Privacy Policy

Last Updated: January 2026

The Tidy Troupe S.à r.l.-S ("we", "us", or "our") operates the website thetidytroupe.lu and provides coordination, organization, and support services for the maintenance, cleaning, and upkeep of private properties and related facilities in Luxembourg (the "Service").

This Privacy Policy explains how we collect, use, disclose, and protect your personal information in compliance with:

• The General Data Protection Regulation (GDPR) - Regulation (EU) 2016/679
• Luxembourg Law of 1 August 2018 on the organisation of the National Data Protection Commission and the general data protection regime
• ePrivacy Directive requirements
• Google Ads and advertising technology requirements

By using our Service, you agree to the collection and use of information in accordance with this policy.

1. Data Controller Information

2. About Our Services

The Tidy Troupe provides comprehensive services including:

• Coordination, organization, and support for maintenance, cleaning, and upkeep of private properties
• Housekeeping and accessory maintenance services
• Concierge services, personal assistance, and lifestyle support for individuals and businesses
• Development and operation of digital platforms and technological solutions connecting service providers
• Use of artificial intelligence, data analysis, and innovative technologies to optimize and anticipate service needs
• Administrative services, consulting, planning, data management, and logistics related to household operations

Service Areas: Central Region, North Region, and South Region of Luxembourg

3. Legal Basis for Processing

We process your personal data based on the following legal grounds under GDPR Article 6:

• Contract Performance (Art. 6(1)(b)): Processing necessary to provide our cleaning and home management services
• Legitimate Interest (Art. 6(1)(f)): Marketing communications to existing customers, fraud prevention, service improvement, and operational optimization
• Consent (Art. 6(1)(a)): Cookie usage, marketing communications to non-customers, video/photo recording for marketing purposes, and optional data sharing
• Legal Obligation (Art. 6(1)(c)): Compliance with Luxembourg tax, employment, and business laws

4. Personal Information We Collect

4.1 Information You Provide Directly

When you book our services, create an account, or contact us, we collect:

• Full name
• Email address
• Telephone number
• Home address and property details
• Property access information (codes, keys, gate access, alarm systems)
• Payment information (processed securely via Stripe)
• Service preferences, special instructions, and cleaning requirements
• Account login credentials
• Communication history with our team
• Feedback and customer satisfaction survey responses

4.2 Property Access and Security Information

To provide our services, we may store:

• Access codes for buildings, gates, and alarm systems
• Key locations and access procedures
• Security system information
• Pet information and special access instructions

This information is encrypted, stored securely, and only accessible to assigned service personnel.

4.3 Visual and Recording Data

With your explicit consent, we may collect:

• Marketing Photos/Videos: Images or videos of our work for marketing materials, testimonials, or social media content
• Service Recording (Premium Service): For clients who request recorded cleaning sessions as an additional paid service, we record video footage of the cleaning process for quality assurance and documentation

All visual recording requires your prior written consent, which you can withdraw at any time.

4.4 Information Collected Automatically

When you visit our website, we automatically collect:

• Log Data: IP address, browser type and version, pages visited, time and date of visit, time spent on pages, referring website
• Device Information: Operating system, device type, unique device identifiers
• Location Data: General geographic location based on IP address
• Cookie Data: Information collected through cookies and similar tracking technologies (see Section 7)

4.5 Google Ads and Analytics Data

When you interact with our Google Ads or website:

• Google Ads conversion tracking data
• Ad interaction data (clicks, impressions, conversions)
• Remarketing and audience data
• Google Analytics data including demographics and interests
• Website behavior and navigation patterns

5. How We Use Your Information

5.1 Service Delivery and Management

• Scheduling, coordinating, and performing cleaning and home management services
• Managing property access and security information
• Communicating about appointments, service updates, and schedule changes
• Processing payments through Stripe
• Managing your customer account and login portal
• Providing customer support and addressing service inquiries
• Quality assurance and service improvement
• Recording services when requested as a premium add-on

5.2 Platform and Technology Operations

• Operating and improving our digital booking and management platform (Booking Koala)
• Using artificial intelligence and data analysis to optimize service delivery
• Anticipating customer needs and personalizing service recommendations
• Coordinating service providers and managing logistics
• Automating scheduling and operational processes

5.3 Marketing and Communications

• Sending promotional offers, service updates, and newsletters via email
• Sending appointment reminders and service notifications via SMS (through Twilio)
• Conducting customer satisfaction surveys
• Managing our founding member program and special offers
• Creating marketing materials using photos/videos (with your consent)

