Privacy Policy

Last updated: 15th January 2026

Introduction

aerohubtrixum Ltd ("we", "our", "us") is committed to protecting and respecting your privacy. This Privacy Policy explains the data we collect about you when you visit our website or use our spa client experience analytics services, how we use your information, and your rights regarding the personal data we process.

Data Controller Information

aerohubtrixum Ltd is the data controller responsible for your personal data. Our company is registered in Malta with registration number C63852, and our registered office is located at Triq il-Merkanti 63, Valletta VLT 4900, Malta.

Data Collection

We collect personal data in several ways when you interact with our services. The data we collect includes information you provide directly to us when you contact us through our website, request information about our services, or engage with our spa analytics platform. This may include your name, email address, phone number, company information, and any other details you choose to share with us.

We also collect technical information automatically when you visit our website, including your IP address, browser type, operating system, referring website, pages viewed, and time spent on our site. This information helps us understand how our website is used and improve the user experience.

How We Use Your Information

We use the personal data we collect for several legitimate business purposes. We use your information to respond to your enquiries, provide information about our spa analytics services, and communicate with you about your account or our services. We also use your data to improve our website and services, conduct analytics to understand user behaviour, and ensure the security and proper functioning of our systems.

For our spa analytics services, we process data to provide client experience insights, generate reports, and deliver the analytics functionality that our clients require. We always process this data in accordance with applicable data protection laws and our contractual obligations.

Cookies and Tracking Technologies

We may use cookies and tracking technologies for analytics, advertising, and remarketing purposes, including Google Ads. These technologies help us measure campaign effectiveness, deliver relevant advertisements, and improve our services. You can manage your cookie preferences at any time through our cookie consent banner.

For detailed information about the cookies we use and how to manage them, please see our Cookie Policy.

Legal Basis for Processing

Under the General Data Protection Regulation (GDPR), we process your personal data based on several legal grounds. For most of our processing activities, we rely on legitimate interests, such as providing our services, improving our website, and communicating with potential and existing clients. When you contact us or request information, we process your data based on our legitimate interest in responding to your enquiries and providing customer service.

In some cases, we may process your data based on your consent, particularly for marketing communications or certain types of cookies. You have the right to withdraw your consent at any time.

Data Sharing and Transfers

We do not sell, trade, or rent your personal information to third parties. We may share your data with trusted service providers who assist us in operating our website and providing our services, such as hosting providers, email service providers, and analytics platforms. These service providers are contractually obligated to protect your data and use it only for the purposes we specify.

We may also disclose your information if required by law, to protect our rights or property, or in connection with a business transaction such as a merger or acquisition.

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected or as required by applicable law. For enquiries and communications, we typically retain data for up to three years after our last interaction with you. For client data related to our spa analytics services, retention periods are determined by our contractual agreements and applicable regulatory requirements.

We regularly review our data retention practices to ensure we do not keep personal data longer than necessary.

Your Rights

Under GDPR and other applicable data protection laws, you have several rights regarding your personal data. You have the right to access the personal data we hold about you and receive a copy of this information. You can request that we correct any inaccurate or incomplete personal data, and in certain circumstances, you have the right to request that we delete your personal data.

You also have the right to object to our processing of your personal data or request that we restrict processing in certain circumstances. If we process your data based on consent, you have the right to withdraw that consent at any time. Additionally, you have the right to data portability, which means you can request that we transfer your data to another service provider in a structured, commonly used format.

Security Measures

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. Our security measures include encryption, access controls, regular security assessments, and staff training on data protection practices.

While we strive to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but are committed to using industry-standard security practices.

International Transfers

As we operate within the European Union, your personal data is primarily processed within the EU/EEA. If we transfer your data outside the EU/EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission or transfers to countries with adequacy decisions.

Children's Privacy

Our services are not intended for children under the age of 16, and we do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child without appropriate consent, we will delete such information promptly.

Contact Information

If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or have concerns about how we handle your personal data, please contact us using the following details:

Complaints

If you believe we have not handled your personal data in accordance with applicable law, you have the right to lodge a complaint with the relevant supervisory authority. In Malta, this is the Office of the Information and Data Protection Commissioner.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. When we make material changes, we will notify you by updating the "Last updated" date at the top of this policy and, where appropriate, provide additional notice such as email notification.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data.