This Privacy Policy explains LUGGEL’s policy in the collection and processing of your Personal Data including the use of such data, as well as other important matters related to your privacy and Personal Data. LUGGEL collects and processes Personal Data in accordance with the PDPA.
When you interact with us through the Websites or through any other means, we may collect Personal Data and other information from you, as further described below. The collection and processing of Personal Data may be obligatory for purposes of providing you with our Services and assistance. You will be notified whether the Personal Data requested is obligatory or voluntary. If you choose not to provide any Personal Data, you may not be able to use certain Services.

Personal Data That You Provide Through the Websites

We collect Personal Data from you when you voluntarily provide such information such as when you register with us as a member of Luggel, to have access to our Services, use certain Services, or contact us for inquiries. Personal Data that we collect and process includes contact information, location, payment information, photographs, and other information that you provide to us. Wherever Luggel collects Personal Data we make an effort to provide a link to this Privacy Policy.

Luggel does not knowingly collect Personal Data from children under the age of 18. If you are under the age of 18, please do not submit any Personal Data through the Websites. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide Personal Data to us through the Websites or through any other means without the prior permission of the parents or legal guardians. If you have reason to believe that a child under the age of 18 has provided Personal Data to Luggel, please contact us, and we will endeavor to delete that information from our database.

By voluntarily providing us with Personal Data, you are consenting to the processing of your Personal Data in accordance with this Privacy Policy.

Non-Identifiable or Aggregated Data

When you interact with Luggel through the Websites or our Services, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Luggel may store such information itself or such information may be included in databases owned and maintained by Luggel affiliates, agents or service providers. The Websites may use such information and pool it with other information to track, for example, the total number of visitors to our Websites, the number of visitors to each page of our Websites, and the domain names of our visitors' Internet service providers. Also, in an ongoing effort to better understand and serve the users of the Services, Luggel often conducts research on its customer demographics, interests and behavior based on the Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis. Luggel may share this non-identifiable and aggregate data with its affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify you personally. Luggel may also disclose aggregated user statistics in order to describe our services to current and prospective business partners and to other third parties for other lawful purposes.


In operating the Websites, we also use 'cookies' Cookie is a text file that is placed on your computer's memory to store your preferences when you visit the Websites. Our cookies help provide additional functionality to the Websites and help us analyze Websites usage more accurately. You may turn off the cookies function from your computer. We recommend that you turn on the Cookie function to enhance your usage of our Websites.

Our Use of Your Personal Data and Other Information

Luggel uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. We will only process your Personal Data for purposes for which the Personal Data was provided to us and for purposes relating to the use of the Websites or our Services. We may use your Personal Data for the following purposes including but not limited to:

a) For purposes of providing you with our Services;

b) Respond to requests for information and/or services:

c) When you register as a member with Luggel:

d) Administration and record keeping purposes;

e) To meet and comply with legal and regulatory requirements;

f) Conduct market surveys, analysis and research; and

g) All other purposes related to our business and the provision of our services.

We will only collect and process your Personal Data for purposes of which it was intended for at the time of collection or for purposes related therein. Luggel and its subsidiaries and affiliates (the “Related Companies”) may also use your Personal Data and other personally non-identifiable information collected through the Websites to help us improve the content and functionality of the Websites, to better understand our users and to improve the Services.

Advertising and Marketing

Luggel and its Related Companies may use the Personal Data to contact you in the future and to notify you of our services which we believe will be of interest to you. If we do so, each communication we send will contain instructions permitting you to 'opt-out' from receiving future communications. In addition, if at any time you wish not to receive any future communications or you wish to have your name deleted from our mailing lists, please contact us via the contact indicated below (Access to Information; Contacting Luggel). If Luggel intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.

Our Disclosure of Personal Data

Luggel is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:

Business Transfers

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets.

Related Companies

We may also share your Personal Data with our related and/or affiliated companies for purposes consistent with this Privacy Policy.

Third Parties Data Processors and Service Providers

Luggel, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. The recipients of such Personal Data are prohibited from using the Personal Data and information for any purpose other than for the purpose(s) specified by us.

Legal Requirements

Luggel may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal or regulatory obligation, (ii) protect and defend the rights or property of Luggel, (iii) act in urgent circumstances to protect the personal safety of users of the Websites or the public, or (iv) protect against legal liability.

Other Web Sites and Services

This Privacy Policy applies only to our Websites and our Services, and does not apply to information you provide separately and directly to Local Experts. The Websites may contain links to other web sites or services not operated or controlled by Luggel (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from this Websites do not mean that Luggel endorses or has reviewed the Third Party Sites or Local Experts. We suggest contacting those sites or Local Experts directly for information on their privacy policies.


Luggel takes reasonable steps to protect your Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet, email or other electronic transmission is ever fully secure or error free, so you should take special care in deciding what information you send to us in this way.

Other Terms and Conditions

Your access to and use of this Site is subject to the Terms of Service.

Changes to Luggel’s Privacy Policy

Luggel reserves the right to update or modify this Privacy Policy from time to time without prior notice. Any changes to this Policy will be reflected on our website together with their effective dates. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Any changes to our Policy will become effective upon posting of the revised Policy on the website. Use of the website following such changes constitutes your acceptance of the revised Policy.

Access to Information; Contacting Luggel

Subject to any exceptions under the PDPA or any applicable laws and regulations and subject to payment of a fee, you are entitled to access and make changes to any personal data provided and collected by us. Any request for access or alteration should be in writing and be directed to the designated officer via the contact details as provided below. We will take reasonable steps to allow access, update or correct your Personal Data which is in our possession. Information allowing Luggel to sufficiently identify you should be provided when submitting an access or correction request. Failure to sufficiently provide such information in allowing us to identify you will result in the refusal of your access and/or correction request. Please also feel free to contact us if you have any questions about Luggel’s Privacy Policy or the information practices of this Site.

You may contact us as follows:

Email address:

Retention of your Personal Data

Personal Data collected and processed in accordance with this Privacy Policy may be retained by Luggel for a reasonable period, or as otherwise permitted under the PDPA and other relevant laws and regulations.