Privacy Policy

1. Introduction

This Privacy Policy explains how Luturex Technologies (“we”, “our”, “us”) collects, uses, stores, and protects personal data in connection with the use of SmartNet, a messaging application developed and operated by Luturex Technologies (the “Service”).

By using SmartNet, you acknowledge that your personal data is processed in accordance with this Privacy Policy.

2. Data Controller

The data controller within the meaning of the General Data Protection Regulation (GDPR) is:

Company name: Luturex Technologies
Legal form: SAS
Registered address: 19 Rue Tiergarten, Strasbourg
Country of registration: France
Contact email: [email protected]

3. Personal Data We Collect

We collect only personal data that is strictly necessary to operate the SmartNet messaging service.

This may include:

a) Account Data

• Email address and/or phone number (used for account creation and authentication)

b) User-Generated Content

• Messages, media files, and other content voluntarily shared by users within chats

c) Technical and Usage Data

• IP address
• Device type and operating system
• Application logs and diagnostic data related to security and performance

We do not collect:

• identity or government-issued documents
• financial or payment information
• biometric data
• sensitive personal data as defined by Article 9 GDPR

4. Purpose of Processing

Personal data is processed exclusively for the following purposes:

• Creating and managing user accounts
• Enabling communication between users via SmartNet
• Ensuring security, stability, and proper functioning of the Service
• Preventing abuse, fraud, and unauthorized access
• Complying with applicable legal obligations

Personal data is not used for advertising, profiling, or marketing purposes.

5. Legal Basis for Processing

Luturex Technologies processes personal data in accordance with Article 6 GDPR, based on:

• Performance of a contract (Art. 6(1)(b)) — processing necessary to provide the SmartNet service requested by the user
• Legitimate interests (Art. 6(1)(f)) — ensuring platform security, preventing misuse, and maintaining service reliability

Where processing is based on consent, users may withdraw such consent at any time.

6. Data Storage and Security

All personal data is stored on servers located within the European Union.

Luturex Technologies implements appropriate technical and organizational security measures, including:

• encrypted connections (HTTPS / TLS)
• access controls and role-based permissions
• secure authentication and data storage mechanisms

While no system can guarantee absolute security, reasonable measures are taken to protect personal data against unauthorized access, loss, or misuse.

7. Data Sharing and Third Parties

We do not sell, rent, or trade personal data.

Personal data may be shared only with trusted third-party service providers acting as data processors, such as:

• cloud hosting and infrastructure providers
• technical maintenance and monitoring services

All such providers are contractually bound to process data in compliance with GDPR.

8. International Data Transfers

Personal data processed in connection with SmartNet is not transferred outside the European Union.

If international transfers become necessary in the future, they will be carried out in accordance with GDPR requirements and appropriate safeguards.

9. Data Retention

Personal data is retained only for as long as necessary to provide the SmartNet service or to comply with applicable legal obligations.

Users may request deletion of their account and associated personal data at any time. Upon deletion, data will be permanently removed unless retention is required by law.

10. User Rights

In accordance with the GDPR, users have the right to:

• Access their personal data
• Rectify inaccurate or incomplete data
• Request erasure of personal data
• Restrict or object to processing
• Request data portability
• Lodge a complaint with a supervisory authority

Requests may be submitted by contacting: [email protected]

11. Changes to This Privacy Policy

Luturex Technologies may update this Privacy Policy to reflect changes to SmartNet or applicable legal requirements.

Material changes will be communicated to users through the Service or by other appropriate means.

12. Contact

For any questions regarding this Privacy Policy or the processing of personal data, please contact:

Luturex Technologies
Email: [email protected]