This Privacy Policy explains how Luxemss Resources (SSM Registration No. 202603121194 / PG0587419-T) ("LuxGov", "we", "us", or "our") collects, uses, stores, and protects personal data and building compliance data when you use the LuxGov platform ("Platform").
This Privacy Policy is designed to comply with:
Where there is a conflict between the requirements of different jurisdictions, LuxGov will apply the higher standard of protection.
Luxemss Resources
SSM Registration No: 202603121194 (PG0587419-T)
No 46, Jalan Bidara 3, Saujana Utama 3, 47000 Sungai Buloh, Selangor, Malaysia
Email: admin@luxgov.net
Where LuxGov processes personal data on behalf of a Tenant (as a data processor), the Tenant is the data controller and LuxGov acts as the data processor. This relationship is governed by the Data Processing Agreement.
Full name, email address, organisation name and role, jurisdiction of operation, and subscription plan selection.
Microsoft Entra ID tokens and session identifiers, email/password authentication records (passwords are hashed — plaintext passwords are never stored), login timestamps, IP addresses, device identifiers, session duration and expiry data.
Audit runs initiated (project IDs, timestamps, jurisdictions), feature usage patterns, API request logs (endpoints accessed, response codes, latency), error logs and diagnostic data.
Subscription plan, billing cycle, and billing history; Stripe customer identifier and subscription identifier; invoice records and payment status.
LuxGov does not collect, store, or have access to payment card numbers, CVVs, or bank account details. All payment processing is handled exclusively by Stripe Inc. in accordance with PCI DSS Level 1 requirements.
Architectural drawings, engineering reports and structural calculations, compliance certificates and professional certifications, building permits, inspection reports, and regulatory correspondence. This data may contain personal data of third parties (e.g., names and professional registration numbers of engineers, architects, and building certifiers). The Tenant, as data controller, is responsible for ensuring it has the necessary consents to upload such data.
| Jurisdiction | Legal Basis |
|---|---|
| Malaysia (PDPA 2010) | Consent (Section 6); performance of contract; legitimate interests; compliance with legal obligation |
| Singapore (PDPA 2012) | Consent; contractual necessity; legitimate interests (Section 17, as amended 2021) |
| Australia (Privacy Act 1988) | Consent; necessary for the performance of a contract; permitted under Australian Privacy Principles (APPs 3, 6) |
| United Kingdom (UK GDPR) | Consent (Art.6(1)(a)); performance of contract (Art.6(1)(b)); legitimate interests (Art.6(1)(f)); legal obligation (Art.6(1)(c)) |
| United States (CCPA/CPRA) | Business purpose; contractual necessity; with notice and consent where required by state law |
Providing the automated compliance auditing service; running the seven-stage compliance pipeline against jurisdiction-specific Building Codes; generating Compliance Outputs (audit reports, deficiency lists, compliance scores); managing Tenant accounts, projects, and user permissions.
Building compliance documents are processed by our AI engine including Anthropic's Claude API for classification, analysis, and compliance scoring.
Document content is transmitted to Anthropic's Claude API for natural language analysis. Anthropic's API Terms of Service explicitly prohibit using API inputs for model training. LuxGov does not use Tenant Data for training, fine-tuning, or improving AI models.
Processing subscription payments via Stripe, generating invoices, enforcing plan limits, and managing trial periods and subscription renewals.
Analysing aggregated, anonymised usage patterns to improve Platform features. Individual Tenant Data is never used in identifiable form for this purpose.
Complying with applicable laws, regulations, and legal processes; responding to lawful requests from government authorities; enforcing our Terms of Service and protecting our legal rights.
LuxGov implements strict technical measures to ensure that each Tenant's data is isolated from all other Tenants:
LuxGov stores Tenant Data in Azure data centres located in the Jurisdiction of the Tenant's operations:
| Jurisdiction | Azure Region | Data Protection Law |
|---|---|---|
| Malaysia (MY) | Malaysia West | PDPA 2010 |
| Singapore (SG) | Southeast Asia | PDPA 2012 |
| Australia (AU) | Australia East | Privacy Act 1988 |
| United Kingdom (UK) | UK South | UK GDPR / DPA 2018 |
| United States (US) | East US | CCPA / State laws |
| Data Category | Retention Period | Basis |
|---|---|---|
| Active project data | Duration of subscription | Contractual necessity |
| Post-termination project data | 30 days after termination | Data export grace period |
| Active audit logs | Retained per jurisdiction and regulatory requirement | Regulatory compliance |
| WORM-protected audit archives | Up to 7 years for AU/US jurisdictions | Regulatory (QBCC Act, State Construction Law) |
| Billing records | 7 years | Malaysian Income Tax Act 1967 |
| Authentication logs | 90 days | Security monitoring |
9.1. Upon termination of a subscription, the Tenant has a thirty (30) day grace period to export all Tenant Data.
9.2. After the grace period, LuxGov will permanently delete Tenant Data from active storage systems through a sovereign purge process specific to the Tenant's Jurisdiction.
