lodent@eclairagers.com

+(352) 621 192 678

Zone Artisanale Gehaansraich, L-6187 Gonderange, Luxembourg

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Privacy Policy

Last Updated: August 28, 2026

1. Introduction

Eclairage Rolf SCHMITT S.à.r.l. (“we”, “us”, “our”) is a Luxembourg-registered home lighting and aroma goods provider operating our official e-commerce platform via www.eclairagers.com. This Privacy Policy is formulated in full compliance with the General Data Protection Regulation (GDPR), Luxembourg’s national data protection laws, and other applicable global data governance frameworks, to clearly outline how we collect, store, process, protect, and share your personal information when you browse, purchase products, create accounts, or interact with any features on our website, including our curated ranges of indoor aroma lamps, scenario mood lights, and complementary home decor collections.

This policy applies to all website visitors, registered account holders, paying customers, newsletter subscribers, contest participants, and any other individuals who share personal data with us through official channels. We respect the fundamental right to data privacy for every user, and all information processing activities are strictly limited to scopes directly tied to delivering secure, high-quality e-commerce experiences for our community. By accessing and using our website after the effective date of this policy, you acknowledge that you have read, understood, and agreed to all terms and conditions laid out in this document. If you do not consent to any clauses outlined here, please discontinue use of our platform immediately.

2. Data Controller Identification

The data controller responsible for your personal information under all applicable data protection regulations is Eclairage Rolf SCHMITT S.à.r.l., with full contact details listed below:

  • Registered Business Address: Zone Artisanale Gehaansraich, L-6187 Gonderange, Luxembourg
  • Official Business Website: www.eclairagers.com
  • Contact Email for Data Privacy Inquiries: lodent@eclairagers.com
  • Telephone Contact: +(352) 621 192 678

Our dedicated Data Protection Representative can be reached via the above contact channels at any time if you have questions, requests, or concerns related to how we manage your personal data. We commit to responding to all legitimate data privacy communications within 14 business days of receipt, in line with GDPR response requirements.

3. Categories of Personal Data We Collect

We only collect personal information that is directly relevant to operating our e-commerce platform and delivering the services you request, and never gather unnecessary or excessive data without explicit, lawful justification. The categories of personal data we may process include the following:

  • ‌Account and Registration Data‌: When you create a user account on our website, we collect your full name, unique username, password (stored in encrypted, hashed format), valid email address, and optional contact telephone number. This data allows you to save shipping addresses, view order history, track active delivery statuses, and access exclusive member-only promotions for our aroma lamp and scenario light collections.
  • ‌Transaction and Order Fulfillment Data‌: When you place a purchase order on our site, we collect your full billing and shipping address, payment information (processed exclusively through PCI DSS-compliant third-party payment gateways that we do not store full credit card or bank account details for), order item records, purchase amount, delivery preferences, and special order notes. This data is used 100% for processing payments, coordinating order fulfillment, arranging last-mile delivery, and resolving any post-sales issues related to your purchased products.
  • ‌Technical Usage Data‌: As you browse www.eclairagers.com, our server automatically logs limited non-identifiable and identifiable technical information including your device IP address, browser type and version, operating system, website entry and exit pages, timestamp of access, pages viewed on our store, search queries you submit on the platform, click stream behavior, and language preference settings. This data helps us optimize website loading speeds, resolve technical bugs, tailor product recommendations for our lighting collections to your preferences, and enhance overall site security against unauthorized access or cyberattacks.
  • ‌Communication and Support Data‌: When you reach out to our customer support team via email, website contact forms, or telephone, we collect the content of your messages, your contact identifiers, and any additional information you voluntarily share with us (such as product usage feedback, custom scenario light design requests, or return-related documentation). This data is used exclusively to respond to your inquiries, resolve after-sales problems, and continuously improve our product and service quality for all users.
  • ‌Marketing Preference Data‌: If you voluntarily subscribe to our official newsletter or opt in to receive promotional updates, we collect your email address, your stated product interests (such as preferences for specific aroma lamp scent profiles, scenario light color temperatures, or new collection launch alerts), and your interaction data with our marketing emails including open rates, link click records, and unsubscription status.

We will never collect sensitive special category personal data (including racial origin, religious beliefs, medical records, political opinions, or biometric information) through our website, and we explicitly request that you do not share such sensitive data with us through any communication channels. If you accidentally submit sensitive personal information to us, we will permanently delete it from all our systems immediately upon detection.

