Privacy Policy

Last Updated: November 1, 2026

1. Overview

Welcome to Subluo.

Subluo is an online beauty and cosmetics retailer operated by BRIGHTORA LLC, a company registered in the United States.

We respect the privacy of our customers and understand the importance of protecting personal information when shopping online.

This Privacy Policy describes how we collect, process, use, retain, and share personal information when you browse our website at https://www.subluo.com, purchase products, communicate with our customer service team, or otherwise interact with our online store.

We handle personal information in accordance with applicable privacy and consumer protection laws.

By accessing our website, you acknowledge that this Privacy Policy has been made available to you. Where applicable law requires consent for specific data processing activities, we will request it separately.

2. Information We May Collect

The personal information we collect depends on how you interact with Subluo and the services you choose to use.

Information Provided by Customers

When you place an order, create an account, or communicate with us, we may collect:

• Your full name and contact details.

• Email address and telephone number.

• Billing and delivery addresses.

• Purchased items, order numbers, and transaction records.

• Payment-related information necessary to complete purchases.

• Messages, inquiries, and correspondence with customer support.

• Marketing preferences and other information voluntarily submitted.

Payments are generally processed through authorized third-party payment providers. Customers should never send complete payment card information through ordinary customer service emails.

Information Collected Through Website Usage

When you browse Subluo, our website and authorized service providers may automatically process certain technical information, including:

• Internet Protocol (IP) address.

• Browser type and device characteristics.

• Operating system and device settings.

• Website pages viewed and browsing activity.

• Referral sources and interactions with website features.

• Cookie identifiers and similar technologies.

• Approximate geographic location based on technical information.

• Security, diagnostic, and website performance data.

The precise information collected may vary according to the technologies used, your privacy settings, and applicable law.

3. Reasons We Process Personal Information

We use personal information to operate our online beauty store and provide customers with the services they request.

Our purposes may include:

• Confirming and processing purchases.

• Facilitating payment transactions.

• Preparing, dispatching, and delivering orders.

• Providing shipment notifications and order updates.

• Managing returns, exchanges, and refunds.

• Responding to customer service inquiries.

• Detecting potentially fraudulent or unauthorized activities.

• Maintaining website functionality and security.

• Analyzing website performance and improving shopping experiences.

• Sending promotional communications when permitted.

• Evaluating advertising effectiveness where applicable.

• Meeting relevant legal, accounting, and regulatory obligations.

When required by law, we process personal information using an appropriate legal basis, including the performance of a contract, compliance with legal obligations, legitimate business interests, or your consent.

4. E-Commerce Platform and Business Partners

Subluo may use Shopify and other third-party technology providers to operate its online storefront and support its e-commerce activities.

Where Shopify is used, its services may support website functionality, checkout processing, customer accounts, payment integrations, and order administration.

Additional information regarding Shopify's privacy practices is available at:

https://www.shopify.com/legal/privacy

To provide our services, we may share necessary information with authorized business partners, including:

• Payment processing companies.

• Delivery carriers and shipping providers.

• Inventory suppliers and order fulfillment partners.

• Customer service technology providers.

• Website infrastructure and cybersecurity services.

• Data analytics providers.

• Advertising and marketing partners, where applicable.

Some suppliers or fulfillment partners may operate outside the United States.

Where necessary to fulfill an order, limited customer information, such as recipient details and shipping addresses, may be provided to the relevant fulfillment or delivery partner.

We seek to work with providers that handle personal information responsibly and in accordance with applicable contractual and legal requirements.

5. Cookies and Website Tracking

Our website may use cookies, pixels, and similar tracking technologies to support online store operations and enhance website functionality.

These technologies may help us:

• Maintain shopping carts and browsing sessions.

• Remember customer preferences.

• Support authentication and website security.

• Identify technical problems.

• Understand how visitors interact with our store.

• Measure website performance.

• Support advertising and promotional activities where enabled.

Some cookies are necessary for essential website functions, while others may be used for analytics or marketing.

Where legally required, we will request consent before activating non-essential tracking technologies.

You may be able to adjust cookie preferences through available website privacy controls or your browser settings.

Restricting certain cookies may affect the operation of some website features.

6. Advertising, Analytics, and Promotional Activities

Subluo may use third-party advertising platforms and measurement technologies to introduce customers to our products and evaluate promotional performance.

Depending on the services enabled, these providers may process technical identifiers, website activity, advertising interactions, and purchase-related events.

Advertising technology providers may include platforms such as AppLovin, where such services have been implemented.

For information about AppLovin's privacy practices, please visit:

https://legal.applovin.com/privacy/

Mentioning an advertising provider in this Privacy Policy does not necessarily mean that its technology is currently active on our website.

When implementing advertising or measurement services, we will assess applicable disclosure, consent, and opt-out requirements.

Certain data disclosures for advertising may qualify as targeted advertising, sharing, or a sale of personal information under applicable privacy legislation, even where no direct monetary payment is involved.

Where required by law, eligible customers will have access to appropriate privacy choices.

7. When Personal Information May Be Disclosed

Subluo does not disclose personal information without a legitimate business purpose or other appropriate legal basis.

Information may be disclosed in circumstances such as:

• Completing customer purchases and transactions.

• Coordinating shipping and product fulfillment.

• Processing refunds or resolving payment disputes.

• Providing technical support and website maintenance.

• Operating authorized analytics or advertising services.

• Investigating fraud or protecting website security.

• Responding to legally valid government or regulatory requests.

• Meeting applicable legal obligations.

