In short. This Policy applies to Customers and to people on the LuxWash waitlist; Washers have their own Washer Privacy Policy. It explains what personal information we collect, why, who receives it, where it is processed and how long we keep it; before-and-after Wash Photos of your vehicle are stored in private cloud storage, which may be outside Québec, and deleted after 365 days. We do not sell personal information, and you can export or delete your data in the app. Nothing in this Policy limits your rights under Quebec law.
1. Introduction and acceptance
1.1 Who we are. 17119402 CANADA CORPORATION, operating as LuxWash ("LuxWash", "we", "us"), operates the Platform. LuxWash is a national technology platform that connects vehicle owners with independent car care professionals on demand ("Washers").
1.2 Scope. This Policy applies to Customers and to people who join the waitlist on our website. It does not apply to Washers or Washer applicants: information about them, including how LuxWash verifies them before they can accept Bookings, is governed by the Washer Privacy Policy, available in the LuxWash app and at luxwash.co/washer-privacy.
1.3 This Policy is our notice. This Policy is the information LuxWash gives you when it collects your personal information, as required by section 8 of the Act respecting the protection of personal information in the private sector, CQLR c. P-39.1 (the "Quebec Private Sector Act"), and by the Personal Information Protection and Electronic Documents Act (PIPEDA) where it applies. When you create an Account you confirm that you have read it. That confirmation is not a contract, is separate from your acceptance of the Terms of Service and is not consent to marketing.
1.4 Privacy Officer. Under section 3.1 of the Quebec Private Sector Act, LuxWash's person in charge of the protection of personal information is Mayedson Pierre, CEO (privacy@luxwash.co). This Policy also summarises the governance rules LuxWash applies to personal information (roles, retention, incidents); the Privacy Officer answers questions about them.
2. Definitions
- Account: a registered Customer or Washer account on the Platform.
- Anonymise: to transform information so that it irreversibly no longer allows a person to be identified, directly or indirectly (s. 23 of the Quebec Private Sector Act). Anonymised information is no longer personal information.
- Booking: a request for car care services made by a Customer through the Platform and accepted by a Washer.
- Customer: a person who uses the Platform to book car care services.
- De-identify: to remove or mask direct identifiers so that information no longer allows a person to be identified directly (s. 12 of the Quebec Private Sector Act). De-identified information is still personal information and stays protected under this Policy.
- Dispute Process: the in-app process described in the Terms of Service, Section 12.
- LuxWash, we, us: 17119402 CANADA CORPORATION, operating as LuxWash.
- Personal information: any information about a natural person that allows that person to be identified, directly or indirectly.
- Platform: the LuxWash mobile application, website and related services.
- Platform Fee: the per-Booking fee LuxWash charges the Customer, shown at checkout.
- Processor: a company that processes personal information on LuxWash's behalf and under its instructions.
- Program: the Damage Protection Program, the discretionary platform benefit described in the Damage Protection Program Terms.
- Service Price: the price of the car care service set by the Washer and shown at checkout, before Platform Fee, tip and taxes.
- Service Zone: a geographic area defined by LuxWash within which Bookings are matched.
- Wash Photos: before- and after-service photographs captured in-app under the Terms of Service, Section 14.
- Washer: a person who provides car care services to Customers through the Platform as an independent business, as introduced in Section 1.1.
3. Information we collect and why
3.1 What we collect. Legal basis: "contract" means the information is necessary to provide the Platform or a Booking you request; "consent" means we rely on your consent; "legal obligation" means a law requires us to keep it. Retention is detailed in Section 10.
