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This notice explains how personal data is used for Black Friday campaign purchases sold by Brilliant Software Solutions OÜ and the associated prize draw.

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1. CONTROLLER AND CONTACT DETAILS

Brilliant Software Solutions OÜ, registry code 11482255, is the controller for the campaign sales and prize-draw processing described here. Registered address: Randla tn 6-12, Põhja-Tallinna linnaosa, Tallinn, Harju maakond, 10312, Estonia. Contact: legal.public@brilliantsoftware.org. NodeMaven FZ-LLC may provide service-delivery, technical and fulfilment support. Its role does not replace BSS’s responsibility for the campaign processing described in this notice.

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2. INFORMATION USED AND ITS SOURCES

BSS uses information reasonably necessary for the campaign, including: a. Account identifiers, names and contact details. b. Age, residence and eligibility information. c. Eligible purchases, invoices, payment status, wallet use and refunds. d. Product quantities, qualifying spend and ticket records. e. Relevant security and fraud-prevention information. f. Winner verification, communications, shipping details and fulfilment records. g. Information required for tax, accounting and legal obligations. Information comes from you, your account and transaction records, and the payment, technical and fulfilment providers supporting the campaign, including NodeMaven FZ-LLC. Identity documents or other verification evidence are requested only where reasonably necessary. BSS seeks to retain a limited verification record rather than unnecessary copies of identification documents. BSS processes information: a. To perform the relevant contract: administering BSS purchases, campaign benefits, entries, winner communications and prizes. b. To comply with legal obligations: maintaining required tax and accounting records and responding to lawful regulatory requests. c. For legitimate interests: protecting campaign integrity, preventing fraud, auditing the draw, resolving complaints and establishing or defending legal claims. d. With consent where required: sending optional marketing or using winner photographs or testimonials for additional publicity. The legitimate interests are operating a fair and secure promotion, protecting participants and maintaining reliable evidence of transactions and awards. Marketing consent is separate. Refusing or withdrawing it does not affect qualifying purchases, valid entries or prize entitlement. Information necessary for purchase administration, eligibility or delivery must be provided for BSS to perform those activities. If essential information is missing, BSS may be unable to validate an entry or deliver a prize.

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4. RECIPIENTS AND INTERNATIONAL TRANSFERS

BSS shares only necessary information with NodeMaven FZ-LLC and relevant payment, hosting, technical, verification, delivery, professional-advisory and other service providers. Information may also be disclosed to competent authorities where legally required. NodeMaven FZ-LLC is located in the United Arab Emirates. BSS protects relevant EEA-to-UAE transfers using the applicable European Commission Standard Contractual Clauses and any necessary supplementary safeguards. Other international transfers must also use an applicable GDPR transfer mechanism. You may request information about the protections applying to your information, including a copy of relevant contractual safeguards, subject to appropriate redactions protecting other persons or confidential information.

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5. TICKET CALCULATION AND DRAW PROCESSING

Ticket calculations use the purchase and spending rules published in the Campaign Terms. Winner selection uses a random electronic process, followed by eligibility verification and confirmation by BSS. You may request human review of an apparent ticket-calculation or eligibility error. BSS does not use campaign participation as consent to unrelated profiling. Provisional or confirmed results may be published using winning ticket references and appropriately limited winner information for transparency. Additional publicity will follow the applicable legal requirements and permissions.

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6. RETENTION

Routine campaign, ticket and draw records are reviewed for deletion or anonymization twelve (12) months after the campaign closes. Records no longer needed are deleted or anonymized. Necessary records may be retained longer for unresolved disputes, documented fraud investigations, legal claims or statutory duties. Accounting records are generally retained for seven years from the end of the relevant financial year, where required by Estonian law. Verification documents are not automatically retained for the same period as accounting records. BSS limits their retention to what is necessary for verification and any continuing legal need.

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7. YOUR RIGHTS

Subject to the applicable legal conditions, you may request access, correction, erasure, restriction of processing or portability of your personal data. You may object to processing based on legitimate interests. Where processing relies on consent, you may withdraw that consent without affecting the lawfulness of earlier processing. Contact legal.public@brilliantsoftware.org to exercise your rights. BSS may request proportionate information to verify your identity. You may complain to the Estonian Data Protection Inspectorate, at aki.ee, or another supervisory authority competent to consider your complaint.

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8. RELATIONSHIP WITH OTHER PRIVACY INFORMATION

This notice supplements the privacy information available at nodemaven.com/privacy-policy. For BSS campaign sales and prize-draw processing, this notice identifies BSS’s controller role and takes precedence over inconsistent wording identifying another company as the controller for those same activities. Separate privacy information continues to apply to processing independently undertaken by another provider for its own lawful purposes.