Naluxe Store Privacy Policy
Effective Date: February 11, 2025
Introduction and Overview
For Naluxe Store customers, this Privacy Policy explains how your personal information is collected, used, shared, processed, and protected when you access our website, our mobile application, or use other services provided by Naluxe Store. This includes any written, electronic, and oral communications, online or offline, and purchases you make. The Policy also outlines your rights regarding your personal data and explains how you can contact us to learn more about our data practices or to exercise your rights.
In the Netherlands, the Naluxe Store website and app are provided by Naluxe Store, which is responsible for collecting, processing, and protecting your personal data. In this Policy, the terms “Naluxe Store,” “Company,” “we,” “us,” and “our” refer to Naluxe Store.
Please read our Terms and Conditions and this Policy before accessing or using our Services. If you cannot agree with this Policy or the Terms and Conditions, please do not access or use our Services.
Policy Modification: Naluxe Store may change this Policy from time to time to reflect how we process your data. If we make changes, we will revise the effective date at the top of this Policy. If we make changes that materially affect your privacy rights, we will attempt to provide advanced notice (including via real- or near real-time disclosures) or otherwise via the Site, or by some other means of contact so that you have a reasonable opportunity to review the changes before you continue to use the Services.
If you do not agree with the modified Policy, please stop using the Services.
Contents
- What Personal Information Do We Collect?
- How Do We Use Personal Information?
- When Do We Share Personal Information?
- How Do We Use Cookies and Other Technologies?
- How Does Naluxe Store Secure Your Personal Information?
- What Are Your Privacy Rights and How to Exercise Them?
- Additional Privacy Matters
- Contact Us
1. What Personal Information Do We Collect?
Personal information is any information that is relatable to an identifiable person. The definition of personal information (used interchangeably in this Privacy Policy with the term “personal data”) depends on where you are located. Personal information does not include data that has been effectively anonymized or aggregated so that it can no longer enable us or others, whether in combination with other information or otherwise, to identify an individual.
We collect personal information from various places, including online, in-person, and from third parties, such as when you shop on our website, engage with us at a promotional event, or interact with us on a social media platform. We may obtain and combine personal information from different sources, technologies, and devices. Not all categories of personal information will be collected or received about every individual, depending on how you use or engage with the Services.
We generally collect the following categories of personal information from you when you use our Services:
Categories of Personal Information
- Basic Personal Identifiers, such as your name, address, email, and phone number.
- Source(s) of Information: Manually received directly from you. Basic Personal Identifiers can also be received from third parties, such as people who order products or services on your behalf or for you.
- Purpose(s) of Collection/Use: All purposes listed in the “How Do We Use Your Personal Information?” section below.
- Retention Criteria: Identifiers that are associated with an account will be retained for the life of the account, plus a reasonable period thereafter to satisfy legal obligations (e.g., financial reporting, warranty, etc.).
- Device/Online Identifiers, such as account login information, MAC address, IP address, cookie IDs, mobile ad IDs, and social media information.
- Source(s) of Information: Automatically received from you when you interact with the Services.
- Purpose(s) of Collection/Use: All purposes listed in the “How Do We Use Your Personal Information?” section below.
- Retention Criteria: Short-term retention; routinely disposed of when no longer reasonably necessary for a business purpose.
- Commercial Information, such as records of products or services purchased, obtained, or considered by you.
- Source(s) of Information: Manually received directly from you.
- Purpose(s) of Collection/Use: All purposes listed in the “How Do We Use Your Personal Information?” section below.
- Retention Criteria: Commercial Information associated with an account will be retained for the life of the account, plus a reasonable period thereafter to satisfy legal obligations (e.g., financial reporting, warranty, etc.).
- Network Activity, such as information regarding your browsing activity (e.g., length of visit, number of page views), click-stream data, your mobile carrier, date and time stamps associated with transactions, and system configuration information.
- Source(s) of Information: Automatically received from you when you interact with the Services.
