Privacy Policy

Elti Traders LP, with registered office at 6 Inns Court, Winetavern Street, Dublin, D08 DV20, Ireland (hereinafter, "we", "us", or "our"), is the operator of this website (the "Site") and handles personal information of users who access and interact with the Site (the "Users").

This Privacy Policy sets out how we collect, use, disclose and protect your personal information in accordance with applicable Australian privacy laws, including the Privacy Act 1988 (Cth) and the Australian Privacy Principles.

Although we are located outside Australia, this Privacy Policy applies where we collect or handle personal information relating to individuals in Australia.

The Site and related services are intended for individuals aged 18 years or over. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have inadvertently collected such information, we will take reasonable steps to delete it as soon as practicable.

We are committed to protecting your privacy and handling your personal information in a transparent and secure manner.

If you have any questions about this Privacy Policy or wish to make a privacy-related enquiry or complaint, you may contact us using the details below:

By post: Elti Traders LP, 6 Inns Court, Winetavern Street, Dublin, D08 DV20, Ireland
By email: privacy@freebeautyadvice.com

We have not appointed a Data Protection Officer, as this is not required under applicable Australian privacy laws.

1. Purpose of the treatment

Users' personal data will be processed lawfully by the Data Controller pursuant to art. 6 of the Regulation for the following processing purposes:

a. Contractual obligations and provision of the service : to implement the regulation of the prize event, which is accepted by the User during registration; fulfill specific User requests. The User's data collected by the Data Controller for the purpose of possible participation include: name, surname, date of birth, gender, address, house number, city, postal code, e-mail, telephone number, as well as all personal information of the 'User possibly and voluntarily provided. Unless the User gives the Owner a specific and optional consent to the processing of their data for marketing purposes or for the purpose of communicating data to the Owner's Partners pursuant to article 2 below, the above data will be used by the Owner at the exclusive purpose of ascertaining the identity of the User (also by validating the e-mail address), thus avoiding possible scams or abuses and contacting the User for service reasons only (e.g. managing any participation by the User at the prize event, notify any winnings and manage the phase of attribution and delivery of prizes; contact the User to obtain additional data and information - such as a copy of the identity document - possibly requested by the notary and by the Chamber of Commerce official in charge of the competitions prizes, in order to ascertain their identity and avoid scams and abuses; make any urgent communications by telephone in phase d withdrawal and use of prizes). Without prejudice to the provisions elsewhere in this privacy statement, in no case will the Data Controller make the Users' personal data accessible to other Users.;

b. Administrative-accounting purposes : i.e. to carry out activities of an organisational, administrative, financial and accounting nature, such as internal organizational activities and functional activities for the fulfillment of contractual and pre-contractual obligations;

c. Legal obligations: to comply with obligations imposed by applicable Australian laws and regulations (for example, obligations under taxation laws, consumer protection laws, or other applicable Commonwealth, State or Territory legislation), including obligations under the Privacy Act 1988 (Cth) and related regulatory requirements.

The provision of personal data for the processing purposes indicated above is optional but necessary, since failure to provide them will make it impossible for the User to use the services offered by the Data Controller and participate in the prize event.

The personal data that are necessary for the pursuit of the processing purposes described in this article 1 are indicated with an asterisk within the initiative registration form.

2. Further processing purposes

2.1. Marketing (sending of advertising material, direct sales and commercial communication)

With the free and optional consent of the User, some personal data of the User (name, surname, date of birth, address, house number, city, zip code, e-mail, telephone number) may be processed by the Data Controller also for marketing purposes (sending of advertising material, direct sales and commercial communication), or so that the Data Controller can contact the User by post, e-mail, telephone (landline and/or mobile, with automated call or call with and/or without the intervention of an operator) and/or SMS and/or other messaging systems, to offer the User the purchase of products and/or services offered by the Owner and/or by third-party companies, present offers, promotions and commercial opportunities.

Profiling

The User's personal data (i.e. personal and contact details, and information relating to the services in which the User has expressed an interest) may also be processed by the Data Controller for profiling purposes, i.e. to reconstruct the User's tastes and consumption habits, identifying the User's consumer profile, in order to be able to send the User commercial offers consistent with the identified profile.

If consent is not given, the possibility of registering on the Site will not be affected in any way.

In the event of consent, the User may revoke it at any time by making a request to the Data Controller sending an email at privacy@freebeautyadvice.com

User ID verification

The Controller informs that, in compliance with the User’s Opt in, the User's personal data (i.e. personal and contact details) may also be processed by the Controller for security purposes, i.e. to verify the User's digital identity and to prevent fraud and abuse of personal data.

The User may at any time object to this processing by making a request to the Data Controller sending an email at privacy@freebeautyadvice.com

In case of lack of consent, the possibility of registering for the initiative will not be affected in any way.

In case of consent, the User may revoke it at any time, making a request to the Data Controller in the manner indicated in the following article "Rights of the interested parties".