• Facilitating a lawful merger, acquisition, restructuring, or transfer of business assets.

We do not provide customer information to unrelated third parties for their independent direct marketing purposes without an appropriate legal basis.

Where personal information is disclosed to service providers, we seek to limit disclosure to information reasonably necessary for the relevant service.

8. Processing Information Across Borders

Although Subluo is operated by a company registered in the United States, some business partners, technology providers, and fulfillment services may operate internationally.

Consequently, customer information may be accessed, stored, or processed in jurisdictions outside the customer's country of residence.

For example, order fulfillment arrangements may involve service providers located in China or other countries.

Privacy laws and data protection standards may differ between jurisdictions.

Where applicable law requires specific protections for international data transfers, we will take appropriate steps to implement the necessary safeguards.

9. How Long We Keep Personal Information

We retain personal information only for as long as reasonably necessary to fulfill legitimate business purposes and comply with applicable requirements.

Retention considerations may include:

• Completing purchases and delivering products.

• Maintaining customer service and transaction records.

• Processing returns and refunds.

• Meeting tax and financial reporting obligations.

• Addressing legal claims or business disputes.

• Investigating fraudulent transactions.

• Complying with statutory recordkeeping requirements.

Different categories of information may be retained for different periods.

When information is no longer reasonably required, we will take appropriate steps to delete, anonymize, or otherwise securely dispose of it, subject to applicable legal obligations.

10. Your Choices and Privacy Rights

Depending on your place of residence and applicable privacy laws, you may have certain rights regarding your personal information.

These may include the ability to:

• Request information about the personal data we process.

• Access eligible personal information.

• Request correction of inaccurate or incomplete information.

• Request deletion of qualifying personal information.

• Obtain a portable copy of certain information.

• Withdraw consent for processing based on consent.

• Object to or request restrictions on certain processing.

• Opt out of qualifying targeted advertising or data sharing.

• Exercise other rights granted by applicable privacy legislation.

To submit a privacy-related request, please contact:

Email: support@subluo.com

We may request reasonable information to verify your identity before fulfilling certain requests.

Subluo will review and respond to privacy requests within the periods required by applicable law.

We will not unlawfully discriminate against customers for exercising their privacy rights.

11. Privacy Rights for United States Residents

Residents of certain U.S. states may have additional privacy protections under applicable state consumer privacy laws.

Depending on eligibility and the relevant legislation, these rights may include access, correction, deletion, data portability, and opting out of certain personal information processing activities.

Some advertising or analytics practices may be legally classified as the sale or sharing of personal information or processing for targeted advertising.

Where applicable, Subluo will provide legally required methods to exercise opt-out rights.

Customers may contact support@subluo.com to submit privacy requests.

Where legally required and technically applicable, we will recognize supported universal opt-out preference signals, including Global Privacy Control.

12. Additional Rights for International Customers

Customers residing in the European Economic Area (EEA), the United Kingdom, or other jurisdictions with specific data protection legislation may be entitled to additional privacy rights.

Where applicable, these protections may include:

• Accessing personal information.

• Correcting inaccurate records.

• Requesting deletion under qualifying circumstances.

• Restricting or objecting to certain processing.

• Requesting data portability.

• Withdrawing consent when consent is the legal basis for processing.

Depending on the processing activity, our legal basis may include contractual necessity, legitimate interests, legal compliance, or consent.

Eligible individuals may also have the right to submit complaints to their relevant data protection authority.

To exercise applicable privacy rights, please contact our customer support team.

13. Protecting Children's Information

Subluo is intended for a general adult audience and is not specifically directed toward individuals under 18 years of age.

We do not knowingly collect personal information directly from children under 18 for the purpose of marketing our products to them.

If a parent or legal guardian believes that a child has submitted personal information to our website inappropriately, they may contact us at support@subluo.com.

We will review the request and take appropriate steps consistent with applicable law.

14. Information Security Measures

Protecting customer information is an important part of our online business operations.

We implement reasonable administrative, technical, and organizational safeguards intended to reduce the risk of unauthorized access, accidental loss, misuse, alteration, or disclosure of personal information.

These safeguards may include access controls, secure payment integrations, and appropriate website security procedures.

However, no internet-based service, electronic communication, or digital storage system can guarantee absolute security.

Customers are encouraged to maintain the confidentiality of their account credentials and contact us if they identify suspicious activity involving their information.

15. External Links and Independent Services

Our online store may contain links to third-party websites, payment services, or other online resources.

External websites operate under their own terms, policies, and data handling practices.

Subluo does not control the privacy practices of independent third-party services and is not responsible for their separate data processing activities.

We encourage customers to review the privacy notices of external websites before sharing personal information.

16. Updates to Our Privacy Practices

We may revise this Privacy Policy periodically to reflect changes in our services, operational practices, technology, legal requirements, or business relationships.

When a revision is published, we will update the Last Updated date at the beginning of this document.

If an amendment requires additional notice or customer consent under applicable law, we will take the necessary steps.

We encourage visitors to review this page periodically to remain informed about how personal information is handled.

17. Contact Subluo About Privacy

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or need information about our personal data practices, please contact us.

Brand / Store Name: Subluo

Legal Business Entity: BRIGHTORA LLC

Registered Business Address:

716 STRATTON ST APT 224
SEGUIN, TX 78155
United States

Customer Service Email: support@subluo.com

Telephone: +1 248-830-8125

Website: https://www.subluo.com

We will review privacy-related inquiries and provide assistance in accordance with applicable legal requirements.

Thank you for visiting Subluo and taking the time to learn about our privacy practices.