Privacy Policy

Introduction

Welcome to Luminox's online store for the United States (the “Website”). This Privacy Policy (“Policy”) explains how information about you is collected and used by the Website, which is developed and operated by Lumondi, Inc. (“Lumondi”, “we”, “us”, “our”).

We are committed to complying with applicable data protection laws, including the California Privacy Rights Act (CPRA) and the Texas Data Privacy and Security Act (TDPSA).

The Website is not directed to users under the age of 18. We do not knowingly collect information or data from children under the age of 18.

This Policy may be amended from time to time. We will post any change to this Policy on our Website at a reasonable time in advance of the effective date of the change, and we will also make efforts to proactively notify you by email of the changes if we have your email address.

Contact us

If you have any questions, comments or concerns regarding this Policy or our processing of your personal information, please contact us at info@lumondi.com.

What we collect and why

Scenario	Purposes	Categories of information processed
When you register to the Website	Providing you with the functionality of the Website, contacting you regarding administrative issues related to the Websites, this Policy, our Terms of Website, support and maintenance.	Email address and full name.
Subscribing to our newsletter	Emailing you our periodic newsletter with news and offers.	Email address or mobile phone number.
When you upload or share user content through the Website	Processing your request to return merchandise. Social media publications.	"Return Merchandise Authorization" (RMA) process - image of the original receipt or your watch photo. Social Shop - images you provide when you tag us on social media.
When you place an order through the Website	Processing and fulfilling your order.	Mobile phone number, email address, your physical / mailing address, full name, financial or payment information.
When you contact us with an inquiry through our email, online contact form or via phone. When you provide us with your feedback and reviews.	Responding to your inquiry or feedback. Our business development.	Your Full name, your email address, the subject of your inquiry and the text of your message or content of your feedback. You may also optionally provide your order number.
Use of cookies on the Website	Facilitate a Website feature that the user specifically requested, analyze how visitors use the Website to evaluate and improve its performance, improve user experience on the Website, inform and serve personalized ads more relevant to user interests.	IP address from which you access the Website, time and date of access, type of device and browser used, language used, links clicked via a mouse or a touch screen, and actions taken while using the Website.
When you initiate a Return Merchandise Authorization (RMA) process or register for warranty	Process your RMA request or warranty registration.	Full name, your physical or mailing address, email address, mobile phone number. When you Register for warranty, you may also optionally provide details on other watch brands owned, your gender and your date of birth.

Please use discretion when providing user content that includes the personal information of you or others. YOU ARE RESPONSIBLE FOR PROTECTING THIRD PARTIES’ AND YOUR OWN PRIVACY WHEN SHARING USER CONTENT, AND FOR OBTAINING THE PRIOR CONSENT OF INDIVIDUALS’ WHOSE PERSONAL INFORMATION IS INCLUDED IN THE USER CONTENT YOU SHARE.

Methods and sources for collecting your personal information

We collect the personal information from several sources:

• Directly from you when you register to our Website, initiate an RMA process, register your product, place an order, or contact us by email, the online contact form or phone.
• We receive information about the sales made to data subject, through our affiliates and partners who sell our watches.
• Through the device you use to access our Website, including through third party cookies and analytics tools, such as Google Analytics, Facebook Ads, YouTube ads and other analytics services;

Sharing your personal information

We will not share your information with third parties, except in the events listed below or when you provide us with your explicit and informed consent.

Scenario	Purposes	Examples of third parties involved
We will share your information with our service providers who assist us with the internal operations of the Website. These companies are authorized to use your personal information in this context only as necessary to provide these services to us and not for their own promotional purposes	Operating the Website and our business.	Shopify, Subject to the following additional Policy: https://www.shopify.com/legal/privacy
We will share your user content with other users of the Website.	Providing the shared user content functionality of the Website, at your choice, and in according to your preference.	Other users of the Website
If you abused your rights to use the Website or violated any applicable law while doing business with us.	Responding to, handling, and mitigating suspected violations of law in connection with our business.	Competent authorities, legal counsels, and advisors.
If a judicial, governmental, or regulatory authority requires us to disclose your information.	Complying with a binding request from a competent authority.	Competent authorities.
If the operation of the Website or our business is organized within a different framework, or through another legal structure or entity.	Enabling a structural change in the operation of the Website and our business.	The target entity of the merger or acquisition, legal counsels, and advisors.
Use of cookies for targeted online ads, unless you opt out	Online advertising.	Facebook, Google Subject to the following additional Policies: https://www.facebook.com/privacy/policy/ https://policies.google.com/privacy

Data retention and security

We retain your information for as long as needed to operate the Website, and thereafter as needed for record-keeping matters.
We will retain your information for as long as needed to operate the Website. Thereafter, we will still retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish, and defend legal claims and enforce our agreements. The overall period of retention is approximately 7 years.

