Privacy Policy (As of: August 30, 2025)

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1. Controller Elaine Puhek – Almalux Rua José Ramalho Viegas 3, R/C B, 8005-226 Faro, Portugal Email: info@almalux-studio.com This Privacy Policy applies to all processing of personal data in connection with our services, website, mobile applications, and external online presences (e.g. social media profiles). All terms are to be understood in a gender-neutral manner.

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2. Types of Data Processed Inventory and contact data: name, address, email, phone number. Contract and payment data: invoices, payment history, bank details. Content data: text inputs/forms, messages, uploads. Usage and metadata: IP address, device/browser data, referrer, access times, pages visited.

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3. Categories of Data Subjects Prospective clients, users, clients, business/contractual partners, communication partners.

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4. Purposes of Processing Provision of contractual services and customer support, communication and inquiry handling, organization/accounting, direct marketing/newsletter, reach measurement and web analytics, conversion and profile measurement (pseudonymous), provision and security of the online offering, feedback/quality assurance.

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5. Legal Bases (Art. 6 GDPR) a) Consent, b) Contract/pre-contractual measures, c) Legal obligation, f) Legitimate interest (operationally secure, efficient, user-friendly, and commercially viable provision of our services).

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6. Security Measures Technical and organizational measures (including access control, encryption, separation principle, backups, need-to-know, incident processes). Privacy by Design/Default.

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7. Transfers, Recipients & Third Countries Disclosure to processors and service providers (hosting, newsletter, payment/communication services) only on the basis of a data processing agreement. Third-country transfers only with an adequacy decision or EU Standard Contractual Clauses (SCC); additional protective measures where applicable.

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8. Retention Period / Deletion Deletion upon achievement of purpose or expiry of legal basis. Statutory retention obligations (generally 10 years for tax records) remain unaffected. Data may be retained for defense or evidentiary purposes (Art. 17(3) GDPR).

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9. Your Rights Access, rectification, erasure, restriction, data portability, objection (Art. 21 GDPR), withdrawal of consent, complaint to a supervisory authority.

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10. Cookies & Consent Management We use cookies/similar technologies for functionality, convenience, analytics, and marketing. Necessary cookies are based on legitimate interest/contract; all others require consent (revocable at any time via the consent tool/browser). Retention period: session cookies until end of session; persistent cookies generally up to 24 months (unless otherwise stated).

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11. Online Offering & Web Hosting (Wix) Wix.com Ltd., Nemal St. 40, 6350671 Tel Aviv, Israel provides infrastructure (servers, CMS, shop, security/maintenance services). Data processed: IP, timestamps, requested resources, referrer, user agent, form inputs. Server log files: stored for max. 30 days, then deleted/anonymized; longer retention only for evidentiary purposes in the event of security incidents. Wix uses servers in the EU/USA/Israel (Israel with adequacy decision). DPA & SCC implemented. Details: de.wix.com/about/privacy

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12. Communication, Contact & Appointment Booking Contact forms/email/phone/social: processing for response purposes (Art. 6 b/f). Calendly LLC (appointment booking, USA): name, email, optional details, time zone. Legal basis: Art. 6 b/f; transfer to USA on basis of SCC + DPA. Privacy: calendly.com/privacy

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13. Video Conferences / Webinars (Zoom) Zoom Video Communications, Inc., USA. Data: name, email, IP, device/usage data, content data (meeting content). Legal basis: Art. 6 b/f. Third-country transfer via SCC. Privacy: zoom.us/privacy

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14. Newsletter & Electronic Communications (ActiveCampaign, Wix, Make, Manychat) Double opt-in, logging of registration/confirmation/IP/timestamp. Content: information about us, services, promotions. Measurement of open/click rates (web beacon, pseudonymous). Legal basis: Art. 6 a (consent) or Art. 6 f (existing customer marketing within the scope of § 7(3) UWG, where permitted). Withdrawal/unsubscription at any time via the link in the newsletter or by email. ActiveCampaign LLC, USA – DPA & SCC. Privacy: activecampaign.com/legal/privacy-policy

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15. Promotional Communications Outside the Newsletter Email/phone/post with consent or legal permission; withdrawal/objection possible at any time. After withdrawal, we retain evidence for up to 3 years (Art. 6 f) for defense against claims.

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16. Web Analytics / Monitoring (Google Analytics) Google Ireland Limited (parent: Google LLC, USA). Purpose: reach measurement, user flows, optimization. IP anonymization (IP masking) active. Cookies/IDs; retention period for usage data generally 14 months (unless otherwise configured). Legal basis: Art. 6 a (consent). Third-country transfer: SCC. Opt-out via consent tool/browser add-on. Privacy: policies.google.com/privacy

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17. Music / Podcast Hosting Anchor by Spotify / Spotify AB (SE) – retrieval/download of audio; processing of IP, device/usage data; reach statistics (pseudonymous). Legal basis: Art. 6 f; details: anchor.fm/privacy, spotify.com/legal/privacy-policy

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18. Social Media Presences & Page Insights (Facebook) We maintain profiles on Instagram, Facebook, Pinterest, Xing. Data processing by platforms (including cookies, profiling, market research/ads). Facebook Page Insights (joint controllership) with Meta Platforms Ireland Ltd.: agreement pursuant to Art. 26 GDPR ("Page Controller Addendum"). Meta fulfills data subject rights regarding Insights data. Details: facebook.com/legal/terms/information_about_page_insights_data, facebook.com/about/privacy Legal basis: Art. 6 f (communication/presence/analysis). Objection/opt-out directly with the respective platform.

