VeluneCompany is operated by SICLOPAY LTD, which is responsible for determining the purposes and means of processing personal information under this policy.

Legal Name: SICLOPAY LTD

Trading Name: VeluneCompany

Business Address:

Spyrou Kyprianou Avenue 14, Office 1
3070 Lemesos, Cyprus

Official Website: velunecompany.com

Privacy Contact: support@velunecompany.com

Customer Support: support@velunecompany.com

For activities where Velune determines how and why personal information is processed, SICLOPAY LTD acts as the data controller.

Certain third-party service providers may act as independent controllers for their own processing activities, as explained in their respective privacy notices.

We may collect and process the following categories of personal information, depending on how you interact with our store.

Personal and Contact Information

• Full name.
• Email address.
• Telephone number.
• Billing and shipping addresses.
• Other contact information voluntarily provided.

Order and Purchase Information

• Products purchased or added to your shopping cart.
• Order numbers and transaction history.
• Shipping addresses and delivery preferences.
• Order status and tracking information.
• Returns, exchanges, refund requests, and warranty claims.

Payment Information

When you make a purchase, payment information is processed through the payment providers available at checkout.

This may include:

• Payment method and transaction amount.
• Payment confirmation and transaction identifiers.
• Billing information required to complete or verify the transaction.

Full payment card details are handled by authorised payment service providers rather than being collected and stored directly by Velune in its own customer-service records.

Payment processors may process additional information in accordance with their own privacy and security practices.

Customer Account Information

If you create a customer account, we may process:

• Account identification details.
• Login and authentication information.
• Saved addresses and preferences.
• Order history and account activity.

Authentication information may be managed through our ecommerce platform or its designated authentication services.

Communications and Customer Support

We may collect information you provide when you:

• Contact our customer care team.
• Submit a return or warranty request.
• Leave a product review.
• Participate in surveys.
• Respond to promotional communications.
• Submit feedback or other enquiries.

This may include the contents of your messages and supporting documents or images voluntarily provided.

Device and Website Usage Information

When you browse our website, certain technical information may be collected automatically, including:

• IP address.
• Device type and operating system.
• Browser type and version.
• Referring pages and traffic sources.
• Pages viewed and browsing activity.
• Approximate location inferred from technical information.
• Shopping cart interactions and website performance data.

Cookies and Similar Technologies

We may use cookies, pixels, tags, and similar technologies to operate our website, remember preferences, measure performance, and support advertising activities.

Further details are provided in the Cookies and Tracking Technologies section.

We do not intentionally request sensitive personal information, such as health information, religious beliefs, political opinions, or other special categories of data, unless a specific lawful purpose requires it.

Please avoid sharing unnecessary sensitive information when contacting our support team.

We collect personal information through several methods.

Information You Provide Directly

We receive information when you:

• Place an order.
• Create or manage an account.
• Complete a checkout form.
• Subscribe to marketing communications.
• Contact customer support.
• Submit a product review or enquiry.
• Request a return, refund, or warranty service.

Information Collected Automatically

Certain device and usage information may be collected automatically when you visit or interact with our website.

This may occur through essential website functions, analytics tools, cookies, or advertising technologies, subject to applicable consent requirements.

Information Received from Third Parties

We may receive relevant information from:

• Payment service providers.
• Shipping carriers and fulfilment partners.
• Ecommerce technology providers.
• Fraud prevention and security services.
• Analytics and advertising partners, where permitted.
• Customer communication and support services.

Information obtained from third parties will be processed for appropriate purposes and in accordance with applicable data protection laws.

We process personal information only where an appropriate legal basis applies.

Where the EU GDPR or UK GDPR applies, our principal purposes and legal bases include the following.

Processing and Fulfilling Orders

We use your information to:

• Verify and process purchases.
• Arrange payment processing.
• Prepare and dispatch orders.
• Provide delivery and tracking updates.
• Manage returns, refunds, and exchanges.

Legal basis: Performance of a contract.

Providing Customer Support

We use personal information to respond to enquiries, resolve order-related issues, provide product assistance, and handle warranty claims.

Legal basis: Performance of a contract and legitimate interests in providing customer service, depending on the circumstances.

Managing Customer Accounts

We process account information to provide access to account features, order history, saved preferences, and customer services.

Legal basis: Performance of a contract.

Preventing Fraud and Maintaining Security

We may process transaction information, device data, and other relevant details to:

• Identify potentially fraudulent activity.
• Protect customer accounts.
• Prevent unauthorised transactions.
• Maintain website security.
• Investigate suspicious activity.

