Privacy Policy
This policy describes how Luxon Partners collects, uses, and protects your personal data. Last updated: March 10, 2026.
1. Introduction
Luxon Partners ("we," "us," or "our") is the data controller responsible for personal data collected from Affiliates in connection with the Luxon Partners Affiliate Programme ("Programme"). This Privacy Policy explains how we collect, use, disclose, and safeguard your data when you participate in our affiliate programme or visit our website. By using our services, you consent to the practices described in this policy. Luxon Partners operates as an independent marketing intermediary managing the official affiliate programme for Luxon Pay. Luxon Partners does not provide payment services, financial services, wallet infrastructure, or any regulated financial activities — these are provided exclusively by Luxon Pay under its own terms and regulatory framework. Luxon Partners' role is limited to the administration of affiliate relationships and the calculation and settlement of affiliate commissions. In connection with commission calculation, Luxon Partners receives referred customer transaction data from Luxon Pay. This data is received solely for the purpose of calculating and settling commissions and is handled in accordance with this Privacy Policy and subject to data sharing arrangements between Luxon Partners and Luxon Pay.
2. Information We Collect
We collect information you provide directly, including: full name, email address, postal address, phone number, payment details (bank account or e-wallet information), tax identification numbers, website URLs and traffic data, and any other information you submit during registration or account management. We also automatically collect certain technical data such as IP addresses, browser type, device identifiers, pages visited, and referral URLs.
3. How We Use Your Information
We use your personal data to: (a) administer your affiliate account and process commission payments; (b) verify your identity and eligibility to participate in the Programme; (c) communicate with you about your account, programme updates, and marketing opportunities; (d) detect and prevent fraud, abuse, or violations of our Terms of Service; (e) comply with our legal obligations under applicable law, including FCA and FINTRAC requirements; and (f) improve our services and platform through analytics and performance monitoring.
4. Legal Basis for Processing
We process your personal data on the following legal bases: (a) Contract — processing your name, contact details, payment information, and account data is necessary to perform our affiliate agreement with you, including calculating and paying commissions; (b) Legal Obligation — processing is required to comply with applicable laws and regulations, including anti-money laundering, fraud prevention, and tax reporting obligations; (c) Legitimate Interests — processing is necessary for fraud detection, security monitoring, and improving our platform, where such interests are not overridden by your data protection rights; (d) Consent — where you have explicitly consented to specific processing activities, such as receiving marketing communications. You may withdraw consent at any time by contacting us at [email protected].
5. Sharing Your Information
We may share your personal data with: (a) Luxon Pay, for the purposes of confirming KYC completion and affiliate eligibility, administering the Programme, exchanging referred customer transaction data necessary for commission calculation, facilitating commission payments to your designated Luxon Pay wallet, and reporting any compliance or conduct concerns arising in connection with the Programme, in accordance with our Terms of Service; (b) Google Analytics, for internal website usage monitoring. This data is used solely for our own performance analysis and is not shared with any other third party. We do not sell your personal data to third parties for their own marketing purposes.
6. International Data Transfers
Your data is stored and processed on servers located in Germany and Finland, both of which are member states of the European Economic Area (EEA) and subject to EU data protection standards. If you are based in the United Kingdom, transfers of your personal data to Germany and Finland are covered by the UK adequacy regulations in respect of the EEA, meaning no additional transfer mechanism is required. Where data is transferred to countries outside the EEA or UK that do not benefit from an adequacy decision, we ensure appropriate safeguards are in place, including standard contractual clauses approved by the relevant data protection authority. If you would like further information about the specific safeguards applied to any such transfer, please contact us at [email protected].
7. Data Retention
We retain your personal data for as long as necessary to provide our services and comply with our legal obligations. Affiliate account data is generally retained for the duration of your participation in the Programme and for a period of up to seven years thereafter to satisfy regulatory and tax requirements. Analytics and technical data may be retained in anonymised form indefinitely.
8. Your Rights
Depending on your jurisdiction, you may have the following rights regarding your personal data: (a) Right of Access — to request a copy of the personal data we hold about you; (b) Right to Rectification — to request correction of inaccurate or incomplete data; (c) Right to Erasure — to request deletion of your data where we no longer have a lawful basis to retain it; (d) Right to Restriction — to request that we limit processing of your data in certain circumstances; (e) Right to Portability — to receive your data in a structured, commonly used, machine-readable format; (f) Right to Object — to object to processing based on legitimate interests; (g) Right to Withdraw Consent — where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing. To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days. We may ask you to verify your identity before processing your request.
9. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to operate our platform, track affiliate referrals, and analyse usage patterns. This includes essential cookies required for the Programme to function, as well as analytics cookies that help us understand how our platform is used. You can manage cookie preferences through your browser settings or our Cookie Policy. Disabling certain cookies may affect your ability to use some features of our platform.
10. Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include encryption of sensitive data in transit and at rest, access controls, regular security assessments, and staff training. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.
11. Children's Privacy
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a minor, we will take steps to delete such information promptly. If you believe we have inadvertently collected data from a minor, please contact us immediately.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. We will notify you of material changes by email or through a notice in your affiliate dashboard. The updated policy will be effective from the date indicated at the top of this page. Your continued use of our services after the effective date constitutes acceptance of the revised policy.
13. Contact and Complaints
For any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact our data protection team at [email protected]. If you are located in the United Kingdom and believe your data protection rights have been violated, you have the right to lodge a complaint with the Information Commissioner's Office (ICO) at ico.org.uk or on 0303 123 1113. If you are located in the EEA, you also have the right to lodge a complaint with the supervisory authority in your country of residence. We encourage you to contact us in the first instance so we can address your concern directly.
For any privacy-related questions or to exercise your data rights, please contact us at [email protected].