| Category | Source | Purpose | Legal basis | Retention | Recipients |
|---|---|---|---|---|---|
| Account: name, email, phone, password (held by our authentication provider), language, optional profile photo; the name and email your sign-in provider shares if you choose a social sign-in | You | Create and secure your Account; send Booking and Account messages | Contract | Life of the Account | Cloud hosting, databases and file storage; communications; sign-in providers (if you choose a social sign-in) |
| Booking: vehicle details (type, make, model, year, colour, licence plate or VIN if you provide it), service address, date and time, services, notes, Service Price, Platform Fee, tip, taxes, receipts, refunds, cancellations, referral credits and promo codes applied | You; the Platform | Perform the Booking; apply credits; issue receipts and refunds; keep accounting records | Contract; legal obligation (tax) | 6 years, de-identified after Account deletion | Washers on the Platform (7.1); payment processing; maps and location services; cloud hosting, databases and file storage |
| Payment: a payment token issued by our payment processing provider; LuxWash never receives your full card number | You, directly to our payment processing provider | Charge, refund and tip; prevent fraud | Contract | Until you remove the card or delete your Account; transaction records 6 years | Payment processing; card networks and your card issuer |
| Foreground location | Your device, with your permission | Set a service address or confirm it at checkout, and show Washers available near that address; never in the background | Consent | Only the address and coordinates you save, with your Account and Booking | Maps and location services; cloud hosting, databases and file storage |
| Booking chat messages | You and the Washer | Communicate about the Booking; the Dispute Process | Contract | 180 days after the Booking ends (10.3) | The Washer; communications (in-app messaging); cloud hosting, databases and file storage |
| Wash Photos | Captured in-app by the Washer | Record vehicle condition and the work done; the Dispute Process and the Program | Contract | 365 days from capture (Section 5) | The Washer; cloud hosting, databases and file storage |
| Ratings and reviews | You | Service quality; the Washer's rating | Contract | With the Booking record | The Washer concerned; cloud hosting, databases and file storage |
| Disputes and damage reports: description, evidence, outcome | You, the Washer, LuxWash | The Dispute Process; refunds; the Program | Contract; legal obligation | 6 years after resolution, de-identified after Account deletion | The Washer concerned; payment processing |
| Support requests | You | Answer and resolve your request | Contract | for as long as needed for the purpose, then deleted | LuxWash staff who handle support |
| Marketing consent record: choice, time, version, withdrawal | You | Prove consent under Canada's Anti-Spam Legislation (CASL) | Legal obligation | 3 years after withdrawal | Cloud hosting, databases and file storage; customer relationship and waitlist management |
| Acceptance and consent records: the document, version and language shown (and, where recorded, whether the French version was presented first and the language you chose), the date and time, IP address, device information and a fingerprint of the exact text shown | The app; our servers | Proof of what you accepted and when | Legal obligation; contract | See 10.1 | Cloud hosting, databases and file storage |
| Device and technical: push token, device and app version, crash diagnostics with identifiers removed, server and audit logs (Account identifier, IP address) | Your device; the Platform | Notifications; security; fixing faults | Contract | Push token until sign-out or deletion; crash data for as long as needed for the purpose, then deleted; audit logs 365 days | Cloud hosting, databases and file storage; communications (push notifications); analytics, performance monitoring and crash reporting |
| Website use: aggregate visit statistics; hosting logs | Your browser | Understand website use in aggregate; deliver and protect the website | Consent (notice and opt-out, 4.4) | for as long as needed for the purpose, then deleted; hosting logs for as long as needed for the purpose, then deleted | Analytics, performance monitoring and crash reporting; cloud hosting, databases and file storage |
| Waitlist: email, language, postal code or city, the user type you select | You (website form) | Tell you when LuxWash is available near you; send the waitlist emails you asked for | Consent | for as long as needed for the purpose, then deleted, or until you ask us to delete it | Cloud hosting, databases and file storage; customer relationship and waitlist management; communications |
3.2 Sensitive information. We treat your precise location and your payment information as sensitive. We collect precise location only when you allow it through your device's permission prompt (Section 4.1), and your card details go directly to our payment processing provider; LuxWash never receives your full card number.
3.3 Website and waitlist. When you join the waitlist, our form-processing service receives the form, stores it with our cloud hosting, databases and file storage providers, sends a confirmation email through a communications provider and passes your contact details to a customer relationship and waitlist management provider. If you apply to become a Washer on the website, the Washer Privacy Policy applies to that application.
4. Device permissions and tracking technologies
4.1 Your location. The app asks for your location only while it is open, and only when you choose to use your current position to set a service address, to see Washers available near you, or at checkout. It never collects your location in the background. If you refuse, you can enter the address yourself; you can withdraw the permission at any time in your device settings.
4.2 The Washer's location during a Booking. While a Washer is en route to you and during the Booking, the app shows you the Washer's location so you can follow their arrival. How that location is collected is described in the Washer Privacy Policy.
4.3 Other permissions and default settings. The app also asks, through your device's prompt, for the camera (to scan a VIN) and notifications. It does not ask for your contacts, calendar or health data. By default, service notifications are on, SMS notifications are on for three events (Booking confirmed, wash completed, Booking cancelled), location is off until you allow it and marketing is off. You can change each setting in the app's notification preferences or your device settings.
