Privacy Policy — House Number.01

1. Scope and Controller

This Privacy Policy explains how neuelux AG, operating the website housenumber01.com under the brand House Number.01 ("we", "us", "our"), collects, uses and protects personal data of visitors to our website, subscribers to our newsletter, and individuals who contact us.

The controller responsible for the processing of your personal data described in this Privacy Policy is:

neuelux AG, Bachwiesenstrasse 42, 5436
Würenlos, Switzerland, Commercial register (UID):
CHE-319.649.718

You can reach us regarding any data protection matter at: office@housenumber01.com

As a Swiss company, we process personal data in accordance with the Swiss Federal Act on Data Protection (revFADP). Because we offer our products to individuals located in the European Union and European Economic Area, the EU General Data Protection Regulation (GDPR) also applies to the corresponding processing under Art. 3(2) GDPR.

This Privacy Policy applies to housenumber01.com and to our direct communications with you (e.g. e-mail). It does not apply to third-party websites we may link to, such as Instagram, which have their own privacy practices.

2. Personal Data We Collect

Data you provide to us directly

• Newsletter sign-up: when you enter your e-mail address to receive launch updates, we collect that e-mail address.
• Inquiries: when you use the "Inquire" link on a product page or otherwise contact us by e-mail (office@housenumber01.com or press@housenumber01.com), we receive your e-mail address, your name if you provide it, and the content of your message, including any details you share about a desired commission.

Data collected automatically

When you visit our website, certain technical data is collected automatically via Google Analytics, including: your IP address, browser and device type, operating system, pages viewed, referring website, approximate location (derived from your IP address, typically at city/country level), date and time of visit, and how you interact with the site (e.g. links clicked). See Section 4 for detail on cookies and analytics.

Made-to-order commissions

We do not currently operate an online checkout. Orders are arranged individually further to an inquiry. If you commission a piece, we will collect the additional personal data needed to fulfil it, such as your delivery address and any measurements or preferences you provide.

3. Purposes of Processing and Legal Bases

We process your personal data for the following purposes:

• Responding to inquiries about our products and handling commission requests (necessary to take pre-contractual steps at your request — Art. 6(1)(b) GDPR / Art. 31 revFADP).
• Sending newsletter and marketing e-mails, based on your consent when you sign up (Art. 6(1)(a) GDPR). You may withdraw this consent at any time, free of charge, without affecting the lawfulness of processing before withdrawal.
• Operating, securing and improving our website, including understanding how visitors use it, which is in our legitimate interest (Art. 6(1)(f) GDPR), balanced against your interests and fundamental rights.
• Fulfilling made-to-order commissions, including coordinating production and delivery with our manufacturing partner (performance of a contract, Art. 6(1)(b) GDPR).
• Complying with legal obligations, such as Swiss commercial and accounting law requirements (Art. 6(1)(c) GDPR / statutory obligation under Swiss law).

We do not use your personal data for any purpose incompatible with those listed above without informing you.

4. Cookies and Tracking Technologies

Our website uses cookies and similar technologies (such as local storage) to enable core functionality and to understand how visitors use our site. A cookie is a small text file placed on your device by your browser.

Categories we use

• Essential cookies: required for the website to function correctly (e.g. remembering basic session state). These do not require consent.
• Analytics cookies: we use Google Analytics 4, a web analytics service provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), which relies on Google LLC (United States) as sub-processor (together "Google"). Google Analytics uses cookies to help us understand how visitors use our website (pages visited, time on site, navigation paths) on an aggregated basis. Our website includes a small first-party script that forwards certain on-site interactions (e.g. which contact link you click) to Google Analytics as events.
• Marketing/functional cookies: our newsletter tool, Klaviyo, may set cookies or use similar technologies to display sign-up forms and to measure engagement with our e-mails (see Section 5).

Your choices

You can control cookies at any time through your browser settings, including blocking or deleting them. Please note that blocking essential cookies may affect how the website functions. We do not currently use a cookie consent banner.

Because no consent banner is currently implemented, our use of Google Analytics is based on our legitimate interest in understanding and improving how visitors use our website (Art. 6(1)(f) GDPR), rather than on consent. We are not aware of Google combining data collected through our website with your Google account, but Google's own privacy policy governs any such processing on their part.

5. Newsletter and E-mail Marketing

If you sign up to our newsletter, we use Klaviyo (Klaviyo, Inc., 125 Summer Street, Boston, MA, United States), an e-mail marketing platform, to manage the sign-up, send you launch updates and other marketing communications, and measure whether e-mails are opened or links within them are clicked.