5.4 Business Operations and Analytics

• Analyzing service usage, customer preferences, and operational efficiency
• Improving our website, platform, and services
• Fraud prevention and security monitoring
• Compliance with Luxembourg legal and tax obligations
• Business planning, development, and strategic decision-making
• Managing data and administrative operations

5.5 Google Ads and Advertising

• Measuring advertising campaign effectiveness
• Remarketing to website visitors across Google Display Network
• Creating similar audiences for targeted advertising
• Optimizing ad targeting, bidding, and campaign performance
• Analyzing user demographics and interests for advertising insights

6. Data Sharing and Disclosure

6.1 Service Providers and Technology Partners

We share your information with trusted third-party service providers who assist us in operating our business:

• Booking and CRM Platform: Booking Koala (booking management, customer relationship management, email marketing)
• Payment Processing: Stripe (secure payment processing and transaction management)
• SMS Communications: Twilio (appointment reminders and service notifications)
• Analytics and Advertising: Google Analytics, Google Tag Manager, Google Ads
• Cloud Storage and Hosting: Secure data hosting and storage providers
• Service Personnel: Vetted and trained cleaning professionals who need access to your property information to perform services

All service providers are contractually bound to GDPR-compliant data processing agreements (DPAs) and only process data on our instructions.

6.2 Google Advertising Services

We use the following Google services that may access your data:

• Google Ads (advertising platform)
• Google Analytics (with advertising features enabled)
• Google Tag Manager (tag management)
• Google Conversion Tracking
• Google Remarketing and Similar Audiences
• Google Display Network

Google's use of advertising cookies enables it and its partners to serve ads based on your visit to our site and/or other sites on the Internet. You can opt out of personalized advertising by visiting Google Ads Settings or www.aboutads.info.

6.3 Legal Requirements and Protection

We may disclose your personal information if required by Luxembourg or EU law, court order, or governmental regulation, including:

• Compliance with Luxembourg tax authorities (Administration des Contributions Directes)
• Response to valid legal processes, subpoenas, or court orders
• Protection of our legal rights and property
• Prevention of fraud, illegal activities, or security threats
• Protection of the safety and rights of our customers, employees, or the public

6.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your personal information may be transferred to the acquiring entity, subject to GDPR protections and your rights.

7. Cookies and Tracking Technologies

7.1 What Are Cookies?

Cookies are small text files stored on your device that help us provide and improve our services. We use both session cookies (temporary) and persistent cookies (stored longer-term).

7.2 Types of Cookies We Use

Essential Cookies (No Consent Required)

• Session management and user authentication
• Security and fraud prevention
• Basic website and booking platform functionality
• Load balancing and performance optimization

Performance and Analytics Cookies (Consent Required)

• Google Analytics cookies to understand website usage and user behavior
• Performance monitoring and website optimization
• Heat mapping and user experience analysis

Marketing and Advertising Cookies (Consent Required)

• Google Ads conversion tracking and remarketing pixels
• Ad performance measurement and campaign optimization
• Audience targeting and similar audience creation
• Cross-site tracking for advertising purposes

7.3 Cookie Consent and Management

When you first visit our website, you'll see a cookie consent banner where you can:

• Accept all cookies
• Reject non-essential cookies
• Customize your cookie preferences by category

You can also manage cookies through your browser settings:

• Chrome: Settings > Privacy and Security > Cookies and other site data
• Firefox: Settings > Privacy & Security > Cookies and Site Data
• Safari: Preferences > Privacy > Cookies and website data
• Edge: Settings > Cookies and site permissions > Cookies and site data

Note: Blocking essential cookies may affect website functionality and your ability to use our booking platform.

8. Your Rights Under GDPR

As a data subject in the European Union and Luxembourg, you have the following rights:

8.1 Right of Access (Art. 15 GDPR)

You have the right to request a copy of the personal data we hold about you, including information about how we process it.

8.2 Right to Rectification (Art. 16 GDPR)

You have the right to request correction of inaccurate or incomplete personal data.

8.3 Right to Erasure / "Right to be Forgotten" (Art. 17 GDPR)

You have the right to request deletion of your personal data when:

• It's no longer necessary for the purposes it was collected
• You withdraw consent (where consent was the legal basis)
• You object to processing and there are no overriding legitimate grounds
• The data was unlawfully processed
• It must be erased to comply with a legal obligation

Note: We may retain certain data where legally required (e.g., tax records for 10 years under Luxembourg law).

8.4 Right to Restriction of Processing (Art. 18 GDPR)

You have the right to request that we limit how we use your personal data in certain circumstances, such as when you contest the accuracy of the data or object to processing.