- Purpose(s) of Collection/Use: All purposes listed in the “How Do We Use Your Personal Information?” section below.
- Retention Criteria: Short-term retention; routinely disposed of when no longer reasonably necessary for a business purpose.
- Communications, such as emails, virtual chat logs, text messages, or other exchanges where Naluxe Store is a party to the communications, including audio recordings where permitted by applicable law.
- Source(s) of Information: Manually received directly from you.
- Purpose(s) of Collection/Use: All purposes listed in the “How Do We Use Your Personal Information?” section below.
- Retention Criteria: Communications that are associated with an account will be retained for the life of the account, plus a reasonable period thereafter to satisfy legal obligations (e.g., financial reporting, warranty, etc.).
- Content you choose to upload to the Services, such as text, images, audio, and video, along with the metadata associated with the files you upload.
- Source(s) of Information: Manually received directly from you.
- Purpose(s) of Collection/Use: All purposes listed in the “How Do We Use Your Personal Information?” section below.
- Retention Criteria: Content that is associated with an account will be retained for the life of the account, plus a reasonable period thereafter to satisfy legal obligations (e.g., financial reporting, warranty, etc.).
- Payment Card and Financial Information, such as credit or debit card numbers, financial account numbers, or other financial data to process payments, refunds, or other financial transactions. This includes MTN MOMO and Orange Money details.
- Source(s) of Information: Manually received directly from you.
- Purpose(s) of Collection/Use: All purposes listed in the “How Do We Use Your Personal Information?” section below.
- Retention Criteria: Payment Card and Financial Information is collected and processed by third-party payment processors and therefore not retained by Naluxe Store. This information may be stored by payment processors for a period to satisfy legal obligations (e.g., financial reporting, warranty, etc.).
- Preferences, Behavior Data, and Inferences, such as your indicated body shape, height, chest/waist/hip circumference, and weight, as well as your preferences for clothing sizes or styles and personalization.
- Source(s) of Information: Preferences are manually received directly from you, though inferences may be collected automatically based on your interaction with the Services and subsequently created by us.
- Purpose(s) of Collection/Use: All purposes listed in the “How Do We Use Your Personal Information?” section below.
- Retention Criteria: Preferences, Behavior Data, and Inferences associated with an account will be retained for the life of the account, plus a reasonable period thereafter to satisfy legal obligations (e.g., financial reporting, warranty, etc.). However, this data may also be anonymized or aggregated, and such resulting data may be retained for analytic purposes.
- Content Posted Online. For influencers and similar persons that Naluxe Store considers for partnerships, we may collect or use any information posted or disclosed on publicly accessible third-party message boards, chat, profile pages, blogs, and other services, including through social media outlets, to assess such opportunities.
- Source(s) of Information: Content Posted Online may be obtained by Naluxe Store or third parties on our behalf.
- Purpose(s) of Collection/Use: All purposes listed in the “How Do We Use Your Personal Information?” section below.
- Retention Criteria: Content Posted Online collected for the purpose of assessing potential partnerships will be retained for the period necessary to evaluate the opportunity or potential future opportunities.
- Profiles or Enrichment Data from Commercial Data Brokers, such as profiling information regarding influencers and similar persons obtained from commercial data brokers and aggregators to supplement the information we collect, in order to assess partnership opportunities, inform marketing strategies, as well as information that assists us in preventing fraud or other illegal activities.
- Source(s) of Information: Profiles or Enrichment Data from Commercial Data Brokers may be obtained from third parties on our behalf.
- Purpose(s) of Collection/Use: All purposes listed in the “How Do We Use Your Personal Information?” section below.
- Retention Criteria: Profiles or Enrichment Data from Commercial Data Brokers will be retained for the period necessary to evaluate the opportunity or potential future opportunities and prevent fraudulent/illegal activities.
We do not knowingly collect protected classifications about our users, biometric information, or education-related information. When communicating with us by email or through forms on our Services, or when you publicly share content through our Services, we ask that you please do not send us any sensitive information pertaining to yourself or to others.
