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Newsletter and Giveaway Terms within the Privacy Policy

1. General Provisions

1.1. This privacy policy governs the collection, processing, and storage of personal data related to newsletter subscriptions and giveaways. The data controller is Perfect Cosmetics OÜ, registration code 12414646, address: Mõisatalli, Uugla village, Lääne-Nigula municipality, Läänemaa, 91013 (hereinafter referred to as the data controller).

1.2. A data subject, within the meaning of this privacy policy, is a customer or any other natural person whose personal data is processed by the data controller.

1.3. The data controller processes personal data lawfully, fairly, and securely, following all applicable data protection regulations.

2. Newsletter Subscription and Data Processing

2.1. Newsletter Subscription

• Subscribing to the newsletter is free and voluntary.
• You can subscribe to the newsletter:
  • When registering an account;
  • Through the designated webpage: https://www.luminordic.com/en/subscribe-to-newsletter/.
• Upon subscription, the customer provides their email address and, if necessary, their name.
• By subscribing, the customer consents to receive marketing materials, special offers, and news.
• Newsletters are sent via the Metrilo platform.

2.2. Data Processing and Retention

• Data provided for newsletter subscription is processed until the customer opts out.
• The customer cannot temporarily pause newsletter reception but can only fully unsubscribe.
• The data subject can unsubscribe at any time by:
  • Clicking the unsubscribe link in the footer of each email;
  • Writing to hei@luminordic.com;
  • Indicating their wish to unsubscribe via the e-store chat window.
• The data subject can update their information:
  • Under “Account” → “My Details” in the e-store;
  • By writing to hei@luminordic.com or using the e-store chat window.
• The data controller does not share newsletter-related data with third parties without the customer’s consent.

3. Giveaway Terms and Data Processing

3.1. Participation in Giveaways

• Giveaways take place within separate campaigns, with terms always specified in the campaign post (e.g., on social media or in a marketing email).
• The following personal data may be processed for giveaway participation:
  • Email address (for conducting the draw, notifying, and announcing the winner);
  • Name or social media username (for conducting the draw, notifying, and announcing the winner).

3.2. Winner Selection and Notification

• Winners are drawn randomly according to the specific campaign terms.
• The giveaway terms define who qualifies for the draw, for example:
  • “Leave your feedback to participate in the giveaway” – all who leave feedback during the campaign period are entered.
  • “Leave a comment and participate in the giveaway” – all who comment on the specified post are entered.
• Winners are drawn on the business day specified in the campaign terms.
• Winners are contacted via email or the relevant social media channel.
• If the winner does not respond within seven (7) days, a new winner is drawn.
• The winner’s name or social media username is published on LUMI’s social media channels (Instagram, Facebook).
• If the customer does not wish their name or username to be public, they can notify us at hei@luminordic.com, and the data will be removed.

3.3. Data Processing for Giveaway Purposes

• Lists of giveaway participants are not retained after the draw ends.
• Once the winner has confirmed their prize and received it, the data subject may request their data deletion by writing to hei@luminordic.com.

4. Legal Basis for Personal Data Processing

4.1. Sending marketing newsletters and conducting giveaways is based on the data subject’s consent.

4.2. To analyze campaign results and optimize marketing activities, data may also be processed based on the company’s legitimate interest, adhering to the principles of data minimization and privacy.

5. Data Subject Rights

5.1. The data subject has the right to:

• Obtain information about the processing of their personal data;
• Request correction or deletion of their personal data;
• Withdraw consent for receiving newsletters or participating in giveaways;
• File a complaint with the Data Protection Inspectorate (info@aki.ee) if they believe their personal data is not being processed in compliance with data protection requirements.

5.2. The data subject can exercise their rights by contacting us at hei@luminordic.com.

6. Use of Cookies and Tracking Technologies

6.1. The data controller does not use third-party tracking technologies (e.g., Google Analytics or Facebook Pixel) for newsletters or giveaways.

6.2. Newsletters are sent via the Metrilo platform (https://www.metrilo.com/), which does not collect additional personal data beyond the email address.

7. Final Provisions

7.1. The data controller may update this privacy policy to reflect changes in services or legislation.

7.2. The data controller has the right to partially or fully modify data protection terms by informing data subjects via the website (www.luminordic.com).