9.3. UK, SG, MY (SOFT WORM jurisdictions): Audit archives can be deleted after the applicable retention period expires, or upon legal basis (e.g., GDPR Article 17 right to erasure, PDPA withdrawal of consent).
AU, US (HARD WORM jurisdictions): Audit archives under HARD LOCK immutability cannot be deleted before the expiration of the regulatory retention period (up to 7 years). This is a regulatory requirement. The Client acknowledges and consents to this retention upon subscribing.
As a general principle, Tenant Data is stored within the Tenant's chosen Jurisdiction. However, certain processing activities require cross-border data transfers:
AI Processing Transfer: Building compliance document content is transmitted to Anthropic's Claude API infrastructure, based in the United States, for AI-powered compliance analysis. This transfer is governed by Anthropic's Data Processing Addendum and API Terms of Service.
Payment Processing: Billing data is processed by Stripe Inc., headquartered in the United States, governed by Stripe's published Data Processing Agreement.
| Transfer Safeguard Mechanism | Applicability |
|---|---|
| Standard Contractual Clauses (EU/UK SCCs) | UK Tenants — incorporated by reference into the DPA |
| APEC Cross-Border Privacy Rules (CBPR) | SG, AU Tenants |
| Malaysia PDPA Section 129 | MY Tenants — transfer only with adequate protection or Client consent |
| Contractual safeguards | All Tenants — sub-processor DPAs with Microsoft, Anthropic, and Stripe |
| Right | MY | SG | AU | UK | US (CA) |
|---|---|---|---|---|---|
| Access | ✅ S.12 | ✅ S.21 | ✅ APP 12 | ✅ Art.15 | ✅ §1798.100 |
| Correction | ✅ S.34 | ✅ S.22 | ✅ APP 13 | ✅ Art.16 | ✅ §1798.106 |
| Deletion | ✅ S.34 | — | — | ✅ Art.17 | ✅ §1798.105 |
| Portability | — | ✅ S.26H | — | ✅ Art.20 | — |
| Withdraw Consent | ✅ S.38 | ✅ S.16 | — | ✅ Art.7 | — |
| Non-discrimination | — | — | — | — | ✅ §1798.125 |
To exercise any of these rights, please contact us at admin@luxgov.net. We will respond within 21 days (Malaysia), 30 days (Singapore, Australia, UK), or 45 days (United States — California).
12.1. The Platform uses session cookies only to maintain authenticated user sessions. These are essential for Platform operation and cannot be disabled.
12.2. The Platform does not use third-party advertising or marketing cookies, cross-site tracking pixels, behavioural analytics cookies, or social media tracking scripts.
12.3. The Platform uses Microsoft Application Insights for server-side performance monitoring and error diagnostics. This telemetry data is anonymised and does not track individual user behaviour.
The Platform is a business-to-business service designed for use by organisations and professionals in the built environment. It is not intended for use by individuals under the age of eighteen (18). LuxGov does not knowingly collect personal data from children.
| Measure | Implementation |
|---|---|
| Encryption in transit | TLS 1.2+ for all data transmission |
| Encryption at rest | AES-256-GCM for state files; Azure Storage Service Encryption for blob storage |
| Secret management | Azure Key Vault for all credentials, API keys, and encryption keys (no hardcoded secrets) |
| Tenant isolation | PostgreSQL Row Level Security; per-tenant storage containers |
| Access control | Role-based access control (RBAC) across defined tenant and platform roles, fail-closed enforcement |
| Audit logging | SHA-256 hash-chained audit trail, WORM-protected archives |
| Authentication | Microsoft Entra ID (Azure AD) with JWT token validation; JWKS key verification |
In the event of a personal data breach, LuxGov will notify the affected Tenant within seventy-two (72) hours of becoming aware of the breach, and notify the relevant data protection authority within the time required by applicable law:
LuxGov does not sell, share, or rent personal data to third parties for monetary or other valuable consideration. LuxGov does not share personal data for cross-context behavioural advertising. California residents may contact us at admin@luxgov.net to exercise their rights under the CCPA/CPRA.
LuxGov may update this Privacy Policy from time to time. Material changes will be notified to Tenants via email or dashboard notification at least thirty (30) days before taking effect. The "Effective Date" at the top of this document indicates when it was last updated.
Luxemss Resources — Data Privacy
No 46, Jalan Bidara 3, Saujana Utama 3, 47000 Sungai Buloh, Selangor, Malaysia
Email: admin@luxgov.net
Website: www.luxgov.net
Supervisory Authorities: