General privacy overview

Luminaara operates spiraela.club to provide private apartment search and luxury property selection services. We collect and process personal information to match clients with appropriate properties, coordinate viewings, support negotiations and manage transactions. Our approach emphasizes case-based decision making and documented scenarios so clients understand why certain pieces of data are needed. We apply technical and organizational measures to protect personal data and limit access to authorized personnel and verified service providers.

11-03-2026 Luminaara 200 Lorraine Avenue, Kitchener ON N2B 3R3, Canada [email protected]

Definitions

For clarity, we define commonly used terms in this policy so you can see how they relate to our services, examples and case-oriented practices.

Personal data means any information that identifies or could reasonably identify an individual, such as name, email, phone number, identification documents, property preferences and transaction details used during private apartment searches.
Processing describes any operation performed on personal data, whether automated or manual, including collection, storage, use, disclosure, analysis, transfer and deletion performed in the course of delivering our services.
User refers to any individual who visits spiraela.club or uses Luminaara services, including prospective buyers, sellers, and contacts engaged to facilitate property searches and transactions.
Service refers to Luminaara’s private apartment search, luxury property selection, market research, concierge coordination and related activities provided to clients through spiraela.club and direct engagement.
Cookies are small text files placed on a device to collect standard internet log information and visitor behavior information. We use cookies to support functionality, preferences and analytics to improve service delivery.

What data we collect

We collect personal data directly from users and automatically through their interaction with spiraela.club. Data collected supports property matching scenarios, secure communications and compliance with legal obligations tied to real estate transactions.

Data you provide directly

When you engage with Luminaara or submit an inquiry, we may collect the following user-provided data:

  • Contact details: full name, email address, phone number and correspondence history used to coordinate searches and viewings.
  • Property preferences: desired neighborhoods, budget range, unit features, accessibility needs and timing to create targeted search scenarios.
  • Identity and verification documents: copies of ID, proof of funds or other documents required for due diligence or to complete transactions when explicitly needed.
  • Transaction details: offers, counteroffers, contract documents and closing-related communications that are necessary to perform the service.
  • Communications: messages, notes from viewings, and feedback collected to refine searches and maintain case histories.
  • Optional marketing preferences and consent choices to tailor information about similar property opportunities or market reports.

Automatically collected data

We automatically collect certain technical and usage data when you interact with spiraela.club to improve service delivery, secure the platform, and compile aggregated case analyses.

  • Device and browser information including device type, operating system, browser version and language settings to ensure compatibility.
  • Usage data and analytics such as pages visited, feature usage, session duration and interaction paths used to refine search workflows and content.
  • IP address and approximate location data for security, fraud prevention and to provide localized market insights.
  • Cookies and similar tracking technologies to remember preferences, support login sessions and measure campaign effectiveness.
  • Error and performance logs to diagnose problems, secure systems and improve reliability of case-management tools.
  • Referrer data and clickstream details that help reconstruct scenario timelines when reviewing how a particular property match progressed.

Data received from third parties

We may receive data about you from trusted third parties to complete searches or verify information as part of a specific engagement. Third-party data augments case research and due diligence.

  • Listing platforms and MLS services that provide property details used to build comparative case notes and shortlist candidates.
  • Identity verification and anti-fraud providers used to confirm identity for transaction-related activities when required.
  • Payment processors and escrow agents that handle business transactions related to service fees or closing procedures.

Purposes of processing

We process personal data to deliver the services described in engagement documents and to support internal case-driven workflows. Processing is limited to what is necessary for these purposes.

  • To perform the contract for private apartment search and luxury property selection, including sourcing, viewings and transaction coordination.
  • To evaluate and match properties to client requirements using documented scenarios and comparative analyses.
  • To communicate with clients, counterparts and service providers about listings, offers, inspections and closing logistics.
  • To secure the service and prevent unauthorized access and fraud through identity verification and monitoring.
  • To analyze site usage and aggregate outcomes from case studies to improve our workflows and client experience.
  • To comply with legal and regulatory obligations applicable to real estate services and business transactions.
  • To manage billing, disputes and service-related records as part of transaction support and archived case documentation.
  • To send operational updates, appointment reminders and, where consented, market insights or property alerts relevant to client preferences.