2. How Do We Use Personal Information?
We use your personal information for the purposes described in this Privacy Policy or otherwise disclosed to you, primarily relating to providing products and services to you and improving our Services. The purposes and types of information we process are listed in the chart below and should be understood to include uses of your personal data that are compatible with the purposes listed.
| Purpose | Personal Information We Process |
| To create an account with us, to manage your account, and to provide you with our Services | Account Creation – Basic Personal Identifiers and contact information (such as email address and password) to register with our Site or App; Profile data, including your style preference, if you voluntarily choose to provide it for personalization purposes. |
| To fulfill or process orders | Basic Personal Identifiers and contact information such as name, phone number, and shipping address, as well as financial information or payment account information (including MTN MOMO and Orange Money), for delivery, returns, refunds, sales tax determinations, and payment operations. Commercial Information, such as return and refund details, gift card number, and order history, in our Services, in order to fulfill basic functions, including processing your payment and return requests, and keeping you informed of the order status and shipping logistics. Location data (inferred from your IP address) to tailor your experience in terms of displaying the appropriate local website, language, or user experience. |
| To provide customer service and support | Your communication history with us via various channels, such as email, phone, social media, mail, instant chat, and our customer service platform, to respond to your requests, as well as to keep you updated about your account and the Services. |
| To provide product and seller feedback | Photographs, customer reviews, and other feedback you upload to our Services in accordance with our Terms and Conditions, to provide product advice and to allow you to voluntarily show other potential customers what items may look like when worn or to relate experiences with sellers on our Services. |
| To undertake marketing, advertising or other promotional activities | Basic Personal Identifiers and contact information, such as phone number and email address, for telemarketing and email marketing purposes. Non-directly identifiable device identifiers, operating system information, and cookie information, to direct and measure the effectiveness of the advertising we offer. Data about how you engage with our Services (such as browsing, adding to your shopping cart, saving items, placing an order, and returns) for market research, statistical analysis, and the display of personalized advertising based on your activity on our site and inferred interests. Basic Personal Identifiers and contact information, such as name, email address, and phone number, when you voluntarily enter a competition, market survey, event, or other marketing campaigns organized by us. Basic Personal Identifiers and contact information for third-party service providers to advertise our Services and/or products on our Site (see “Disclosure of Personal Information” below). |
| To improve our product or service, or for personalization | Device/Online Identifiers and Network Activity for fault analysis, troubleshooting, and system maintenance, as well as setting default options for you, such as language and currency. Preferences, Behavior Data, and Inferences, including collection of your “like” records and votes when prompted as to your preference between two items, used by us to recommend clothing sizes or styles, personalization, or to provide fit prediction services for you. Commercial Information to share within and across our corporate organization for our business administration and improvement needs. |
| To prevent and investigate fraud and other illegal activities | Device/Online Identifiers and Network Activity, such as browser type, device information, operating system, and account setting information are processed for fraud prevention and detection and credit risk reduction. Basic Personal Identifiers (e.g., log-in data) are used for risk control and fraud reporting. Billing address is processed to verify payment information. |
| To comply with legal or compliance requirements | Identity information, such as ID- or passport-related information, for customs clearance purposes. Commercial Information and certain identifying information to handle and resolve legal disputes, for regulatory investigations purposes, and to comply with lawful requests from a competent law enforcement agency or court. |
| Other Consent-Based Purposes | We may use your personal information for a new or secondary purpose if disclosed to you prior to you providing us your personal information or which is reasonably necessary to provide the Services or other related products and/or services requested, with your consent or upon your direction. |
Please note that we may disclose, without restriction, aggregated or anonymized information about the users of our Services, which is information that does not identify any specific individual.
3. When Do We Share Personal Data?
We may disclose and share your personal information with the parties as described below.
