Privacy Policy

Last updated: 1st January 2026

Introduction

SmartEdge SARL ("we", "our", or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, and protect your personal information when you visit our website or use our services.

Data Controller

SmartEdge SARL is the data controller for the purposes of the General Data Protection Regulation (GDPR) and other applicable data protection laws. Our contact details are:

Data We Collect

We collect and process the following types of personal data:

Information You Provide

  • Contact information (name, email address, phone number)
  • Business information (salon name, business details)
  • Communication content (messages, inquiries, feedback)
  • Any other information you voluntarily provide through our contact forms or communications

Information Automatically Collected

  • Website usage data (pages visited, time spent, browser type)
  • Device information (IP address, device type, operating system)
  • Cookies and similar tracking technologies (see our Cookie Policy)

How We Use Your Information

We process your personal data for the following purposes based on legitimate legal grounds:

  • Service Provision: To provide our consulting services and respond to your inquiries
  • Communication: To contact you regarding our services, appointments, and business matters
  • Business Operations: To manage our business relationships and maintain records
  • Legal Compliance: To comply with legal obligations and regulations
  • Website Improvement: To analyse website usage and improve our online services
  • Marketing: To send relevant business information and updates (with your consent)

Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

  • Consent: Where you have given clear consent for specific processing activities
  • Contract: Where processing is necessary for performing our services
  • Legitimate Interest: Where we have legitimate business interests that do not override your rights
  • Legal Obligation: Where we must process data to comply with legal requirements

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 see our Cookie Policy.

Data Sharing

We do not sell your personal data. We may share your information with:

  • Service Providers: Trusted third parties who assist with our business operations
  • Legal Authorities: When required by law or to protect our legal rights
  • Business Partners: With your consent, for specific business purposes

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this policy:

  • Contact inquiries: 3 years from last contact
  • Client records: 7 years after service completion
  • Website analytics: 26 months
  • Marketing data: Until you withdraw consent

Your Rights

Under GDPR and applicable data protection laws, you have the following rights:

  • Access: Request copies of your personal data
  • Rectification: Correct inaccurate or incomplete data
  • Erasure: Request deletion of your data in certain circumstances
  • Restriction: Limit how we process your data
  • Portability: Receive your data in a portable format
  • Objection: Object to processing based on legitimate interests
  • Withdraw Consent: Withdraw consent for consent-based processing

Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These include:

  • Encryption of data in transit and at rest
  • Regular security assessments and updates
  • Access controls and staff training
  • Secure data storage and backup procedures

International Transfers

Your data may be processed in countries outside the European Economic Area (EEA). We ensure appropriate safeguards are in place, including:

  • EU Commission adequacy decisions
  • Standard contractual clauses
  • Binding corporate rules

Contact Us

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us:

Complaints

If you believe we have not handled your personal data in accordance with this policy or applicable law, you have the right to lodge a complaint with the relevant supervisory authority. In Luxembourg, this is the Commission Nationale pour la Protection des Données (CNPD).

Changes to This 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.

Cookie Policy Reference

For detailed information about how we use cookies and similar technologies, please refer to our Cookie Policy, which forms part of this Privacy Policy.