Eleh Privacy Policy
This Website collects certain Personal Data of its Users.
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Data Controller
LUMINA By HQ s.r.l.
Via Friuli Venezia Giulia, 17 - 59100 Prato Italy
Indirizzo email del Titolare: modahqsrl@gmail.com
types of data collected
personal data collected by this website, either independently or through third parties, include: usage data; tracking tool; telephone number; email.
full details on each type of data collected are provided in the dedicated sections of this privacy policy or by means of specific information texts displayed prior to data collection. personal data may be freely provided by the user or, in the case of usage data, automatically collected during the use of this website.
unless otherwise specified, all data requested by this website are compulsory. if the user refuses to provide such data, it may be impossible for this website to provide the service. in cases where this website indicates certain data as optional, users are free to refrain from communicating such data, without this having any consequence on the availability of the service or its operation.
users who are in any doubt as to which data is compulsory are encouraged to contact the owner. the possible use of cookies - or of other tracking tools - by this website or by the owners of third party services used by this website, unless otherwise specified, has the purpose of providing the service requested by the user, in addition to the further purposes described in this document and in the cookie policy, if available.
the user assumes responsibility for the personal data of third parties obtained, published or shared through this website and warrants that he/she has the right to communicate or disseminate them, releasing the owner from any liability towards third parties.
Method and place of processing of collected Data
Processing methods
The Controller takes appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of Personal Data.
The processing is carried out using computer and/or telematic instruments, with organisational methods and logics strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organisation of this Web Site (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.
Legal basis for processing
The Controller processes Personal Data relating to the User where one of the following conditions exists:
- the User has given consent for one or more specific purposes; Note: in some jurisdictions, the Controller may be authorised to process Personal Data without the need for the User's consent or another of the legal bases specified below, as long as the User does not object ("opt-out") to such processing. However, this does not apply if the processing of Personal Data is governed by European legislation on the protection of Personal Data; the processing is necessary for the performance of a contract with the User and/or the performance of pre-contractual measures;
- processing is necessary for the performance of a legal obligation to which the Controller is subject;
- processing is necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested in the Controller;
- processing is necessary for the pursuit of the legitimate interest of the Controller or of third parties. However, it is always possible to request the
Controller to clarify the concrete legal basis of each processing operation and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.
Location
The Data are processed at the Controller's premises and in any other place where the parties involved in the processing are located. For further information, please contact the Data Controller.
Your Personal Data may be transferred to a country other than the country where You are located. For further information on the processing location, the User may refer to the section on Personal Data processing details.
The User has the right to obtain information about the legal basis for the transfer of Data outside the European Union or to an international organisation under public international law or consisting of two or more countries, such as the UN, as well as about the security measures taken by the Data Controller to protect the Data.
The User can check whether one of the transfers just described has taken place by examining the section of this document relating to details on the processing of Personal Data or request information from the Controller by contacting him at the contact details given at the beginning.
Conservation period
Data are processed and stored for the time required by the purposes for which they were collected.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Controller and the User will be retained until the performance of that contract is completed.
- Personal Data collected for purposes related to the legitimate interest of the Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.
When the processing is based on the User's consent, the Controller may keep the Personal Data for a longer period until such consent is revoked. In addition, the Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this period, the right of access, cancellation, rectification and the right to Data portability can no longer be exercised.
Purposes of Data Processing
User Data are collected to enable the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), detect any malicious or fraudulent activities, as well as for the following purposes: Displaying content from external platforms, Payment management, Interaction with social networks and external platforms, Statistics, Tag management, Contacting the User, Contact management and sending messages, Traffic optimization and distribution, Protection from SPAM, Remarketing and behavioral targeting, Advertising and Hosting and backend infrastructure, to fulfil pre-contractual and contractual obligations towards Users and Customers; to fulfil and demand the fulfilment of specific obligations deriving from laws and regulations; to send commercial proposals for the purpose of selling products and/or services similar to those already purchased (soft-spam); to send newsletters; to carry out marketing activities (by means of paper mail, operator calls, calls without operator, e-mail, telefax, MMS, SMS) and market research; to carry out profiling activities pursuant to Art. 4.4. GDPR.
In order to obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User may refer to the section 'Personal Data Processing Details'.
Details of Personal Data Processing
Personal Data are collected for the following purposes and using the following services:
Contacting the User
Contact by telephone (this Website)
Users who have provided their telephone number may be contacted for commercial or promotional purposes related to this Web Site, as well as to fulfil support requests.
