Data Security

Policy for the Luxifer data collection script

1. Where is the script going to run?
   • It depends on how you install it, so you have control over this.
   • Generally, frameworks have a way to install the script on every page in the header section for convenience.
   • This means the script runs on the front-end in the browser of your end-clients.
   • If you’re using google tag manager or a similar solution, there should be a way to omit pages if necessary.
2. What is the script going to read?
   • Personally Identifiable Information (PII) outlined in our Privacy Policy under “Data of your end-users“
   • In depth information on this PII on Matomo official docs
   • Clicked Element information – tag type, attributes, classnames, timestamp, url it was clicked on, matomo visitorId that clicked on it.
     • In the case of a text box or a dropdown, it will NOT collect the content that the user entered.
3. What are the access rights needed for the script?
   • The script requires JavaScript to be executable on the end-client browser
   • The script requires the ability to communicate with our Azure server and Google Cloud Platform infrastructure via navigator.sendBeacon
   • The script requires the ability to download a script from JsDelivr (main script) and run third party scripts (Matomo tag manager)
   • The script requires access to read and write Matomo first party cookies. A full list is available here. Note: hsr & uid cookies are not used.
   • The script requires access to read and write Luxifer first party cookies. These can be seen in the Privacy Policy under “Data of your end-users“
4. Where is the script sending its gathered information (for the reports)?
   • Matomo information (PII) is sent to our Azure server where our Matomo instance is self-hosted.
   • Element information (also PII) is sent to a Google Cloud Platform endpoint which validates the data, and then sends it to an internal function that saves it in Firestore.
5. Who’s going to be using (and responsible) for the script?
   • Your developers are responsible for installing the script.
   • Luxifer developers are responsible for updating, maintaining and securing the script. 
   • One option is to have subresource integrity (sha384) for added security. This adds responsibility for the your developers to re-install the script to update. Updates to this script rare, but SRI adds a layer of security and prevents tampering.
   • The other option is to automatically pull the latest version of the script, but less recommended.
6. Who can modify the script?
   • The first part is the script we give you (Not recommended to modify)
     • This can be modified by the developer that installs it. 
     • Modifying it will change the percentage of customers tracked, the associated project and the main script that is loaded.
     • We do a redundant check for both the project id and the website the data was sent from. We drop the data in the case of a mismatch.
   • The second part is what is sent to you via JsDelivr (main script).
     • This can only be modified by Luxifer developers.
     • This is implemented with subresource integrity (sha384) to ensure it hasn’t been tampered with.
7. Is this script a read only or can it modify the website directly?
   • Outside of adding scripts to capture data or assist in capturing data, Luxifer does not modify your website.
   • The exception is A/B testing, which DOES modify your website directly.
   • A/B testing is optional and requires a different script to be installed.

Policy for use of AI/LLMs

1. Is the technology in use external or internal?
   • We fully manage and configure an Azure Cloud instance which is considered internal. We do not own the physical infrastructure.
   • The technology is hosted within our Azure Resource Group and contains:
     • The APIs built using Azure Functions.
     • The Azure OpenAI instances.
     • The Blob Storage for output files.
2. What are the hosting locations in regards to use of AI?
   • Our instance of Azure OpenAI is hosted in Sweden, and is physically located in Gävle and Sandviken.
   • The function endpoints are hosted in France, and is physically located in Paris.
   • The blob storage is hosted in France (general use) and Sweden (Personas).
   • You can access more information about the compliance and standards for data centers in France here, and in Sweden here.
3. Does Luxifer or OpenAI use any of your information for training their models?
   • Luxifer generates an in-house model based on PII solely to classify future traffic into your “Personas”. These are cohorts of your users used throughout Luxifer.
   • These personas are unique and exclusive to your project. The data is not used to train Luxifer models outside of this context, or interact with data of other projects.
   • The model is a file that can be loaded into the LLM and is not used outside of the context of generating & classifying personas. It is not used to interact with data of other projects, for training, or outside of this context.
   • OpenAI as a company does not have access to any of your data or our models and as such cannot use them.
   • Please see the full statement in regards to data privacy given by OpenAI.
4. Does OpenAI as a company have access to any data provided to Luxifer?
   • Since we use an internal model of Azure OpenAI, no data goes externally to the company OpenAI.
5. What data is stored by Luxifer in regards to AI/LLM use?
   • Logs for debugging, security & compliance.
   • Inputs including any PII are discarded after use.
   • General use data is used for Luxifer processes and unrelated to customer data.
   • Data stored for Personas (models) is aggregate data and is only used to classify future traffic of that project.
   • Data stored for Persona enrichment (business context) is aggregate data and is used to tailor personas to your website goals.
6. If a customer requests for data deletion, what is deleted?
   • The models generated for Personas.
   • Logs for debugging, security & compliance.
   • The persona data itself (name, picture, type, etc)
   • Data mapping visitors to personas. (Existing users will no longer be personas)

Cloud Hosting Geography

Provider	Usage	Location(s)
Firebase	Storage	Belgium (eur3)
Google Cloud Platform	Collection, processing	St. Ghislain, Belgium (europe-west1)
Microsoft Azure	Collection, processing, and storage	Gävle and Sandviken, Sweden
Microsoft OpenAI	Processing	Gävle and Sandviken, Sweden Paris, France

Changelog

Version	Changes
2025-09-02	Added HTML anchors and Geography section
2025-08-21	Added to AI policy #5 – saving of business context
2025-07-19	Initial version. Includes policies for data collection script and AI/LLM use.