The User can also easily oppose further sending of promotional communications via e-mail by clicking on the appropriate link for the withdrawal of consent, which is present in each promotional e-mail. If the User intends to revoke his consent to the sending of promotional communications by telephone, while continuing to receive promotional communications by e-mail, or vice versa, please send a request to the Data Controller in the manner indicated in the following article "Rights of Interested".

The Data Controller informs that, following the exercise of the right to object to the sending of promotional communications via e-mail, it is possible that, for technical and operational reasons (e.g. formation of contact lists already completed shortly before receipt by of the Holder of the opposition request) the User continues to receive some further promotional messages. If the User should continue to receive promotional messages after 24 hours have passed from exercising the right to object, please report the problem to the Owner, using the contacts indicated in the following article "Rights of the interested parties".

2.2. Communication of data to the Owner's Partners

With the User's free and optional consent , the User's personal data (name, surname, date of birth, address, house number, city, zip code, e-mail, telephone number and IP address) will be communicated from the Owner to the following categories of third-party companies:

(i) landline and mobile phone companies;

(ii) companies active in the publishing world (printed paper, internet, television and new media); (iii) companies active in the sector of electronic commerce of products and services;

(iv) companies operating in the energy sector;

(v) companies operating in the travel and leisure sector;

(vi) companies involved in professional and/or educational training;

(vii) advertising agencies, media centers and contact centres;

(viii) companies operating in the food sector; (ix) NGOs and ONLUS;

(x) companies operating in the financial and insurance sector

(xi) companies operating in the marketing and web communication sector.(collectively ,the “Partners of the Owner”).

We and our website sponsors, partners and selected third parties operate in the following areas:

Retail, Automotive, Lifestyle, Charity, Utility, Telecommunications, Insurance, Publishing / Media, Entertainment/Gaming/Leisure, Public Sector, Financial Services, Travel, Mail Order, Health/Beauty, Education, FMCG, Marketing Agencies and Brokers, Property, Pharmaceuticals, Claims Companies and Short Term Loans.

We may share your personal information with our partner WINR Data Pty Ltd (WINR) and their global partners for the purposes of:

Fraud Prevention - preventing others from misusing your personal information. This may involve identity verification for anti-fraud, anti-money laundering, anti-crime, asset recovery, debt collection and reuniting individuals with unclaimed assets; and

Digital Advertising - providing personalised advertising and content that is relevant to you. This may involve identity resolution for data analysis, matching and linkage.

WINR and their global partners will process and retain your personal information for as long as necessary for these specific purposes and on the lawful bases of legitimate interests and consent, where required.

You can submit a request to exercise any of your privacy rights to the Data Protection Officer at WINR https://www.winrdata.com/privacy-policy/

We may share your personal information with selected third-party partners for purposes such as targeted advertising, measurement, analytics, personalisation, profiling, identity resolution, fraud prevention, verification and compliance activities.

We will only collect, use or disclose your personal information for these purposes where you have provided your express, informed and voluntary consent (opt-in). You may withdraw your consent at any time.

Our third-party partners may use your personal information for purposes including campaign measurement and analytics, database matching and enrichment, identity verification, fraud detection and prevention, anti-money laundering compliance, national security, crime prevention and detection, enforcement, asset recovery and revenue collection, where permitted by applicable laws.

We will take reasonable steps to ensure that any third-party recipients handle your personal information in accordance with applicable Australian privacy laws and only for the purposes for which it was disclosed.

Where your personal information is disclosed to third parties, including for online data matching or fraud prevention purposes, such disclosure will occur solely on the basis of your consent or where otherwise required or authorised by law.

Such third-party partners include;

We use suitable safeguards to transfer your data to third countries such as standard contractual clauses and adequacy decisions to protect your rights. If you would like to receive a copy of our safety measures, you can contact us via email.

These categories include third-party companies that have requested to be explicitly indicated as Partners of the Owner's websites/domains.

The Owner's Partners, as independent data processors, will process the User's personal data for their own marketing purposes (direct sales, sending advertising material and commercial communication), and may contact the User by post, e-mail, telephone (fixed and/or mobile, with automated call or call communication systems with and/or without the intervention of an operator) and/or SMS and/or MMS to offer the User the purchase of products and/ or services offered by the same categories of third-party companies and/or by other companies and presenting offers, promotions and commercial opportunities to the User. Once the transfer has taken place, it will be the responsibility of the Owner's Partner (except for cases in which the Partner is included in the above list and has already made its own information available there), to provide Users pursuant to art. 14 c. 3 of the Regulation, all the information required by

the same art. 14 of the Regulation.

In case of lack of consent, the possibility of registering for the Initiative will not be affected in any way.

In case of consent, the User may revoke it at any time, making a request to the Data Controller in the manner indicated in the following article "Rights of the interested parties" . Furthermore, it is possible to analytically select for which Partners you

intend to give your consent to the transfer of your personal data when registering for the competition.

The Owner informs that the User's personal data will be processed by the Owner's Partners as independent data processors, on the

basis of the specific information that will be issued by the Owner's Partners to Users

The Owner informs that the User's personal data will be processed by the Owner's Partners as independent data processors, on the basis of the specific information that will be issued by the Owner's Partners to Users. A list of the Owner's Partners is constantly updated and can be obtained by writing to the Owner at the addresses indicated in the following article "Rights of the interested parties".