4. Lawful Bases for Data Processing

All of our personal data processing activities strictly comply with GDPR Article 6 requirements, and are justified by at least one of the following lawful bases:

  1. ‌Performance of a Contract‌: Most of our data processing is necessary to fulfill the purchase and service contract we enter into with you when you place an order on our platform, including processing payments, shipping your ordered aroma lamps or scenario lights, handling returns and refunds, and providing post-sales product warranty support.
  2. ‌Legitimate Business Interests‌: Where it does not override your fundamental data privacy rights, we process limited user data to pursue our legitimate business interests, which include optimizing our website user experience, preventing fraudulent transaction activities, sending relevant personalized product recommendations for our lighting collections (where permitted by applicable law), conducting anonymous user behavior analysis to improve our product ranges, and ensuring the long-term operational security of our e-commerce store. We always conduct strict balancing assessments to confirm that these interests do not negatively impact your data privacy rights before initiating any such processing activities.
  3. ‌Your Explicit Consent‌: For any processing activities that rely on your voluntary consent, such as sending non-transactional marketing newsletters, placing non-essential functional cookies on your device, or sharing your order details with third-party custom engraving partners for personalized scenario light products, we will always collect your clear, freely given, specific, and revocable consent in advance. You reserve the full right to withdraw this consent at any time, via the unsubscribe link included in all our marketing emails, or by sending a request to our dedicated data protection email at lodent@eclairagers.com. Withdrawing your consent will never affect the lawfulness of data processing activities we completed prior to your request.
  4. ‌Compliance with Legal Obligations‌: We may process your personal data when it is necessary for us to comply with explicit legal obligations that we are bound to as a Luxembourg-based business, such as retaining transaction records for local tax authority audits, responding to valid, legally authorized requests from Luxembourg judicial or regulatory bodies, and fulfilling mandatory product safety reporting requirements for our electrical lighting products.

5. How We Share Your Personal Information

We will never sell, rent, or trade your personal information to unrelated third parties for their own marketing purposes under any circumstances. We may only share your limited personal data with the following categories of trusted third parties, and only to the extent strictly necessary to deliver the services you have requested:

  • ‌Authorized Service Providers‌: We share relevant necessary data with our vetted, GDPR-compliant third-party service partners, including PCI DSS certified payment processors that handle your transaction payments, vetted last-mile logistics and delivery providers that ship your ordered lighting products to your specified address, professional cloud hosting providers that securely store our website data on servers located within the European Economic Area (EEA), and professional e-commerce analytics partners that help us analyze anonymous website usage trends to improve platform performance. All of these service partners are bound by strict data processing agreements with us that require them to protect your personal data to standards equal to our own, and prohibit them from using your shared data for any purposes outside of the services they are contracted to deliver for us.
  • ‌Legal and Regulatory Authorities‌: We may disclose your personal information if we are legally required to do so by a valid, enforceable court order, governmental regulatory request, or other binding legal procedure issued under Luxembourg or European Union law. We will make every reasonable effort to notify you of such a disclosure request where legally permitted, before releasing any of your personal data to the requesting authority.
  • ‌Business Transaction Successors‌: In the event of a future merger, acquisition, full or partial asset sale, or other corporate restructuring involving Eclairage Rolf SCHMITT S.à.r.l., your personal data may be transferred to the succeeding business entity. We will require the new controlling party to continue to abide by all terms outlined in this Privacy Policy, and notify all registered users via prominent notice on our website if there are any material changes to how your personal data will be processed following the transaction.

We explicitly prohibit any cross-border transfer of your personal data to countries outside of the European Economic Area that do not have an adequacy decision issued by the European Commission, unless we have implemented appropriate, legally required data protection safeguards (such as signing standard contractual clauses approved by the European Commission) to ensure your personal data receives the same level of strict protection as it is guaranteed within the EU. You may request a full copy of these safeguards at any time by contacting our data protection representative.