We implement measures to secure your information
We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information, such as secure socket layer technology (SSL) and an AES-256 encryption. However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, there is no guarantee that it will be immune from information security risks.

Additional information for individuals in California and Texas

If you are an individual residing in California or Texas, we provide you with the following information pursuant to the privacy law in California (CPRA) and Texas (TDPSA). This is also the information we have collected in the past 12 months.

Personal Information We Collect

Categories of personal information	Specific types of personal information collected	Source of Information
Identifiers	Real name, IP address, postal address, email address.	The consumer themselves. An acquaintance of the consumer (where a user provides content about another consumer).
Other personal information that identifies, relates to, describes, or is capable of being associated with, a particular individual	Telephone number, credit card number.	The consumer themselves. An acquaintance of the consumer (where a user provides content about another consumer).
Sensitive information (optional)	Sex, age.	The consumer themselves. An acquaintance of the consumer (where a user provides content about another consumer).
Consumer Commercial information	Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	The consumer themselves. An acquaintance of the consumer (where a user provides content about another consumer). Affiliates and partners.
Internet or other electronic network activity information	Internet or other electronic network activity information.	The consumer’s device.
Audio, electronic, visual, thermal, olfactory, or similar information	Photos and videos of receipts and watches as part of the RMA Process and photos that were tagged to us through social media.	The consumer themselves. An acquaintance of the consumer (where a user provides content about another consumer).

We only use your sensitive personal information for the limited purposes as authorized in the CPRA or TDPSA.

Business Purposes for Which the Personal Information is Used

The following are the business or commercial purposes for which we use each category of personal information. Details about the information we collect for each category are provided in the table above. More details about the business or commercial purposes are provided in the privacy policy’s section titled ‘What we collect and why‘.

Categories of personal information	Business Purposes for which the information is used
Identifiers	Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards. Helping to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for these purposes. Debugging to identify and repair errors that impair existing intended functionality. Maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business. Undertaking internal research for technological development and demonstration. Undertaking activities to verify or maintain the quality or safety of a service or device, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business. Sale of information to affiliates and partners.
Other personal information that identifies, relates to, describes, or is capable of being associated with, a particular individual
Consumer Commercial information
Internet or other electronic network activity information
Audio, electronic, visual, thermal, olfactory, or similar information
Internet or other electronic network activity information	All of the above Cross-context behavioral advertising
Inferences
Sensitive information (optional)	For the limited purposes as authorized in the CPRA or TDPSA.

Sharing, Selling and Disclosing to third parties

The chart below explains about the personal information we disclosed or sold in the preceding 12 months. It also explains about the personal information we shared for online behaviorally targeted ads in the preceding 12 months. Other than this, we have not disclosed your personal information for a business purpose in the preceding 12 months.

We do not have actual knowledge that we share the personal information of consumers under 16 years of age for online behaviorally targeted ads, or that we sell personal information of consumers under 16.

Categories of personal information	Categories of third parties to whom we disclose your information and the specific business or commercial purpose for the disclosure
Identifiers; Other personal information that identifies, relates to, describes, or is capable of being associated with, a particular individual Consumer Commercial information Internet or other electronic network activity information; Audio, electronic, visual, thermal, olfactory, or similar information Inferences	Competent authorities, legal counsels, and advisors if you abused your rights to use the Website or violated any applicable law in the course of doing business with us. Judicial, governmental, or regulatory authority if they require us to disclose your information. Target entity of the merger or acquisition, legal counsels, and advisors If the operation of the Website or our business is organized within a different framework, or through another legal structure or entity.
Internet or other electronic network activity information; Inferences	Sharing with advertising networks for online behaviourally targeted ads.
Consumer Commercial information; Identifiers	Sale to our affiliates and partners for their marketing purposes.

Your rights if you are a resident of California or Texas

Notice of the Right to Opt-Out Using the Opt-Out Preference Signal

You have a right to opt-out of sharing your personal information for behavioral targeted ads and selling your information to our affiliates and partners. You can exercise this right by using the opt-out preference signal as explained here.

