Among the types of personal data that this application collects, either by itself or through third parties, are: first name; last name; company name; email address; trackers; usage data. Complete information on each type of collected personal data is provided in the sections dedicated to this privacy policy or by specific explanatory texts displayed before the data collection.

Personal data may be provided voluntarily by the user or, in the case of usage data, collected automatically when using this application.

Unless otherwise specified, the provision of all data requested by this application is mandatory, and failure to provide this data may make it impossible for this application to provide its services. In cases where this application specifically states that some data is not mandatory, users are free not to communicate this data without any consequences for the availability or functionality of the service.

Users who are unsure about which personal data is mandatory can contact the owner.

Any use of cookies or other tracking tools by this application or by the owners of third-party services used by this application is intended to provide the service requested by the user, in addition to any other purposes described in this document and in the cookie policy, if available.

Users are responsible for any third-party personal data obtained, published, or shared through this application.

Methods of processing and location of data processing

Processing methods

The owner takes appropriate security measures to prevent unauthorized access, disclosure, alteration, or unauthorized destruction of the data.

Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the owner, in some cases, the data may be accessible to certain types of responsible persons involved with the operation of this application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communication agencies) appointed, if necessary, as data processors by the owner. The updated list of these parties may be requested from the owner at any time.

Location

The data is processed at the owner's operating offices and at any other locations where the parties involved in the processing are located.

Depending on the user's location, data transfers may involve transferring the user's data to a country other than their own. For specific information about the personal data used for each purpose, the user can contact the owner by email at info@lumiiagency.com.

Retention time

Unless otherwise specified in this document, personal data is processed and stored for as long as required for the purpose they were collected and may be retained longer due to legal obligations or with the user's consent.

Purposes of processing

The user's data is collected to allow the owner to provide its service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its users or third parties), detect any malicious or fraudulent activity, as well as the following purposes: contacting the user and analytics.

For specific information about the personal data used for each purpose, users can refer to the section "Detailed information on the processing of personal data."

Further information for users

Legal basis of processing

The owner may process users' personal data if one of the following conditions applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations, the owner may be allowed to process personal data until the user objects to such processing ("opt-out") without relying on consent or any other of the following legal bases. However, this does not apply when the processing of personal data is subject to European data protection law;

• The provision of data is necessary for the performance of an agreement with the user and/or for any pre-contractual obligations thereof;

• The processing is necessary for compliance with a legal obligation to which the owner is subject;

• The processing is related to a task carried out in the public interest or in the exercise of official authority vested in the owner;

• The processing is necessary for the purposes of the legitimate interests pursued by the owner or a third party.

In any case, the owner will gladly clarify the specific legal basis that applies to the processing, and in particular, whether the provision of personal data is a statutory or contractual requirement or a necessary requirement to enter into a contract.

Further information on retention time

Unless otherwise specified in this document, personal data is processed and stored for as long as required for the purpose they were collected and may be retained longer due to an applicable legal obligation or with the user's consent.

Therefore:

• Personal data collected for purposes related to the performance of a contract between the owner and the user will be retained until such contract has been fully performed.

• Personal data collected for the purposes of the owner's legitimate interests will be retained as long as needed to fulfill such purposes. Users can find specific information regarding the legitimate interests pursued by the owner in the relevant sections of this document or by contacting the owner.

• The owner may be permitted to retain personal data for a longer period whenever the user has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the owner may be obliged to retain personal data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, personal data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the retention period has expired.

User rights

Users may exercise certain rights regarding their data processed by the owner. In particular, users have the right to do the following, to the extent permitted by law:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their personal data.

• Object to the processing of their data. Users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent.

• Access their data. Users have the right to learn if data is being processed by the owner, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the data undergoing processing.

• Verify and seek rectification. Users have the right to verify the accuracy of their data and ask for it to be updated or corrected.

• Restrict the processing of their data. Users have the right, under certain circumstances, to restrict the processing of their data. In this case, the owner will not process their data for any purpose other than storing it.

• Have their personal data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their data from the owner.

• Receive their data and have it transferred to another controller. Users have the right to receive their data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed by automated means and that the processing is based on the user's consent, on a contract which the user is part of, or on pre-contractual obligations thereof.

• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

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Users also have the right to obtain information about the legal basis for data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the owner to safeguard their data.

Details about the right to object to processing

Where personal data is processed for a public interest, in the exercise of an official authority vested in the owner, or for the purposes of the legitimate interests pursued by the owner, users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that should their personal data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn whether the owner processes personal data for direct marketing purposes, users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise user rights can be directed to the owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the owner as early as possible and always within one month, providing the users with the information required by law. Any rectification or erasure of personal data or restriction of processing will be communicated by the owner to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves a disproportionate effort. Upon request of the users, the owner will inform them about those recipients.