6. Data Retention Periods

We will never retain your personal information for longer than is strictly necessary to fulfill the exact purposes for which the data was originally collected. We define our standard data retention timelines in line with Luxembourg legal requirements as follows:

  • Transaction-related order, payment, and fulfillment data: Retained for a minimum of 10 years, to comply with Luxembourg national tax authority record-keeping obligations, and to support any post-sales product warranty claims for our aroma lamps and scenario lights that may be submitted within our 2-year standard warranty period.
  • Registered user account data: Retained for the full lifetime of your active user account on our website. If you submit a verified account deletion request to us, we will permanently erase all your account-related personal data from all our active servers within 30 business days, except for the limited transaction records we are legally obligated to retain for tax and regulatory compliance purposes.
  • Marketing contact data (such as newsletter subscription email addresses): Retained only for as long as you maintain your active subscription, or until you submit a valid unsubscription request. We will permanently remove your contact information from all our marketing distribution lists within 7 business days of receiving your unsubscription notice.
  • Customer support communication records: Retained for 3 years after the final resolution of your support inquiry, to allow us to track historical feedback trends and resolve any follow-up product-related issues you may raise at a later date.
  • Anonymous technical website usage analytics data: Retained in fully de-identified form that cannot be linked back to any individual user for a maximum of 5 years, after which it is permanently deleted.

Once the applicable retention period for any category of your personal data expires, we will securely and permanently erase, anonymize, or aggregate the relevant data, with no possibility of recovery or restoration.

7. Your Data Privacy Rights

Under the General Data Protection Regulation and Luxembourg’s national data protection legislation, you hold a comprehensive set of enforceable data rights related to your personal information that we process. These rights include:

  1. ‌Right of Access‌: You have the right to request a full, free copy of all personal data that we currently hold about you, as well as clear information about the purposes of processing, categories of shared recipients, applicable retention periods, and the origin of any data we did not collect directly from you.
  2. ‌Right to Rectification‌: If you find that any of the personal data we hold about you is inaccurate, incomplete, or outdated (such as an old shipping address, misspelled name, or outdated contact telephone number), you have the right to request immediate correction and completion of that data at no cost.
  3. ‌Right to Erasure (“Right to be Forgotten”)‌: You have the right to request permanent deletion of all your personal data held by us, in circumstances where the data is no longer necessary for the original purposes it was collected for, you have withdrawn your consent to the processing, or the processing violates applicable data protection laws. This right does not apply when we are legally obligated to retain the data to comply with official legal or regulatory requirements.
  4. ‌Right to Restriction of Processing‌: You have the right to request that we temporarily pause all processing activities related to your personal data, in scenarios where you contest the accuracy of the data, the processing is unlawful but you object to erasure, we no longer need the data for our original processing purposes but you require it to establish, exercise, or defend legal claims, or you have exercised your right to object to processing and we are in the process of verifying our legitimate legal grounds to continue processing.
  5. ‌Right to Data Portability‌: Where our processing of your data is based on your consent or the performance of a contract, you have the right to request that we provide all your personal data in a structured, commonly used, machine-readable format, or directly transmit that data to a third-party data controller of your choice, where it is technically feasible for us to do so.
  6. ‌Right to Object‌: You have the full right to object to any of our processing activities that are justified on the basis of our legitimate business interests, at any time. If you raise a valid objection, we will pause the relevant processing immediately, unless we can demonstrate compelling, legally valid, overriding legitimate grounds that supersede your privacy rights, or the processing is necessary to defend or pursue legal claims. You also hold the absolute right to object at no cost to any of our non-transactional direct marketing communications, at any moment.
  7. ‌Right to Lodge a Complaint‌: If you believe that our processing of your personal data violates applicable data protection regulations, you have the full right to submit a formal complaint to the relevant national data protection authority in your country of residence, or the Luxembourg National Commission for Data Protection (CNPD), the official supervisory authority for our business operations.

You can exercise any of these above rights at no cost, at any time, by sending a clear, signed request to our data protection representative via email at lodent@eclairagers.com, or via post to our registered business address at Zone Artisanale Gehaansraich, L-6187 Gonderange, Luxembourg. We may request limited additional information to verify your identity before processing your request, to prevent unauthorized third parties from gaining access to your personal data. We will respond to all valid, verifiable rights requests within 14 business days as required by GDPR.