4.4 Website analytics. Our website uses a cookieless website analytics service that records aggregate page views and two form-submission events and sets no cookie. It records visits in aggregate (page, referring site, browser, device type, approximate location derived from the connection) and two events after a form is submitted successfully: waitlist_submit and washer_apply. It sends no name, email or form content to the analytics service. We are adding support for the browser Do Not Track signal; you can also use a browser content blocker, and the website works normally.
4.5 Cookies and on-device storage. The website sets no cookies and serves its fonts from our own domain. The app stores small items on your device (language, preferences, drafts, the active Booking) and uses third-party providers for crash diagnostics and to deliver app updates. The app contains no advertising SDK, does not access your advertising identifier and does not track you across other companies' apps or websites. Details are in the Cookie & Tracking Policy at luxwash.co/cookies.
5. Wash Photos
5.1 Capture and use. The Washer takes Wash Photos in the app before and after the service and may mark pre-existing damage on a before-service photo. You can see the Wash Photos of your Booking in the app. Wash Photos record the condition of your vehicle and the work done; they are used to resolve disagreements through the Dispute Process and to assess damage reports under the Program.
5.2 Licence plates. Wash Photos may incidentally show your licence plate. We do not use them to read, extract or index plate numbers.
5.3 Storage. Wash Photos are stored in private, encrypted cloud storage, which may be outside Québec (Section 8). They are never public and are retrieved only through signed, time-limited links.
5.4 Retention. Wash Photos are deleted automatically and permanently 365 days after capture. A Wash Photo that is evidence in an open Dispute Process, or subject to a legal hold (Section 10.5), is kept with the dispute record until the matter is resolved and then for the period that applies to dispute records.
6. Consent and your choices
6.1 Information needed for your Bookings. When you provide information to create an Account or make a Booking after receiving this notice, you consent to its use and communication for the purposes stated in Section 3 (s. 8.3 of the Quebec Private Sector Act). We do not use it for any other purpose without asking you.
6.2 Separate express consents. We ask separately, never pre-checked and never bundled with the Terms of Service, before we (a) access your device's location, (b) send you marketing email, or (c) use your information for a new purpose or communicate it for a purpose not described here.
6.3 Marketing. We send marketing by email only, and only if you opt in. We do not send marketing by push notification or SMS. Booking updates, receipts, one-time codes and dispute notices are service messages, not marketing. We keep a record of your choice, its time and the version of the request for 3 years after you withdraw, as CASL allows.
6.4 Withdrawing consent. You may withdraw a consent at any time: use the unsubscribe link in any marketing email, change your notification preferences or device settings, or write to privacy@luxwash.co. Withdrawal does not affect service messages. If you withdraw consent to information a Booking needs, we may be unable to perform that Booking; we will tell you.
7. Who receives your information
7.1 Washers on the Platform. Washers are independent businesses. A Washer who accepts your Booking receives what is needed to perform it: your name, the service address, your vehicle details, the services booked and your notes, the Booking chat, the Wash Photos and your rating and review of their service. Calls through the app use a masked number. The Washer Agreement binds Washers to use this information only to perform the Booking and the Dispute Process and not to use it to solicit you outside the Platform (Washer Agreement, Section 13.2).
7.2 Processors. These Processors, by category, handle personal information for LuxWash, under its instructions. The list of categories may include, but is not limited to, the following:
| Category | What they do for us | Information involved | Where they may process it |
|---|---|---|---|
| Payment processing: card payments | Process card payments, refunds and tips, and screen for fraud | Card details (directly from you), name, email, amounts, device information for fraud screening | Inside or outside Québec (Section 8) |
| Cloud hosting, databases and file storage | Host the Platform, its database, real-time data and private file storage (including Wash Photos), deliver app updates, and protect and deliver the website, including its forms | Account identifier, email, phone, live Booking status, Washer location, stored files, Wash Photos, network traffic, IP addresses, website form submissions and requests, app version and update identifiers | Inside or outside Québec (Section 8) |
| Communications: email, SMS, push notifications and in-app messaging | Send service email, SMS and push notifications, provide masked calling, carry Booking chat and send the website confirmation email | Email, name, phone numbers, message content, push tokens, Booking chat messages, display name | Inside or outside Québec (Section 8) |
| Maps and location services | Provide maps, geocoding and directions | Addresses, coordinates, map usage data from the app | Inside or outside Québec (Section 8) |
| Analytics, performance monitoring and crash reporting | Measure website use in aggregate with a cookieless service that sets no cookie, and monitor crashes and performance | Aggregate website statistics; crash and performance diagnostics, identifiers removed | Inside or outside Québec (Section 8) |
| Customer relationship and waitlist management | Keep waitlist and Customer contact records and send opted-in email | Waitlist and Customer contact details, language, email preferences | Inside or outside Québec (Section 8) |
| Sign-in providers, where you choose a social sign-in (for example Google or Apple) | Let you sign in with an existing account | Sign-in data, if you choose a social sign-in | Inside or outside Québec (Section 8) |
7.3 Other recipients. We communicate personal information without your consent only where the law allows: to comply with a law, court order or lawful request; to card networks and your card issuer to process payments, refunds and chargebacks; to a licensed collection agency if an amount you owe under the Terms of Service remains unpaid after notice; to protect a person's life, health or safety; and to a party to a contemplated business transaction (such as a sale or financing of LuxWash), under an agreement limiting its use to that transaction, as section 18.4 of the Quebec Private Sector Act permits. Within LuxWash, only people who need it for their role have access.