Legal basis: Legitimate interests in protecting our customers and business, and compliance with legal obligations where applicable.

Marketing and Promotional Communications

Where permitted by applicable law, we may use your contact information to send:

• Product announcements.
• Promotional offers.
• Newsletters.
• Information about new collections.
• Relevant updates about Velune.

Legal basis: Consent where required, or legitimate interests where permitted by applicable direct marketing laws.

You may unsubscribe from marketing emails at any time using the unsubscribe link or by contacting us.

Website Analytics and Improvement

We may analyse website performance and customer interactions to:

• Improve website functionality.
• Understand customer preferences.
• Identify technical problems.
• Improve product presentation.
• Evaluate marketing performance.
• Enhance the overall shopping experience.

Legal basis: Legitimate interests where appropriate, and consent where required for non-essential cookies or similar tracking technologies.

Legal and Regulatory Compliance

We may retain and process information to meet applicable obligations relating to accounting, taxation, consumer protection, legal claims, and regulatory requirements.

Legal basis: Compliance with a legal obligation.

Where we rely on legitimate interests, we consider the impact of the processing on individuals and their rights.

You may have the right to object to certain processing activities, as explained below.

Velune operates an international ecommerce business and may use external suppliers, fulfilment centres, and shipping partners to process and deliver orders.

Depending on the product and destination, your order may be prepared or shipped directly by a fulfilment partner.

We disclose personal information to third parties where necessary for legitimate business purposes, contractual performance, or compliance with legal requirements.

Payment Service Providers

Payment processors receive the information required to authorise payments, process transactions, manage refunds, and help prevent fraud.

Shipping and Logistics Partners

We may share your name, delivery address, relevant contact details, and order information with shipping carriers and logistics providers.

Where necessary, limited information may also be disclosed to customs authorities.

Suppliers and Fulfilment Partners

Suppliers and fulfilment partners may receive information necessary to prepare, package, dispatch, or manage your order.

This may include your name, delivery address, purchased products, and relevant shipping instructions.

Ecommerce and Technology Providers

Our online store operates using Shopify.

Ecommerce platform providers and other technology services may process information necessary to operate our website, manage customer accounts, support checkout, and maintain store functionality.

Their processing activities may also be subject to their own privacy terms.

Analytics Providers

Analytics tools may process information about website visits, interactions, and performance to help us understand and improve our services.

Advertising and Marketing Partners

Where permitted by applicable law and your privacy choices, advertising and marketing providers may process certain identifiers, website interactions, or conversion information to help deliver and measure advertising campaigns.

Some advertising technologies may involve tracking across websites or services.

These activities are subject to applicable privacy and consent requirements.

Professional Advisers and Public Authorities

We may disclose relevant information to legal advisers, accountants, auditors, regulators, or public authorities when reasonably necessary or legally required.

Business Transfers

If Velune or its operating company undergoes a merger, acquisition, restructuring, or transfer of business assets, relevant personal information may be transferred as part of that process, subject to applicable privacy laws.

We do not sell personal information in exchange for money as part of our ordinary ecommerce operations.

However, certain advertising-related disclosures may be legally classified as a sale or sharing of personal information in some jurisdictions, even when no monetary payment is involved.

Where such laws apply, we will provide the relevant disclosures and choices required by law.

Because Velune works with ecommerce technology providers, suppliers, payment processors, and logistics partners in different countries, personal information may be accessed, transferred, or processed outside your country of residence.

This may include countries outside the European Economic Area or the United Kingdom.

Data protection laws in those countries may differ from those applicable in your country.

Where the GDPR, UK GDPR, or other relevant legislation requires safeguards for an international transfer, appropriate legal transfer mechanisms must be used.

Depending on the circumstances, these may include:

• Adequacy decisions or regulations recognising an appropriate level of data protection.
• European Commission Standard Contractual Clauses.
• The UK International Data Transfer Agreement or applicable UK Addendum.
• Other legally recognised transfer mechanisms or exceptions.

The mechanism used will depend on the relevant service provider, destination, and circumstances of the transfer.

You may contact support@velunecompany.com for further information about applicable international transfer safeguards or to request information about obtaining a copy where legally available.

Velune uses cookies and similar technologies to support essential website functions, improve performance, and, where permitted, measure marketing effectiveness.

Cookies are small data files stored on your device when you visit a website.

We may use the following categories of cookies and tracking technologies.

Strictly Necessary Cookies

These technologies support essential website functions, such as:

• Shopping cart operation.
• Checkout functionality.
• Session management.
• Website security.
• Authentication.
• Remembering privacy preferences.