Personal data processed: telephone number.
Mailing list or newsletter (this website)
By registering for the mailing list or newsletter, the User's email address is automatically added to a list of contacts to whom email messages containing information, including information of a commercial and promotional nature, relating to this Web Site may be sent. The User's email address may also be added to this list as a result of registering on this Web Site or after making a purchase.
Personal data processed: email.
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, telephone contacts or contacts of any other kind used to communicate with the User.
These services may also collect data on the date and time the User views the messages, as well as the User's interaction with them, such as information on clicks on links in the messages.
Personal data processed: email.
Place of processing: Luxembourg - Privacy Policy.
Payment Management
Unless otherwise specified, this Website processes all payments by credit card, bank transfer or other means through external payment service providers. In general, and unless otherwise stated, Users are requested to provide payment details and personal information directly to such payment service providers.
This Website is not involved in the collection and processing of such information: instead, you will only receive a notification from the payment service provider in question that payment has been made.
PayPal (Paypal)
PayPal is a payment service provided by PayPal Inc., which enables the User to make online payments.
Personal Data processed: various types of Data as specified by the privacy policy of the service.
Place of processing: See Paypal's privacy policy - Privacy Policy.
Tag Management
This type of service is functional for the centralised management of tags or scripts used on this website.
The use of such services entails the flow of User Data through them and, where applicable, their retention.
- Google Tag Manager (Google Ireland Limited)
- Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.
Hosting and backend infrastructure
These types of services have the function of hosting data and files that allow this Website to function, enable its distribution and provide a ready-to-use infrastructure to deliver specific functionalities of this Website.
Some of the services listed below, if any, may operate on geographically dispersed servers, making it difficult to determine the actual location where Personal Data is stored.
Personal Data processed: various types of Data as specified by the privacy policy of the service.
Place of processing: Ireland - Privacy Policy; Germany – Privacy Policy.
Interaction with social networks and external platforms
This type of service enables interaction with social networks, or other external platforms, directly from the pages of this website.
Interactions and information acquired from this Website are in each case subject to the User's privacy settings relating to each social network.
This type of service may still collect traffic data for pages where the service is installed, even when Users do not use it.
It is recommended to disconnect from the respective services to ensure that the data processed on this Website is not linked back to the User's profile.
Paypal button and widget (Paypal)
The PayPal button and widget are PayPal platform interaction services, provided by PayPal Inc.
Personal data processed: Usage Data; Tracking Tool.
Place of processing: See Paypal's privacy policy – Privacy Policy.
Facebook Like button and social widgets (Facebook Ireland Ltd)
The Facebook 'Like' button and social widgets are interaction services with the social network Facebook, provided by Facebook Ireland Ltd.
Personal data processed: Usage Data; Tracking Tool.
Place of processing: Ireland – Privacy Policy.
Traffic optimisation and distribution
This type of service enables this Web Site to distribute its contents via servers located throughout the territory and to optimise its performance.
The Personal Data processed depends on the characteristics and the way in which these services are implemented, which by their nature filter communications between this Website and the User's browser.
Given the distributed nature of this system, it is difficult to determine the places to which content is transferred, which may contain the User's Personal Data.
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimisation and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all traffic on this website, i.e. communication between this website and the User's browser, and also allows the collection of statistical data on it.
Personal Data processed: Tracking Tool; various types of Data as specified by the privacy policy of the service.
Place of processing: United States – Privacy Policy.
SPAM protection
This type of service analyses traffic on this Website, potentially containing Users' Personal Data, in order to filter it from traffic, messages and content recognised as SPAM.
Google reCAPTCHA (Google Ireland Limited)
Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
The use of the reCAPTCHA system is subject to the privacy policy and the terms of use di Google.
Personal data processed: Usage Data; Tracking Tool.
Place of processing: Ireland – Privacy Policy.
Publicity
This type of service allows the User's Data to be used for commercial communication purposes. These communications are displayed on this Website in the form of banners and other forms of advertising, also related to the User's interests.
This does not mean that all Personal Data is used for this purpose. Data and conditions of use are set out below.
Some of the services mentioned below may use Tracking Tools to identify the User or use the behavioral retargeting technique, i.e. displaying advertisements tailored to the User's interests and behaviour, also detected outside this Website. For more information on this subject, we suggest that you check the privacy policies of the respective services.
