Privacy Policy

Last updated: July 13, 2026

This Privacy Policy governs the processing of personal data collected through the ASÖKA B2B website, owned by Alluring Luck, Lda., headquartered at Rua Monte de São Caetano 668, Armazém 2, 4405-817 Vila Nova de Gaia, Portugal, VAT number PT519234200 (hereinafter "ASÖKA").

1. Collection and Processing of Professional Client Data

Unlike retail consumer channels, this B2B Website is intended for commercial interactions between legal entities and business partners. Nonetheless, we process personal data from representatives, buyers, or contact points of the companies we work with.The data collected includes:

a) Partnership and Contact Forms ("Partner with us"): contact name, corporate email, phone number, company role, company legal name, VAT number, and business sector (Retail, HoReCa, Distribution).

b) Billing and Logistics: headquarters address, delivery address for goods, and bank details for commercial invoice settlements.

1.1 Source of the Data

Most data is collected directly from the data subject, through the forms available on the Website. However, ASÖKA may also collect professional contact data from public sources, namely LinkedIn, and at trade fairs and industry events in which it participates. In these cases, any subsequent processing of such data is likewise governed by this Privacy Policy.

2. Purpose and Legal Basis for Processing

The processing of personal data from B2B partners relies on different legal bases, depending on the purpose:

a) Performance of pre-contractual steps and of the contract, to evaluate applications from new distributors, manage the opening of professional accounts, and process, ship, and invoice wholesale commercial orders.

b)Legitimate interest of ASÖKA in developing and maintaining commercial relationships, namely for commercial prospecting purposes (including contacts obtained via LinkedIn or at trade fairs) and to send product catalogs, technical data sheets, price lists, and operational updates exclusive to partners.

c) Compliance with legal obligations, namely tax and accounting obligations to which ASÖKA is subject under Portuguese and European Union law.Where processing is based on legitimate interest, the data subject has the right to object to it at any time, as described in Section 7.

3. Data Sharing with Third PartiesASÖKA only shares strictly necessary data with external service providers that support the B2B value chain, namely:

a) Transport providers and cold-chain logistics operators, for delivery of goods.

b) Billing systems integrated into the WordPress platform and accounting software.

c) Email service providers (Microsoft Outlook/Microsoft 365) for communication with partners.

d) Traffic analysis and advertising tools, namely Google services (Google Analytics, Google Tag Manager, Google Site Kit) and advertising/remarketing tools, as described in Section 5 (Cookies and Analytics Tools).

e) Competent tax authorities, for compliance with legal obligations in Portugal and the European Union.

3.1 International Data TransfersSome of the providers identified above (namely Google and Microsoft) are headquartered or process data outside the European Economic Area, particularly in the United States. These transfers are carried out under the EU-U.S. Data Privacy Framework, a mechanism recognized by the European Commission as ensuring an adequate level of data protection, or under other legally equivalent safeguards provided for under the GDPR (namely Standard Contractual Clauses). The website itself is hosted on servers located in Portugal.

4. Data Retention

ASÖKA retains personal data only for the period strictly necessary to fulfill the purposes described above, according to the following criteria:

a) Billing and accounting records: retained for 10 years, in accordance with applicable Portuguese tax and accounting legislation (namely the VAT Code and the Corporate Income Tax Code).

b) Applications from distributors that were not accepted: retained for 24 months following the rejection decision, after which they are deleted.

c) Data of active partners and clients: retained for the duration of the commercial relationship and, following its termination, for the additional period necessary to comply with legal obligations and for purposes of defense in the event of a dispute, namely until the expiry of applicable statutory limitation periods.

5. Cookies and Analytics Tools

Our website uses essential, analytical, and advertising cookies to ensure proper platform functionality, analyze corporate traffic trends, and support marketing and remarketing activities, namely through Google tools (Google Analytics 4, Google Tag Manager) and other digital advertising tools. For more information on these tools and how to manage them, please review our Cookie Policy.

6. Data Security

ASÖKA implements appropriate technical and organizational measures to protect the personal data it processes, namely:

a) Secure connection to the website via SSL certificate/encryption in transit.

b) Restricted access to internal systems (website and management tools) through individual accounts and passwords.

c) Regular backups of stored data.

7. Automated Decision-Making

ASÖKA does not use fully automated decision-making processes, including profiling or artificial intelligence, to make decisions that produce legal effects concerning, or significantly affect, data subjects.

8. Data Subject Rights

Under the General Data Protection Regulation (GDPR), legal representatives and business contacts have the right to:

a) Access their personal data;

b) Request its rectification;

c) Request restriction of its processing;

d) Object to its processing, namely where it is based on legitimate interest;

e) Request erasure of their data;

f) Request the portability of their data, where applicable.

To exercise these rights, you may submit a written request by email to marketing@asoka.pt. ASÖKA will respond to such requests within one month, which may be extended under the terms provided for in the GDPR.

ASÖKA does not have an appointed Data Protection Officer (DPO), as such an appointment is not mandatory given the nature and scale of the data processing carried out.

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Portuguese Data Protection Authority (Comissão Nacional de Proteção de Dados — CNPD), the competent supervisory authority in Portugal.

9. Changes to this Privacy PolicyASÖKA reserves the right to update or amend this Privacy Policy at any time, to reflect changes in its data processing practices or in applicable legislation. The updated version will be published on this page, indicating the date of the last update. We recommend reviewing this page periodically.