Privacy Policy

Last updated: July 17, 2026

1. Introduction

SBMF LTD, trading as Frilume (“Frilume,” “Company,” “We,” “Us,” or “Our”) respects Your privacy and is committed to protecting Your Personal Information.

This Privacy Policy explains how We collect, use, disclose, retain, transfer, and protect Personal Information when You:

• Visit or use frilume.com (the “Site”);

• Create or use a customer account;

• Purchase Our products;

• Contact Our customer-support team;

• Subscribe to email marketing;

• Submit a product review or other content; or

• Otherwise interact with Frilume.

For purposes of applicable data-protection law, SBMF LTD is generally the controller of the Personal Information described in this policy.

By using the Site or providing Personal Information to Us, You acknowledge that You have read and understood this Privacy Policy.

If You do not agree with Our practices, You should discontinue use of the Site and avoid providing Personal Information, except where necessary to exercise Your legal rights or contact Us.

This policy should be read together with Our:

• Terms of Service;

• Shipping Policy;

• Cancellation & Refund Policy;

• Payment Policy;

• Cookie consent and privacy-preference tools; and

• Any other notice displayed when Personal Information is collected.

2. Personal Information We Collect

In this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an identifiable individual or household.

Personal Information does not generally include information that has been lawfully anonymized or aggregated so that it can no longer reasonably identify an individual.

2.1 Information You Provide Directly

We may collect Personal Information that You provide when You:

• Place an order;

• Create or update a customer account;

• Contact customer support;

• Request a cancellation, return, replacement, or refund;

• Subscribe to marketing emails;

• Submit a product review, rating, photograph, or feedback;

• Participate in a promotion, survey, or contest;

• Exercise a privacy right; or

• Communicate with Us by email, telephone, form, or another channel.

This information may include:

• Full name;

• Email address;

• Telephone number;

• Billing address;

• Shipping address;

• Account information;

• Order number;

• Products ordered;

• Purchase history;

• Return and refund information;

• Customer-support communications;

• Marketing preferences;

• Review content;

• Photographs or videos submitted with a review or claim;

• Information used to verify identity or prevent fraud; and

• Any other information You voluntarily provide.

Please do not submit sensitive medical records, diagnoses, treatment information, financial account credentials, government identification numbers, or other unnecessary sensitive information through product reviews or ordinary customer-support communications.

2.2 Payment and Transaction Information

Payments are processed through Shopify and applicable third-party payment providers.

Depending on the payment method, We may receive limited payment-related information, including:

• Payment status;

• Transaction identifier;

• Payment method type;

• Card brand;

• The final digits of a payment card;

• Billing address;

• Fraud-screening results;

• Refund information; and

• Other transaction details needed to process or reconcile an order.

Frilume does not ordinarily receive or store Your complete payment-card number, card security code, digital-wallet credentials, or online-banking password through the standard checkout process.

Complete payment credentials are handled by the applicable payment processor, bank, card network, or digital-wallet provider under its own terms and privacy practices.

2.3 Customer Account Information

If You create a customer account, We or Shopify may collect:

• Your name;

• Email address;

• Telephone number;

• Shipping and billing addresses;

• Login and authentication information;

• Account preferences;

• Order history;

• Saved checkout information, where enabled; and

• Account activity.

You are responsible for maintaining the confidentiality and security of Your account credentials.

2.4 Product Reviews and User Content

If You submit a product review, rating, photograph, video, testimonial, question, or other content, We may collect and display:

• Your name, initials, username, or chosen display name;

• Rating;

• Review text;

• Uploaded photographs or videos;

• Product purchased;

• Verification that the review relates to a purchase;

• Date of submission; and

• Other information included in the submission.

Published reviews may be visible to the public.

Do not include information in a review that You do not want publicly displayed, including medical details, contact information, financial information, or information about another person.

We may moderate, reject, remove, or retain reviews in accordance with Our Terms of Service, legal obligations, and legitimate business interests.

2.5 Information Collected Automatically

When You visit or interact with the Site, We and Our service providers may automatically collect information through cookies, pixels, tags, local storage, server logs, software-development tools, and similar technologies.

This information may include:

Device and browser information

• Browser type and version;

• Operating system;

• Device type;

• Screen resolution;

• Language settings;

• Mobile or advertising identifiers;

• Unique device identifiers; and

• Browser configuration.

