This policy applies to any users of the Services of LUXOS or its affiliates in any location. Including but not subject to users who contact LUXOS and provide personal information via online form submission.
1.3 Data Controllers
For the purpose of the Personal Data (Privacy) Ordinance (the Act), the data controller for the information you provide or that is collected by LUXOS or its affiliates is the following:
LUXOS Italia SRL.
Via Pietrasanta 14, 7b
Milan, Italy. 20141
2. Information We Collect
There are three general categories of information collected:
- Information you provide to us
- Information collected automatically
- Information collected via third parties
Depending on the LUXOS Services you request or use, different information may be collected about you. The below is inclusive of this data collection.
2.1. Information You Provide to Us
2.1.1 Personal Information
You are free to explore the Services of LUXOS without providing any personal information about yourself. We only collect information you voluntarily provide to us when you register or use some of our Services. This includes contact information from or about you that identifies you personally, such as your name, email address and phone number.
2.1.3. Other Information
You may choose to provide us information when you fill out a form, subscribe to our newsletters, participate in contests, sweepstakes or promotions, or communicate with us via third party sites and other services such as customer support requests.
We also may receive information about you from other publicly available sources, marketing service providers, and social media platforms, such as Facebook, Linkedin, Instagram and Google.
2.2 Automatically Collected Information
When you use the LUXOS Services, we may collect information about the services you use and how you use them. This includes:
- Usage Information. We collect information about your interactions with LUXOS
- Location Information. When you use certain features of the LUXOS Services, we may collect information about your general location, such as IP address. With your permission, we may collect information about the specific location as determined through data that includes GPS, wireless networks, and WiFi. You can revoke this permission at any time by changing the preferences of location services for applications on your device.
- Log Data. We collect log information when you access and use the LUXOS Services. This includes:
- Details about how you have used the LUXOS Services
- Device information (for example, your web browser type and language)
- Access times
- Pages visited
- IP address
- Hardware & software information (for example, your operating system)
- Identifiers associated with cookies or other technologies that may uniquely identify your device or browser
- Page you visited after using the LUXOS Services
- Transaction Information. We collect certain information related to your transactions on LUXOS Services such as your name, email address, the date and time and other related transaction details.
2.3 Cookies and Local Storage
2.3.1 What are cookies?
LUXOS treats information collected by cookies as non-personal information, thereby particular individuals are not identified by association. In some instances, if Internet Protocol (IP) addresses or similar identifiers are considered personal information by applicable law, these identifiers will be treated as personal information.
Cookies set by LUXOS are called “first-party cookies.” Cookies set by parties other than LUXOS are called “third party cookies” that enable third party providers to contribute to our website and Services with additional features and/or functionalities, such as advertising, interactive content and analytics.
The cookies we use generally fall into one of the following categories:
Category of cookie
We use these cookies to collect information about how you interact with our Services. For example, we may use these cookies to collect information about which web page you opened or items you clicked on. This data may be used to improve our Services and make them easier for you to navigate.
We use these cookies to gather statistical information about the usage of the Services to improve their design and features. For example, we can use these cookies to analyze which features are the most popular with our users and which ones might need some improvement according to web traffic data.
These cookies are essential to allow us to operate the LUXOS Services as you browse around our websites and use our Services. For example, they enable you to log into our Services and assist with loading page content faster. Without these cookies, the Services that you have requested for cannot be provided.
These cookies help us remember choices you make while using our Services. For example, these cookies allow our websites to remember your details for simple login and the preferences you make to some parts of our Services, which are customizable, such as text size and language preferences. The purpose of these cookies are to provide you with a more personalized experience and greater convenience while using our Services.
We use these cookies to serve you with advertisements, and make them more relevant and meaningful to you. The information may also be used to help us regulate the advertisements you receive and measure their effectiveness.
2.4 Information We Collect from Third Parties
LUXOS may collect data including personal information from any of the websites that we operate during use. We do not control, supervise or respond to the processing of any information request by third parties regarding the disclosure of your personal information.
Third party sources include:
- LUXOS business partners
- Technical contractors
- Financial services providers (credit reference agencies)
- Advertising networks
- Analytics providers
- Search information providers
- Marketing service providers
- Publicly available sources
LUXOS may combine the information collected from these sources with other information in its possession.
