Privacy policy

PRIVACY POLICY

Effective date: 26 October 2026

1. Purpose and scope of this Privacy Policy

Natural Bond Korlátolt Felelősségű Társaság considers the protection of personal data and privacy to be of fundamental importance.

This Privacy Policy describes the processing of personal data in connection with the lustiqlab.hu website, the Lustiq Lab educational platform, the Lustiq App and the related services.

This Privacy Policy applies in particular to:

  1. use of the lustiqlab.hu website,

  2. creation and management of user accounts,

  3. use of free and paid courses,

  4. subscriptions and other digital services,

  5. payments and invoicing,

  6. learning progress, quizzes and assignments,

  7. artificial intelligence powered features,

  8. use of the Emotion Diary,

  9. use of the Lustiq App,

  10. contacting us and customer support,

  11. email newsletters and marketing communications,

  12. SMS marketing communications,

  13. requests for free content, tests, educational materials and other digital content,

  14. web analytics, cookies, online advertising and conversion measurement.

Lustiq Lab and the Lustiq App are digital services connected to the Lustiq brand.

Where a user has given valid consent to Lustiq marketing communications after receiving appropriate prior information, Natural Bond Kft. may send news, educational content and offers relating to the Lustiq brand and its related services through the communication channel to which the user has consented.

Marketing communications may relate in particular to:

  1. the Lustiq Lab educational platform, its courses, services, expert content, events, updates and offers,

  2. Lustiq products available on the getlustiq.hu online store, including new products, bundles, discounts, promotions and related content,

  3. Lustiq App features, digital services, content, updates and offers,

  4. the Szexplicit podcast, including new episodes, guests, events, news and related content.

Consent to email marketing and consent to SMS marketing are treated as separate consents.

Subscribing to the email newsletter does not automatically constitute consent to SMS marketing.

Providing a phone number alone does not automatically constitute consent to SMS marketing.

The processing necessary for using Lustiq Lab or the Lustiq App and processing for marketing purposes are also separate processing purposes.

Creating a user account, purchasing a subscription or service, or using the Lustiq App does not automatically constitute consent to marketing communications.

This Privacy Policy has been prepared in accordance with Regulation EU 2016/679 of the European Parliament and of the Council, hereinafter GDPR, Act CXII of 2011, applicable Hungarian legislation relating to commercial advertising, and other applicable Hungarian and European Union laws.

2. Data Controller

Data Controller:
Natural Bond Korlátolt Felelősségű Társaság

Registered office:
1011 Budapest, Fő utca 56–58. 3rd floor, door 21, Hungary

Company registration number:
01 09 430770

Tax number:
32562323 2 41

Data protection contact:
hello@lustiqlab.com

Phone:
+36 30 848 7788

Website:
https://lustiqlab.hu

For questions relating to data protection, the exercise of data subject rights or complaints concerning data processing, you may contact us using the email address above.

3. Our data protection principles

We process personal data only for specified, explicit and lawful purposes.

We process only personal data that is necessary for the relevant purpose.

We seek to ensure that the personal data we process is accurate and kept up to date.

We retain personal data only for as long as necessary for the relevant processing purpose or as required by law.

We apply technical and organisational measures appropriate to the level of risk in order to protect personal data.

Due to the nature of certain Lustiq Lab and Lustiq App features, users may voluntarily provide information relating to health, sex life or other information considered special category personal data under the GDPR.

We apply enhanced data protection requirements to such data.

4. Sources of personal data

We primarily receive personal data directly from the user.

Processing may take place in particular when the user:

  1. creates a user account,

  2. purchases a subscription or another service,

  3. uses a course or other digital content,

  4. completes a quiz or assignment,

  5. uses an AI feature,

  6. creates an entry in the Emotion Diary,

  7. uses a feature of the Lustiq App,

  8. contacts us,

  9. subscribes to an email newsletter,

  10. provides a phone number and separately consents to SMS marketing communications,

  11. requests free content or educational materials,

  12. registers for an event or another service,

  13. otherwise provides personal data.