Network and location information

• Internet Protocol address;

• Internet service provider;

• Country;

• State or region;

• Approximate city-level location; and

• Time zone.

We do not intentionally collect precise GPS location through the Site unless a feature clearly requests it and You authorize it.

Usage information

• Pages viewed;

• Products browsed;

• Links and buttons selected;

• Search terms;

• Referring and exit pages;

• Time spent on pages;

• Navigation patterns;

• Site errors;

• Session information; and

• Interactions with Site content.

Commerce information

• Products added to or removed from a cart;

• Checkout activity;

• Abandoned-cart activity;

• Purchases;

• Discount-code usage;

• Order value;

• Return history; and

• Other transaction-related activity.

Advertising information

• Advertisement viewed or selected;

• Campaign and referral information;

• Conversion activity;

• Audience classification;

• Cookie or pixel identifiers;

• Interactions across websites or services, where permitted; and

• Information used to measure or personalize advertising.

2.6 Information From Third Parties

We may receive Personal Information from third parties, including:

• Shopify, which provides e-commerce hosting, checkout, account, order-management, analytics, and related services;

• Payment providers, which provide transaction authorization, payment processing, refund handling, and fraud-screening information;

• Shipping and fulfillment providers, which provide address validation, tracking, delivery, loss, damage, and return information;

• Meta, through Meta Pixel and associated advertising tools;

• Google, through Google Analytics, Google Ads, and associated measurement and advertising tools;

• Product-review providers, which help collect, verify, publish, and manage reviews;

• Email-marketing providers, which help deliver and analyze marketing communications;

• Fraud-prevention providers, which help assess transaction and account risk;

• Customer-support providers, which help manage communications and claims; and

• Other service providers used to operate the Site and fulfill orders.

We may combine information received from third parties with information collected directly from You or automatically through the Site.

3. How We Use Personal Information

We may use Personal Information for the following purposes.

3.1 Order Fulfillment and Customer Service

We use Personal Information to:

• Process and fulfill orders;

• Verify and process payments;

• Arrange shipping and delivery;

• Send order, payment, shipping, and delivery confirmations;

• Manage cancellations, returns, replacements, and refunds;

• Respond to customer inquiries;

• Provide product-related support;

• Maintain purchase and support records; and

• Communicate material changes affecting an order.

3.2 Customer Accounts

We use Personal Information to:

• Create and administer customer accounts;

• Authenticate account access;

• Display order history;

• Save customer preferences where enabled;

• Detect unauthorized access;

• Provide account-related communications; and

• Process account-access, correction, or deletion requests.

3.3 Site Operations and Improvement

We use Personal Information to:

• Operate, maintain, and secure the Site;

• Preserve cart and checkout functionality;

• Diagnose errors and technical problems;

• Analyze traffic and Site performance;

• Understand how customers interact with products and content;

• Improve navigation and user experience;

• Test Site features;

• Develop products, services, and business processes; and

• Generate aggregated analytics and business reports.

3.4 Email Marketing

Where permitted by law, We use Personal Information to:

• Send promotional emails;

• Announce products, offers, and discounts;

• Provide abandoned-cart or browsing reminders where enabled;

• Personalize email content;

• Measure email delivery, opening, and engagement; and

• Maintain records of marketing consent and opt-out requests.

You may unsubscribe from marketing emails at any time by selecting the unsubscribe link contained in the message or contacting Us.

Opting out of marketing does not prevent Us from sending transactional or service-related messages concerning an order, account, return, security issue, or legal notice.

3.5 Analytics and Advertising

Subject to applicable consent and opt-out requirements, We may use Personal Information to:

• Measure Site traffic and customer engagement;

• Analyze advertising performance;

• Attribute purchases or other actions to advertising campaigns;

• Create or use advertising audiences;

• Display advertisements likely to be relevant to You;

• Retarget visitors who previously interacted with the Site;

• Limit repetitive advertising;

• Measure conversions; and

• Improve marketing strategy.

We currently use Meta Pixel, Google Analytics, and Google Ads for some of these purposes.

3.6 Reviews and Feedback

We use Personal Information to:

• Collect and publish reviews;

• Verify whether a reviewer purchased a product;

• Contact reviewers concerning their submission;

• Detect fraudulent or manipulated reviews;

• Moderate unlawful or inappropriate content;

• Improve products and customer service; and

• Use reviews or testimonials in accordance with the permissions granted when submitted.