8.5 Right to Data Portability (Art. 20 GDPR)

You have the right to receive your personal data in a structured, commonly used, machine-readable format (such as CSV or JSON) and to transmit it to another controller.

8.6 Right to Object (Art. 21 GDPR)

You have the right to object to:

• Processing based on legitimate interests
• Direct marketing (including profiling for marketing purposes)
• Processing for scientific, historical research, or statistical purposes

8.7 Right to Withdraw Consent

Where processing is based on your consent (such as marketing emails, SMS messages, or video recording), you can withdraw consent at any time. This won't affect the lawfulness of processing before withdrawal.

8.8 Right to Lodge a Complaint

You have the right to lodge a complaint with the Luxembourg supervisory authority:

8.9 How to Exercise Your Rights

To exercise any of these rights, please contact us at:

• Email: contact@thetidytroupe.lu
• Phone: +352 651 209 196
• Mail: 19 Rue de l'Industrie, L-8069 Bertrange, Luxembourg

We will respond to your request within one month as required by GDPR. In complex cases, we may extend this by an additional two months and will inform you of any such extension.

9. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this policy or as required by Luxembourg law:

9.1 Active Customer Data

• Service Records: Duration of active service relationship plus 3 years (Luxembourg statute of limitations)
• Property Access Information: Duration of active service plus 30 days after service termination (then securely deleted)
• Account Information: Duration of active account plus 3 years of inactivity

9.2 Legal and Financial Records

• Accounting and Tax Records: 10 years (Luxembourg legal requirement)
• Invoices and Payment Records: 10 years (Luxembourg legal requirement)
• Contracts and Service Agreements: 10 years from contract end

9.3 Marketing and Communications

• Marketing Consent: Until consent is withdrawn or 3 years of no engagement
• Email Marketing Lists: Until unsubscribe or 3 years of inactivity
• SMS Marketing Consent: Until opt-out or 2 years of no engagement

9.4 Analytics and Technical Data

• Google Analytics: 26 months (automatically expires)
• Website Logs: 90 days
• Security Logs: 12 months

9.5 Visual Content

• Marketing Photos/Videos: Until consent is withdrawn or 5 years, whichever comes first
• Service Recording Videos: 90 days after service completion (unless client requests longer retention)

After the retention period expires, we securely delete or anonymize your personal data in accordance with GDPR requirements.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction:

10.1 Technical Measures

• Encryption of data in transit using SSL/TLS certificates (HTTPS)
• Encryption of data at rest for sensitive information (property access codes, payment data)
• Secure authentication and access controls for customer accounts and staff systems
• Regular security audits and vulnerability assessments
• Automated backup systems with encrypted storage
• Firewall protection and intrusion detection systems
• Two-factor authentication for administrative access

10.2 Organizational Measures

• Staff training on GDPR compliance and data protection best practices
• Strict access controls limiting data access to authorized personnel only
• Confidentiality agreements with all employees and service providers
• Data processing agreements (DPAs) with all third-party processors
• Regular review and update of security policies and procedures
• Incident response plan for data breaches

10.3 Property Access Security

• Access codes and keys stored in encrypted format
• Access restricted to assigned service personnel only
• Automatic deletion of access information 30 days after service termination
• Audit logs of all access to sensitive property information

While we strive to protect your personal information using industry-standard security measures, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security but maintain rigorous protections appropriate to the sensitivity of the data.

11. Data Breach Notification

In the unlikely event of a personal data breach that poses a risk to your rights and freedoms, we will:

• Notify the CNPD (Luxembourg Data Protection Authority) within 72 hours of becoming aware of the breach
• Notify affected individuals without undue delay if the breach poses a high risk
• Provide information about the nature of the breach, potential consequences, and measures taken to address it
• Implement measures to mitigate any adverse effects

12. International Data Transfers

Your data is primarily processed within the European Economic Area (EEA). Some of our service providers may process data outside the EEA:

12.1 Non-EEA Transfers

• Stripe (USA): Participates in EU-US Data Privacy Framework and uses Standard Contractual Clauses (SCCs)
• Twilio (USA): Uses Standard Contractual Clauses (SCCs) for GDPR compliance
• Google (USA): Participates in EU-US Data Privacy Framework and uses Standard Contractual Clauses (SCCs)
• Booking Koala: Data processing location confirmed to be GDPR-compliant with appropriate safeguards

12.2 Safeguards for International Transfers

All international data transfers include adequate safeguards through:

• EU Standard Contractual Clauses (SCCs) approved by the European Commission
• EU-US Data Privacy Framework certification (where applicable)
• Adequacy decisions by the European Commission
• Binding Corporate Rules (where applicable)

You can request copies of the safeguards we have in place by contacting us at contact@thetidytroupe.lu.

13. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children under 18.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at contact@thetidytroupe.lu. We will promptly investigate and delete such information from our systems.

14. Marketing Communications

14.1 Email Marketing

We may send you marketing emails about our services, special offers, and updates via Booking Koala or direct email. You can opt out at any time by:

• Clicking the "unsubscribe" link in any marketing email
• Contacting us at contact@thetidytroupe.lu
• Updating your communication preferences in your account portal

Note: Opting out of marketing emails won't affect service-related communications (booking confirmations, appointment reminders, service updates, invoices).

14.2 SMS Marketing

If you provide your phone number and consent to SMS communications, you may receive text messages via Twilio about:

• Appointment reminders and confirmations
• Service updates and schedule changes
• Special offers and promotions (if you opt in)

Standard message and data rates may apply. Reply STOP to any SMS to opt out immediately. You can also update your SMS preferences by contacting us or through your account settings.

14.3 Marketing Based on Legitimate Interest

As an existing customer, we may send you marketing about similar services based on legitimate interest. You can opt out at any time using the methods above.

15. Third-Party Links and Services

Our website may contain links to third-party websites, services, or platforms not operated by us, including:

• Social media platforms
• Payment processors (Stripe)
• Partner service providers
• Review platforms

We have no control over and assume no responsibility for the content, privacy policies, or practices of third-party sites. We strongly advise you to review the privacy policy of every website you visit.

The inclusion of any link does not imply our endorsement of the site or any association with its operators.

16. Google Ads Specific Disclosures

16.1 Google Remarketing

We use Google Ads remarketing to advertise to previous visitors to our website. This means:

• You may see our ads on other websites you visit across the Google Display Network
• Ads are targeted based on your previous interaction with thetidytroupe.lu
• Google uses cookies to serve ads based on your browsing history
• You can opt out at any time (see opt-out options below)

16.2 Google Analytics Advertising Features

We've enabled the following Google Analytics Advertising Features:

• Remarketing with Google Analytics
• Google Display Network Impression Reporting
• Demographics and Interest Reporting
• Integrated services that require Google Analytics to collect data for advertising purposes

These features allow us to use Google Analytics data for advertising purposes, including targeting ads based on user behavior and demographics.

16.3 Conversion Tracking

We use Google Ads conversion tracking to measure the effectiveness of our advertising campaigns. This tracks actions you take after clicking on our ads, such as:

• Form submissions
• Service bookings
• Phone calls
• Account registrations

16.4 Opt-Out Options for Google Ads

You can control and opt out of Google's use of cookies and personalized advertising through:

• Google Ads Settings: www.google.com/settings/ads
• Google Analytics Opt-out Browser Add-on: tools.google.com/dlpage/gaoptout
• Network Advertising Initiative: www.networkadvertising.org/choices/
• Digital Advertising Alliance: www.aboutads.info/choices/
• European Interactive Digital Advertising Alliance: www.youronlinechoices.eu/

17. Automated Decision-Making and Profiling

We use artificial intelligence and data analysis to optimize our services, including:

17.1 Service Optimization

• Predicting service needs and scheduling recommendations
• Optimizing route planning for service personnel
• Matching customers with appropriate service providers
• Personalizing service recommendations based on your preferences

17.2 Marketing Personalization

• Customizing offers based on your service history and preferences
• Creating audience segments for targeted advertising
• Predicting customer lifetime value for business planning

17.3 Your Rights Regarding Automated Decisions

You have the right to:

• Not be subject to decisions based solely on automated processing that produce legal effects or similarly significantly affect you
• Request human intervention in automated decision-making processes
• Express your point of view and contest automated decisions
• Obtain an explanation of decisions reached after automated processing

To exercise these rights or learn more about our automated decision-making, contact us at contact@thetidytroupe.lu.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

18.1 How We Notify You of Changes

• Posting the updated policy on this page with a new "Last Updated" date
• Sending an email notification to registered users for material changes
• Displaying a prominent notice on our website
• For significant changes affecting your rights, requesting renewed consent where required

18.2 Review and Acceptance

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when posted on this page.

Continued use of our Service after changes constitutes acceptance of the updated policy. If you do not agree with the updated policy, you should discontinue use of our services and request deletion of your data.

19. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

We will respond to your inquiry within 30 days as required by GDPR. For urgent matters, please call us directly.

This Privacy Policy is compliant with GDPR (Regulation EU 2016/679), Luxembourg data protection laws,
ePrivacy Directive requirements, and Google Ads advertising policies.

© 2025 The Tidy Troupe S.à r.l.-S. All rights reserved.