2.5. Information Regarding Children
3. How we use information collected
Our Services are made to be useful and convenient, but we need your information to keep them running while developing features and improving on existing ones based on your feedback.
Where you have consented to our use of your information.
Where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
Where your information is necessary to enter into or perform our contract with you.
Where we need to use your information to comply with our legal obligations.
Where your information is necessary for us to defend, prosecute or make a claim against you, us or a third-party.
In furtherance of legal grounds set out in applicable law, LUXOS uses your information in the following such examples. LUXOS will collect your information based on our legitimate interests in improving LUXOS and our users’ experience with it. More specifically, LUXOS uses information to:
- Provide and improve the LUXOS Services
- Keep our Services safe & secure
- Provide relevant marketing content & advertisement
3.1 Provide & Improve LUXOS Services
Your information is one of the key elements informing continual provision of and improvements on LUXOS Services, for example customer service
Improve and optimize the LUXOS Services through personal information analysis to better understand trends, usage, and activities in connection with our Services
Provide reliable and convenient features that allow you to interact with our Services Communicate with you about products, services and events that could be of interest to you
If you provide us with your contact(s) information, we may process this information to:
- Send you technical notices
- Security alerts
- Other support and administrative messages
- Facilitate any requests you make
- For any purpose, you authorize at the time of collection
- Personalize your experience and provide content and features that match your interests.
This information is processed in accordance with our legitimate interests to improve the LUXOS Services and enhance the user experience, and where necessary, for the performance of the contract with you.
3.2 Keeping Our Services Safe & Secure
In ensuring the security of our Services, it is necessary to pursue our legitimate interests by doing the following:
- Help protect the safety of our Services and our users, which includes detecting and preventing spam, addressing abuse, and other harmful activities
- Verify or authenticate information or identifications provided by you
- Comply with our legal obligations
- Investigate or address claims or disputes relating to our users, or as otherwise allowed by applicable law
- To ensure technical functionalities of our Services, we monitor our products and services’ usages and analyze data to maintain our operations.
We process this information given our legitimate interest in protecting LUXOS and its Services, and where it is necessary to measure the performance of our contract with you and comply with applicable laws.
3.3 Provide Relevant Marketing Content & Advertisement
- Send you promotional messages, marketing content, offers, and relevant advertisement based on your preferences, where you have chosen to receive these
- We may use your information to market our own and/or our business partners’ products and services through LUXOS Services and/or social media platforms such as Instagram, Linkedin, Facebook or Google
- Measure and improve our advertising
- We will process your personal information for the purposes listed in this section given our legitimate interests in undertaking marketing activities that offer you products or services that may be of interest.
3.4 Profiling & Automated Decision Making
The advertisements and recommendations we show you are chosen by analyzing the personal information you provide us, including your inquiry history, account information, email marketing preferences, and other requests you have submitted. To choose tailored marketing content and advertisements of your interest, we conduct profiling—automated data processing that analyzes and makes predictions about our users. In addition, we compile and analyze information received from all our customers to gain a better understanding of your preferences from customers similar to you.
4. Information Sharing & Disclosure
This section describes how LUXOS may share and disclose your information, including personal information. We do so in the following ways:
4.1 With Your Consent
Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you participate in communication and marketing activities conducted by LUXOS’ partners or third parties.
4.2 Subsidiaries & Business Entities
4.3 Service Providers
LUXOS may engage a variety of third party service providers as business partners, subcontractors or agents to help us provide services related to the LUXOS Services. For example, Service providers may provide services on our behalf as account administration, data processing, fraud detection, analytics and marketing.
4.4 Business Transfers
4.5 Legal Compliances, Proceedings and Requirements
We may share your information with third parties, if we reasonably believe that disclosing the information is in accordance with or required by any applicable law, regulation or legal process. We may also share information about in the following ways for legal reason:
In the case of legal dispute, we will comply with court order for the protection of our Services and assets. For example, we will proceed legal action for the collection of overdue accounts.If we receive a request or are under a duty to disclose or share your personal data in order to comply with any legal obligation. In these cases, your personal information may be provided to legal, regulatory or law enforcement authorities or anti-fraud organizations for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements of governments or regulatory authorities.To enforce and administer our Terms of Conditions or other policies with other parties.To protect the safety and rights of LUXOS, its employees, its users, or members of the public.