3.7 Security and Fraud Prevention

We use Personal Information to:

• Verify transactions and customer identity;

• Assess potentially fraudulent orders;

• Protect customer accounts;

• Detect unauthorized payment activity;

• Prevent chargeback, refund, return, and promotional abuse;

• Investigate security incidents;

• Enforce Our policies;

• Protect Our legal rights; and

• Protect customers, service providers, and the public.

3.8 Legal, Accounting, and Compliance Purposes

We use Personal Information to:

• Maintain accounting and tax records;

• Comply with legal and regulatory obligations;

• Respond to lawful governmental, regulatory, and court requests;

• Establish, exercise, or defend legal claims;

• Enforce contracts and policies;

• Conduct audits;

• Respond to privacy requests; and

• Maintain records demonstrating compliance.

4. Lawful Bases for Processing

Where the UK General Data Protection Regulation or another law requiring a lawful basis applies, We rely on one or more of the following bases.

4.1 Performance of a Contract

We process Personal Information when necessary to:

• Process an order;

• Accept and verify payment;

• Fulfill and deliver products;

• Administer a customer account;

• Provide customer service;

• Process cancellations, returns, and refunds; and

• Perform Our obligations under Our Terms of Service.

4.2 Consent

We may rely on consent for:

• Marketing emails where consent is required;

• Non-essential cookies and tracking technologies;

• Personalized advertising where consent is required;

• Publication or promotional use of certain user content; and

• Other processing for which We specifically request consent.

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

Withdrawal does not affect processing that lawfully occurred before consent was withdrawn.

4.3 Legitimate Interests

We may process Personal Information where reasonably necessary for Our legitimate interests or those of a third party, provided those interests are not overridden by Your rights.

These interests may include:

• Operating and improving the Site;

• Providing customer service;

• Preventing fraud and abuse;

• Protecting Site and account security;

• Understanding business performance;

• Maintaining accurate records;

• Defending legal claims;

• Conducting limited analytics; and

• Communicating with existing customers where legally permitted.

4.4 Legal Obligations

We process Personal Information when necessary to comply with:

• Tax and accounting requirements;

• Consumer-protection obligations;

• Product-safety obligations;

• Data-protection laws;

• Court orders;

• Regulatory requests; and

• Other applicable legal duties.

4.5 Legal Claims and Vital Interests

We may process Personal Information where necessary to establish, exercise, or defend legal claims.

In rare circumstances, We may process information where necessary to protect an individual’s vital interests or safety.

5. How We Disclose Personal Information

We may disclose Personal Information to the categories of recipients described below.

We do not sell Personal Information for money to unrelated third parties.

Certain disclosures to advertising and analytics partners may, however, be considered a “sale,” “sharing,” or use for targeted advertising under some United States privacy laws.

5.1 Shopify

We use Shopify to operate the Site and provide:

• Website hosting;

• Storefront functionality;

• Checkout;

• Customer accounts;

• Order management;

• Commerce analytics;

• Fraud screening;

• Payment-related integrations; and

• Privacy-management features.

Shopify processes information according to its own terms, data-processing commitments, and privacy notice.

5.2 Payment Providers

We disclose transaction and order information to payment processors, banks, card networks, digital-wallet providers, and fraud-prevention providers as necessary to:

• Authorize payments;

• Process transactions;

• Issue refunds;

• Prevent fraud;

• Resolve payment disputes; and

• Meet legal and financial obligations.

5.3 Fulfillment and Shipping Providers

We disclose information including Your name, address, telephone number, email address, order contents, and tracking information to fulfillment centers, warehouses, shipping carriers, logistics providers, and return facilities.

5.4 Marketing and Email Providers

We may disclose information to email-marketing and related providers to:

• Deliver messages;

• Maintain subscriber lists;

• Process unsubscribe requests;

• Analyze campaign performance; and

• Prevent unauthorized or abusive use.

5.5 Analytics and Advertising Partners

Subject to applicable consent and opt-out requirements, We may disclose identifiers, device information, Site activity, purchase information, advertising data, and related information to:

• Meta;

• Google;

• Shopify advertising and analytics services; and

• Other advertising or measurement providers that We identify through Our cookie or privacy-preference tools.

