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Privacy Policy

Last Updated: December 2024

1. Introduction

Welcome to Luxa Energy ("we," "our," or "us"). We are committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website, use our services, or interact with us. Luxa Energy Ltd is a solar engineering and installation company registered in Cyprus (Registration Number: HE 482253, VAT: CY60244887P), with our registered office at Chrysanthou Mylona 1, PANAYIDES BUILDING, Limassol, 3030, Cyprus.

2. Information We Collect

We collect information that you provide directly to us, including: **Personal Information:** - Name and contact details (email address, phone number, postal address) - Company information for commercial clients - Property details for solar installation assessments - Financial information for quotes and invoicing - Government-issued identification documents (for subsidy applications) **Automatically Collected Information:** - IP address and device information - Browser type and operating system - Pages visited and time spent on our website - Referral sources and search queries - Cookies and similar tracking technologies **Documents You Upload:** - Electricity bills and consumption data - Property title deeds and building licenses - Utility bills for proof of residence - Other documents required for solar installation permits

3. How We Use Your Information

We use the information we collect to: - Provide solar consultation and installation services - Process your quotes, orders, and payments - Submit applications for government subsidies on your behalf - Communicate with you about your projects and our services - Send you marketing communications (with your consent) - Improve our website and customer experience - Comply with legal obligations and regulatory requirements - Analyze website traffic and usage patterns - Prevent fraud and ensure security

4. Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your personal data based on: **Contractual Necessity:** Processing necessary to perform our contract with you for solar installation services. **Legitimate Interests:** Processing for our legitimate business interests, such as improving our services, marketing, and fraud prevention. **Legal Obligations:** Processing required to comply with Cyprus and EU laws, including tax regulations and building permits. **Consent:** Processing based on your explicit consent, such as for marketing communications and non-essential cookies.

5. Data Sharing and Disclosure

We may share your information with: **Service Providers:** - Cloud storage providers (for secure document storage) - Email service providers (for communications) - Payment processors (for transactions) **Government Authorities:** - Cyprus Energy Regulatory Authority (CERA) - Electricity Authority of Cyprus (EAC) - Local municipalities (for building permits) - Tax authorities (as required by law) **Business Partners:** - Solar equipment manufacturers (for warranty registration) - Licensed electricians and subcontractors - Insurance providers We do not sell your personal information to third parties.

6. Data Retention

We retain your personal data for: - **Active customer records:** Duration of our business relationship plus 7 years - **Installation documentation:** 25 years (matching warranty periods) - **Financial records:** 7 years (as required by Cyprus tax law) - **Marketing preferences:** Until you withdraw consent - **Website analytics:** 26 months After the retention period, we securely delete or anonymize your data.

7. Your Rights

Under GDPR, you have the right to: - **Access:** Request a copy of your personal data - **Rectification:** Correct inaccurate or incomplete data - **Erasure:** Request deletion of your data ("right to be forgotten") - **Restriction:** Limit how we process your data - **Portability:** Receive your data in a machine-readable format - **Objection:** Object to processing based on legitimate interests - **Withdraw Consent:** Revoke consent for marketing communications To exercise these rights, contact us at support@luxa-energy.com.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including: - Encryption of data in transit (TLS/SSL) and at rest - Secure cloud storage with access controls - Regular security assessments and updates - Employee training on data protection - Incident response procedures While we strive to protect your information, no method of transmission over the Internet is 100% secure.

9. International Data Transfers

Your data may be processed by service providers located outside the European Economic Area (EEA). When we transfer data internationally, we ensure appropriate safeguards are in place, such as: - EU Standard Contractual Clauses - Adequacy decisions by the European Commission - Binding Corporate Rules

10. Cookies

We use cookies and similar technologies to enhance your experience. For detailed information about our use of cookies, please see our Cookie Policy. You can manage your cookie preferences through our cookie consent banner or your browser settings.

11. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you believe we have collected information from a child, please contact us immediately.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes by posting the updated policy on our website and updating the "Last Updated" date. Your continued use of our services after changes constitutes acceptance of the updated policy.

13. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us: **Luxa Energy Ltd** Chrysanthou Mylona 1, PANAYIDES BUILDING, Limassol, 3030, Cyprus Email: support@luxa-energy.com Phone: +357 94 421 463 You also have the right to lodge a complaint with the Cyprus Commissioner for Personal Data Protection: Website: www.dataprotection.gov.cy