Certain technical data may also be processed automatically when the user uses the website, application, browser or device, in accordance with applicable law and the user's privacy settings.

5. User accounts

When a user account is created, we may process in particular:

  1. name,

  2. email address,

  3. account identifier,

  4. authentication information,

  5. user settings,

  6. purchased services,

  7. subscription entitlements,

  8. access rights relating to courses and other features,

  9. information relating to learning progress.

The purpose of processing is to provide the user account, provide access to purchased or free services and operate the platform.

The legal basis for processing is performance of a contract under Article 6(1)(b) GDPR.

Data associated with the account is generally processed for as long as the account remains active.

Data that must be retained by law or is necessary for the establishment, exercise or defence of legal claims may be retained after this period.

6. Subscriptions, courses and digital service purchases

When purchasing a subscription, course or another paid digital service, we may process in particular:

  1. name,

  2. email address,

  3. billing address,

  4. information required for invoicing,

  5. purchased service,

  6. subscription type and status,

  7. date of purchase,

  8. payment status,

  9. transaction identifier.

The purpose of processing is to fulfil the purchase and subscription, provide access to the service, issue invoices and provide customer support.

The legal basis is performance of a contract under Article 6(1)(b) GDPR and, for invoicing and accounting data, compliance with a legal obligation under Article 6(1)(c) GDPR.

Accounting documents are retained for the period required by law, generally for at least 8 years.

7. Payments

We may use external payment service providers to process online payments.

We may process in particular:

  1. confirmation that payment has been made,

  2. payment status,

  3. amount,

  4. transaction identifier,

  5. technical information relating to the payment.

Natural Bond Kft. generally does not receive or store full bank card numbers or card security codes.

The legal basis for processing is Article 6(1)(b) GDPR.

8. Learning progress, quizzes and assignments

The platform may process user activity relating to courses in order to provide the service.

Such data may include in particular:

  1. lessons started and completed,

  2. course progress,

  3. quiz results,

  4. completion of assignments,

  5. usage events,

  6. technical information relating to use of the platform.

The purpose of processing is to provide the learning experience, display progress and operate and improve the service.

The legal basis is generally Article 6(1)(b) GDPR.

Where a user response relates to health, sex life or another special category of personal data, the provisions of this Privacy Policy relating to special category personal data also apply.

9. AI coach and artificial intelligence powered features

Lustiq Lab and the Lustiq App may provide artificial intelligence powered features.

When using these features, we may process in particular:

  1. text entered by the user,

  2. questions and answers,

  3. conversation content,

  4. voice data or its text transcription where a feature is voice based,

  5. responses generated by the system,

  6. technical data necessary for proper operation.

The purpose of AI features is to provide educational support, personalised feedback, practical assistance and relevant content recommendations.

Users may voluntarily provide information while using AI features that relates to health, sex life or other special category personal data.

Where processing of such special category personal data is necessary for the relevant feature, the user will be appropriately informed and, where required, explicit consent will be obtained under Article 9(2)(a) GDPR.

Users are asked not to provide identifiable personal data or special category personal data relating to third parties unless they have an appropriate legal basis to do so.

Information provided by AI features is for educational purposes and does not replace medical, psychological, psychiatric, legal or other professional examination, diagnosis or therapy.

Special category personal data provided through AI features is not used for direct marketing purposes.

10. Emotion Diary

The Emotion Diary may allow users to create entries relating to their own relationship, emotional or sexual experiences.

Content provided in the diary may contain personal data and special category personal data under the GDPR.

Data processed may include in particular:

  1. diary entry content,

  2. date and time of the entry,

  3. user responses,

  4. analyses and feedback generated by the system,

  5. technical data required for operation of the feature.

The purpose of processing is to provide the diary feature, support recognition of personal patterns and provide educational feedback.

Where diary content contains special category personal data, Article 9 GDPR applies.

Where required, the legal basis for processing special category personal data is the user's explicit consent under Article 9(2)(a) GDPR.