3. Method of treatment and data retention

The Data Controller will process Users' personal data using paper, electronic and automated tools, in compliance with the provisions of the Applicable Law, in order to guarantee the confidentiality and security of the data and to avoid the risks of loss or destruction, even accidental, of the data themselves, unauthorized access or treatment that does not comply with the purposes indicated in this privacy statement. The data will be stored in a form that allows the identification of the User for the time strictly necessary for the purposes for which the data were collected and subsequently processed, and in any case within the limits of the law. In particular:

For the purposes referred to in article 1, letter. a) (contractual obligations and provision of the service) the data will be kept for the entire duration of the relationship with the Owner and subsequently, if the relationship is terminated, also for the ordinary limitation period of 10 years. For the purposes referred to in art. 1, lett. b) (administrative-accounting) the data will be kept for the entire duration of the relationship with the Owner and subsequently for the period required by law for this purpose (10 years). For the purposes referred to in art. 1, lett. c) (legal obligations) the data will be kept for the period required by specific legal obligations or applicable regulations.
For the purposes referred to in article 2.1 (marketing) and 2.2 (communication of data to Partners of the Owner), the data will be kept until the revocation of consent by the User and, in any case, for a period not exceeding 24 months from the collection of data for the purposes of marketing and 12 months from the collection of data for the purposes of communication to Partners.

At the end of the retention period, the personal data will be deleted or transformed into an anonymous form.

4. Scope of communication and dissemination of data

We may disclose your personal information, for the purposes described in this Privacy Policy, to:

Third parties authorised by law: including government authorities, regulators, or other organisations where disclosure is required or authorised under applicable Australian laws and regulations;
Service providers and contractors: organisations that assist us in delivering our services or performing functions on our behalf (for example, IT service providers, payment processors, logistics and delivery providers, promotional partners, and professional advisers), where such disclosure is reasonably necessary for those purposes;
Our personnel: our employees, contractors and related personnel who require access to personal information to perform their duties, and who are subject to appropriate confidentiality and privacy obligations;
Business partners: where you have provided your consent, we may disclose your personal information to selected partners who may act as independent controllers of your personal information for the purposes described in this Privacy Policy.

We take reasonable steps to ensure that any recipient of your personal information handles it in accordance with applicable Australian privacy laws.

You may request further information about the categories of third parties with whom we share personal information by contacting us using the details set out in this Privacy Policy.

The personal data processed by the Data Controller are not subject to dissemination.

5. Transfer of data to third countries

We may disclose your personal information to recipients located overseas for the purposes described in this Privacy Policy.

Where we disclose personal information to overseas recipients, we will take reasonable steps to ensure that the recipient does not breach applicable Australian privacy laws in relation to that information. This may include implementing contractual arrangements and other safeguards to protect your personal information.

In some circumstances, we may disclose your personal information to an overseas recipient where:

you have provided your express consent to the disclosure; or
the disclosure is required or authorised by Australian law.

Where practicable, we will inform you of the countries in which such overseas recipients are likely to be located, or otherwise make this information available upon request.

You may contact us using the details provided in this Privacy Policy to request further information about our cross-border data disclosures.

6. Rights of individuals

Users, as individuals, may exercise at any time the rights recognised under applicable Australian privacy laws, including the right to:

Access: to request access to the personal information we hold about you, subject to certain exceptions permitted by law;
Correction: to request the correction of personal information that is inaccurate, out-of-date, incomplete, irrelevant or misleading;
Complaints: to make a complaint about an alleged breach of applicable privacy laws, including the Australian Privacy Principles;
Withdraw consent: to withdraw consent where the collection, use or disclosure of personal information is based on consent (where applicable), noting that this does not affect the lawfulness of processing prior to withdrawal.

Where applicable and subject to Australian law, we will take reasonable steps to give you access to your personal information and to correct it.

If you wish to exercise any of these rights or make a complaint, you may contact us using the details provided in this Privacy Policy. We will respond within a reasonable period. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC).

To exercise these rights, Users may contact the Data Controller at any time using the following methods:

By sending a registered letter with return receipt to the Data Controller's registered office at 6 Inns Court, Winetavern Street, Dublín, D08 DV20, Ireland
By sending an e-mail message to: privacy@freebeautyadvice.com

Users who believe that the processing of their personal information by the Data Controller is not in accordance with applicable Australian privacy laws may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) or seek a remedy through the relevant courts or tribunals in Australia.

The exercise of rights is not subject to any form constraint and is free of charge, except in cases where the requests are manifestly unfounded, excessive or repetitive, in which case the Data Controller may charge a reasonable fee or refuse to satisfy the requests.

7. Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy statement at any time, giving appropriate publicity to Users on the Site and ensuring in any case adequate and similar protection of personal data. In order to always be aware of the methods of treatment and of any changes, Users are invited to regularly consult this privacy statement. In case of substantial changes that may affect the rights of Users, these will be communicated directly by the Owner.

Last updated: March 2026