Legal bases for processing

We rely on appropriate legal bases for processing personal data depending on the purpose and jurisdiction, including contractual necessity and legitimate interests supported by case-specific documentation.

  • Performance of a contract: processing necessary to perform services you requested, such as search, viewings and transaction support.
  • Consent: where you have explicitly consented to processing for optional features such as marketing communications or profiling for recommendations.
  • Legitimate interests: for fraud prevention, security, platform improvement and limited research and analytics related to case outcomes, after balancing interests.
  • Legal obligation: processing necessary to comply with laws, court orders or regulatory requirements related to real estate transactions.

When GDPR applies

To the extent GDPR applies, Luminaara respects and facilitates rights available to data subjects and implements measures consistent with GDPR principles in relevant engagements.

  • Right of access: you can request a copy of personal data we hold about you, along with details about how it is processed in the context of your case.
  • Right to rectification: you may request corrections to inaccurate personal data used in any ongoing search or transaction scenario.
  • Right to erasure: in certain situations you may request deletion of data that is no longer necessary for contractual or legal reasons.
  • Right to restriction: you can request limitation of processing while a dispute about accuracy or lawful basis is resolved.
  • Right to data portability: where processing is based on consent or performance of a contract and carried out by automated means, you may request a portable copy of your data.
  • Right to object: you may object to processing based on legitimate interests for direct marketing or profiling; we will assess and respond in line with applicable rules.

Cookies and tracking

We use cookies and related technologies on spiraela.club to support functionality, record preferences and gather analytics about how the site and our search tools are used.

Types include essential cookies for site operation, preference cookies for saved settings, analytics cookies for usage measurement and marketing cookies to support optional property alerts.

Categories: strictly necessary, performance and analytics, functional, and advertising/marketing. Essential cookies cannot be disabled without affecting core features like secure sessions.

You can manage cookie preferences through our cookie banner or browser settings. Disabling certain categories may change the behavior or availability of some features used in private search workflows.

View Cookie Policy

Sharing personal data

We share personal data only as necessary to provide our services, fulfill legal obligations, or when you have authorized sharing. Third parties are contractually bound to protect data in line with this policy.

  • Service providers that support our platform, such as cloud hosting, analytics, identity verification and secure document storage.
  • Real estate counterparties including listing agents, building management and escrow agents when necessary to progress an offer or transaction.
  • Payment processors and business institutions engaged to process fees, deposits or transaction-related payments.
  • Legal or regulatory authorities when disclosure is required by law, court order or to respond to lawful requests for information.
  • Third parties approved by you explicitly, such as co-buyers, legal advisors or property managers involved in a specific case.
  • Aggregated and anonymized data derived from multiple cases that cannot reasonably be re-identified and is used to improve service design.

International transfers

Personal data may be transferred to service providers or partners located outside your country. When transfers occur, we apply safeguards to preserve privacy and align with applicable laws.

Safeguards include using standard contractual clauses, assessing adequacy decisions where available, applying encryption in transit and at rest, and limiting transferred data to what is necessary for the service.

Data retention

We retain personal data as long as necessary to fulfill contractual obligations, comply with legal requirements, resolve disputes, or until you request deletion, subject to retention constraints for real estate records.

Account and client engagement records are retained for the duration of the engagement plus a period required by regulatory recordkeeping rules and for the purposes of defending any potential claims or audit requirements.

Communications, messages and transactional correspondence related to property searches and offers are retained to preserve case histories and support ongoing transaction logistics.

System logs, analytics and security records are retained for a limited period to support operational monitoring, troubleshooting and incident response, in line with industry standards.