Personal data and special category personal data provided through the Emotion Diary are not used for direct marketing purposes.

We do not use diary content to send advertisements or offers from which a user's health, sex life, sexual orientation or other special category personal data could be inferred.

Enhanced technical and organisational safeguards are applied to data processed through the diary.

11. Lustiq App

The Lustiq App is a digital application connected to the Lustiq brand.

Depending on the features used, we may process in particular:

  1. user account information,

  2. email address,

  3. user preferences,

  4. in app activity,

  5. features used,

  6. usage and technical information,

  7. device and application version information,

  8. content voluntarily provided by the user.

The purpose of processing is to operate the Lustiq App, provide its features, maintain the user experience, resolve technical issues and improve the service.

Depending on the relevant feature, the legal basis may be performance of a contract under Article 6(1)(b) GDPR, legitimate interests under Article 6(1)(f) GDPR or consent under Article 6(1)(a) GDPR.

Where a Lustiq App feature may involve special category personal data, Article 9 GDPR also applies.

Using the Lustiq App does not automatically constitute consent to marketing communications.

12. Email newsletter and marketing communications

Where you subscribe to the Lustiq email newsletter after receiving appropriate prior information, Natural Bond Kft. may send you news, educational content and commercial offers by email.

The Lustiq newsletter may contain communications relating to the previously identified Lustiq ecosystem.

This means that if you subscribe to the Lustiq newsletter through lustiqlab.hu, you may receive emails relating to more than just Lustiq Lab.

Email marketing communications may relate in particular to:

  1. Lustiq Lab courses, educational content, expert materials, new features, events, discounts and offers,

  2. Lustiq products available through the getlustiq.hu online store, including new products, bundles, promotions, discounts, educational content and offers,

  3. Lustiq App features, digital services, content, developments, updates and offers,

  4. the Szexplicit podcast, including new episodes, guests, events, content, collaborations and related news.

Subscriptions may take place in particular:

  1. on lustiqlab.hu,

  2. on getlustiq.hu,

  3. in the Lustiq App,

  4. through a popup,

  5. on a campaign or landing page,

  6. through Play or another promotional interface,

  7. through another Lustiq interface where the user receives appropriate information before subscribing.

Providing an email address constitutes a newsletter subscription only where the user is clearly informed before submitting the data that they are subscribing to a newsletter and about the topics covered by the communication.

For email newsletters, we may process in particular:

  1. name, where provided,

  2. email address,

  3. date and time of consent,

  4. source of subscription,

  5. the content or version of the information displayed when consent was given,

  6. marketing campaign activity,

  7. email open and click events,

  8. marketing segments.

The legal basis is consent under Article 6(1)(a) GDPR.

Consent is voluntary and may be withdrawn at any time free of charge.

Users may unsubscribe using the unsubscribe option included in emails or by sending a request to hello@lustiqlab.com.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

For marketing purposes, personal data is generally processed until consent is withdrawn.

13. SMS marketing communications and processing of phone numbers

Natural Bond Kft. may allow users to separately subscribe to SMS marketing communications by providing their mobile phone number.

Marketing SMS messages are sent only to users who have separately consented to SMS communications after receiving appropriate prior information.

Providing a phone number alone does not constitute consent to SMS marketing.

Consent to email marketing does not automatically constitute consent to SMS marketing.

Consent to SMS marketing does not automatically constitute consent to email marketing.

Consent for the two communication channels is managed separately.

SMS marketing communications may include in particular:

  1. offers relating to Lustiq products and services,

  2. promotions and discounts,

  3. new products and services,

  4. Lustiq Lab courses and educational content,

  5. Lustiq App content and updates,

  6. Szexplicit content and events,

  7. temporary campaigns,

  8. cart reminders,

  9. reminders relating to previously viewed products or services where an appropriate consent is available.