We process your e-mail address for this purpose on the basis of your consent (Art. 6(1)(a) GDPR), given when you submit the sign-up form. You can withdraw your consent and unsubscribe at any time, free of charge, using the unsubscribe link in any e-mail we send or by contacting us at office@housenumber01.com. Withdrawal does not affect the lawfulness of processing before it was withdrawn.

Klaviyo acts as our processor and only uses your data on our instructions. Where your data is transferred to the United States, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses and/or Klaviyo's certification under the EU-U.S. Data Privacy Framework, where applicable.

6. Recipients of Personal Data and International Transfers

We only share your personal data where necessary for the purposes described above, or where we are legally required to. Recipients may include:

• Google Ireland Limited / Google LLC, for website analytics (Section 4).
• Klaviyo, Inc., for newsletter and e-mail marketing (Section 5).
• Our IT and website hosting provider(s), to operate and secure housenumber01.com.
• Our manufacturing partner in Morrovalle (Macerata), Italy, where you commission a made-to-order piece, we share the details needed to produce and ship it (e.g. your name and delivery address).
• Professional advisors (e.g. auditors, lawyers), where necessary for our business.
• Swiss and foreign authorities or courts, where we are legally obliged to disclose data.

We do not sell your personal data to third parties.

International transfers. Our manufacturing partner is located in Italy (EU/EEA), so no additional safeguards are required for that transfer. Google and Klaviyo are based in, or transfer data to, the United States. For such transfers, we rely on recognized safeguards, in particular the European Commission's Standard Contractual Clauses (2021/914) and, where applicable, the recipient's certification under the EU-U.S. Data Privacy Framework, to ensure your data continues to benefit from an adequate level of protection.

7. Retention Periods

We retain personal data only as long as necessary for the purposes described in this Privacy Policy, or as required by law:

• Newsletter data: for as long as you remain subscribed; if you unsubscribe, we delete or anonymize your e-mail address within our systems within a reasonable period thereafter (typically no more than 30 days), subject to what Klaviyo's own retention settings allow.
• Inquiries and commission requests: for as long as needed to handle your request and for a reasonable follow-up period afterwards (typically up to 24 months from your last contact with us), unless a longer period is required, for example under Swiss accounting-record retention rules (generally 10 years) where an inquiry results in a completed transaction.
• Website analytics data: retained in Google Analytics in line with the retention period configured in our account (Google's own default is 14 months), after which it is automatically deleted or aggregated.

Where we no longer need personal data for these purposes, we delete or anonymize it.

8. Data Security

We take appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, misuse or disclosure, including encrypted transmission of data between your browser and our website (HTTPS), restricting access to personal data to those who need it to perform the purposes described above, and using reputable, established third-party service providers. No method of transmission or storage is completely secure, but we work to protect your data using appropriate means for the scale of our business.

9. Your Rights

Subject to the conditions set out in applicable law, you have the right to:

• Access the personal data we hold about you;
• Rectification of inaccurate or incomplete data;
• Erasure of your data, in particular where it is no longer needed or you withdraw consent;
• Restriction of the processing of your data in certain circumstances;
• Object to processing carried out on the basis of our legitimate interests, including direct marketing, at any time;
• Data portability, i.e. to receive the data you provided to us in a structured, commonly used, machine-readable format;
• Withdraw your consent at any time, with effect for the future, where processing is based on consent (see Sections 3 and 5).

To exercise any of these rights, please contact us at office@housenumber01.com. We may need to verify your identity before we can act on your request. We will respond within the timeframe required by applicable law.

You also have the right to lodge a complaint with a competent data protection supervisory authority, see Section 12.

10. Children's Privacy

Our website and products are directed at adults and not intended for individuals under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will take steps to delete it.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time, for example to reflect changes to our website, our data processing practices, or applicable law. The version published on this page is always the current one. Where required by law, we will notify you of material changes by appropriate means.

12. Contact and Right to Lodge a Complaint

For any questions about this Privacy Policy or our handling of your personal data, please contact us:

neuelux AG, Bachwiesenstrasse 42, 5436
Würenlos, Switzerland
E-mail: office@housenumber01.com

You have the right to lodge a complaint with a data protection supervisory authority. In Switzerland, the competent authority is:

Federal Data Protection and Information Commissioner (FDPIC), Feldeggweg 1, 3003 Bern, Switzerland www.edoeb.admin.ch

If you are located in the EU/EEA, you may also lodge a complaint with the supervisory authority of your country of habitual residence, place of work, or the place of the alleged infringement.