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Privacy Policy

DATA PROTECTION POLICY PURSUANT TO EU REGULATION 679/2016

Dear Data Subject, we wish to inform you that in accordance with "European Regulation 2016/679 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter "GDPR"), the protection of personal data relating to persons is to be considered a fundamental right of the individual. Pursuant to Article 13 of the GDPR, therefore, we are pleased to inform you of the following.

 

 1. CATEGORIES OF DATA

    Luminal Agency Limited will process your personal data, such as:

    - Data collected automatically. During the ordinary course of operations, the IT systems and applications for running this website acquire some data (whose transmission is implicit in the use of internet communication protocols) that could potentially be associated with identifiable users. These data include the IP addresses and domain names of computers used by users who connect to the site, URI (Uniform Resource Identifier) addresses of any requested resources, the time of such requests, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc.) and certain other parameters concerning the user’s operating system, browser and IT environment. These data are processed, for the amount of time strictly necessary, for the sole purpose of obtaining statistical information about the use of the website usage and to check its correct functioning. The provision of such data is mandatory, as it is directly related to the web browsing experience.

    - The site uses technical/profiling cookies of third parties, which may collect browsing data from users, the provision of which is optional and takes place by providing free and informed consent. The function of cookies is to analyse the efficacy of the site and make it progressively easier to use and more intuitive. The data collected through cookies is used to make your browsing experience more enjoyable and more efficient in the future, trying to evaluate user behaviour and to modify the content offered in accordance with their behaviour. For more information, a dedicated cookie policy is provided.

     

     2. SOURCE OF PERSONAL DATA

    The personal data in the possession of Luminal Agency Limited are collected directly from the data subject.

    - Personal data

    Personal data are collected through the use of contact information referring to the Data Controller and published online. Whenever you visit https://eu.d1milano.com/ we will collect general information about the geographical origin of visitors and their computer systems, but strictly anonymously. All these data are incorporated into files under the responsibility of Luminal Agency Limited's staff.

    We collect personal data:

    - to allow you to communicate with our staff;

    - to set up a database for consultation 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 in Lai Cheong Factory Building, 479 Castle Peak Road, Cheung Sha Wan, Hong Kong at privacy@d1milano.com.

    3.1 DATA PROCESSING PURPOSES AND LEGAL BASIS

    The legal basis for the processing of your data is your free, spontaneous and informed decision to provide such data to the Data Controller through the communication channels published on the website https://d1milano.com/ and processing is carried out in order to respond to your requests for information.

    3.2 METHODS OF DATA PROCESSING

    The personal data you provide will be subject to processing operations in compliance with current legislation and the confidentiality obligations that inspire the activity of the Data Controller. The data will be processed both by computer and on paper and on any other suitable type of support, in compliance with the appropriate security measures, pursuant to art. 5 para 1, letter f) of the GDPR.

    3.3 RECIPIENTS OF DATA

    Within the limits pertinent to the processing purposes indicated, your data may be communicated to partners, consulting companies, private companies, appointed as Data Processors by the Data Controller, or for legal obligations or to fulfil your specific requests. Your data will not be disclosed in any way. The Data Processors and Persons in Charge of the processing in office are identified in the Data Protection Document, updated periodically.

    3.4 TRANSFER OF DATA ABROAD

    The data collected may be transferred outside the European Union.

    3.5 DISCLOSURE OF DATA. DATA PROFILING

    The data will not be disclosed. The data are subject to profiling.

    3.6 STORAGE PERIOD

    The data collected will be stored for a period of time not exceeding the time necessary for the achievement of the purposes for which they are processed ("principle of limitation of storage", art. 5, GDPR) or in accordance with the deadlines required by law. Obsolescence of the data stored in relation to the purposes for which they were collected is verified periodically.

    3.7 RIGHTS OF THE DATA SUBJECT

    The data subject is always entitled to ask the Data Controller for access to his or her data, their rectification or deletion, limitation of processing or the possibility to oppose processing, as well as to request data portability, to withdraw consent for processing by asserting these and other rights provided for in the GDPR by means of a simple communication addressed to the Data Controller. The data subject may also lodge a complaint with a supervisory authority or by sending an e-mail to the following address privacy@d1milano.com

    3.8 MANDATORY OR OPTIONAL CONSENT

    The provision of your data is not mandatory while browsing our website.

    3.9 SECURITY OF PERSONAL DATA OF THE DATA SUBJECT

    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 compatible with these purposes. Luminal Agency Limited undertakes to adopt appropriate and preventive security measures to safeguard the confidentiality, integrity, completeness and availability of personal data of the data subject.

    Personal data are processed on paper and/or with automated tools for the time strictly necessary for achieving the purposes for which they were collected.

    Specific security measures are adopted to prevent the loss of data, including accidental loss, alterations to data, improper, unlawful or incorrect uses thereof and unauthorised access thereto. Luminal Agency Limited may not be held responsible for untrue information sent directly by the user of the website to the address privacy@d1milano.com (e.g. correctness of the e-mail address or credit card details or postal address), or for information regarding him/her provided by a third party, even fraudulently.

    3.10 CONSULTATION, MODIFICATION AND ERASURE OF PERSONAL DATA

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