Privacy Policy
Last updated: 7th September 2026
Luster Beacon Systems Ltd ("Luster," "we," "us," or "our") operates the Luster mobile application (the "App"), a marketplace for booking car wash, mobile mechanic, tow, fuel delivery and other car care services in Nigeria. This Privacy Policy ("Policy") explains what personal data we collect, why we collect it, how we use and share it, and the rights you ("User") have over it.
By creating an account or using the App, you agree to the collection and use of personal information as described in this Policy. Personal information means information that identifies you and includes information such as your name, email address, telephone number as well as any other personal data collected. We recommend that you read this Privacy Policy carefully to understand your rights and our duties towards managing your personal data. For further information or enquiries, reach out to us at Lusterng@gmail.com.
1. Notification of Changes to Privacy Policy
This Privacy Policy will be reviewed annually to ensure compliance with applicable data protection laws and regulations in all jurisdictions where the Services are provided, including but not limited to the Nigeria Data Protection Act (NDPA), 2023. Nonetheless, we are continually improving our methods of communication and adding new functionalities and features to our website and existing services. Because of these ongoing changes, changes in the law and the changing nature of technology, our data protection practices will change from time to time. If and when our data protection practices change, we will update this Policy to describe our new practices and publish them on our website and applications.
2. Data we collect
We collect the following categories of personal data, only where relevant to the feature you're using:
Account & identity data (collected for every user)
- Phone number (used to sign in via SMS one-time passcode)
- Full name
- Email address (optional)
- Profile photo (optional — you choose an existing photo from your device; the App never accesses your camera directly)
Location data
Precise or approximate device location, used to show nearby wash shops, mechanics, and operatives, to calculate estimated arrival times for dispatched services, and to pre-fill your address when booking a doorstep service. Location is only accessed while the App is in use — we do not collect location in the background. If you decline location access, you can still select your city/neighbourhood manually.
Verification data (only if you apply to become a partner shop, mechanic shop, or individual operative)
- Business name, address, and city
- A photo of a government-issued ID document (passport, driver's licence, or national ID card), used solely to verify your identity/business before approving your listing
Payment data
We do not directly collect or store your card number, expiry date, or CVV. Payments are processed by our third-party payment processors, Paystack and Flutterwave, who are independently responsible for the security of your payment card data. We retain only the transaction reference, status, amount, and payment channel (e.g., card, bank transfer) returned to us by the processor.
Booking & usage data
Booking history, service type, scheduled times, ratings and reviews you leave, referral activity, and your Luster credit balance.
Device & technical data
- A push-notification token (used to deliver booking status updates)
- Crash and error reports (device type, OS version, app version, and the technical details of the crash)
- App usage analytics (which screens and booking flows are used, for the purpose of improving the App — not tied to advertising)
Communications
Support messages you send us, and the SMS one-time-passcode messages we send to verify your phone number.
3. How we use your data
We use the data described above to:
- Create and manage your account, and verify your identity where required
- Match you with nearby shops, mechanics, and operatives, and calculate dispatch/arrival estimates
- Process bookings and payments, and send you status updates about them
- Verify and approve partner and operative applications
- Operate our referral and credit programs
- Detect, investigate, and prevent fraud, abuse, and security incidents
- Diagnose and fix crashes and bugs
- Understand how the App is used, so we can improve it
- Comply with our legal obligations, including under the Nigeria Data Protection Act 2023
4. Understanding what you want (use of cookies)
We might use cookies (small text files in your browser) and other techniques such as web beacons (small, clear picture files that follow your movements on our website). These collect information that makes the website remember you and tells us how you use our website, web-related products and services. This, in turn, helps us make our website relevant to your interests and needs. They also help us find information once you have logged in or help us link your browsing information to you and your personal information, for example, when you choose to register for a service. We may use a persistent cookie (that stays linked to your browser) to record your details so we can recognise you if you visit our website again. Your cookie preferences, including whether you accept or reject cookies, may also be stored to remember your choice for future visits. If you choose not to accept cookies from our website, this may limit its functionalities or performance.
5. Consent
You accept this Policy when you click on the "continue" button to sign up and use any of our Platforms, products and Services. You also consent to the collection and processing of your personal information (which includes but is not limited to your name, date of birth, email address, address, telephone number, etc), your order details, order history and any other information for the purpose of providing the Services. If you decide to opt out of any of the Services or withdraw consent for the processing of your personal information, you can do so by reaching out to us at Lusterng@gmail.com.
6. Legal basis for processing
Under NDPA 2023, we process your personal data on the following bases:
- Performance of a contract: To create your account, process bookings, and facilitate payments
- Legitimate interest: To improve the App, prevent fraud, and diagnose technical issues, balanced against your rights
- Consent: For location access, push notifications, and optional profile fields (email, avatar), each requested separately by the App and revocable at any time in your device settings
- Legal obligation: Where we're required to retain or disclose data by law
7. Who we share your data with
We share personal data only with the following third parties, and only as needed to operate the App: Paystack/Flutterwave for payment processing, Termii for login verification, Google (Maps / Firebase Cloud Messaging) for location and push notification, etc. We do not sell your personal data. We do not share it with third parties for their own marketing purposes.