7.4 No sale. We do not sell or rent personal information and do not share it for advertising.
8. Transfers outside Québec
8.1 The rule. Communicating personal information outside Québec includes communicating it to another Canadian province. LuxWash communicates personal information outside Québec only after assessing it as section 17 of the Quebec Private Sector Act requires and under a written agreement with the recipient that reflects that assessment.
8.2 Destinations. Your information may be stored or processed outside Québec, including elsewhere in Canada, in the United States and in the European Union, by providers in the categories above. Before communicating personal information outside Québec, LuxWash assesses the protection it will receive and requires a written agreement with the provider, as the law requires. Information processed outside Québec is subject to the laws of the place where it is processed, and authorities there may be able to access it.
8.3 Details. For details about a specific transfer, write to the Privacy Officer at privacy@luxwash.co.
9. Automated decisions
9.1 Matching your Booking. When you request a Booking, the Platform automatically selects which Washers in your Service Zone are offered it, based on your service address, distance, availability, rating and service history.
9.2 Price adjustments. If the Platform adjusts a price automatically, for example for demand, time or Service Zone, the adjusted price is shown before you confirm the Booking.
9.3 Your rights. Where a decision about you is based exclusively on automated processing, we inform you of it at or before the decision. On request, we tell you the personal information used, the reasons and principal factors that led to the decision, and your right to have that information corrected. You may submit observations to a member of LuxWash staff who can review the decision (s. 12.1 of the Quebec Private Sector Act). Write to privacy@luxwash.co.
10. Retention, destruction and anonymisation
10.1 Schedule.
| Category | Kept for | Then |
|---|---|---|
| Account profile (name, email, phone, language, photo) | Life of the Account | Deleted or de-identified on deletion (10.2); anonymised after 24 months of inactivity (10.4) |
| Saved addresses, vehicles, payment methods, push tokens, notification preferences | Life of the Account | Deleted on Account deletion |
| Booking, payment, refund, receipt and tax records; ratings and reviews | 6 years | De-identified after Account deletion; destroyed at the end of the period |
| Booking chat messages | 180 days after the Booking ends | Deleted with the chat (10.3) |
| Wash Photos | 365 days from capture | Deleted automatically (5.4) |
| Dispute records and evidence | 6 years after resolution | De-identified after Account deletion; destroyed at the end of the period |
| Support requests; waitlist entries | each for as long as needed for the purpose, then deleted | Destroyed |
| Acceptance and consent records — the document, version and language shown (and, where recorded, whether the French version was presented first and the language chosen), the date and time, IP address, device information and a fingerprint of the exact text shown; purpose: proof of what you accepted and when | For the life of your Account and 3 years after it closes, or longer while a dispute, claim or legal hold is open | When you delete your Account, your name and contact details are removed and the record is kept in de-identified form linked to an internal identifier; at the end of the period the whole record is deleted |
| Marketing consent records | 3 years after withdrawal | Destroyed |
| Administrator audit logs | 365 days | Destroyed |
| Crash diagnostics; website analytics; hosting logs | each for as long as needed for the purpose, then deleted | Deleted by the provider |
| One-time codes and session tokens | Short-lived; revoked on sign-out or deletion | Destroyed |
10.2 Deleting your Account. You can delete your Account in the app. We then delete your profile details, saved addresses, vehicles, payment methods and notification data, and your Booking history is removed from your Account. Records we must keep by law (Bookings, payments, ratings, reviews and disputes) are kept in de-identified form for the periods in Section 10.1. Acceptance and consent records are kept in de-identified form for the period in Section 10.1.
