Last updated: November 2026. This policy explains how personal data is processed on vexpick.com. It is written to meet the GDPR / UK GDPR, Canada's PIPEDA and Quebec Law 25, and the Microsoft Advertising policies.
1. Who is responsible (controller)
Lumeris Agency, [Registered address of Lumeris Agency] ("we", "us"), runs this website and the advertising that promotes it, and is the controller of the personal data described here. Contact for all privacy matters: [email protected]. Data protection contact: [email protected]
2. Purposes, legal bases and retention
| Purpose | Data | Legal basis (GDPR Art. 6) | Retention |
|---|---|---|---|
| Provide and secure the website | IP address, device/browser data, server logs | Legitimate interests (6(1)(f)) – running and securing the site | Up to 30 days |
| Remember your cookie choice | Consent record (choices, timestamp) | Legal obligation / legitimate interests – proving consent | 12 months, then you are asked again |
| Site analytics (only if enabled) | Pages viewed, approximate location, device, pseudonymous cookie IDs | Consent (6(1)(a)) | Up to 13 months |
| Advertising measurement & conversion tracking (only if enabled) | Ad click and conversion identifiers, cookie IDs | Consent (6(1)(a)) | Up to 13 months |
| Affiliate click attribution | Query parameters appended to outbound links (campaign, placement). They contain no personal data. | Legitimate interests – paying and verifying referral commissions | Up to 24 months in aggregated form |
| Answer your requests and complaints | Name, email, message, ID needed to verify you | Legitimate interests / legal obligation | Up to 24 months after the request is closed |
We do not use cookies or tracking technologies other than strictly necessary ones until you give consent. We do not collect special-category data and do not knowingly collect data from anyone under 19 (18 in Alberta, Manitoba and Quebec).
3. Who we share data with
- Microsoft Corporation (Microsoft Advertising UET / Clarity) – only if you consent to the relevant cookies; Microsoft acts under its own terms and privacy statement.
- Hosting and security providers – process server logs on our behalf under data processing agreements.
- Advertising operators you click on – when you click a link you leave this site; the operator becomes responsible for what it collects. We pass only the tracking parameters in the link.
- Professional advisers and authorities where required by law.
We do not sell personal data.
4. International transfers
Some providers (including Microsoft) may process data outside the EEA, UK or Canada, for example in the United States. Where this happens we rely on an adequacy decision (such as the EU–US Data Privacy Framework for certified providers) or Standard Contractual Clauses with supplementary measures.
5. Your rights
Under the GDPR/UK GDPR you can: access your data; have it rectified; have it erased; restrict processing; receive it in a portable format; object to processing based on legitimate interests; and withdraw consent at any time (withdrawal does not affect earlier processing). Residents of Canada have equivalent access, correction and withdrawal rights under PIPEDA and, in Quebec, Law 25. You may also complain to your supervisory authority (e.g. your national data protection authority, the UK ICO, or the Office of the Privacy Commissioner of Canada).
6. How to submit a privacy / GDPR request
- Email [email protected] with the subject line “Privacy request – [access / erasure / rectification / objection / portability / withdraw consent]”. You can also write to Lumeris Agency, [Registered address of Lumeris Agency].
- Tell us the right you want to use and the email address or device/cookie information relevant to you. We may ask for proof of identity.
- We reply within one month (extendable by two months for complex requests, and we will tell you why). There is no charge unless a request is manifestly unfounded or excessive.
To withdraw or change cookie consent at any time, use Cookie settings in the footer.
7. Cookies
See our Cookie Policy for the types of cookies, purposes, providers and expiry periods.
8. Security and changes
We use appropriate technical and organisational measures. We will post changes to this policy on this page with a new date.