A. Within Our Corporate Organization. Naluxe Store is a corporate organization that has a network of legal entities, business processes, management structures, and technical systems. Where permitted by applicable law, we may share your personal information with our related group companies and, in some cases, other affiliates of our corporate group to provide you with Services, administer our business, provide you with a personalized user experience, or to take actions based on your orders, requests, or preferences.
B. Third-Party Sellers. When you order products from a third-party seller on our Services and the seller will ship the products to you directly, we may share your Basic Personal Identifiers (name, address, and telephone number) with them so that they may fulfill your order and provide your personal data to a shipping logistics provider in order to perform the contract and ship the products to you.
C. Service Providers. We may provide access to or share your personal information with the following types of third-party service providers as set out in the table below:
| Supplier/Service Provider/Processor | Services Offered |
| IT system and software service provider | Website hosting services (including cloud storage), mobile app or software optimization services, customer relationship management software, email service providers, or system maintenance services. |
| Payment service provider | Third-party payment processing services, including those for MTN MOMO and Orange Money. |
| Marketing and advertising services | Assistance in reaching potential new customers across multiple communications channels or sharing with affiliated companies that promote our products on their websites. |
| Order fulfillment service provider | Provision of logistics, warehousing, and distribution services, return and exchange services, and order status notification services for your purchased items. |
| Customer service provider | Assistance with customer services and support. |
| Fraud prevention and information security service provider | Identity verification, fraud prevention, or credit risk reduction services to protect our Site/App and our business. |
| Other Service providers selected by you | Other third parties, such as size recommendations and fit prediction services providers if you have chosen to help us provide you with product recommendations. |
All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, excluding aggregators and providers of the text message services.
We strive to ensure that our third-party service providers can only use your data for the purposes for which it was provided to them and to the extent necessary for such purposes, in accordance with our written instructions. For this purpose, third-party service providers are required to execute data protection agreements, limiting the purposes for which they can process Naluxe Store customer data and requiring them to implement reasonable and appropriate security measures to protect data.
D. To Maintain Legal and Regulatory Compliance. We have the right to disclose your personal information as required by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us. We also may disclose your information where we reasonably believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that disclosure will help us protect the rights, property, or safety of Naluxe Store or our customers.
E. Co-Branded Services and Features. Portions of our Services may be offered as part of co-branded services and features. We will share your personal information with our co-branded partners based on your voluntary use of or participation in a co-branded service or feature. The co-branded partners will be identified on the co-branded feature or service, along with an applicable co-branded partner’s privacy policy. Use of your personal information by a co-branded partner will be subject to a co-branded partner’s privacy policy. If you wish to opt-out of a co-branded partner’s future use of your personal information, you will need to contact the co-branded partner directly.
F. Consent. We may disclose your personal information for any purpose with your consent.
G. Corporate Transactions. We may disclose personal information—including account information, Wallet balance, or points information—to a buyer, prospective buyer, corporate affiliate, or other successors in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding in which personal information held by us about our Services users is among the assets transferred. You acknowledge and agree to our assignment or transfer of rights to your personal information.
Please note that we may disclose, without restriction, aggregated or anonymized information about the users of our Services, which is information that does not identify any specific individual.
4. How Do We Use Cookies and Other Technologies?
We may use cookies, tags, web pixels, and similar technologies to automatically collect information through our Services. Cookies or tags are bits of code that allow our technology partners to collect information that usually does not directly identify you. Information within this section describes our use of cookies and your ability to control the use of cookies.
A. Cookies. Cookies are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the Site’s or provider’s system to recognize your browser and remember certain information. In many cases, cookies are necessary for your web browser to interact with the Services, such as maintaining your logged-in session, storing items in your shopping cart, and providing fraud detection and security tools to protect your data. Generally, we use first-party and third-party cookies for the following purposes: to make our Services function properly; to provide a secure browsing experience during your use of our Services; to collect passive information about your use of our Services; to measure how you interact with our marketing campaigns; to help us improve our Services; and to remember your preferences for your convenience.