Strictly necessary cookies are generally required for the operation of essential services.

Analytics and Performance Cookies

These technologies may help us understand:

• How visitors interact with our website.
• Which pages are visited.
• How customers navigate our store.
• Website performance and technical issues.
• How our services can be improved.

Where applicable law requires consent, non-essential analytics technologies will be used only after valid consent has been obtained.

Advertising and Marketing Cookies

Advertising technologies may help us:

• Measure advertising performance.
• Understand campaign conversions.
• Evaluate marketing effectiveness.
• Display more relevant advertisements.
• Measure interactions with advertisements and products.

Depending on the services enabled, these technologies may involve third-party cookies, pixels, or similar identifiers.

Where consent is legally required, optional advertising technologies will be subject to the customer's consent preferences.

Managing Your Cookie Preferences

Where available, you may manage optional cookie categories through our website's cookie consent settings.

You can also manage or delete cookies through your browser settings.

Disabling certain cookies may affect optional functionality or your browsing experience.

Where applicable law requires consent, refusing optional cookies will not prevent access to the essential functions of our online store.

For additional information, please review our Cookie Policy.

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including contractual obligations, customer service, fraud prevention, and legal requirements.

Retention periods depend on the category of information and the relevant purpose.

Order and Transaction Information

Purchase and transaction records may be retained for the period necessary to process orders, manage customer claims, and comply with applicable accounting, tax, and legal obligations.

Customer Account Information

Account information may be retained while an account remains active and for an additional period where necessary for legitimate purposes or legal compliance.

Marketing Information

Marketing contact details may be retained until you unsubscribe, withdraw consent, or otherwise exercise applicable privacy rights.

Limited information may be retained afterwards where necessary to record and respect your communication preferences.

Customer Support Communications

Support requests and related correspondence may be retained for the period necessary to resolve enquiries, manage disputes, and maintain appropriate business records.

Analytics and Technical Information

Retention periods for technical identifiers and analytics information depend on the relevant service, its configuration, and applicable legal requirements.

When personal information is no longer required, we take appropriate steps to delete, anonymise, or otherwise securely manage it.

We take the security of personal information seriously.

We use appropriate technical and organisational security measures designed to reduce the risk of unauthorised access, disclosure, alteration, loss, or misuse.

Depending on the systems and services involved, these measures may include:

• Secure payment processing through specialised providers.
• Encryption during data transmission.
• Access controls and authentication measures.
• Restricted access to customer information.
• Security features provided by our ecommerce platform.
• Appropriate procedures for handling security incidents.

We also expect service providers processing information on our behalf to comply with applicable data protection and security obligations.

Although we take reasonable precautions, no method of internet transmission or electronic storage can be guaranteed to be completely secure.

If a personal data breach occurs, we will assess and address it in accordance with applicable legal requirements, including notification obligations where necessary.

Our online store is intended for adult customers and is not directed towards children.

We do not knowingly seek to collect personal information from children in circumstances prohibited by applicable law.

If we become aware that personal information has been collected from a child without the required lawful basis or parental authorisation, we will take appropriate steps to address the situation.

If you believe that a child has provided personal information through our website, please contact support@velunecompany.com.

Depending on your country of residence and the applicable data protection legislation, you may have some or all of the following rights.

Right of Access

You may request information about the personal data we hold about you and, where applicable, obtain a copy.

Right to Rectification

You may request correction of inaccurate personal information or completion of incomplete information.

Right to Erasure

You may request deletion of personal information in circumstances where applicable law provides this right.

Certain information may need to be retained to comply with legal obligations or establish, exercise, or defend legal claims.

Right to Restrict Processing

You may request that we restrict certain processing activities where the legal conditions are met.

Right to Data Portability

Where applicable, you may request certain personal information in a structured, commonly used, machine-readable format or ask for it to be transmitted to another controller where technically feasible.

Right to Object

You may object to certain processing activities based on legitimate interests.

You may also object to the processing of your personal information for direct marketing purposes.

Right to Withdraw Consent

Where processing is based on consent, you may withdraw that consent at any time.

Withdrawal does not affect the lawfulness of processing performed before consent was withdrawn.

Right to Lodge a Complaint

You may have the right to lodge a complaint with the relevant data protection supervisory authority.

How to Exercise Your Rights

To submit a privacy-related request, email:

support@velunecompany.com

Please provide sufficient information to help us identify the relevant records and understand your request.

We may request reasonable additional information to verify your identity before disclosing, modifying, or deleting personal data.

We will respond within the deadlines required by applicable law.