When personal data is no longer required, we securely delete or anonymize it, unless retention is necessary for legal compliance or legitimate business needs tied to recorded case outcomes.

Security measures

Luminaara applies technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure or destruction. Measures are chosen based on the sensitivity of the data and the context of the processing.

  • Access controls and role-based permissions to limit data access to authorized team members and vetted service providers involved in a case.
  • Encryption of data in transit and at rest, multi-factor authentication for administrative access, and regular security reviews and vulnerability assessments.
  • Role-based access controls and periodic access reviews: only authorized employees and vetted partners receive credentials, and access rights are reviewed quarterly to limit exposure. Administrative actions are logged and monitored to detect anomalous behavior using automated alerts and manual audits.

Your privacy rights

At Luminaara we respect your control over personal information. Below are the practical rights available to individuals in Canada and steps for exercising them, illustrated with reference scenarios and typical timelines to set expectations.

  • Right to access — request a copy of personal data we hold about you, such as saved search criteria or communications with agents.
  • Right to correction — request updates or corrections to inaccurate or incomplete details, for example an address or preferred contact method.
  • Right to deletion — request removal of personal information where retention is no longer necessary for the purpose collected, subject to legal or contractual retention obligations.
  • Right to restriction — ask us to limit processing while a dispute about accuracy or lawful use is resolved.
  • Right to data portability — request a machine-readable copy of personal data you provided to Luminaara for transfer to another service provider.
  • Right to object — object to processing based on legitimate interests, for example direct marketing or profiling related to property suggestions.
  • Right to withdraw consent — when processing is based on consent you may withdraw that consent at any time without affecting processing prior to withdrawal.
  • Right to lodge a complaint — if you believe your rights are not respected, you can contact Luminaara or a relevant data protection authority to raise a concern.

How to request your rights

To exercise any of the rights above, submit a request via our contact page at https://spiraela.club/contact or send a written request to our office at 200 Lorraine Avenue, Kitchener ON N2B 3R3, Canada. Include your full name, the specific right you wish to exercise, and any relevant examples or documents. We may ask you to verify your identity to protect your information.

[email protected]

We aim to acknowledge requests within 5 business days and provide a substantive response within 30 calendar days. If a request requires additional time for complex cases we will inform you of the expected extension and reasons for the delay.

Marketing communications

Luminaara may send property alerts, market analyses, and service updates if you opt in. Marketing content is based on preferences you provide and interactions such as saved searches or tour bookings. We rely on legitimate interest and consent as lawful bases and apply frequency caps and relevance filters to reduce unwanted contact. Each campaign is documented with an opt-in source and timestamp for traceability.

You can unsubscribe from marketing emails using the link in any message or by updating preferences on your Luminaara account. If email controls are not available, contact us through https://spiraela.club/contact or by mail to the address listed; we will process unsubscribe requests promptly and confirm the change.

Children and minors

Luminaara services are intended for adults and property decision-makers. We do not knowingly collect personal information from individuals under 16. If we become aware that we have collected data from a minor without appropriate authorization, we will take steps to delete that information in accordance with applicable law and our removal procedures.

Third-party links and services

Our website and communications may include links to third-party property portals, analytics providers, payment processors, and mapping services. These third parties have their own privacy practices; Luminaara is not responsible for their content or policies. We document the most commonly used vendors and review their data handling practices as part of onboarding.

Changes to this privacy policy

We periodically update this policy to reflect operational changes, new features, or legal developments. Material changes will be posted on spiraela.club with an updated effective date. For example, an update might add a new vendor used for virtual tours and explain how that impacts data sharing and retention.

Contact information

For privacy questions or requests, contact Luminaara at: 200 Lorraine Avenue, Kitchener ON N2B 3R3, Canada; phone +14167727870; Business ID 081105893. For web inquiries use https://spiraela.club/contact. Policy effective date: 2026-01-22.