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19. Plugins & Embedded Content (e.g. Google Fonts) Retrieval of content/fonts from third-party servers requires processing of the IP address. Used for consistent, secure display (Art. 6 f). Google Fonts: fonts.google.com / policies.google.com/privacy

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20. Business Services (Agency / Design / Coaching) Processing of contract/communication/payment data for service provision, billing, organization, rights protection, security (Art. 6 b/c/f). Required data is marked as mandatory. Deletion: generally after 4 years (warranty) or 10 years (tax/commercial). Use of subcontractors/banks/tax advisors/payment providers as required.

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21. Changes We update this policy when processing, technology, or legal requirements change. For changes requiring participation (consent), we will inform separately.

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Withdrawal Notice (Digital Content / Coaching) Right of withdrawal: Consumers may withdraw within 14 days of conclusion of contract without giving reasons. To exercise this right, a clear statement by email to info@almalux-studio.com is sufficient. Consequences of withdrawal: Refund of all payments promptly, no later than 14 days after receipt of the withdrawal declaration, via the same payment method (unless otherwise agreed). Special notice for digital content/immediate access: The right of withdrawal expires early if we have begun performance after you have expressly consented and simultaneously confirmed that you lose your right of withdrawal upon commencement of performance (checkbox at checkout).

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General Terms and Conditions (GTC)

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1. Scope & Subject Matter These GTC apply to all services provided by Almalux (Elaine Puhek), in particular coaching/mentoring programs, online courses, design/agency services, and digital products. Essenz to Brand is a coaching/mentoring program. It does not constitute distance learning within the meaning of the FernUSG, involves no learning assessments, and awards no state-recognized certificates.

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2. Conclusion of Contract The presentation of services does not constitute a binding offer. Orders/bookings are offers which we accept by confirmation (email/checkout confirmation).

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3. Prices & Payment Prices in EUR (plus/including VAT as indicated). Deposit (if agreed) prior to project start. Due date: unless otherwise noted, 10 working days after invoice date. Installment payments: fixed due dates; payment received no later than the due date. Late payment fees: in the event of default additionally: 10% of the net total amount 1 week after due date, 20% a further week later, 30% a further week later; legal action reserved thereafter. Set-off/retention rights only with undisputed or legally established counterclaims.

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4. Scope of Services & Delivery Services are provided digitally (email, member area, download, Zoom). Appointments can be arranged via Calendly. Coaching requires the client's active participation (personal responsibility, implementation).

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5. Withdrawal, Cancellation & Rebooking The withdrawal notice applies. After program start, cancellations are generally excluded; rebooking/rescheduling by arrangement and subject to availability.

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6. Copyright & Usage Rights (1) Transfer of exclusive usage rights: Upon full payment, the client receives all transferable, unlimited usage rights (in terms of time, territory, and subject matter) to the delivered final data (copyrighted works). (2) Condition: Transfer of rights is subject to the condition precedent of full payment. (3) Scope: Use in all known and unknown types of use, print (stationery, flyers, advertisements, etc.) and digital (web, social, banners, etc.); repeated use, reproduction, distribution, public accessibility, broadcast. (4) Prohibition of modification: No editing/adaptation/redesign by the client or third parties without consent; in particular no distorting or significantly deviating changes. (5) Exclusivity & portfolio: Transfer is exclusive in favor of the client. Drafts/materials not selected as final remain with the designer and may be used for other projects. (6) Intellectual property rights: The client may register trademark/design protection for the final logo; necessary information will be provided.

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7. Client Obligations & Acceptance Submissions/feedback/punctuality by the client are required. Acceptance occurs upon confirmation or use/going live.

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8. Warranty & Liability Statutory warranty rights apply. Liability for simple negligence only in the event of breach of essential contractual obligations (cardinal duties) and limited to typical, foreseeable damage; no liability for lost profits. No guarantee of commercial success. No medical/psychological/therapeutic advice.

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9. Confidentiality & References Confidential information must be kept secret. Almalux may present projects anonymously or with attribution (after approval) as a reference/case study.

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10. Final Provisions Portuguese law applies, excluding the UN Convention on Contracts for the International Sale of Goods. Place of jurisdiction: Faro, Portugal, where permitted. OS platform:

https://ec.europa.eu/consumers/odr – our email is in the imprint. Contract language: German.

Appendix: Services / Processing Overview (Summary) Hosting/Shop/CMS: Wix (EU/Israel/USA; DPA, SCC) Analytics: Google Analytics (IP anonymization, consent-based; SCC) Newsletter/CRM: ActiveCampaign (DOI, tracking; SCC) Meetings/Webinars: Zoom (SCC) Appointment booking: Calendly (SCC) Podcast: Anchor/Spotify (pseudonymous reach) Social: Instagram, Facebook (Page Insights, Joint Controllership), Pinterest, Xing

Last updated: August 2025