Smartsleep Privacy Policy

Policy last updated on 21/11/2025

📘 PRIVACY POLICY – SMARTSLEEP / SMARTSAVEURS / SMARTHUB

(Version compliant with Luxembourg and EU GDPR requirements)

1. Data Controller

Personal data collected through the websites:

are processed by:

MVI FLOWER
14 Am Eck, L-9690 Watrange, Luxembourg
Matricule: 2019 2433 410
RCS: B235054
VAT: LU31902953
Email: info@smartsleep.lu
Legal representative: Management of MVI Flower

2. Data Collected

We only collect the data necessary for the smooth operation of our services.

2.1. Data provided by the user

First and last name
Email address
Phone number
Postal address (for Smart Saveur deliveries)
Reservation details (dates, stay, options)
Order details (dishes, quantities, time slots)
Messages sent via contact forms
Newsletter consent (if provided)

2.2. Automatically collected data

IP address
Technical browsing data
Cookies (see dedicated section)
Session identifiers (site security and functionality)

2.3. Payment data

Payments are fully processed by Wix Payments or other secure payment providers.
MVI Flower never stores credit card information.

3. Purpose of Data Processing (Why we collect your data)

3.1. For SmartSleep

Reservation management
Communications related to the stay
Invoicing
Service improvement

3.2. For Smart Saveur

Order preparation
Delivery
Communications about orders
Invoicing

3.3. For SmartHub

Navigation between both services
Customer support

3.4. Other purposes

Website security
Sending newsletters (with consent)
Anonymous statistics (website traffic)

4. Legal Basis (GDPR – Article 6)

Data processing is based on:

Performance of a contract
(accommodation reservation, meal order)
Consent
(newsletter, non-essential cookies)
Legal obligation
(invoicing, mandatory retention)
Legitimate interest
(site security, fraud prevention)

5. Data Retention

Reservations / orders: 5 years (legal accounting requirement)
Customer messages / contact forms: up to 3 years
Newsletter: until consent is withdrawn
Cookies: varies depending on type (see Cookie section)

6. Data Sharing

Data may be shared only with:

Wix.com (hosting, payments, form processing)
Internal service providers at MVI Flower (management, Smart Saveur deliveries)
Legal authorities when required by law

❗ We never sell your data.

7. Data Security

MVI Flower implements:

HTTPS encryption
Anti-intrusion systems
Secure Wix infrastructure
Restricted access to personal data
Secure backups

8. Cookies

Our websites use:

Functional cookies (essential for site operation)
Analytics cookies (statistics through Wix or associated tools)
Marketing cookies (if activated)

Visitors can manage their preferences via the cookie banner.

9. User Rights (GDPR)

You have the following rights:

Right of access
Right to rectification
Right to erasure
Right to object
Right to restriction of processing
Right to data portability
Right to withdraw consent
Right to lodge a complaint with the Luxembourg CNPD

To exercise these rights:
📩 info@smartsleep.lu

10. CNPD – Supervisory Authority

Commission Nationale pour la Protection des Données (Luxembourg)
Website: https://cnpd.public.lu

11. Policy Changes

MVI Flower may update this policy at any time.
The date of the latest update will appear at the bottom of the page.

12. Applicable Law

This policy is governed by Luxembourg law.