v.1 – May 2023

thelumiclub.com/uk Privacy Policy is deemed to demonstrate that our visitors’, partners’ and customers’ (collectively “you” or “your”) privacy is one of thelumiclub.com/uk’s cardinal objectives, especially when using any thelumiclub.com/uk services or accessing this website. thelumiclub.com/uk is owned by Kylmäkorpi sp. z o.o., registered at ul. Bałtycka 6, 61-013 Poznań, Poland, registration number: 7831857847.  It sets forth the manner and legal commitments which any of the worldwide thelumiclub.com/uk entities agrees to maintain in collecting, processing and (where applicable) disclosing information about users of this website. By using the thelumiclub.com/uk website, our products and/or services you agree to the practices described in this Privacy Policy.

Collection of Information

thelumiclub.com/uk gathers information in most of its interactions with you, whether directly or indirectly. Although some of the information may be considered as “Personal Data”, most of the gathered information is not Personal Data. Personal Data is defined as information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context.

thelumiclub.com/uk has taken extensive safety and operational precautions, including administrative, physical and technical safeguards to protect personal information. Furthermore, thelumiclub.com/uk deploys reasonable safeguards across the company databases to prevent unauthorised access, disclosure or loss of personal information.

Where information is provided to thelumiclub.com/uk for the purpose of the establishment of a contractual relationship, thelumiclub.com/uk processes your data on the basis of Article 6 I b) GDPR. In all other cases, your data is processed on the basis of and in accordance with your explicit consent as required by Article 6 I a) GDPR.

Information received from you directly

thelumiclub.com/uk. collects and stores information during the registration of products, the creation of online profiles, the application via our website and any contact for support or other matters (e.g. contact or comment forms, telephone contact). Examples of information transmitted by you:

• Name, address, phone number, email address
• IP addresses
• Billing and other purchasing and shipping information;
• Records of transactions, including purchases, inquiries and service requests;
• Authentication data such as user name and password to verify access.

thelumiclub.com/uk does not collect or process any credit card data during purchases. Any credit card purchase is made through our reliable and secure online payment processor PauU S.A., with the result that thelumiclub.com/uk is never furnished with your sensitive credit card information;

In order to provide its services, its websites or fulfil its contractual obligations to you, 

thelumiclub.com/uk may be required to forward data which may include some of your personal information to third parties. In order to follow the requirements of data minimization, the data so transferred is reduced to the necessary minimum. Those subcontractors are required to adhere to a data processing agreement with thelumiclub.com/uk under which they are committed to process data solely in accordance with the applicable laws (including the GDPR and other national privacy laws). This processing includes a required screening of your provided data against international export and economic sanctions lists bythelumiclub.com/uk. A negative (no match) screening result is a mandatory requirement for thelumiclub.com/uk to communicate with, deal with, do business with or provide any form of services to you.

thelumiclub.com/uk has an extensive data protection policy in place across its organisation, which every thelumiclub.com/uk employee or contractor must adhere to at all times. Such data protection policy sets forth the mandatory way information is expected to be handled within thelumiclub.com/uk and describes the necessary internal processes and the required level of confidentiality to be maintained in order to be compliant with national and international data protection laws (like e.g. GDPR).

thelumiclub.com/uk strives to comply with the concept of data minimization (“privacy by default”) by only collecting as much information as needed for the intended and approved purpose. Only information which is relevant to such a purpose and which has been provided to thelumiclub.com/uk in free and informed manner by you as the data subject will be processed by thelumiclub.com/uk for as long as needed for the purpose. Thereafter, any Personal Data is subject to a defined deletion routine as defined in thelumiclub.com/uk’s record of processing activities created and maintained in accordance to Article 30 of the GDPR.

Information Collected Automatically

thelumiclub.com/uk may automatically collect and store information about how users utilise the thelumiclub.com/uk website(s) and applications. This may include anonymized IP addresses of website visitors, browser type and other information such as search terms, which helps us to improve our services and our website to provide you with the best possible services and user experience. Any collected data which may be considered as Personal Data is subject to immediate anonymization upon its collection with the result that the automatically-collected data will not allow thelumiclub.com/uk or any other party to identify you.

Data Protection for Minors

The thelumiclub.com/uk website as well as its contents, services and offers are not directed at children or minors. Accordingly, thelumiclub.com/uk does not want and does not assume that any information collected on the thelumiclub.com/uk website or any forum will be personal data pertaining to children or minors. Any data which is identified as belonging to a child or minor is subject to immediate deletion.

Is my data secure at thelumiclub.com/uk ?

thelumiclub.com/uk has implemented appropriate technical and organisational measures related to the respective processing purpose in order to protect the Personal Data provided by you against abuse and loss. Personal Data and other information about you are stored in a secure operating environment that is not accessible to the public.

Any data transmission performed by thelumiclub.com/uk  is encrypted during transmission via SSL.

In addition, each of thelumiclub.com/uk’s employees is contractually bound by comprehensive confidentiality and non-disclosure terms and is further required to abide by the thelumiclub.com/uk data protection policy at all times.