For SMS communications, we may process in particular:

  1. mobile phone number,

  2. name, where provided,

  3. date and time of consent,

  4. source of consent,

  5. the content or version of the information displayed when consent was given,

  6. SMS subscription status,

  7. SMS unsubscribe status,

  8. sent messages and their technical delivery data,

  9. interactions with links contained in SMS messages,

  10. technical and measurement data relating to marketing campaigns.

The legal basis for SMS marketing is consent under Article 6(1)(a) GDPR.

Consent is voluntary.

Subscription to SMS marketing is not a condition of purchase, creation of a user account, use of a course or use of another service.

The frequency of SMS messages may vary.

Depending on the user's mobile service provider and tariff, charges may apply in connection with SMS communications, particularly when sending reply messages.

SMS unsubscribe

Users may withdraw their consent to SMS marketing at any time free of charge.

Where supported by the SMS technology used, users may unsubscribe by replying STOP.

Where an SMS message contains an unsubscribe link, users may also unsubscribe through that link.

Users may also request to unsubscribe by contacting hello@lustiqlab.com.

Unsubscribing from SMS marketing using STOP or another SMS unsubscribe method generally only terminates SMS marketing communications and does not automatically unsubscribe the user from email marketing.

Email and SMS marketing consents can be managed separately.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

For marketing purposes, phone numbers are generally processed until SMS marketing consent is withdrawn.

The minimum information necessary to demonstrate that consent was given or withdrawn may be retained thereafter for as long as necessary for accountability and the establishment, exercise or defence of legal claims.

14. Klaviyo marketing system

We may use Klaviyo to manage our email and SMS marketing communications.

Within Klaviyo, we may process in particular:

  1. email address,

  2. mobile phone number,

  3. name,

  4. email consent status,

  5. SMS consent status,

  6. date and time of subscription and unsubscription,

  7. source of subscription,

  8. campaign activity,

  9. email open and click events,

  10. interactions relating to SMS messages,

  11. purchase and marketing events,

  12. marketing segments.

Klaviyo may be used to manage email and SMS campaigns, automated marketing flows, subscription forms, segmentation and campaign measurement.

Email and SMS consent are managed separately within the system.

We do not send SMS marketing communications merely because a user's phone number is available to us for another purpose.

Separate SMS marketing consent is required for SMS marketing communications.

15. Separation of marketing consents

Consent for different communication channels is managed separately.

Accordingly:

  1. subscribing to the email newsletter does not constitute consent to SMS marketing,

  2. subscribing to SMS marketing does not automatically constitute consent to email marketing,

  3. providing a phone number during a purchase or account creation does not constitute consent to SMS marketing,

  4. creating a user account does not constitute marketing consent,

  5. downloading or using the Lustiq App does not automatically constitute marketing consent,

  6. purchasing a course or product does not automatically constitute marketing consent.

Users may freely decide through which communication channels they wish to receive marketing messages.

16. Free content, tests and downloadable materials

Lustiq Lab and other Lustiq interfaces may provide free courses, tests, workbooks, PDF documents, videos or other digital content.

To provide such content, we may process the user's email address, phone number and other information necessary for the relevant service.

Requesting free content does not automatically constitute consent to email or SMS marketing.

Where providing an email address or phone number through a particular interface also results in marketing subscription, the user will be clearly informed before submitting the data.

17. Transactional and service communications

Messages necessary in connection with a user account, subscription, purchase, payment, access, security, password or another requested service are not automatically considered marketing communications.

Such messages may be sent where necessary to provide the service even if the user has not subscribed to marketing communications or has previously unsubscribed.

Where transactional SMS services are used, their purpose and legal basis are managed separately from SMS marketing consent.

18. Contact and customer service

When you contact us, we may process in particular:

  1. your name,

  2. email address,

  3. phone number,

  4. subject of the message,

  5. content of the message,

  6. other information necessary to handle the request.

The purpose of processing is to respond to your question or request and provide customer support.

Depending on the circumstances, the legal basis may be Article 6(1)(b) or Article 6(1)(f) GDPR.

