PRIVACY POLICY

1. ABOUT THIS POLICY AND WHO CONTROLS YOUR DATA

Minvio is the personal information controller or data controller for the processing described in this Policy, except where another party independently determines how it uses your information.

3. PERSONAL INFORMATION WE COLLECT

Depending on how you use Minvio, we may collect:

• identity and contact information, such as your name, email address, telephone number, billing address, delivery address, and gift recipient details;
• account information, such as login credentials, account preferences, saved addresses, and order history;
• order and transaction information, such as products, device model, personalization selections, quantity, price, currency, discounts, delivery method, payment status, refund information, and transaction references;
• payment-related information, such as billing contact details, payment method type, masked card or account details, authorization status, and fraud-screening results received from payment providers. Full payment credentials are generally collected and processed directly by the payment provider rather than stored by Minvio;
• personalization content, such as photographs, names, messages, artwork, logos, and other files or instructions submitted for custom printing;
• communications and support information, including live-chat messages, emails, reviews, survey responses, claim evidence, photographs, video, and records relating to returns, refunds, delivery problems, or warranty requests;
• technical and usage information, such as IP address, browser and device type, operating system, language, approximate location derived from IP, referring page, pages viewed, clicks, cart activity, session information, advertising identifiers, and cookie or similar-technology data; and
• fraud, compliance, and security information, such as risk signals, failed transaction information, account or order anomalies, sanctions-screening results where applicable, and records needed to protect the Site or comply with law.

We do not ask you to provide government identification, financial account credentials, health information, or other sensitive personal information unless it is reasonably necessary for a specific lawful purpose and clearly requested. Please do not include unnecessary sensitive information in personalization files or support messages.

4. HOW WE COLLECT INFORMATION

We collect personal information:

• directly from you, when you browse the Site, create an account, add an item to your cart, upload content, place an order, submit a review, join a promotion, or contact us;
• from another customer, when someone purchases a gift for you or provides your delivery details. The purchaser must be authorized to provide that information;
• automatically, through cookies, pixels, log files, order-attribution tools, and similar technologies;
• from service providers, including payment providers, fraud-prevention services, fulfillment partners, carriers, address-verification providers, customer-support providers, and analytics or advertising partners; and
• from public or social-media sources, where you communicate publicly with Minvio, tag us, submit public content, or authorize a social-media platform to share information with us.

5. WHY WE USE PERSONAL INFORMATION

We may use personal information to:

• operate, maintain, personalize, and improve the Site and online store;
• create and manage accounts, carts, wish lists, and customer preferences;
• review, accept, produce, print, fulfill, ship, track, and deliver orders;
• process payments, refunds, returns, replacements, and warranty claims;
• communicate about orders, service notices, inquiries, and customer support;
• verify personalization instructions and resolve production or quality issues;
• detect, investigate, and prevent fraud, chargebacks, abuse, security incidents, and unlawful activity;
• perform analytics, measure Site and campaign performance, and understand customer preferences;
• provide advertising, promotions, or marketing where permitted and manage consent or opt-out choices;
• establish, exercise, or defend legal claims and enforce our Terms and policies;
• comply with tax, accounting, customs, sanctions, consumer-protection, data-protection, law-enforcement, and other legal obligations; and
• carry out a corporate transaction, audit, risk review, or business continuity activity subject to appropriate safeguards.

Where required by law, we will not use personal information for a materially incompatible new purpose without giving additional notice or obtaining consent.

6. LEGAL BASES FOR PROCESSING

Where applicable law requires a legal basis, we rely on one or more of the following:

• performance of a contract, including taking steps requested before a purchase and processing, producing, delivering, supporting, returning, or refunding an order;
• legitimate interests, such as operating and improving our business, securing the Site, preventing fraud, measuring performance, maintaining records, and communicating with customers, where those interests are not overridden by your rights;
• consent, including for certain marketing communications, non-essential cookies, advertising technologies, or uses of submitted content where consent is required. You may withdraw consent without affecting processing already lawfully completed;
• compliance with a legal obligation, including tax, accounting, customs, sanctions, consumer-protection, and lawful disclosure requirements; and
• establishment, exercise, or defense of legal claims, or another basis permitted by applicable law.

If required information is not provided, we may be unable to create an account, personalize a product, process payment, deliver an order, or respond to a request.

7. PERSONALIZATION CONTENT

Customer Content may itself contain personal information, including names, faces, locations, messages, or information about another person. You must have the right or permission to provide that content for the requested personalization.

We and our production or fulfillment providers use Customer Content only as reasonably necessary to review the order, prepare the print file, manufacture and deliver the product, provide support, resolve claims, maintain security and necessary business records, and comply with law. We will not use private Customer Content in public advertising or marketing without separate permission.

