confidentiality requirements and vendor oversight.
Additional controls may be appropriate for DealerOS customer lists, private collection information and authentication documents. No electronic platform is entirely risk-free.
18. PERSONAL DATA BREACHES
If a personal data incident occurs, LUXORA will investigate, contain and remediate the issue as appropriate. Notifications to the Personal Data Protection Commissioner and affected individuals will be made where required by applicable Malaysian rules.
19. YOUR PERSONAL DATA RIGHTS
Subject to applicable law and exceptions, individuals may request access, correction, withdrawal of applicable consent, objection or prevention of certain processing, exclusion from direct marketing and applicable data portability.
Requests may require identity verification. Where a DealerOS subscriber is the responsible controller, requests may need to be directed to that dealer, with LUXORA assisting as appropriate.
20. CHILDREN AND MINORS
LUXORA's luxury trading and dealership services are intended for adults aged 18 or older. We do not intentionally provide trading accounts to minors. Information relating to minors, if encountered, will be handled in accordance with applicable requirements.
21. THIRD-PARTY WEBSITES
LUXORA may link to payment providers, dealers or other independent websites. Their separate privacy notices and terms may apply. We are not responsible for the independent information practices of third-party services outside our control.
22. POLICY UPDATES
We may update this Privacy Policy to reflect changes to services, technology, practices or legal requirements. The latest published version will be available at www.myluxora.ai. Material changes will be notified, and consent sought where required.
23. CONTACT AND PRIVACY ENQUIRIES
LUXORA AI SDN. BHD.
Registration No.: 201801024763
LUXORA Flagship Sales Gallery
#06-11-1, Level 6, Berjaya Times Square, No. 1, Jalan Imbi, 55100 Kuala Lumpur, Malaysia
Website: www.myluxora.ai
Privacy Enquiries Email: info@myluxora.ai
Telephone: +60 12 345 6789