“First-party cookies” are cookies set by us on the Site. “Third-party cookies” are cookies set by other companies whose functionality is embedded into our site (for example, those set by Google).
We use the following types of cookies on our Services:
- Strictly Necessary Cookies. These cookies are essential because they enable you to use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work, and they cannot be disabled.
- Functional Cookies. We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name or preferences on our Services. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.
- Performance or Analytics Cookies. These cookies collect passive information about how you use our Services, including webpages you visit and links you click. We use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies as described below.
- Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases, selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to identify your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.
B. Your Choices. Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to delete cookies from your browser. You can exercise your preferences in relation to cookies on our Services by taking the steps outlined below.
- First-Party Cookies. You can use your browser to enable, disable or delete cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access secure areas of the Services. Also, if you disable cookies, other parts of the Services may not work properly. You can find more information about how to change your browser cookie settings at https://www.allaboutcookies.org.
- Third-Party Cookies. If you wish to opt-in or opt-out of third-party advertising networks and similar entities that use advertising cookies, please click the “Manage Cookies” link in our Site footer. For more information about third-party advertising networks and similar entities that use these technologies, please see https://www.aboutads.info/consumers. You may withdraw your consent or update your preferences at any time by clicking the “Manage Cookies” link within the Site footer or within the App menu.
- Mobile Applications. To opt-out of data collection for interest-based advertising across mobile applications by participating companies, download the Digital Advertising Alliance’s AppChoices mobile application opt-out offering here: https://youradchoices.com/appchoices.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences.
C. Web Pixels. To see how successful our marketing campaigns or other features of the Services are performing, we sometimes use conversion pixels, which fire a short line of code to tell us when you have clicked on a particular button or reached a particular page (e.g., a thank you page once you have completed the procedure for subscribing to one of our services or have completed one of our forms). We also use web pixels to analyze usage patterns on our Services. The use of a pixel allows us to record that a particular device, browser, or application has visited a particular webpage.
D. Analytics and Social Media Advertisements. We may use third-party service providers to analyze the use of our Services or serve interest-based advertisements on their platforms. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at: https://tools.google.com/dlpage/gaoptout. To modify your preferences or turn off personalization for ads served by Facebook, you can visit Facebook’s Ad Preferences in addition to the Your Choices section below. We may also show ads to audiences that share similar characteristics as you. To do so, a list of email addresses is irreversibly encrypted through hashing and uploaded or transmitted from our site, and the hashed data is compared against the third party’s own users, generating a “lookalike audience” of matching addresses and deleting the uploaded list. We do not have access to the identity of any person in the “lookalike” audience unless they choose to click on one of our advertisements.
E. JavaScript. Pages of our Site may also use JavaScript, which are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components; entity tags, which are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser to accelerate website performance; and HTML5 local storage, which allows data from websites to be stored or “cached” within your browser to store and retrieve data in HTML5 pages when the website is revisited.
F. Other Tracking Technologies. We may also use Tracking Technologies to collect “clickstream” data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Site, webpages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Site for the same purposes.
G. Do Not Track. Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. To the extent that uniform standards for “DNT” signals have not been adopted, our Services does not currently process or respond to “DNT” signals.
H. Location Information. You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings.
5. How Does Naluxe Store Secure Your Personal Information?
We maintain reasonable physical, electronic, and procedural safeguards designed to guard your personal data from unauthorized processing, use, or disclosure. Our security measures include industry-standard physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information. We also require our service providers to provide privacy and security controls to protect data shared with them in order to perform services.
The Internet is not an absolutely secure environment, and we cannot guarantee that your personal data will be secure. We therefore strongly recommend that you use a unique, complex password to help us ensure the security of your account. We also strongly recommend that you do not share your password with others or re-use passwords on our Services that you use on other sites or apps, as doing so increases the likelihood of your being the victim of a credential-stuffing attack or other malicious cyber behavior. If you feel that the security of your account or personal data has been compromised, please immediately contact us at our dedicated Privacy Center.