Please avoid submitting confidential information or sensitive personal information that is not necessary for the design. If Customer Content depicts a child or another person, you are responsible for having the authority required to submit and use that content.

8. PAYMENT INFORMATION

Payments may be processed by third-party payment service providers and acquiring partners selected at checkout. Those providers may collect payment credentials, identity and billing information, device information, and transaction data directly from you and use them for authorization, fraud prevention, compliance, settlement, refunds, and dispute handling.

Minvio generally receives information needed to manage the transaction, such as the payment method type, transaction identifier, amount, currency, payment status, masked account or card information, and risk or verification results. We do not normally receive or store your complete card number, card security code, online-banking password, or wallet credentials.

A payment provider may act as our processor for some activities and as an independent controller for its own legal, compliance, fraud-prevention, and financial-service obligations. Its privacy notice may also apply.

9. COOKIES, ANALYTICS, AND ADVERTISING TECHNOLOGIES

We use cookies and similar technologies to keep the Site functioning, remember cart or session information, secure transactions, understand traffic and order attribution, measure performance, and, where permitted, provide or measure advertising.

Depending on the Site configuration and your consent choices, analytics and advertising partners may include services provided by Google, Meta/Facebook, and TikTok. These technologies may collect online identifiers, IP address, device and browser information, pages viewed, interactions, referral or campaign information, and purchase or conversion events. We do not intentionally send private personalization images or full payment credentials to advertising partners.

For cookie categories, purposes, providers, duration, and available controls, please review our Cookie Policy. Where required, non-essential technologies will be used only after consent, and you may change or withdraw your choice through the cookie settings made available on the Site.

10. MARKETING COMMUNICATIONS

We may send service communications needed to manage an account, order, delivery, refund, return, warranty claim, security issue, or policy change. These are not promotional messages and may still be sent when reasonably necessary to provide a requested service.

We will send promotional email, SMS, or similar direct marketing only where permitted by law. You may opt out at any time by using the unsubscribe method in the message or sending a request through our support email. Opting out of marketing does not prevent necessary transactional or service communications.

If you interact with advertising on a third-party platform, you may also need to use that platform’s own privacy or advertising settings.

11. WHEN WE DISCLOSE PERSONAL INFORMATION

We may disclose personal information only as reasonably necessary to:

• website, hosting, cloud-storage, security, ecommerce, and technology providers;
• payment, banking, fraud-prevention, and transaction-processing providers;
• printing, production, quality-control, fulfillment, packaging, and warehousing partners;
• carriers, postal services, customs brokers, address-verification services, and customs or import authorities;
• live-chat, email, customer-support, review, survey, and communication providers;
• analytics and advertising partners, subject to applicable consent and opt-out requirements;
• professional advisers, auditors, insurers, financial institutions, and contractors bound by appropriate duties;
• regulators, courts, law-enforcement bodies, tax authorities, or other recipients where disclosure is legally required or reasonably necessary to protect rights, safety, security, or prevent fraud; and
• a buyer, investor, lender, successor, or adviser involved in a merger, financing, reorganization, sale of assets, insolvency, or similar corporate transaction, subject to appropriate confidentiality and legal safeguards.

Service providers acting on our instructions may use the information only for authorized purposes and must protect it as required by contract and applicable law. We do not disclose private personalization content to advertising partners for use in their advertising.

12. TARGETED ADVERTISING

Minvio does not sell personal information in exchange for money. However, the use of certain advertising cookies or pixels may be considered a “sale,” “sharing,” or use for targeted advertising under some privacy laws, even when no money is exchanged.

Where such laws apply, you may use the Site’s cookie controls or send a privacy request to opt out. We will honor legally valid requests to the extent required and technically applicable. Cookie choices are browser- and device-specific and may need to be repeated after clearing cookies or using another browser or device.

13. INTERNATIONAL DATA TRANSFERS

Elorivo Limited is incorporated in Hong Kong, Minvio primarily serves customers in the Philippines, and our service providers, production partners, carriers, and technology systems may operate in Hong Kong, the Philippines, and other countries. Your information may therefore be processed outside the country where you live.

Privacy laws and enforcement mechanisms may differ between countries. Where required, we use contractual, organizational, technical, or other legally recognized safeguards for cross-border transfers and require recipients to protect personal information consistently with applicable law.

You may contact us to request further information about safeguards relevant to a transfer, subject to confidentiality and legal restrictions.

14. DATA RETENTION

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including to complete and support orders, maintain security, prevent fraud, satisfy tax, accounting, customs, and recordkeeping requirements, resolve disputes, and establish or defend legal claims.

