Privacy Policy

Last updated on 06.11.2026.

1. Who is responsible for your data

The websites https://tesla.luxcar.ee and https://luxcar.ee (LuxCar) are operated by UX GENIUS OÜ, registry code 14378400, Tallinn, Estonia (hereinafter "we"). We are the controller of the personal data described in this policy.

Contact: info@luxcar.ee, +372 5361 5545.

2. What data we process and why

Booking requests

When you send a booking request through the form on the website, we receive your name, e-mail address, phone number, the date and time of the trip, the number of passengers, the type of transfer, the departure point, the destination and the language of the page you used.

We use this data to answer your request, to agree on the details and to provide the service. The legal basis is taking steps at your request before entering into a contract and performing the contract (Article 6(1)(b) of the GDPR).

The request is sent to us by e-mail. It is not saved in a database on the website. The form is only a request: it is not a confirmed booking, and no payment data is collected through it.

Contacting us directly

If you contact us by e-mail, by phone or through Facebook Messenger, we process your contact details and the content of your message in order to reply to you. The legal basis is taking steps before entering into a contract or performing the contract (Article 6(1)(b) of the GDPR) or, for other enquiries, our legitimate interest in answering them (Article 6(1)(f) of the GDPR). Messages sent through Messenger are also processed by Meta under its own privacy policy.

Protecting the form against abuse

To protect the booking form against spam and automated abuse, we use Cloudflare Turnstile, which checks your browser and receives your IP address and technical data about your device. We also use your IP address to limit the number of requests sent from one address; for this purpose it is held in the server's memory for about 10 minutes and is not saved in the request. The legal basis is our legitimate interest in keeping the form secure and usable (Article 6(1)(f) of the GDPR).

Statistics

We use Google Analytics and Microsoft Clarity to understand how the website is used and to improve it.

• Microsoft Clarity is loaded only after you have given your consent. It records how the pages are used, for example clicks, scrolling and page navigation.
• With your consent, Google Analytics stores cookies on your device and measures visits and how the website is used.
• Before you have made a choice, or if you refuse, Google Analytics may send measurements without storing cookies on your device. In this case Google still receives your IP address, technical data about your browser and the address of the page. Advertising features are switched off.

The legal basis for the statistics cookies and Microsoft Clarity is your consent (Article 6(1)(a) of the GDPR), which you can withdraw at any time. The legal basis for the measurements without cookies is our legitimate interest in knowing how much the website is used (Article 6(1)(f) of the GDPR). The contents of the booking form are not sent to these services.

Video on the website

The video at the top of the page is embedded from YouTube in its privacy-enhanced mode (youtube-nocookie.com). When the video loads, Google receives your IP address and technical data about your browser, and the player stores technical data on your device. The legal basis is our legitimate interest in presenting the service with a video (Article 6(1)(f) of the GDPR). More information is in the Cookie Policy.

Delivering the website

When you visit the website, our infrastructure provider Cloudflare processes your IP address and technical data about your request in order to deliver the pages and protect them against attacks. The legal basis is our legitimate interest in running a secure website (Article 6(1)(f) of the GDPR).

Advertising

We send advertising by e-mail only with your separate consent, which you can withdraw at any time. Sending a booking request does not subscribe you to advertising.

Accounting

If you use our service, we keep the data on invoices and payments in order to meet our accounting obligations (Article 6(1)(c) of the GDPR).

3. Whether you have to provide your data

Your name, contact details and trip details are needed to answer a booking request; without them we cannot process it. Consenting to statistics is voluntary, and refusing does not limit any function of the website.

4. Who receives your data

We do not sell your personal data. Depending on the situation, the following recipients may receive it:

• our staff and the partners who help to provide the service, for example drivers;
• Cloudflare, for delivering the website and protecting the form;
• our e-mail service provider, for delivering booking requests and correspondence;
• Google, for Google Analytics and the YouTube video;
• Microsoft, for Microsoft Clarity, if you have given your consent;
• Meta, if you contact us through Facebook Messenger;
• our accountants and auditors, and public authorities where the law requires it.

5. Transfers outside the European Economic Area

Some of these providers may process data outside the European Economic Area, including in the United States. In such cases the transfer relies on the safeguards provided for in the GDPR, such as an adequacy decision of the European Commission (including the EU-US Data Privacy Framework) or standard contractual clauses.

6. How long we keep your data

• Booking requests and correspondence: for as long as needed to handle the request, provide the service and resolve any related questions.
• Accounting documents: for the period required by law, currently 7 years in Estonia.
• Statistics data: according to the retention settings of Google Analytics and Microsoft Clarity.
• Your consent choice: on your device until you change it or clear your browser data.
• IP address used for limiting requests: about 10 minutes.

7. Your rights

You have the right to:

• access your personal data;
• have inaccurate data corrected;
• have your data erased, unless we are required to keep it;
• restrict the processing of your data;
• receive the data you have provided to us in a commonly used format, and have it transmitted to another controller;
• object to processing based on our legitimate interest;
• withdraw your consent at any time, which does not affect processing carried out before the withdrawal.

You can change your statistics choice with the "Manage Consent" link at the bottom of the page. To exercise your other rights, write to info@luxcar.ee.

You also have the right to lodge a complaint with the Estonian Data Protection Inspectorate (www.aki.ee).

We do not make decisions about you that are based solely on automated processing and have legal or similarly significant effects.

8. Changes to this policy

If the way we process data changes, we will update this policy. The current version and its date are always on this page.