These providers may combine information received from the Site with information collected through other websites, applications, devices, or services, according to their own privacy practices.

5.6 Review and Customer-Support Providers

We may disclose information to service providers that help Us:

• Collect and publish reviews;

• Verify purchases;

• Moderate content;

• Manage customer inquiries;

• Process claims;

• Store communications; and

• Measure service quality.

5.7 Professional Advisers

We may disclose Personal Information to lawyers, accountants, auditors, insurers, consultants, tax advisers, and other professional advisers where reasonably necessary.

5.8 Legal and Compliance Disclosures

We may disclose Personal Information where We reasonably believe disclosure is necessary to:

• Comply with applicable law;

• Respond to a subpoena, court order, warrant, or regulatory request;

• Detect, prevent, or investigate fraud or security incidents;

• Enforce Our contracts and policies;

• Protect Frilume, customers, service providers, or the public;

• Establish, exercise, or defend legal claims; or

• Cooperate with lawful investigations.

5.9 Business Transfers

Personal Information may be disclosed or transferred as part of:

• A merger;

• Acquisition;

• Financing;

• Reorganization;

• Sale of assets;

• Insolvency;

• Bankruptcy;

• Change of control; or

• Similar business transaction.

The recipient may continue processing Personal Information subject to this policy, a replacement privacy notice, and applicable law.

6. Cookies and Tracking Technologies

We use cookies, pixels, tags, local storage, server logs, and similar technologies to operate the Site, understand Site use, remember preferences, and support advertising.

6.1 Essential Cookies

Essential cookies are required for functions including:

• Page navigation;

• Shopping-cart operation;

• Checkout;

• Security;

• Fraud prevention;

• Customer authentication;

• Account access;

• Network management;

• Privacy-preference storage; and

• Remembering items selected during a session.

Disabling essential technologies may prevent parts of the Site from operating correctly.

6.2 Functional Cookies

Functional cookies may remember:

• Language;

• Region;

• Currency;

• Account preferences;

• Display preferences; and

• Other choices that improve Site functionality.

6.3 Analytics Cookies

Analytics technologies help Us understand:

• Number of visitors;

• Traffic sources;

• Pages viewed;

• Site navigation;

• Error rates;

• Product engagement;

• Checkout behavior; and

• General Site performance.

We use Google Analytics and Shopify analytics for these purposes.

6.4 Marketing and Advertising Cookies

Marketing technologies may be used to:

• Measure advertisement performance;

• Attribute purchases to campaigns;

• Build advertising audiences;

• Retarget Site visitors;

• Personalize advertisements; and

• Measure interactions across websites or services.

We use Meta Pixel and Google advertising technologies for these purposes.

6.5 Cookie Duration

Some cookies expire when You close Your browser. Others remain for a defined period or until manually removed.

Specific cookie names, providers, purposes, and durations may change as Shopify, installed applications, and Our settings change.

Where available, current information is displayed through the Site’s cookie-consent or privacy-preference tool.

6.6 Managing Cookies

You may manage non-essential cookies through:

• The cookie banner or privacy-preference tool displayed on the Site;

• The “Your Privacy Choices” or equivalent footer link, where available;

• Your browser settings;

• Device privacy settings; and

• Applicable provider opt-out controls.

Blocking cookies may affect Site functionality, account access, cart operation, checkout, and saved preferences.

Deleting cookies may also remove previously stored privacy choices, requiring You to select them again.

7. Behavioral Advertising and Privacy Choices

We may use Personal Information to display advertisements based on Site activity, product interests, or interactions with advertising platforms.

Depending on applicable law, these practices may be described as:

• Targeted advertising;

• Personalized advertising;

• Interest-based advertising;

• Cross-context behavioral advertising;

• Sale of Personal Information; or

• Sharing of Personal Information.

Where required, You may opt out through the Site’s privacy-preference or “Your Privacy Choices” link.

We will process recognized browser-based opt-out preference signals, including Global Privacy Control, where required by applicable law and supported by Our systems.

An opt-out preference signal generally applies to the browser or device from which it is sent. You may need to repeat Your choice on another browser, device, or cleared-cookie session.

Opting out of personalized advertising does not prevent You from seeing advertisements. Advertisements may instead be selected without using information associated with Your activity across different businesses.