Retention periods depend on the type of information and context. For example:

• order, transaction, refund, and accounting records are retained for the period required by applicable financial, tax, consumer, and limitation laws;
• support, return, warranty, and dispute records are retained until the matter is resolved and for a reasonable period afterward;
• personalization files are retained as needed for production, fulfillment, quality review, customer support, disputes, fraud prevention, backups, and legal requirements, then deleted or anonymized when no longer reasonably needed;
• account information is retained while the account remains active and afterward where necessary for legitimate business or legal purposes;
• marketing information is retained until you unsubscribe or object, subject to a limited suppression record needed to honor your choice; and
• cookie and analytics information is retained according to the duration described in our Cookie Policy or the relevant provider’s settings.

When information is no longer required, we take reasonable steps to delete, anonymize, or securely isolate it. Residual copies may remain temporarily in backups and be removed through the normal backup cycle.

15. INFORMATION SECURITY AND DATA BREACHES

We use reasonable administrative, technical, contractual, and physical safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or disclosure. Measures may include access controls, secure transmission, system monitoring, restricted provider access, staff or contractor confidentiality, and incident-response procedures.

No website, transmission, or storage system is completely secure. You are responsible for protecting your account credentials, using a unique password, and notifying us promptly if you suspect unauthorized use.

If a personal-data breach occurs, we will investigate, mitigate the risk, and notify affected individuals or regulators when and within the period required by applicable law.

16. YOUR PRIVACY RIGHTS

Depending on the law that applies to you, you may have the right to:

• be informed about how your personal information is processed;
• request access to or a copy of your personal information;
• request correction of inaccurate or incomplete information;
• request deletion, blocking, restriction, or cessation of certain processing;
• object to processing based on legitimate interests or for direct marketing;
• withdraw consent at any time where processing relies on consent;
• request data portability where legally applicable;
• opt out of certain targeted advertising, sale, or sharing practices where applicable;
• request information about significant automated decision-making and challenge a decision where the law provides that right;
• lodge a complaint with a competent privacy regulator; and
• seek compensation or another remedy where provided by law.

These rights are not absolute. We may retain or continue processing information where required or permitted by law, including to complete a transaction, comply with legal obligations, protect other persons’ rights, prevent fraud, or establish or defend legal claims.

18. PHILIPPINES, HONG KONG, AND OTHER REGIONAL RIGHTS

Customers in the Philippines may have rights under the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules. You may contact the National Privacy Commission if you believe your rights have been violated. We encourage you to contact Minvio first so that we can try to resolve the matter promptly, but doing so does not restrict your right to complain to the regulator.

As Elorivo Limited is incorporated in Hong Kong, applicable processing may also be subject to the Personal Data (Privacy) Ordinance (Cap. 486). Information about data-access and correction rights is available from the Office of the Privacy Commissioner for Personal Data, Hong Kong.

Individuals in the European Economic Area, United Kingdom, or another jurisdiction may have additional rights under local privacy law and may complain to the competent supervisory authority. Nothing in this Policy limits a right that cannot lawfully be limited.

19. CHILDREN’S PRIVACY

The Site is intended for customers who are at least the age of legal majority in their place of residence, or who use the Site with the involvement and consent of a parent or legal guardian as stated in our Terms of Use. We do not knowingly request personal information directly from a child who cannot lawfully provide it without appropriate parental or guardian authorization.

A parent or legal guardian who believes a child has provided personal information without proper authorization may contact us. We will investigate and take appropriate steps, which may include deletion, subject to legal retention obligations and the rights of other persons.

A customer may submit a photograph depicting a child for a personalized product only if the customer has the lawful authority and permissions required to do so.

20. AUTOMATED PROCESSING AND FRAUD PREVENTION

We and our service providers may use automated rules or risk-scoring tools to identify suspicious transactions, protect accounts, prevent fraud, comply with financial or sanctions requirements, and decide whether an order needs manual review.

We do not intend to make a decision based solely on automated processing that produces legal or similarly significant effects for you unless it is necessary for a contract, authorized by law, or based on your explicit consent and the safeguards required by applicable law are provided. Where you have a legal right to do so, you may request information, human review, or challenge a significant automated decision.

21. THIRD-PARTY LINKS, REVIEWS, AND SOCIAL MEDIA

The Site may link to third-party websites, payment pages, social networks, or services. Their privacy practices are governed by their own notices, and we encourage you to review them before providing information.

If you publish a product review, comment, photograph, video, testimonial, or social-media post, the information you choose to make public may be viewed, copied, or used by others. Do not publish information you wish to keep private. We may moderate submissions as described in our Terms, but cannot control information after it has been publicly shared or copied by others.

22. CHANGES TO THIS POLICY

We may update this Policy to reflect changes to our Site, products, providers, processing activities, security practices, or legal obligations. The updated version will be posted on this page with a revised “Last updated” date.

If a change materially affects how we use information already collected, we will provide additional notice or obtain consent where required by law. We encourage you to review this Policy periodically.