PRIVACY POLICY

PRIVACY POLICY

Last updated: August 30, 2026

This Privacy Policy describes how NOVARO ECOMMERCE LTD, operating as Lunero ("Lunero", "we", "us", or "our"), collects, uses, stores, and shares personal data when you visit our website, purchase products from us, contact us, or otherwise use our services.

The data controller is:

NOVARO ECOMMERCE LTD
Company Number: 16419911
PO Box 4385
16419911 – Companies House Default Address
Cardiff
CF14 8LH
United Kingdom



1. PERSONAL DATA WE COLLECT

We may collect the following personal data:

• name;
• email address;
• phone number;
• billing address;
• shipping address;
• order and purchase information;
• payment and payment status information;
• your communications with customer service;
• IP address;
• device and browser type;
• website usage information;
• cookies and other electronic identifiers;
• marketing and communication preferences;
• information you voluntarily provide to us.

We generally do not store full credit card information. Such information is processed by authorized payment service providers.


2. HOW WE COLLECT INFORMATION

We collect information, among other times, when you:

• place an order;
• subscribe to a mailing list;
• create an account, if such an option is available;
• contact customer service;
• participate in a promotion or offer;
• use or browse the website.

We may also receive information from our service providers, such as payment service providers, delivery services, technical providers, and marketing services.


3. PURPOSE OF PROCESSING

We use your personal data, among other purposes, to:

• receive and process orders;
• execute and confirm payments;
• ship and deliver products;
• send confirmations and order information;
• provide customer service;
• process returns, refunds, and complaints;
• prevent fraud and unauthorized transactions;
• maintain website security;
• fulfill accounting, tax, and legal obligations;
• improve our products and services;
• analyze website usage;
• send marketing communications when we have permission to do so;
• display or measure advertisements when valid authorization or consent is in place.


4. LEGAL BASIS FOR PROCESSING

We only process personal data when we have a legal basis to do so.

Processing may be based on, among other things:

• contract performance – to process your order and deliver products;
• legal obligation – for example, due to accounting and tax liabilities;
• legitimate interests – for example, for service, security, and fraud prevention;
• consent – for example, for marketing, analytics, or certain cookies when consent is required.

When processing is based on consent, you can withdraw your consent at any time.


5. PAYMENTS

Payments are processed through payment service providers who may process information necessary to:

• confirm payment;
• execute payment;
• prevent fraud;
• fulfill legal obligations.

We generally do not have access to your full card information.


6. SERVICE PROVIDERS

We may share personal data with trusted service providers when it is necessary for the operation of the business.

These may include, among others:

• web store operators;
• payment services;
• shipping and delivery companies;
• warehouses and fulfillment providers;
• customer service;
• email and communication services;
• hosting and IT services;
• analytics services;
• advertising and marketing services;
• auditors;
• lawyers and other professional advisors.

These parties may only process the information in accordance with the law and as necessary for the respective service.


7. COOKIES

We use cookies and similar technologies to operate the website.

Necessary cookies enable, among other things, to:

• manage the shopping cart;
• remember settings;
• execute payment;
• protect the website from misuse.

With your consent, where consent is required, we may also use cookies for:

• web analytics;
• measurement;
• marketing;
• remarketing;
• social media;
• personalized advertising.

You can change your choices in the website's cookie settings.


8. MARKETING COMMUNICATIONS

If you consent to marketing communications, we may send you information about Lunero, offers, new products, and other promotional material.

You can unsubscribe at any time via an unsubscribe link in an email or by contacting us at:

[EMAIL ADDRESS]

Unsubscribing from marketing messages does not affect necessary communications regarding orders, payments, or deliveries.


9. DISCLOSURE OF PERSONAL DATA

We do not sell your personal data for direct payment.

We may disclose information to service providers when it is necessary due to:

• website operation;
• payment;
• delivery;
• customer service;
• analytics;
• marketing;
• fraud prevention;
• legal obligations.

We may also provide information when required by law or legitimate government request.


10. INTERNATIONAL TRANSFER OF PERSONAL DATA

NOVARO ECOMMERCE LTD is registered in the United Kingdom.

Some of our service providers may be located outside of Iceland or the European Economic Area (EEA).

When personal data is transferred to a country where adequate data protection has not been recognized, we take appropriate measures under applicable data protection laws, such as through standard contractual clauses or other recognized transfer mechanisms.


11. DATA RETENTION

We retain personal data only as long as necessary for the purpose for which it was collected.

This may include, among other things, to:

• process orders;
• maintain transaction history;
• provide services;
• fulfill accounting and tax obligations;
• prevent fraud;
• resolve disputes;
• defend our legal rights.

When the information is no longer necessary, it is deleted or anonymized, unless otherwise required by law.


12. SECURITY

We use appropriate technical and organizational measures to protect personal data against:

• unauthorized access;
• misuse;
• alteration;
• disclosure;
• loss or destruction.

However, no electronic storage or transmission method is entirely risk-free.


13. YOUR RIGHTS

According to applicable data protection laws, you may, as applicable, have the right to:

• receive information about the processing of your personal data;
• access your information;
• have incorrect information corrected;
• request deletion of information;
• request restriction of processing;
• object to specific processing;
• receive your personal data in a portable format where applicable;
• withdraw consent;
• object to direct marketing;
• lodge a complaint with a competent data protection authority.

To exercise your rights, please contact:

[EMAIL ADDRESS]

We may need to verify your identity before processing a request.


14. DATA PROTECTION IN ICELAND

If you are in Iceland, you may also lodge a complaint with Persónuvernd (the Icelandic Data Protection Authority) if you believe that your personal data has been processed in violation of applicable data protection laws.


15. CHILDREN

Lunero's products and services are not intended for children.

We do not knowingly collect personal data from children in violation of applicable laws.

If you believe that a child has provided us with personal data without proper authorization, please contact us.


16. CHANGES TO THE POLICY

We may update this Privacy Policy due to changes in our operations, technology, or legal requirements.

The latest version of the policy will be published on the website.


17. CONTACT

If you have any questions about this Privacy Policy or the processing of personal data, please contact:

NOVARO ECOMMERCE LTD
Company Number: 16419911
PO Box 4385
16419911 – Companies House Default Address
Cardiff
CF14 8LH
United Kingdom