8. Email Marketing

8.1 Marketing Consent

We may send marketing emails when:

• You expressly subscribe;

• You select a marketing option during checkout or account creation;

• Applicable law permits communication with an existing customer; or

• Another lawful basis applies.

Consent to marketing is not a condition of purchase.

8.2 Unsubscribing

You may unsubscribe by:

• Selecting the unsubscribe link in a marketing email; or

• Contacting info@frilume.com.

We may retain limited information on a suppression list to ensure that Your unsubscribe request continues to be honored.

8.3 Transactional Communications

Even after unsubscribing from marketing, You may continue to receive non-promotional communications concerning:

• Orders;

• Payments;

• Shipping;

• Returns;

• Refunds;

• Customer accounts;

• Security;

• Policy updates; and

• Privacy requests.

9. Consumer Health-Related Information

Frilume sells wellness and comfort-related products. A customer’s product browsing, purchase history, communications, or review content may reveal or permit an inference regarding health interests or physical concerns.

We do not request medical records, formal diagnoses, prescriptions, genetic information, or complete treatment histories through ordinary Site functions.

You should not include sensitive health information in a public product review.

Where information is treated as consumer health data under applicable law, We will collect, use, disclose, or retain it only as permitted by that law and subject to any required consent, authorization, deletion right, or other restriction.

Where required, Frilume will provide a separate Consumer Health Data Privacy Policy describing applicable collection, purposes, sources, disclosures, and rights.

Nothing in this general Privacy Policy replaces any separate consumer-health-data notice required by law.

10. Your Privacy Rights

Depending on Your location and applicable law, You may have the right to:

• Request access to Personal Information;

• Request confirmation that We process Your information;

• Request correction of inaccurate information;

• Request deletion;

• Request restriction of processing;

• Object to processing;

• Request data portability;

• Withdraw consent;

• Opt out of direct marketing;

• Opt out of sale, sharing, or targeted advertising;

• Limit certain uses of sensitive Personal Information;

• Appeal a decision concerning a privacy request;

• Lodge a complaint with a regulator; and

• Receive equal service without unlawful discrimination for exercising a privacy right.

These rights may be subject to legal exceptions.

For example, We may retain information needed to:

• Complete a transaction;

• Maintain tax and accounting records;

• Prevent fraud;

• Protect security;

• Resolve disputes;

• Establish or defend legal claims; or

• Comply with another legal obligation.

11. United Kingdom Privacy Rights

Where the UK General Data Protection Regulation and Data Protection Act 2018 apply, You may have the right to:

• Be informed about processing;

• Access Your Personal Information;

• Correct inaccurate or incomplete information;

• Request erasure;

• Restrict processing;

• Receive eligible information in a portable format;

• Object to direct marketing;

• Object to certain legitimate-interest processing;

• Withdraw consent;

• Challenge certain solely automated decisions; and

• Lodge a complaint with the Information Commissioner’s Office.

To exercise a right, contact info@frilume.com.

You may also complain directly to the Information Commissioner’s Office if You believe Your information has been handled unlawfully.

12. United States State Privacy Rights

Residents of certain United States states may have additional rights under state privacy laws.

These rights apply only where the relevant law applies to Frilume and the particular processing activity.

12.1 California Rights

California residents may have the right to:

• Know the categories of Personal Information collected;

• Know the sources from which it was collected;

• Know the business or commercial purposes for collection;

• Know the categories of third parties receiving it;

• Request specific pieces of Personal Information;

• Request correction;

• Request deletion;

• Opt out of sale or sharing;

• Limit certain uses and disclosures of sensitive Personal Information; and

• Receive equal service without unlawful discrimination.

12.2 California Collection Disclosure

During the preceding twelve months, We may have collected the following categories of Personal Information:

• Identifiers;

• Customer-record information;

• Commercial information;

• Internet or electronic-network activity;

• Approximate geolocation;

• Audio, visual, or similar information submitted by customers;

• Professional information where voluntarily supplied;

• Account-access information;

• Payment-related information handled through payment providers; and

• Inferences concerning likely preferences or product interests.

We collect this information from:

• Customers;

• Devices and browsers;

• Shopify;

• Payment providers;

• Fulfillment and shipping providers;

• Meta;

• Google;

• Review and email providers; and

• Other service providers.

We use it for the purposes described in Section 3.