In addition to the opt-out functionalities offered by the services below, the user can opt out by visiting the Network Advertising Initiative opt-out page.
Users can also opt out of certain advertising features through the corresponding device configuration options, such as the mobile device advertising configuration options or the generic advertising configuration.
Similar public of Facebook (Facebook Ireland Ltd)
Similar public of Facebook is an advertising and behavioural targeting service provided by Facebook Ireland Ltd that uses Data collected through Facebook's Custom Audience service in order to show advertisements to Users with similar behaviour to Users who are already on a Custom Audience list based on their previous use of this Website or their interaction with relevant content through Facebook applications and services.
On the basis of this Data, personalised advertisements will be shown to Users suggested by similar Facebook audiences.
Users can opt out of the use of Facebook cookies for ad customisation by visiting this opt-out page .
Personal data processed: Usage Data; Tracking Tool.
Place of processing: Ireland – Privacy Policy – Opt Out.
Remarketing e behavioral targeting
This type of service allows this Website and its partners to communicate, optimise and serve advertisements based on the User's past use of this Website.
This activity is facilitated by the tracking of Usage Data and the use of Tracking Tools to collect information that is then transferred to partners handling remarketing and behavioral targeting activities.
Some services offer a remarketing option based on email address lists.
In addition to the opt-out functionalities offered by the services below, the user can opt out by visiting the Network Advertising Initiative opt-out page.
Users can also opt out of certain advertising features through the corresponding device configuration options, such as the mobile device advertising configuration options or the generic advertising configuration.
Facebook Remarketing (Facebook Ireland Ltd)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that links the activity of this Website with the Facebook advertising network.
Personal data processed: Usage Data; Tracking Tool.
Place of processing: Ireland – Privacy Policy – Opt Out.
Facebook Custom Audiences (Facebook Ireland Ltd)
Facebook's personalised audience is a remarketing and behavioural targeting service provided by Facebook Ireland Ltd that links the activity of this website with Facebook's advertising network.
Users can opt out of the use of Facebook cookies for ad customisation by visiting this opt-out page.
Personal Data Processed: email; Tracking Tool.
Place of processing: Ireland – Privacy Policy – Opt Out.
Statistics
The services contained in this section allow the Data Controller to monitor and analyse traffic data and serve to keep track of the User's behaviour.
Google Analytics (Google Ireland Limited)
Google Analytics is a web analytics service provided by Google Ireland Limited ("Google"). Google uses the Personal Data collected in order to track and examine the use of this Website, compile reports and share them with the other services developed by Google.
Google may use the Personal Data to contextualise and personalise the ads on its advertising network.
Personal data processed: Usage Data; Tracking Tool.
Place of processing: Ireland – Privacy Policy – Opt Out.
Facebook Ads conversion monitoring (Facebook pixel) (Facebook Ireland Ltd)
The Facebook Ads conversion tracking (Facebook pixel) is a statistics service provided by Facebook Ireland Ltd that links data from the Facebook ad network with actions taken within this Website. The Facebook pixel monitors conversions that can be attributed to Facebook Ads, Instagram and the Audience Network.
Personal data processed: Usage Data; Tracking Tool.
Place of processing: Ireland – Privacy Policy.
Displaying content from external platforms
This type of service makes it possible to display content hosted on external platforms directly from the pages of this Website and to interact with them.
This type of service may still collect data on web traffic related to pages where the service is installed, even when users are not using it.
MyFonts (Monotype Imaging Holdings Inc.)
MyFonts is a font style display service operated by Monotype Imaging Holdings Inc. that allows this Website to integrate such content within its pages.
Personal Data processed: Usage Data; various types of Data as specified by the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Google Fonts (Google Ireland Limited)
Google Fonts is a font display service operated by Google Ireland Limited, which enables this website to integrate fonts into its pages.
Personal Data processed: Usage Data; various types of Data as specified by the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Font Awesome (Fonticons, Inc. )
Font Awesome is a font style display service operated by Fonticons, Inc. which allows this Website to integrate such content into its pages.
Personal data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Further information on Personal Data
Online sale of goods and services
The Personal Data collected is used for the provision of services to the User or for the sale of products, including payment and possible delivery. The Personal Data collected to finalise payment may be that relating to the credit card, bank account used for the transfer or other payment instruments provided. The Payment Data collected by this Website depends on the payment system used.
