Privacy policy in accordance with EU Regulation 679/2016 

Dear Data Subject, We would like to inform you that “European Regulation 2016/679 on the Protection of Individuals with regard to the Processing of Personal Data and on the free movement of such data” (henceforth “GDPR”) provides that the protection of personal data referring to individuals is to be considered a fundamental right of the individual. Pursuant to Article 13 of the GDPR, therefore, we inform you of the following.

1. DATA CATHEGORY

LUMINAL AGENCY LIMITED will process your personal data such as:

• Automatically collected data. The computer systems and applications dedicated to the operation of this website detect, in the course of their normal operation, certain data (the transmission of which is implicit in the use of Internet communication protocols) potentially associated with identifiable users. The data collected include the IP addresses and domain names of the computers used by users who connect to the site, the addresses in URI (Uniform Resource Identifier) notation of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters regarding the operating system, browser and computer environment used by the user. These data are processed, for the time strictly necessary, for the sole purpose of obtaining statistical information on the use of the site and to check its regular operation. The provision of such data is mandatory as it is directly related to the web browsing experience.
• Cookies. All information about the cookies used is available by consulting the appropriate cookie policy.

2. SOURCE OF PERSONAL DATA:

The personal data that LUMINAL AGENCY LIMITED holds are collected directly from the data subject.

• Personal Data.

Personal data is collected through the use of contact information referable to the owner and posted online. Whenever you visit https://eu.d1milano.com/ we will collect generic information about the geographical origin of visitors, their computer systems, but in a strictly anonymous manner. All this data is incorporated into files under the responsibility of the staff of LUMINAL AGENCY LIMITED. We collect personal data to:

• enable you to enter into communication with our staff;
• constitute a database for reference purposes to which only the staff of LUMINAL AGENCY LIMITED has access.

3. DATA CONTROLLER

The data controller is LUMINAL AGENCY LIMITED, with registered office at Unit 802, 8/F, Laws Commercial Plaza, 788 Cheung Sha Wan Road, Cheung Sha Wan, Hong Kong at the e-mail privacy@d1milano.com.

3.1 PURPOSE OF DATA PROCESSING AND LEGAL BASIS

The processing of your data has as its legal basis your free, spontaneous and conscious choice to give such data to the Controller by means of the communication channels published on the website https://eu.d1milano.com/ , and is carried out in order to respond to your requests for information.

3.2 DATA PROCESSING METHODS

The personal data provided by you, will form the subject of processing operations in compliance with current legislation and the obligations of confidentiality that inspire the activity of the Owner. The data will be processed both with computer tools and on paper media as well as on any other type of suitable media, in compliance with the adequate security measures pursuant to Art 5 par. 1 lett. f) of the GDPR.

3.3 RECIPIENTS OF DATA

To the extent applicable to the stated processing purposes, your data may be disclosed to partners, consulting companies, private companies, appointed as Data Processors by the Data Controller or for legal obligations or to fulfill your specific requests. Your data will not be disseminated in any way. The Data Processors and Data Trustees in office are punctually identified in the Privacy Document, updated periodically.

3.4 DATA TRANSFER ABROAD

The data collected may be subject to transfer outside the European Union, by virtue of the Holder's registered office.

3.5 DATA DISSEMINATION. DATA PROFILING

Data are not subject to dissemination. Data are not subject to profiling.

3.6 RETENTION PERIOD

Collected data will be retained for a period of time not exceeding the achievement of the purposes for which they are processed (“principle of limitation of retention,” Art.5, GDPR) or in accordance with the deadlines stipulated by legal regulations. Verification of the obsolescence of the retained data in relation to the purposes for which they were collected is carried out periodically.

3.7 RIGHTS OF THE DATA SUBJECT

The data subject always has the right to request from the Data Controller access to his/her data, rectification or erasure of data, restriction of processing or the possibility to object to processing, to request data portability, to withdraw consent to processing by asserting these and other rights under the GDPR by simple communication to the Data Controller. The data subject may also lodge a complaint with a supervisory authority or by sending an email to privacy@d1milano.com.

3.8 MANDATORY OR NON-MANDATORY CONSENT

Providing your data is not mandatory while browsing our website.

3.9 SECURITY OF THE DATA SUBJECT'S PERSONAL DATA

LUMINAL AGENCY LIMITED., declares that the personal data collected are processed lawfully and fairly, collected and recorded for the purposes indicated, and used in other operations that are compatible with these purposes. LUMINAL AGENCY LIMITED undertakes to adopt appropriate and preventive security measures to safeguard the confidentiality, integrity, completeness, and availability of the personal data of the interested party. Personal data are processed on paper and/or with automated tools, for the time necessary to achieve the purposes for which they were collected. Specific security measures are observed to prevent even accidental loss, alteration, misuse, illegal or incorrect use and unauthorized access. LUMINAL AGENCY LIMITED is not responsible about untrue information sent directly by the user of the site to the address privacy@d1milano.com (example: correctness of e-mail address or credit card details or postal address), as well as information concerning him/her that has been provided by a third party, even fraudulently.

3.10 CONSULTATION, MODIFICATION AND DELETION OF PERSONAL DATA

The data subject, as provided for in EU Regulation 679/2016 has the right at any time to obtain from the Data Processor: confirmation of the existence of the data and its communication; updating, rectification, integration, deletion, transformation; blocking of data processed in violation of the law, and may object to the processing of their personal data by sending an email to privacy@d1milano.com