12.3 California Sale and Sharing Disclosure

We do not sell Personal Information for monetary payment.

During the preceding twelve months, We may have disclosed or “shared” the following categories for cross-context behavioral advertising:

• Identifiers and online identifiers;

• Internet or network activity;

• Commercial information;

• Approximate location;

• Advertising interaction information; and

• Inferences concerning product interests.

The recipients may include Meta, Google, Shopify advertising services, and related advertising or measurement providers.

You may opt out through the “Your Privacy Choices” or equivalent link displayed on the Site and through a recognized Global Privacy Control signal where required.

We do not knowingly sell or share the Personal Information of consumers under sixteen years of age.

12.4 Sensitive Personal Information

Frilume uses sensitive Personal Information only as reasonably necessary to provide requested products and services, process transactions, maintain account security, prevent fraud, comply with law, and perform other permitted purposes.

Where applicable law provides a right to limit additional uses of sensitive Personal Information, instructions for exercising that right will be provided through the Site’s privacy tools or by contacting Us.

12.5 Authorized Agents

Where permitted by law, You may appoint an authorized agent to submit a request.

We may require:

• Proof of the agent’s authority;

• Direct verification of Your identity; and

• Confirmation that You authorized the request.

13. Exercising Your Privacy Rights

To submit a privacy request, contact:

Email: info@frilume.com
Telephone: +44 7537 132859

Your request should describe:

• Your name;

• The email address associated with Your account or order;

• The right You wish to exercise;

• The information or transaction concerned; and

• Any details reasonably necessary to locate the relevant records.

We may verify Your identity before processing the request.

Verification may require matching information already held by Us or requesting limited additional evidence.

We will respond within the period required by applicable law.

We may deny or limit a request where permitted by law and will provide an explanation where required.

14. Data Retention

We retain Personal Information only for as long as reasonably necessary for the purposes described in this policy, including legal, tax, accounting, security, fraud-prevention, customer-service, and dispute-resolution purposes.

Retention periods may include:

14.1 Order and Transaction Records

Order, payment, invoice, shipping, return, and refund records may generally be retained for at least six years from the end of the relevant financial or accounting period, or longer where required for:

• Tax compliance;

• Audits;

• Legal claims;

• Chargebacks;

• Fraud investigations; or

• Other legal obligations.

14.2 Customer Accounts

Customer-account information may be retained while the account remains active and for a reasonable period after closure or inactivity.

Some associated order and transaction records may be retained longer under separate legal requirements.

14.3 Customer-Support Records

Support, complaint, return, and refund communications may generally be retained for up to three years after the last communication, or longer where necessary for an active dispute, legal claim, fraud investigation, or compliance obligation.

14.4 Marketing Records

Marketing contact information is retained until:

• You unsubscribe;

• You withdraw consent;

• The information is no longer needed; or

• We discontinue the relevant marketing activity.

A limited suppression record may be retained after opt-out to prevent further marketing.

14.5 Product Reviews

Product reviews and related content may be retained for as long as the review remains published, the applicable product is sold, or the content is reasonably needed for moderation, fraud prevention, recordkeeping, or legal claims.

14.6 Analytics and Cookie Information

Cookie and analytics information is retained according to:

• The lifespan of the relevant cookie;

• The settings configured in Shopify, Google, Meta, or another provider;

• Your privacy preferences; and

• Our business and legal requirements.

When information is no longer required, We will delete, anonymize, or securely dispose of it, subject to technical limitations and lawful backup-retention periods.

15. Data Security

We use reasonable technical and organizational measures designed to protect Personal Information from:

• Unauthorized access;

• Unlawful use;

• Accidental loss;

• Alteration;

• Destruction; and

• Unauthorized disclosure.

Measures may include:

• Encrypted transmission;

• Secure Shopify checkout;

• Payment processing through established providers;

• Access restrictions;

• Account authentication;

• Fraud screening;

• Service-provider controls;

• Security monitoring; and

• Internal procedures for responding to incidents.

No internet transmission, electronic-storage system, or security measure is completely secure.

We therefore cannot guarantee absolute security.

You are responsible for protecting Your devices, email account, passwords, customer-account credentials, and payment methods.

If You believe Your Frilume account or Personal Information has been compromised, contact Us promptly.

16. International Data Transfers

SBMF LTD is established in the United Kingdom.

