Privacy Policy
Last updated: 8 August 2026
This Privacy Policy explains how Flytohealth Kft, operating the Luxera Health Concierge service, processes personal data collected through the Luxera Health Concierge public website.
This Policy applies to the public website and its communication, analytics and marketing functions. It does not govern the processing of medical records or other health information submitted through the separate Krinex Clinical portal. Portal users receive a separate privacy notice before submitting such information.
1. Data Controller
The data controller for the Luxera Health Concierge website is:
Flytohealth Kft
Company registration number: 01-09-436151
Tax number: 32663596-2-41
EU VAT number: HU32663596
Registered office: Taborhegyi út 16/G No:3, 1037 Budapest, Hungary
Email: info@luxerahealthconcierge.com
“Luxera Health Concierge” or “Luxera” is a service operated by Flytohealth Kft and is not a separate legal entity.
2. Scope of This Privacy Policy Data
This Privacy Policy applies when you:
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Visit the Luxera Health Concierge website
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Contact us by email or WhatsApp
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Request information about our services
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Subscribe to marketing communications, where available
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Interact with website analytics or marketing technologies
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Follow a link from the website to the separate medical intake portal
Luxera’s public website is primarily an information and referral website. Medical records and detailed health information should not be sent through general website contact channels.
3. Personal Data We May Collect
3.1 Information You Provide
When you contact us, we may receive:
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Your name
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Email address
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Telephone or WhatsApp number
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Country of residence
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Preferred language
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General service enquiry
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Communication history
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Marketing preferences
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Any other information you voluntarily include in your message
Please do not include medical records, diagnostic reports or detailed health information in ordinary email, WhatsApp or general website enquiries.
3.2 Website and Device Information
Depending on your cookie choices and the technologies active on the website, we may collect:
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IP address
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Browser and device type
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Operating system
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Approximate location
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Pages visited
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Referring website or advertising campaign
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Date, time and duration of visits
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Website interactions and technical events
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Cookie and similar technology identifiers
Non-essential analytics and marketing technologies are used only where the required consent has been obtained.
3.3 Marketing Information
If you separately agree to receive marketing communications, we may process:
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Your contact details
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Your marketing consent
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Communication and engagement information
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Your unsubscribe or objection preferences
Marketing consent is optional and is not required to access general information or begin a medical intake.
4. Purposes and Legal Bases
We process personal data for the following purposes:
Responding to Enquiries
To answer questions, provide requested information and communicate about Luxera services.
Legal basis: Taking steps at your request before entering into a service arrangement, or our legitimate interest in responding to enquiries.
Website Operation and Security
To operate the website, maintain security, prevent misuse, diagnose technical problems and ensure service availability.
Legal basis: Our legitimate interests and, where applicable, compliance with legal obligations.
Analytics
To understand how visitors use the website and improve its structure, content and performance.
Legal basis: Your consent where non-essential analytics cookies or similar technologies are used.
Marketing and Advertising
To send communications you have requested and, where enabled, evaluate or improve advertising campaigns.
Legal basis: Your consent. You may withdraw consent or object to direct marketing at any time.
Legal and Compliance Purposes
To establish, exercise or defend legal claims and comply with applicable legal or regulatory obligations.
Legal basis: Legal obligation or legitimate interests, depending on the circumstances.
5. Medical and Health Information
The Luxera public website is not intended to collect medical records or detailed health information.
Selecting Start Your Case directs you to a separate medical intake environment powered by Krinex Clinical. The portal may collect health information, medical records and other special-category personal data necessary for case preparation, clinician review and healthcare coordination.
Before submitting information through that portal, you will receive a separate Clinical Portal Privacy Notice and the relevant consent choices.
Information submitted through the medical intake portal is not governed solely by this public website Privacy Policy.
6. Cookies and Similar Technologies
The website may use essential cookies required for security and technical operation.
With your permission, it may also use analytics and marketing technologies, including services provided by Google or Meta.
You can accept, reject or manage non-essential technologies through the website’s cookie settings. More information is available in our Cookie Policy.
7. Service Providers and Recipients
Where necessary, personal data may be processed by service providers supporting:
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Website hosting and content management
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Email and communications
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Website security
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Analytics
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Advertising and campaign measurement
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Customer relationship management
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Legal, accounting or compliance services
These providers may include Wix, Google, Meta and other service providers used by Flytohealth Kft.
If you choose to contact us through WhatsApp, Meta’s own privacy terms also apply to your use of that service.
We require service providers acting on our behalf to process personal data only for authorized purposes and to apply appropriate safeguards.
We do not sell personal data.
8. International Data Transfers
Some service providers may process data outside Hungary or the European Economic Area.
Where required, transfers are protected through an adequacy decision, approved Standard Contractual Clauses or another legally recognized transfer mechanism, together with appropriate technical and organizational safeguards.
9. Data Retention
We retain personal data only for as long as reasonably necessary for the relevant purpose.
Unless a longer period is legally required or justified:
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General enquiries may be retained for up to two years after the last substantive communication.
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Marketing information is retained until consent is withdrawn or an objection is received, with a limited suppression record retained to respect that choice.
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Website security and technical records are retained according to operational and security requirements.
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Cookie durations are described in the Cookie Policy or cookie settings.
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Information required for legal claims or regulatory compliance may be retained for the applicable statutory limitation period.
Retention periods may be shortened where the information is no longer required.
10. Your Rights
Subject to applicable law, you may have the right to:
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Request access to your personal data
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Request correction of inaccurate or incomplete data
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Request deletion of your data
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Request restriction of processing
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Object to processing based on legitimate interests
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Object to direct marketing at any time
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Request data portability where applicable
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Withdraw consent at any time
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Submit a complaint to a supervisory authority
Withdrawing consent does not affect processing that was lawful before withdrawal.
Requests may be sent to:
info@luxerahealthconcierge.com
We may request information reasonably necessary to verify your identity. Data protection requests are generally answered within one month, subject to extensions permitted by law.
11. Supervisory Authority
You may submit a complaint to the Hungarian data protection authority:
Hungarian National Authority for Data Protection and Freedom of Information — NAIH
Address: 1055 Budapest, Falk Miksa utca 9–11, Hungary
Postal address: 1363 Budapest, Pf. 9
Website: www.naih.hu
Email: ugyfelszolgalat@naih.hu
You may also have the right to contact the data protection authority in the EU or EEA country where you live or work.
12. Children and Minors
Luxera’s services are intended for adults aged 18 or over.
A medical enquiry concerning a person under 18 must be submitted by their parent or legal guardian through the appropriate intake process.
The public website is not intentionally designed to collect personal data directly from children.
13. Data Security
Flytohealth Kft applies reasonable technical and organizational safeguards designed to protect personal data against unauthorized access, disclosure, alteration, loss or misuse.
No internet transmission or electronic storage system can be guaranteed to be completely secure. Users should not send medical records or sensitive health information through unsecured general communication channels.
14. External Websites and Platforms
The website may contain links to external websites, healthcare providers, communication platforms and the separate Krinex Clinical portal.
Those services may operate under their own privacy notices and terms. Flytohealth Kft is not responsible for the independent privacy practices of third-party websites.
15. Changes to This Privacy Policy
We may update this Privacy Policy to reflect changes in our website, services, technologies or legal requirements.
The updated version will be published on this page with a revised “Last updated” date. Material changes may also be communicated through an appropriate additional notice.
16. Contact
For privacy questions or data protection requests:
Flytohealth Kft
Luxera Health Concierge
Taborhegyi út 16/G No:3
1037 Budapest, Hungary