Privacy Policy

Last updated: November 23, 2025

This Privacy Policy explains how RÉACLYSE (“we”, “us”, “our”) collects, uses, shares, and protects your personal data when you visit our website, purchase our products, use our digital portal, or interact with us (collectively, the “Services”).

We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and applicable Luxembourg law. If you do not agree with this policy, please discontinue use of the Services.

1) Who we are

RÉACLYSE Roksana Skubis
Email (privacy requests): hello@reaclyse.com
Registered address:
22 Rue de Montmédy, L-2164 Luxembourg

Supervisory authority: Commission nationale pour la protection des données (CNPD), Luxembourg (cnpd.lu). You can lodge a complaint with the CNPD or your local EU authority. We’d appreciate the chance to resolve concerns first – please email us.

2) What data we collect

a) Data you provide

  • Identity & contact: name, email, phone, billing/shipping address
  • Account & portal: login/email, password (hashed), preferences, entries you choose to store
  • Orders & payments: order details, payment confirmation (card data handled by Stripe)
  • Support & feedback: messages and any information you share
  • Marketing choices: newsletter opt-ins/opt-outs

b) Data collected automatically

  • Technical & usage: IP address, device IDs, browser/OS, pages viewed, time on page, referrers
  • Cookies/pixels: set by us and our partners (e.g., Google Analytics, Meta) for analytics, performance, and advertising (see Cookies section)

c) Data from third parties

  • Payment processor (Stripe): payment confirmations, fraud signals
  • Email/CRM (Klaviyo, Brevo): subscription status, email engagement
  • Advertising/analytics (Google Analytics, Meta Ads): aggregated metrics, audiences

We do not collect special categories of data on purpose (e.g., health, beliefs). Please avoid sharing such data in free-text fields.

3) Why we process your data (purposes & legal bases)

PurposeExamplesLegal basis
Order processing & deliveryTake and fulfill orders, shipping, returnsContract (Art. 6(1)(b))
Payments & fraud preventionProcess via Stripe, prevent misuseContract; Legitimate interests (Art. 6(1)(f))
Account & digital portalCreate/maintain your account, personalize portal experienceContract; Legitimate interests
Customer supportRespond to emails, fix issuesLegitimate interests
Service improvement & analyticsMeasure traffic, improve UX/contentLegitimate interests
Marketing & newslettersSend emails via Klaviyo & Brevo, show ads/remarketingConsent for emails & non-essential cookies; Legitimate interests for some direct marketing to customers where permitted
Security & integrityDetect abuse, ensure network/app securityLegitimate interests; Legal obligation
Legal & accountingInvoices, tax, recordsLegal obligation (Art. 6(1)(c))

Where we rely on consent, you can withdraw it at any time (e.g., cookie banner, email “unsubscribe”).

4) Cookies & similar technologies

We use cookies, pixels, and similar tech to:

  • remember preferences and keep you signed in;
  • analyze usage (Google Analytics);
  • run ads/remarketing (Meta/others).

In the EU, non-essential cookies require opt-in consent (ePrivacy). Our banner lets you accept, reject, or customize categories and access a preference center anytime (footer link). Blocking cookies may affect some features.

5) Who we share data with

We do not sell personal data. We share limited data with trusted processors under GDPR-compliant contracts (they act only on our instructions):

  • Stripe (payments & fraud prevention)
  • Klaviyo (email & customer messaging)
  • Hosting/IT & security providers
  • Analytics/ads: Google Analytics, Meta Ads
  • Fulfilment/shipping partners (to deliver your order)

We may disclose data when required by law or to protect our rights, users, or the Services.

6) International transfers

Some providers are outside the EEA (e.g., US). When data is transferred internationally, we use appropriate safeguards such as the European Commission Standard Contractual Clauses (SCCs) and additional measures where necessary, to ensure an adequate level of protection.

7) Data retention

We keep data only as long as needed for the purposes above, then delete or anonymize it.

  • Orders, invoices, accounting: up to 10 years (Luxembourg legal retention)
  • Customer service: up to 3 years after last interaction (unless needed longer for claims)
  • Marketing (email/ads audiences): until you unsubscribe/withdraw consent or after 24 months of inactivity
  • Analytics: according to provider settings/policies (we use truncated IP where available and reasonable retention periods)

8) Security

We implement technical and organizational measures to protect data (encryption in transit, access controls, least-privilege, secure passwords hashing, vendor due diligence). No method is 100% secure; please keep your credentials confidential and notify us if you suspect misuse.

9) Your rights (GDPR)

You have the right to:

  • Access your data;
  • Rectify inaccurate data;
  • Erase your data (“right to be forgotten”);
  • Restrict processing;
  • Object to processing based on legitimate interests (including direct marketing);
  • Data portability (copy in a structured, commonly used, machine-readable format);
  • Withdraw consent at any time (e.g., cookies, newsletters);
  • Complain to the CNPD or your local authority.

How to exercise your rights

Email hello@reaclyse.com from the address linked to your account/order. We may ask for identity verification (e.g., order ID, reply-to confirmation) to protect you. We aim to respond within one month (extendable by two months for complex requests).

10) Children’s privacy

Our Services are not directed to children under 13. We do not knowingly collect data from children. If you believe a child provided data, contact us to delete it.

11) Third-party sites

Links to third-party sites/services are provided for convenience. Their privacy practices apply to your use of those sites. We are not responsible for their policies.

12) Changes to this policy

We may update this policy to reflect changes to laws, our Services, or vendors. We will post updates here with a new “Last updated” date and, where appropriate, provide additional notice.

13) Contact

For questions or privacy requests:
hello@reaclyse.com
Address:
22 Rue de Montmédy, L-2164 Luxembourg