8. Data Security Measures

We implement a comprehensive, multi-layered set of industry-leading technical, administrative, and physical data security measures to protect all your personal data against unauthorized access, accidental loss, unlawful destruction, alteration, disclosure, theft, or any other form of misuse. These measures include:

  • Full end-to-end 256-bit TLS encryption for all data transmitted between your device and our www.eclairagers.com website, ensuring no third party can intercept or read your personal information during transmission.
  • All user account passwords are stored in our systems using a one-way, salted cryptographic hashing algorithm, which means even our internal technical team cannot retrieve your plaintext account password at any time.
  • All our production servers that store personal data are hosted in ISO 27001 certified data centers located exclusively within the European Economic Area, with 24/7 physical security monitoring, fire suppression systems, redundant power supplies, and strict biometric access control for on-site staff.
  • We enforce the principle of least privilege for all our internal team members: only a very limited number of authorized employees who require access to your personal data to perform their job duties (such as customer support staff processing your order, or fulfillment teams arranging your delivery) are granted restricted, role-based access to your information, and all access activities are logged and audited on a regular monthly basis.
  • We conduct regular third-party cybersecurity penetration testing, full system vulnerability scans, and annual data protection training for all our employees, to ensure that our data protection practices remain fully aligned with evolving security standards and regulatory requirements.

While we have invested extensive resources to implement the most robust possible security safeguards, it is important to note that no method of data transmission over the internet or electronic storage system can be guaranteed to be 100% invulnerable. In the extremely unlikely event of a personal data breach that poses a high risk to your rights and freedoms, we will notify you and the relevant Luxembourg CNPD supervisory authority without undue delay, in full compliance with GDPR mandatory breach notification requirements.

9. Children’s Privacy

Our e-commerce website and all products we sell, including our range of indoor aroma lamps, electric scenario mood lights, and home decor products, are designed and marketed explicitly for use by adults aged 18 years or older. We do not knowingly, intentionally collect any personal information from children under the age of 16, and our website does not contain any content targeted at underage audiences. If you are a parent or legal guardian of a child under 16 and you discover that your child has submitted personal data to our platform without your explicit prior consent, please contact us immediately at lodent@eclairagers.com. We will take all necessary steps to permanently delete all relevant personal information related to the minor from all our systems as quickly as possible.

10. Cookie and Tracking Technology Policy

Our website uses cookies and similar lightweight tracking technologies to enhance your browsing experience, analyze website traffic, and personalize our product recommendations for our aroma lamp and scenario light collections. For full transparency, we categorize the cookies we use on our platform as follows:

  • ‌Strictly Necessary Cookies‌: These core functional cookies are essential for you to navigate our website, use basic e-commerce features such as accessing your logged-in account, adding items to your shopping cart, and completing the checkout process. These cookies do not store any personally identifiable browsing data, and cannot be disabled through our website consent banner, as the platform will not function correctly without them.
  • ‌Performance and Analytics Cookies‌: These cookies help us collect anonymous, aggregated data about how visitors interact with our website pages, so we can identify technical bottlenecks, optimize page loading speeds, and continuously improve the overall user experience of our store. We only deploy these non-essential cookies after we have collected your explicit opt-in consent via our website cookie preference center.
  • ‌Functional Cookies‌: These cookies remember your personal custom preferences when you visit our site, including your selected language setting, saved shipping address, and preferred scenario light product filter options, so we can provide a more convenient, personalized experience on your subsequent return visits to www.eclairagers.com.
  • ‌Marketing and Personalization Cookies‌: With your explicit separate consent, these cookies may be used to display targeted, relevant advertisements for our new aroma lamp collections on third-party social media and e-commerce platforms, tailored based on your past browsing activity on our website. You can opt out of all non-essential marketing cookies at any time, by adjusting your browser settings, or modifying your preferences in our cookie consent center at the footer of our website.

11. Policy Updates and Amendments

We reserve the right to revise, update, or amend the terms of this Privacy Policy from time to time, to reflect changes to our business operations, new regulatory requirements, or updates to our website service features. When we make material changes to this policy, we will update the “Last Updated” date at the top of this document, and post a prominent, visible notification banner on the homepage of www.eclairagers.com at least 30 days before the new revised policy comes into effect. For any changes that significantly alter how we collect, process, or share your personal data, we will also send a direct notification email to all registered active user accounts on file. Your continued use of our website after the effective date of the revised Privacy Policy will constitute your acknowledgment and acceptance of the updated terms.

12. Contact Information for Privacy Inquiries

If you have any questions, concerns, feedback, or formal requests related to this Privacy Policy, our data processing practices, or wish to exercise any of your data privacy rights outlined in this document, you may contact our dedicated data protection team via any of the following official channels at any time:

  • Email: lodent@eclairagers.com
  • Postal Mail: Eclairage Rolf SCHMITT S.à.r.l., Zone Artisanale Gehaansraich, L-6187 Gonderange, Luxembourg
  • Telephone: +(352) 621 192 678