You can also unsubscribe from marketing emails using the unsubscribe link included in eligible promotional messages.

Customers in the European Union and European Economic Area may benefit from the rights and protections established by the General Data Protection Regulation (GDPR).

Customers in the United Kingdom may benefit from protections under the UK GDPR and relevant UK data protection legislation.

Customers in Switzerland may benefit from rights under the Swiss Federal Act on Data Protection and other applicable laws.

Depending on the applicable framework, these rights may include:

• Access to personal information.
• Correction of inaccurate information.
• Erasure where legally available.
• Restriction of certain processing activities.
• Data portability where applicable.
• Objection to processing based on legitimate interests.
• Objection to direct marketing.
• Withdrawal of consent.
• Protection in relation to qualifying solely automated decisions.
• The right to complain to an appropriate supervisory authority.

Automated Decision-Making

Certain service providers may use automated systems to assist with fraud prevention, payment verification, security, or other operational functions.

Where automated processing results in decisions that have legal or similarly significant effects on individuals, applicable data protection requirements and safeguards will be respected.

Response Times

For requests subject to the EU GDPR or UK GDPR, we will generally respond within one month of receiving a valid request, subject to applicable rules regarding verification, extensions, and other relevant circumstances.

Most requests are handled without charge, although applicable law may permit a reasonable fee or refusal in limited circumstances.

Supervisory Authorities

Depending on your location, you may contact the relevant data protection authority.

For EU and EEA customers, this may be the supervisory authority in your country of residence, workplace, or where an alleged infringement occurred.

For customers in the United Kingdom, the relevant authority is the Information Commissioner's Office (ICO).

For customers in Switzerland, the relevant federal authority is the Federal Data Protection and Information Commissioner (FDPIC).

We encourage you to contact us first if you have concerns so that we have an opportunity to address them.

Where the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), applies to our processing activities, eligible California residents may have additional privacy rights.

These may include:

Right to Know

You may request information about the categories and specific pieces of personal information collected, the purposes for which it is used, its sources, and relevant disclosures to third parties.

Right to Delete

You may request deletion of eligible personal information, subject to applicable legal exceptions.

Right to Correct

You may request correction of inaccurate personal information maintained about you.

Right to Opt Out of Sale or Sharing

Where applicable, you may request that a covered business stop selling or sharing your personal information, including qualifying disclosures for cross-context behavioural advertising.

Although Velune does not sell personal information in exchange for money as part of its ordinary ecommerce operations, certain advertising-related disclosures may qualify as sharing under California law.

Applicable opt-out rights will be respected where the law requires them.

Right to Limit Certain Uses of Sensitive Information

Where applicable, you may have the right to limit specific uses or disclosures of sensitive personal information.

Right to Non-Discrimination

We will not unlawfully discriminate against eligible consumers for exercising their privacy rights.

Submitting a California Privacy Request

You may contact:

support@velunecompany.com

Where California law applies, any additional legally required opt-out methods and preference signals must also be honoured.

We may take reasonable steps to verify your identity or the authority of an authorised representative before fulfilling applicable requests.

Our website may contain links to websites, platforms, or services operated by third parties.

These external services may have privacy practices that differ from ours.

Velune does not control the privacy policies or data processing practices of independent third-party websites.

We recommend reviewing the privacy notices of any external services you choose to access.

This Privacy Policy applies to the personal information processed by Velune in connection with our store and services, except where another privacy notice expressly governs a specific processing activity.

We may update this Privacy Policy periodically to reflect changes in our business practices, technologies, service providers, or applicable legal requirements.

When changes are made, we will update the Last updated date at the top of this page.

Where required by applicable law, we will provide additional notice or obtain consent before implementing material changes to certain processing activities.

The most current version of this Privacy Policy will be available on velunecompany.com.

Changes to this policy do not remove any rights or protections provided by applicable data protection legislation.

We encourage customers to review this page periodically.

VELUNE · CUSTOMER CARE

Here when you need us.

If you have questions about this Privacy Policy, how we handle your information, or how to exercise your privacy rights, please contact us.

Business: VeluneCompany

Legal Entity: SICLOPAY LTD

Business Address:

Spyrou Kyprianou Avenue 14, Office 1
3070 Lemesos, Cyprus

Privacy and Data Protection Contact: support@velunecompany.com

Customer Support Email: support@velunecompany.com

Official Website: velunecompany.com

Email is our official channel for privacy-related enquiries and customer support.

We aim to respond to enquiries as promptly as possible and within the timeframes required by applicable law.

Thank you for trusting Velune.