What are my rights?

You have the following rights in respect to the Personal Data you provide to thelumiclub.com/uk:

• You may at any time request thelumiclub.com/uk to delete the data you provided or withdraw any data processing consent you provided to thelumiclub.com/uk by contacting support@kylmakorpi.com.
• You may further limit the scope of processing to certain processing activities or request a correction of your data.
• You have the right to be informed about where, for which purpose and for how long which data is collected by thelumiclub.com/uk. You may at all times request to receive such information in a structured, commonly-used and machine-readable format to transfer your data to another data controller.
• In the unlikely case that thelumiclub.com/uk may, in your reasonable discretion, not comply with the applicable data protection law, you have the right to file a complaint directed at the competent regulatory authority.

thelumiclub.com/uk may ask you to provide a proper identification of yourself before performing any Personal Data-related action to avoid misuse.

Is my data shared with third parties?

In order for thelumiclub.com/uk to execute its business processes in a convenient and optimal manner, it may be necessary for certain data to be processed by trusted 3rd parties and reliable partners. These 3rd parties may

• process payments
• fulfil orders
• verify your age
• send email
• manage communication (e.g. newsletters, security notifications, chat)
• website hosting
• conduct other related activities

on behalf of thelumiclub.com/uk. However, thelumiclub.com/uk only shares such information needed to serve the specific purpose for which the 3rdparties were engaged. thelumiclub.com/uk ensures that these 3rd parties are under similar obligations to maintain privacy and confidentiality as thelumiclub.com/uk’s own employees are and that they will handle your information in the way and to the extend as thelumiclub.com/uk itself is permitted to. thelumiclub.com/uk does not allow any 3rd party to use your information for any purposes for which the information was not collected. 

Does thelumiclub.com/uk sell my information ?

No – thelumiclub.com/uk does not sell your information to third parties for any commercial or non-commercial interest (a traditional “sale”). However, the term “sale” may in some jurisdictions also comprise providing data to third parties to process payment for services, and, if chosen by you, the provision of your personal information to entities, whose products thelumiclub.com/uk resells. If you opt out of the sale of your information by contacting support@thelumiclub.com/uk or clicking the link on the corresponding thelumiclub.com/uk website, thelumiclub.com/uk may be unable to provide services to you if your request not to sell information includes a prohibition on processing payments for the products you purchase in your jurisdiction.

How long will my data be stored?

thelumiclub.com/uk only maintains your Personal Data for as long as it is required for the intended and approved purpose. Data which is collected on basis of your explicit consent will be retained until such consent will be withdrawn or expires. Some data (e.g. billing related data) may be subject to statutory data retention obligations, which thelumiclub.com/uk adheres to. Product trial licenses are tied to email addresses. For fraud protection purposes, such addresses are subject to an extended retention term of up to 12 months after license expiration. As soon as your Personal Data is no longer needed to serve the purpose of its collection and no other retention policies apply, thelumiclub.com/uk has implemented revolving routines to delete your data. thelumiclub.com/uk employs data destruction techniques designed to completely destroy data and prevent any future recovery in all such routines.

Cookies and Other Technologies (incl. Third-Party Providers)

A cookie is a piece of data stored on your computer, tied to information about you. thelumiclub.com/uk may use all kinds of cookies. This may either include cookies which terminate and erase once you close your browser or log out or cookies stored on your computer for an extended timeframe. During your first visit on the thelumiclub.com/uk website, you will be asked to confirm the cookie categories you agree to be set (Cookie Bot). At the same time you will be provided with detailed information about the respective cookies. 

Links to 3rd Parties

This Privacy Policy applies only to thelumiclub.com/uk websites and not to websites owned by 3rd parties. The thelumiclub.com/uk website may contain links to websites of certain 3rdParties. Although thelumiclub.com/uk pays particular attention to the contents of linked websites and the quality of the links posted on its website, thelumiclub.com/uk neither has any influence on the contents of these 3rd parties’ websites, nor on the way, these 3rd parties treat personal information collected on their own websites.

Accordingly, thelumiclub.com/uk disclaims any responsibility and liability for actions of any 3rd parties or the observance of data protection regulations by 3rd parties, linked to from thelumiclub.com/uk’s websites. In the event you envisage any shortcomings or breaches of data protection regulations by one of the 3rd parties linked on the thelumiclub.com/uk website, please immediately contact  thelumiclub.com/uk per the address below to allow to thelumiclub.com/uk take the appropriate actions to stop this misbehavior.

Contact

If you have questions about this thelumiclub.com/uk Privacy Policy and the procedures in effect, please contact our Data Privacy Officer at support@thelumiclub.com/uk

Responsible data processor: Kylmäkorpi sp z o.o. Lobo Park, ul. Bałtycka 6, 61-013  Poznań, Poland.

Version: v.1 (issued 05.2023)

This policy is subject to periodic revisions and may be amended by thelumiclub.com/uk from time to time if necessary. thelumiclub.com/uk offers a service to inform you about changes to this policy via the appropriate communication channels directly.