If you're a customer booking a service, we share the minimum information the assigned operative or shop needs to fulfil your booking — your name, phone number, and location.
8. Disclaimer
Luster has no prior relationship or representation with the partner/operative whose services are listed on Luster's Platform. Luster is solely responsible for the purchase of the service and the delivery of the service to the customer upon confirmation of payment.
Luster will not be responsible for any breach in the representations made by the partner/operative concerning any service made by the customer and does not guarantee that the representations will be fit for purpose, true and accurate.
9. Storage and Security
We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, disclosure, or alteration and unauthorised access.
Personal information is collected on servers in electronic databases which are in the EU and managed by our related entities and/or vendors. We will ensure that your information is protected and that they only process your information in the way we have authorized them to. These organizations will not be entitled to use your personal information for their own purposes unless authorised by you. Where such cross-border transfers occur, we will ensure that they are carried out in accordance with applicable data protection laws and that appropriate safeguards are implemented to protect your personal data.
We have put in place suitable physical, and electronic administrative procedures and measures to safeguard and protect the information that we collect, and to reduce the risks of loss, misuse, disclosure, alteration and unauthorised access to your personal information within our custody. Personal information and associated data stored on servers are encrypted and stored through data isolation technology.
We limit access to personal information to individuals within our employ or that of our related entities or contracted vendors who we believe reasonably need access to such information to provide products or services to you, or to us, or to perform their duties. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorization controls. To prevent unauthorised access to your information, we have implemented strong controls and security safeguards at the technical and operational levels. Our website uses a Secure Sockets Layer (SSL) to ensure secure transmission of your Personal Data. You should see the padlock symbol in your URL address bar when browsing through our website. The URL address will also start with https:// depicting a secure webpage. SSL applies encryption between two points such as your PC and the connecting server. Any data transmitted during the session will be encrypted before transmission and decrypted at the receiving end. This is to ensure that data cannot be read during transmission.
We will never ask for your secure personal or account information by unsolicited means of communication. You are responsible for keeping your personal and account information secure and not sharing it with others. We shall not be liable for any unauthorised access or loss of personal and account information.
10. Data retention
We retain personal data for as long as your account is active, and for 5 years afterward to comply with our legal, accounting, and dispute-resolution obligations. Verification documents (ID photos) submitted by partners/operatives are retained for 5 years after account closure or rejection.
11. Your rights
Under the Nigeria Data Protection Act 2023, you have the right to:
- Confirm the personal information we hold about you
- Access the personal information we hold about you, provided that such requests are made in compliance with the Freedom of Information Act and other applicable laws
- Correct or update the personal information we hold about you
- Anonymization, blocking or erasure of your personal information that is no longer necessary in order for us to provide services to you or no longer necessary for our normal business operations and activities
- Data portability. In some circumstances, you may, by express request ask us to provide a third-party vendor with a copy of the personal information we hold about you in a structured, machine-readable and commonly used format (as selected by us), or otherwise in accordance with the requirements of the applicable law
- Deletion or erasure of personal information we hold about you, where we relied on your consent to use your personal information, unless an exception applies, such as where we are required to retain such information to comply with our legal or regulatory obligations
- Revoke your consent, where we rely on your consent to use and disclose your personal information
- Exercise your right to lodge complaints with the Nigeria Data Protection Commission
You can make any of the above requests by contacting us via email at Lusterng@gmail.com. Our office address is 6 Caroline Atounah Street, Lekki Phase 1.
We will provide you with a response as soon as possible. If we are unable to comply with your request for any reason (such as not being permitted or required to do so under privacy legislation in force or any other applicable legislation) we will inform you of this.
If the personal information we provide in response to your request includes information that is the personal information of a third party, or that is confidential, or in which we own the copyright (such as transcripts or recordings of customer service call records), we may redact such information where reasonably necessary, and you must keep such information confidential and not make the information public, including by sharing the information on social media, without our written consent sought and obtained.
Users can also delete their accounts from the Luster application. If you delete your account, we will retain your personal information in accordance with our Retention Policy.
Luster may retain your personal information after you have requested us to delete or de-identify your information if:
- There is an ongoing investigation or unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute
- We are required to by any applicable law; and/or
- Necessary for our legitimate business interests, such as fraud prevention and enhancing users' safety and security
- Required by our Records Retention Policy
When personal information is no longer required, we will take reasonable steps to delete the personal information from our systems or de-identify the personal information.
12. Children's privacy
The App is not directed at children under 18. We do not knowingly collect personal data from anyone under 18. If you believe a child has provided us with personal data, contact us and we will delete it.
13. Data Protection Officer
In compliance with the Nigeria Data Protection Act (NDPA) 2023, we have appointed a Data Protection Officer (DPO) responsible for overseeing our data protection strategy and implementation. You may contact our DPO regarding any issue related to this Privacy Policy or your personal data at: clintonjacklegal@gmail.com.
14. Governing Law
This Policy is governed by the laws of the Federal Republic of Nigeria. Where any provision of this Policy is deemed inconsistent with a law, regulation or convention, such provision shall be subject to the overriding law, regulation or convention.
This Policy applies to all Users of the Services provided by Luster, and to anyone else who contacts Luster or otherwise submits information to Luster.
Contact us
Last reviewed in September 2026