4.6 Transfer Outside of the EEA
We may transfer your personal information from inside the EEA to outside the EEA. In this case where LUXOS’ transfer and processing of your personal information may be subject to the General Data Protection Regulation (“GDPR”), LUXOS replies on aforementioned legal grounds, including legitimate interests, to safeguard and process your personal information.
Certain countries (click here for the list) which outside the EEA have been recognized by the European Commission as providing an adequate level of protections, and therefore no additional safeguards are required to export your personal information to these jurisdictions. In countries which have not had these recognitions, we will establish legal grounds permitted by applicable legal requirements to justify the transfer of our personal information.
4.7 Aggregated Data
We may disclose or use aggregated information, meaning de-identified information which cannot be used to identify you, for any purpose. Aggregated information can help us provide more useful information to our users and business partners, while we also use it for regulatory compliance and market analysis. For example, we may share aggregated information with our business partners or advertising network to show the average amount of time our users spent on our Services within a period of time.
5. Your Controls & Privacy Rights
5.1 The Right of Access
In some jurisdictions, for example, the EEA, applicable law may entitle you to request copies of your personal information held by us. You will need to contact us via email, explaining the details of what you want in order for us to help you reviewing or editing your account information, including your marketing preferences, location data, and account deletion.
We will respond to your request within 30 days of receiving the request and will provide the necessary means for you to access your personal information. If we have received a number of requests from you or your request is substantive and complex in nature, we will extend the time to respond by further two months, meanwhile you will be notified of our reasons and the date arrangement within 30 days of receiving the request.
5.2 The Right to Data Portability
You also have the right to ask for and download personal information you have given us in a structured, commonly used, and machine-readable format, so that you can:
Request us to transmit this information to another service provider (where technically feasible)Keep it for yourself
5.3 Retention and Erasure of Personal Information
We retain your personal information for as long as it is necessary for the processing purpose for which the information was collected, and any other permissible purposes, such as comply with our legal obligations, resolve disputes, and enforce our Agreements. If you no longer want us to use your information to provide the LUXOS Services to you, you can request that we erase your personal information. Please note that if you request the erasure of your personal information, we may retain and/or use your personal information as necessary:
For our legitimate business interests, such as the safety of our Services.To comply with our legal obligations.If we are required to by applicable law, regulation or legal process.If there is an unresolved issue or dispute relating to our users.
5.4 The Right to Rectification
5.5 The right to Restrict Processing
You contest the accuracy of your personal information.You claim our processing of your information is unlawful while you deny to exercise the right of erasure.you require the information for your own establishment, exercise or defence of legal claims while we no longer need your personal information for our purposes of the processing.You have objected to the processing in accordance of Objection to Processing and pending the verification whether the legitimate ground of LUXOS override your own.
5.6 Objection to Processing
5.7 Withdrawing Consent
In certain cases, your exercise of these rights is subject to certain exemptions, for example, we may continue to process your information after you have withdrawn consent if we have a legitimate ground to do so, such as comply with legal obligations, resolve disputes and safeguard the public interest.
6. Operating Globally
To facilitate our global operations LUXOS may process your personal information with our business affiliates or service providers in any country where we have facilities or in which we engage service providers. If you are a user in the European Union, you should know that we deploy safeguards to protect your personal information if we transfer your personal information from the EEA to other countries not deemed adequate under applicable data protection law.
6.1 Where We Store Your Personal Data
Data is also stored with our third party service providers - ‘data processors’ in North America, Asia and is subjected to their commitment of data protection and privacy policies they have with LUXOS and laws governed within those countries.
6.2 Means to Ensure an Adequate Level of Data Protection
You also need to take your security seriously. Where we have given you or where you have chosen a password which enables you to access certain parts of our Services, you must keep your password secure, and never disclose it to a third party.
7. Security of Your Personal Information
LUXOS are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using SSL technology. Some of the safeguards we also use to protect your information are firewalls and data encryption, and information access controls.
9. Privacy Questions & Complaint
LUXOS Italia SRL.
Via Pietrasanta 14, 7b
Milan, Italy. 20141