Our service providers, including Shopify, Google, Meta, payment processors, fulfillment providers, and other technology vendors, may process Personal Information in the United States, Canada, the European Economic Area, the United Kingdom, and other countries.

Data-protection laws in those countries may differ from those in Your location.

Where a transfer is restricted under applicable law, We will use a permitted transfer mechanism where required, which may include:

• An adequacy regulation or decision;

• The United Kingdom International Data Transfer Agreement;

• The United Kingdom Addendum to approved Standard Contractual Clauses;

• Contractual protections;

• Consent where legally valid;

• Transfer necessary to perform a contract; or

• Another lawful safeguard.

Our service providers may also rely on their own legally recognized transfer mechanisms.

17. Children’s Privacy

The Site and Frilume products are not directed to children under sixteen years of age.

We do not knowingly collect Personal Information directly from children under sixteen without legally valid authorization.

If You are a parent or guardian and believe that a child has submitted Personal Information to Us, contact info@frilume.com.

Where appropriate and legally required, We will take reasonable steps to delete the information.

18. Third-Party Websites and Services

The Site may contain links to websites, applications, social-media platforms, payment services, or other services operated by third parties.

Frilume does not control those third parties and is not responsible for their:

• Privacy practices;

• Security;

• Content;

• Terms; or

• Data-processing activities.

This Privacy Policy applies only to processing controlled by Frilume.

You should review the privacy notice of each third-party service before providing Personal Information.

19. Automated Decision-Making

Frilume and its service providers may use automated tools to assess:

• Fraud risk;

• Payment risk;

• Account security;

• Order legitimacy;

• Advertising audiences; and

• Site personalization.

These tools may use transaction, device, behavioral, location, account, and payment-related information.

Frilume does not currently intend to make decisions based solely on automated processing that produce legal or similarly significant effects, except where permitted by law and appropriate safeguards are provided.

20. Data Breaches

If We become aware of a Personal Information breach, We will investigate and take reasonable steps to:

• Contain the incident;

• Assess the nature and risk;

• Protect affected systems and records;

• Notify service providers or authorities where required; and

• Notify affected individuals where required by law.

The timing and content of any notice will depend on the circumstances and applicable legal requirements.

21. Limitation of Liability

To the fullest extent permitted by applicable law, Frilume will not be liable for indirect, incidental, special, consequential, exemplary, or punitive damages arising solely from:

• Acts of independent third-party service providers;

• Security incidents outside Our reasonable control;

• A customer’s failure to protect account credentials;

• Unauthorized access caused by compromised customer devices; or

• Other circumstances for which liability may lawfully be excluded.

Nothing in this Privacy Policy excludes or limits liability, regulatory obligations, or data-subject rights that cannot legally be excluded or limited.

22. Complaints and Regulatory Authorities

If You have concerns about Our handling of Personal Information, contact Us first at info@frilume.com.

We will review and respond to the complaint within the timeframe required by applicable law.

Depending on Your location, You may also have the right to complain to a regulator, including:

• The United Kingdom Information Commissioner’s Office;

• The California Privacy Protection Agency;

• The California Attorney General;

• A United States state attorney general;

• A European data-protection authority; or

• Another competent privacy or consumer-protection authority.

23. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes to:

• Our practices;

• Shopify or installed applications;

• Advertising and analytics technologies;

• Products and services;

• Legal requirements; or

• Business operations.

When We make changes, We will update the “Last updated” date.

Where required by law, We may provide additional notice by email, through the Site, through a customer account, or by another appropriate method.

The revised policy becomes effective when posted unless another effective date is stated.

24. Contact Information

For questions, privacy requests, complaints, or concerns regarding this Privacy Policy, contact:

Brand
Frilume

Legal Entity and Data Controller
SBMF LTD, trading as Frilume

Company Number
16269068

Email
info@frilume.com

Telephone
+44 7537 132859

Registered Office
71–75 Shelton Street
Covent Garden
London, WC2H 9JQ
United Kingdom

25. Governing Law

This Privacy Policy will be governed by the laws of England and Wales, except where superseded by mandatory privacy, consumer-protection, or data-protection law applicable to an individual.

Nothing in this section limits an individual’s right to exercise a privacy right or complain to a competent regulator in another jurisdiction.

By using frilume.com, You acknowledge that You have read and understood this Privacy Policy.