We process the opt-out preference signal if it is sent by your browser in accordance with the "global privacy control". For more information on how to install and implement the global privacy control, please visit globalprivacycontrol.org/#download.

If you turn on this global privacy control in your browser, we will receive the signal, process it in a frictionless manner, and treat it as a request to opt-out of the use of your personal information for behavioral-targeted ads and to opt out of us selling your information to our affiliates and partners. The opt-out request is specific to the browser in which you have it turned on. It is effective as an opt-out request only while you use that browser to visit our Website.

Knowing the personal information we collect about you and to obtain the personal data in a readable format

You have the right to know:

• The categories of personal information we have collected about you.
• The categories of sources from which the personal information is collected.
• Our business or commercial purpose is for collecting personal information.
• The categories of third parties with whom we share personal information, if any.
• The specific pieces of personal information we have collected about you.

Right to delete personal data provided by or obtained about you

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

• Delete your personal information from our records; and
• Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us.
• Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
• Comply with the applicable privacy act.
• Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete such research, provided we have obtained your informed consent.
• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us and compatible with the context in which you provided the information.

or

• Comply with an existing legal obligation.

We also will deny your request to delete if it proves impossible or involves disproportionate effort, or if another exception to the CPRA or the TDPSA applies. We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to delete your information.

Right to correct inaccurate personal information, taking into account the nature of the data and the purposes for processing the data

If we receive a verifiable request from you to correct your information and we determine the accuracy of the corrected information you provide, we will correct inaccurate personal information that we maintain about you.

In determining the accuracy of the personal information that is the subject of your request to correct, we will consider the totality of the circumstances relating to the contested personal information.

We also may require that you provide documentation if we believe it is necessary to rebut our own documentation that the personal information is accurate.

We may deny your request to correct in the following cases:

• We have a good-faith, reasonable, and documented belief that your request to correct is fraudulent or abusive.
• We determine that the contested personal information is more likely than not accurate based on the totality of the circumstances.
• Conflict with federal or state law.
• Other exception to the CPRA or the TDPSA.
• Inadequacy in the required documentation
• Compliance proves impossible or involves disproportionate effort.

We will provide you a detailed explanation that includes enough facts to give you a meaningful understanding as to why we cannot comply with the request to correct your information

Protection against discrimination for exercising these rights

You have the right to not be discriminated by us for exercising the rights granted to you under applicable law. If you exercise your rights, we cannot:

• Deny you services.
• Charge different prices or fees for services, also through discounts, benefits, or fines.
• Provide you a different level or quality of services.
• Propose that you receive different prices or tariffs for services.

Please note that we may charge a different fee or provide a different level or quality of services, if the difference is reasonably related to the value we gain from your personal information.

Exercising your rights by yourself or through an authorized agent

If you would like to exercise any of your rights as described in this Policy, please contact us by e-mail at: info@lumondi.com.

We will ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data you requested, by using a two or three points of data verification process, depending on the type of information you require and the nature of your request.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal data requested to you, by using a two or three points of data verification process, depending on the type of information you require.

You may also designate an authorized agent to make a request on your behalf. To do so, you need to provide the authorized agent with written permission to do so and the agent will need to submit to us proof that they have been authorized by you. We will also require that you verify your own identity, as explained below.

Our response to your requests
We will respond to your requests within 45 days (or within 90 days, where the law permits and we determine it necessary considering the complexity and number of the requests you have filed). If we take longer than 45 days, we will inform you of the extension within the initial forty-five-day response period, together with the reason for the extension.
We may deny your request in the following cases:

• If we believe in good faith, based on reasons which are documented in writing, that your request is fraudulent or is an abuse of your rights under applicable law.
• If we conclude that the request is irrelevant, based on all the circumstances at issue (e.g., if you requested to correct your personal information, and we find that it is likely to be accurate).
• If it is contrary to federal or state law.
• Due to discrepancy in the required documentation.
• If the fulfilment of your request turns out to be impossible or involves disproportionate effort.

We will provide you with a detailed explanation including sufficient facts, to enable you to meaningfully understand why we cannot fulfil your request.

Do Not Track

Our Do Not Track Notice. We do not currently respond or take any action with respect to web browser “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Data about a User’s online activities over time and across third-party web sites or online services.