10.3 Chat after Account deletion. Deleting your Account does not delete messages you sent in a Booking chat. They remain visible to the other party, without your name or profile, until the chat is deleted 180 days after the Booking ends. Before you delete your Account, your data export includes these messages.
10.4 Inactive Accounts. If an Account has no activity for 24 months, we close it and anonymise the personal information in it. Records we must keep for tax purposes stay de-identified for the rest of their period.
10.5 Legal holds and destruction. Where litigation, an investigation or a regulator's request requires it, we keep the relevant information until the matter ends. At the end of a period, we destroy information securely or anonymise it.
11. Security and confidentiality incidents
11.1 Safeguards. We use encryption in transit (TLS) and at rest; private storage with signed, time-limited links and access logging; hashed session tokens; passwords managed by our authentication provider; role-based access control; account lockout; malware scanning and metadata removal on uploads; and deny-by-default real-time database rules. Staff and administrator access is limited to role need and logged.
11.2 Confidentiality incidents. If we have reason to believe a confidentiality incident has occurred, we take reasonable measures to reduce the risk of injury and prevent a recurrence. If the incident presents a risk of serious injury, we promptly notify the Commission d'accès à l'information and the persons concerned. We record every incident in a register (ss. 3.5 to 3.8 of the Quebec Private Sector Act) and report breaches to the Office of the Privacy Commissioner of Canada where PIPEDA requires.
12. Your rights
12.1 Access. You may ask whether we hold personal information about you and obtain a copy (s. 27 of the Quebec Private Sector Act). Access is free; if a reasonable fee for transcription, reproduction or transmission applies, we tell you before acting.
12.2 Portability. You may download the personal information you provided, in a structured, commonly used technological format (JSON), from the app's data export, or ask us to communicate it to any person or body authorised by law to collect it (s. 27, para. 3).
12.3 Rectification. You may have inaccurate, incomplete or equivocal information corrected, and you can correct most Account details yourself in the app (s. 28).
12.4 De-indexation. You may ask us to stop disseminating your personal information or to de-index any hyperlink attached to your name, where the conditions of section 28.1 are met.
12.5 Deletion. You may delete your Account in the app at any time (Section 10.2), or ask us to delete information that is no longer needed or was collected unlawfully.
12.6 How to exercise your rights. Use the app or write to privacy@luxwash.co. We may ask you to confirm your identity. We answer in writing within 30 days of receiving your request; if we refuse, we give our reasons and tell you how to seek a review (Section 13).
13. Complaints
13.1 Privacy Officer. Write first to the Privacy Officer at privacy@luxwash.co. We acknowledge your complaint, look into it and answer in writing.
13.2 Commission d'accès à l'information du Québec. If we refuse a request under Section 12 or do not answer within 30 days, you may apply to the Commission d'accès à l'information for an examination of the disagreement within 30 days of the refusal or the end of the time limit. You may also file a complaint with it at any time (www.cai.gouv.qc.ca).
13.3 Office of the Privacy Commissioner of Canada. Where PIPEDA applies, you may complain to the Office of the Privacy Commissioner of Canada (www.priv.gc.ca).
14. Minors
14.1 Adults only. The Platform is not offered to anyone under 18. If we learn that we hold a minor's personal information, we delete it.
15. Changes to this Policy
15.1 How we notify you. We post the new version on the website and in the app and update the "Last updated" date. We notify you of a material change in the app or by email before it takes effect. If a change requires your consent, we ask for it separately (Section 6.2).
16. Governing law and language
16.1 Governing law. This Policy is governed by the laws of Québec and the federal laws of Canada applicable there. Nothing in it limits your rights under the Quebec Private Sector Act, the Consumer Protection Act or PIPEDA.
16.2 Language. This Policy is drawn up in French and English; the French version prevails where Quebec law requires.
17. Contact and legal notice
- 17.1 Contacts. Privacy Officer: Mayedson Pierre, CEO — privacy@luxwash.co · General support: support@luxwash.co.
- 17.2 Legal notice. 17119402 CANADA CORPORATION, operating as LuxWash · 101 Rue Villeneuve O, #2804, Montréal, QC H2T 2R6 · NEQ 1182352170.