Privacy Policy

1. Introduction

Lumeralia ("we", "our", or "us") is a digital products brand operated by an individual based in Argentina. We sell downloadable digital products through our website at lumeralia.com and through the Hotmart platform.

This Privacy Policy explains what information we collect, how we use it, and your rights as a user — regardless of where you are located.

By accessing lumeralia.com, you agree to the practices described in this policy.

2. What data we collect

2.1 Data you provide indirectly through purchases

We sell our products through Hotmart, which acts as the Merchant of Record. Hotmart processes all payments and handles payment data directly. We do not collect or store credit card numbers or financial information.

Following a purchase, Hotmart may share with us the following data to facilitate product delivery:

• Your name
• Your email address
• Your country of residence

2.2 Data collected automatically through tracking technologies

When you visit lumeralia.com, we use the following tools that automatically collect behavioral and technical data:

Meta Pixel (Facebook/Instagram Ads): We use the Meta Pixel to measure the effectiveness of our advertising campaigns on Facebook and Instagram. This tool may collect your IP address, browser type, pages visited, time spent on pages, and actions taken on the site. This data is processed by Meta Platforms, Inc. under Meta's own Privacy Policy.

Hotmart Tracking: Hotmart uses tracking technologies to attribute purchases to marketing campaigns and to measure conversion. This data is processed by Hotmart under their own Privacy Policy.

We do not use Google Analytics at this time. If we add additional tracking tools in the future, this policy will be updated accordingly.

3. How we use your data

We use the data described above exclusively for the following purposes:

• To deliver purchased digital products to you
• To respond to customer support inquiries
• To measure and optimize the performance of our advertising campaigns
• To comply with applicable legal obligations

We do not sell your personal data to third parties. We do not use your data for automated decision-making or profiling beyond advertising campaign optimization.

4. Legal basis for processing (GDPR — EU users)

If you are located in the European Union or European Economic Area, we process your personal data on the following legal bases under the General Data Protection Regulation (GDPR), Regulation (EU) 2016/679:

Contractual necessity (Art. 6(1)(b)): We process your name and email to deliver the product you purchased.

Legitimate interests (Art. 6(1)(f)): We use behavioral data collected via the Meta Pixel to optimize our advertising — an interest we balance against your privacy rights.

Legal obligation (Art. 6(1)(c)): We may retain certain data to comply with applicable tax and accounting laws.

5. Data retention

We retain your data only for as long as necessary for the purposes described in this policy, or as required by applicable law.

• Purchase-related data (name and email shared by Hotmart): retained for the duration of your access to the product and for up to 5 years to comply with Argentine tax law (Ley 11.683 de Procedimiento Fiscal).
• Behavioral data collected via Meta Pixel: governed by Meta's own retention policies. We recommend reviewing Meta's Privacy Policy for details.

If you request deletion of your data, we will delete what we hold directly and, where technically possible, submit deletion requests to third-party processors on your behalf.

6. Third-party data processors

We share data with the following third parties solely to operate our business:

Hotmart: Payment processing, product delivery, and purchase tracking. Hotmart operates as an independent data controller for payment data and as a data processor for purchase-related data shared with us. Privacy Policy.

Meta Platforms, Inc.: Advertising measurement via the Meta Pixel. Meta operates as an independent data controller for data collected through the Pixel. Privacy Policy.

We do not transfer personal data to other third parties. If this changes, this policy will be updated and, where required by law, your consent will be obtained.

7. International data transfers

Lumeralia is operated from Argentina. Argentina has been recognized by the European Commission as a country providing an adequate level of data protection (Commission Decision 2003/490/EC).

Some of our third-party processors (Meta, Hotmart) may process data in the United States or other countries. Where these transfers occur, we rely on the processors' own compliance mechanisms, including Standard Contractual Clauses (SCCs) where applicable under GDPR.

8. Your rights

8.1 For users in the European Union (GDPR)

Under GDPR, you have the following rights:

• Right of access (Art. 15): request a copy of the personal data we hold about you
• Right to rectification (Art. 16): correct inaccurate or incomplete data
• Right to erasure (Art. 17): request deletion of your data
• Right to restriction of processing (Art. 18): limit how we use your data
• Right to data portability (Art. 20): receive your data in a structured, machine-readable format
• Right to object (Art. 21): object to processing based on legitimate interests
• Right to lodge a complaint: with your local supervisory authority (e.g., in Spain: AEPD; in Germany: your state DPA)

8.2 For users in California, USA (CCPA / CPRA)

Under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), California residents have the following rights:

• Right to know what personal information we collect, use, disclose, or sell
• Right to delete personal information we hold about you
• Right to opt out of the sale or sharing of personal information
• Right to non-discrimination for exercising your privacy rights

We do not sell personal information as defined under CCPA/CPRA. We do share behavioral data with Meta for advertising purposes, which may qualify as "sharing" under CPRA. You can opt out of this by using Meta's off-Facebook activity controls.

8.3 For users in Argentina (Ley 25.326)

Under Argentine Personal Data Protection Law No. 25.326, you have the right to access, rectify, and suppress your personal data held by us. Lumeralia is not currently registered as a data controller with the Argentine Agencia de Acceso a la Información Pública (AAIP), as we do not maintain a database of personal data beyond what is strictly necessary for product delivery.

8.4 For users in other Latin American countries

Users in Brazil (LGPD), Mexico (LFPDPPP), Chile, Colombia, and other countries with applicable data protection laws have rights similar to those listed above. We respect these rights and will respond to requests from users in any jurisdiction. To exercise your rights, contact us using the information below.

9. Cookies and tracking technologies

Lumeralia.com uses the Meta Pixel, which places a cookie in your browser to track behavior across sessions and across websites. This constitutes use of non-essential cookies under GDPR and similar frameworks.

By continuing to use our site, you acknowledge the use of this tracking technology. If you wish to opt out:

• Use Meta's off-Facebook activity controls
• Use browser extensions that block tracking pixels (e.g., uBlock Origin)
• Enable "Do Not Track" in your browser settings (note: not all tools honor this signal)

We do not use any additional cookies beyond those placed by the Meta Pixel and Hotmart's tracking system.

10. Children's privacy

Our products are intended for adults aged 18 and over. We do not knowingly collect personal data from children under 13 (or under 16 for EU residents). If you believe a child has provided us with personal data, please contact us immediately and we will delete it.

11. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The date at the top of this document reflects the most recent update. We encourage you to review this policy periodically.

For material changes that affect your rights, we will make reasonable efforts to notify affected users where we have contact information available.

12. Contact

To exercise your privacy rights, ask a question about this policy, or submit a complaint, contact us at: