This Privacy Policy describes how personal data is collected, used and protected within the Lumnae Affiliate Program (the "Program"), operated by ELM Company FZ-LLC, trading as Lumnae ("Lumnae", "we", "us"), a UAE-based company.
It applies to affiliates who join the Program, and to customers whose orders are referred through it. By joining the Program, you agree to this Privacy Policy. If you do not agree, you must not use the Program.
1. Data Controller
- For data collected directly for the purpose of running the Program (registering you as an affiliate, evaluating your application, paying commissions, shipping gifted products to you), Lumnae (ELM Company FZ-LLC) is the data controller.
- The Program is operated using UpPromote, a third-party affiliate-tracking application. UpPromote processes certain data (registration details, referral tracking, order data) on Lumnae's behalf as a data processor, under its own privacy policy for the technical operation of the app.
When you register for and participate in the Program, we (directly or through UpPromote) collect:
- Contact details: name, email address, social media handles/profile links.
- Payment details: bank account or IBAN, or other payment information needed to pay commissions.
- Delivery address and phone number, where gifted products are sent to you.
- Any other information you choose to provide (e.g. professional credentials, for medical/healthcare affiliates).
This information is used to evaluate your application, administer the Program, pay commissions, ship products, and contact you about the Program.
To track and pay commissions on referred sales, UpPromote collects order-level information from lumnae.com when a customer completes a purchase through your affiliate link or coupon code: order total, items purchased, and order ID. This does not give you access to the customer's personal contact details.
4. Legal Basis & Compliance
Lumnae processes personal data in accordance with the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL). We process your data on the basis of: performing our contract with you (running the Program, paying commissions), your consent where required, and our legitimate interest in operating and improving the Program.
5. Cookies & Tracking
UpPromote places cookies on a visitor's device to track referral clicks and coupon usage, so commissions can be correctly attributed. If a visitor does not accept, or later clears, cookies, we cannot track their activity or attribute a resulting purchase to you. More on cookies generally: allaboutcookies.org.
6. Data Retention
We retain affiliate data for as long as you are active in the Program, and for up to 24 months after your last activity, to comply with accounting, tax and legal obligations and to resolve any disputes. You may request earlier deletion under Section 11 (Your Rights), subject to our legal retention obligations.
7. International Data Transfers
Some of our service providers, including UpPromote, may process data outside the UAE. Where personal data is transferred internationally, we take reasonable steps to ensure it receives a comparable level of protection, in line with PDPL requirements on cross-border data transfer.
8. Security Measures
We use reasonable technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure or destruction, including restricted internal access to affiliate payment and contact details and reliance on UpPromote's own platform security for tracking data.
We do not sell your personal information. We share it only with:
- UpPromote, to operate the affiliate tracking and payment platform.
- Payment providers, to process commission payouts.
- Shipping and logistics partners (e.g. Jeebly), to deliver gifted products to you.
- Any other third party, with your prior consent, or where required by law.
These providers may only use your data to perform their function for us, and must handle it in line with this Policy.
10. Children's Data
The Program is not intended for children. Affiliates must be at least 18 years old to register and participate.
11. Your Rights
Under the UAE PDPL, you have the right to access, correct, amend, delete, port, or restrict the use of your personal data, subject to applicable exceptions. To exercise these rights, contact us at contact@lumnae.com. We may ask you to verify your identity before acting on your request.
If your request concerns data held only within UpPromote's platform, we will forward it to UpPromote as our processor to action on our behalf.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for legal reasons. Continued participation in the Program after changes are posted constitutes acceptance of the revised Policy.
Questions about your personal data or this Privacy Policy, or complaints about how we process it: contact@lumnae.com