Data relating to customer service requests may generally be retained for up to 2 years after the matter is closed unless a longer retention period is required by law or necessary for a legal claim.

19. Cookies and similar technologies

lustiqlab.hu and related Lustiq digital services may use cookies, pixels, tags, local storage and similar technologies.

Strictly necessary technologies

These are necessary for operation of the website, user accounts, security, carts, purchases and other essential functions.

Analytics technologies

These may be used to measure use, performance and operation of the website and services.

Non essential analytics technologies are generally used on the basis of consent.

Marketing technologies

These may be used for advertising measurement, conversion measurement, remarketing and campaign optimisation.

These are generally used on the basis of consent.

Users can modify their preferences relating to non essential cookies through the consent management interface available on the website.

20. Cart reminders and browsing related marketing

Where a Lustiq interface includes cart functionality, the website may use cookies, technical identifiers, cart data and other technologies to detect when a user adds a product or service to their cart but does not complete the purchase.

Where appropriate marketing consent exists, this information may be used to send a reminder about the abandoned cart by email or SMS.

SMS cart reminders are sent only to phone numbers for which valid SMS marketing consent is available.

For cart reminder communications, we may process in particular:

  1. email address,

  2. phone number,

  3. cart contents,

  4. cart value,

  5. browsing or purchase event,

  6. campaign and technical identifiers.

Non essential tracking technologies are used subject to the user's relevant consent settings.

21. Marketing profiles and segmentation

Where appropriate consent and another applicable legal basis exist, we may create marketing segments based on information such as:

  1. previous purchases,

  2. source of subscription,

  3. interests,

  4. activity relating to email communications,

  5. activity relating to SMS communications,

  6. website activity that may lawfully be used for marketing purposes.

The purpose is to provide more relevant Lustiq products, Lustiq Lab content, Lustiq App features and Szexplicit content.

We do not use the content of AI coach conversations, Emotion Diary entries or other information from which health, sex life, sexual orientation or other special category personal data could be inferred to create marketing profiles.

We do not make decisions based solely on automated processing that produce legal effects concerning users or similarly significantly affect them unless the legal requirements for such processing are met and separate information is provided.

22. Processors and recipients

We may use external service providers to operate Lustiq Lab, the Lustiq App and related services.

These may include in particular:

  1. hosting and IT infrastructure providers,

  2. cloud service providers,

  3. online payment providers,

  4. invoicing and accounting providers,

  5. email and SMS marketing automation providers,

  6. telecommunications and SMS delivery providers,

  7. web analytics providers,

  8. advertising and conversion measurement providers,

  9. artificial intelligence providers,

  10. voice technology providers,

  11. customer support and communication providers,

  12. IT developers and system operators,

  13. legal, accounting and other professional advisers.

Klaviyo

We may use Klaviyo to manage email and SMS marketing.

Klaviyo may assist in particular with:

  1. managing email and SMS subscriptions,

  2. recording consent status,

  3. sending newsletters and SMS messages,

  4. operating automated marketing flows,

  5. segmentation,

  6. campaign measurement,

  7. unsubscribe management.

Only data necessary to provide the relevant service is shared with Klaviyo and service providers involved in SMS communications.

SMS marketing consent and SMS subscription status are not shared with third parties for purposes unrelated to providing the SMS service.

Data necessary to operate SMS communications may be shared with service providers that technically participate in delivery of messages, including marketing platform providers, telecommunications providers and technical SMS delivery partners.

We do not sell personal data or marketing consents.

Depending on the service and contractual structure, providers may act as processors, independent controllers or, in certain cases, joint controllers.

23. Transfers outside the European Economic Area

Certain technology providers or their subcontractors may process personal data outside the European Economic Area.

Such transfers are carried out only in accordance with applicable data protection laws.

Appropriate legal mechanisms or safeguards may include in particular:

  1. an adequacy decision adopted by the European Commission,

  2. an applicable data protection framework,

  3. Standard Contractual Clauses adopted by the European Commission,

  4. additional data protection safeguards where necessary.