Cookie Solution (Consent cookies)
The iubenda Consent Cookie (_iub_cs-X) is installed by the iubenda Cookie Solution and stores the User's preferences regarding Tracking Tools in the local domain.
User Rights
Users may exercise certain rights with regard to the Data processed by the Data Controller.
In particular, the User has the right to:
- revoke consent at any time. The User may revoke his or her previously expressed consent to the processing of his or her Personal Data.
- oppose the processing of their Data. The User may object to the processing of his or her Data when it is done on a legal basis other than consent. Further details on the right to object can be found in the section below.
- access their Data. The User has the right to obtain information on the Data processed by the Controller, on certain aspects of the processing and to receive a copy of the Data processed.
- verify and ask for rectification. The User may check the correctness of its Data and request that it be updated or corrected.
- obtain the restriction of processing. When certain conditions are met, the User may request the restriction of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its storage.
- obtain the deletion or removal of their Personal Data. When certain conditions are met, the User may request the deletion of his/her Data by the Controller.
- receive its Data or have it transferred to another controller. The User has the right to receive its Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another controller. This provision is applicable when the Data are processed by automated means and the processing is based on the User's consent, on a contract to which the User is a party or on contractual measures related thereto.
- propose a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.
Details of the right of opposition
Where Personal Data are processed in the public interest, in the exercise of public authority vested in the Controller or in pursuit of a legitimate interest of the Controller, Users have the right to object to the processing on grounds relating to their particular situation.
Users are informed that, should their Data be processed for direct marketing purposes, they may object to the processing without giving any reason. To find out whether the Controller processes Data for direct marketing purposes, Users may refer to the respective sections of this document.
How to exercise your rights
In order to exercise their rights, Users may address a request to the contact details of the Controller indicated in this document. Requests are filed free of charge and processed by the Controller as quickly as possible, in any case within one month.
Cookie Policy
This Website makes use of Tracking Tools. To find out more, the User may consult the Cookie Policy.
More information on treatment
Legal defence
The User's Personal Data may be used by the Data Controller in legal proceedings or in the preparatory stages of such proceedings in order to defend against abuses in the use of this Website or related Services by the User.
The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.
Specific Informations
At the User's request, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services used by it may collect system logs, i.e. files that record interactions and which may also contain Personal Data, such as the User's IP address.
Information not contained in this policy
Further information in connection with the processing of Personal Data may be requested at any time from the Data Controller using the contact details.
Response to 'Do Not Track' requests
This Web Site does not support 'Do Not Track' requests.
To find out whether any third-party services used support them, the User is invited to consult their respective privacy policies.
Modifications to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Website as well as, when technically and legally feasible, by sending a notification to Users through one of the contact details it has. Therefore, please consult this page frequently, referring to the date of last modification indicated at the bottom.
If the changes affect processing whose legal basis is consent, the Controller will collect the User's consent again, if necessary.
Definitions and legal references
Personal Information (or Data)
Personal data is any information that, directly or indirectly, even in conjunction with any other information, including a personal identification number, makes a natural person identified or identifiable.
Utilisation Data
This is the information collected automatically through this Website (including by third party applications integrated into this Website), including: IP addresses or domain names of the computers used by the User who connects with this Website, URI (Uniform Resource Identifier) notation addresses, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server response (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various time connotations of the visit (e.g. the time spent on each page) and details of the itinerary followed by the User. ), the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the operating system and the User's IT environment.
User
The individual using this Website who, unless otherwise specified, is the Data Subject.
Interested
The private person to whom the Personal Data refer.
Data Processor (or Manager)
The individual, legal person, public administration and any other entity that processes personal data on behalf of the Controller, as set out in this privacy policy.
Data Controller (or Owner)
The individual or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this Web Site. The Data Controller, unless otherwise specified, is the owner of this Web Site.
This Website (or this Application)
The hardware or software tool by which Users' Personal Data are collected and processed.
Service
The Service provided by this Website as defined in the relevant terms (if any) on this site/application.
European Union (or UE)
Unless otherwise specified, any reference to the European Union in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area.
Cookie
Cookies are tracking tools that consist of small portions of data stored within the User's browser.
Tracking Instrument
Tracking Tool means any technology - e.g. cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that allows Users to be tracked, for example by collecting or storing information on the User's device.
Legal references
This privacy policy is drafted on the basis of multiple legal regulations, including Articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy relates exclusively to this Website.
Last modified:10 May 2021