24. Special category personal data

Due to the nature of Lustiq Lab and the Lustiq App, users may voluntarily provide information relating to health, sex life, sexual orientation or other special category personal data when using certain features.

Such data is processed only where an appropriate legal basis exists under Article 9 GDPR.

Where processing is based on explicit consent, the user may withdraw that consent at any time.

Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

We do not sell special category personal data.

Special category personal data provided through the AI coach, Emotion Diary or other sensitive features is not used for direct marketing or advertising purposes.

25. Data security

We apply technical and organisational measures appropriate to the level of risk in order to protect personal data.

Such measures may include in particular:

  1. access restrictions,

  2. appropriate authentication solutions,

  3. encrypted data transmission,

  4. access management,

  5. technical logging,

  6. regular system updates,

  7. backups,

  8. review of service provider permissions,

  9. incident response processes.

Enhanced security measures are applied to features involving sensitive or special category personal data.

Absolute security cannot be guaranteed for internet based data transmission or electronic storage.

In the event of a personal data breach, we carry out the risk assessment and documentation required by the GDPR and notify the competent authority or affected individuals where necessary.

26. Rights of data subjects

Subject to the conditions of the GDPR, you have the right to:

  1. request information about the processing of your personal data,

  2. request access to personal data processed about you,

  3. request correction of inaccurate or incomplete data,

  4. request deletion of your personal data where the legal conditions are met,

  5. request restriction of processing,

  6. request data portability in certain cases,

  7. object to processing based on legitimate interests,

  8. object at any time to processing for direct marketing purposes,

  9. withdraw consent at any time,

  10. exercise your rights relating to automated decision making in the cases provided for by the GDPR.

Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

Once marketing consent for a particular communication channel has been withdrawn, we will no longer use your personal data for marketing communications through that channel.

Requests relating to data subject rights may be sent to:

hello@lustiqlab.com

To protect your identity and personal data, we may request reasonable verification where necessary.

We generally respond to requests within one month.

In the cases provided for by the GDPR, this period may be extended by a further two months.

27. Unsubscribing from email and SMS marketing

Email

Consent to email marketing may be withdrawn at any time free of charge.

Users may unsubscribe using the unsubscribe function included in emails or by contacting hello@lustiqlab.com.

SMS

Consent to SMS marketing may also be withdrawn at any time.

Users may unsubscribe in particular:

  1. by replying STOP, where supported by the SMS service used,

  2. through an unsubscribe link included in the SMS, where available,

  3. by contacting hello@lustiqlab.com.

Unsubscribing from one marketing channel does not necessarily unsubscribe the user from the other channel.

Users may manage email and SMS marketing consents separately.

After unsubscribing from marketing, users may still receive transactional or service communications necessary in connection with their user account, subscription, purchase, payment, security or another requested service.

28. Minors

Lustiq Lab, the Lustiq App and related sexual education services are primarily intended for an adult audience.

Access to features, content or services intended exclusively for adults may be restricted.

Where we become aware that we are processing a minor's personal data without an appropriate legal basis, we will take the necessary steps to delete the data or restrict its processing.

29. Complaints and legal remedies

For questions or complaints relating to data processing, you may first contact us at:

hello@lustiqlab.com

You also have the right to lodge a complaint with the supervisory authority.

Hungarian National Authority for Data Protection and Freedom of Information

Address:
1055 Budapest, Falk Miksa utca 9–11., Hungary

Postal address:
1363 Budapest, Pf. 9., Hungary

Email:
ugyfelszolgalat@naih.hu

Phone:
+36 1 391 1400

In addition to lodging a complaint with the supervisory authority, you may seek judicial remedy in accordance with applicable law.

30. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time due to legal, technological, service related or business changes.

The version currently in force is available on lustiqlab.hu.

The Privacy Policy states its effective date.

Where an amendment materially changes the purpose or scope of previously given consent, amendment of the Privacy Policy alone does not automatically extend the scope of that consent.

Where required, new consent will be obtained.