INFORMATION PURSUANT TO ARTICLES. 13 - 14 OF EU REGULATION 2016/679

(GENERAL DATA PROTECTION REGULATION - GDPR)

According to the above mentioned regulation, the processing of data, will be based on the principles of fairness, lawfulness, transparency and protection of your privacy and your rights. Luminal Agency Limited, with registered office at Unit 802, 8/F, Laws Commercial Plaza, 788 Cheung Sha Wan Road, Cheung Sha Wan, Hong Kong as the Data Controller, informs you pursuant to Articles 13 and 14 of GDPR 2016/679, that your data will be processed in the following manner and for the following purposes:

1) Object of processing

The Data Controller, processes personal, identifying data (in particular, first name, last name, e-mail, telephone-mobile phone number - hereinafter, “personal data” or also “data”) communicated to Him. Information about the cookies used is available by consulting the appropriate cookie policy.

2) Purposes of processing

Purposes of the processing The processing of your data is based on your consent and is carried out for the following purpose: - to enable the sending of newsletters, for communications, organization of events and the further Services that may be requested, for the allocation of discounts and commercial advantages; - to fulfill the obligations required by law, regulation, EU legislation or an order of the Authority; - to exercise the rights of the Contractors, e.g. the right to defense in court.

3) Method of processing

The processing of your personal data is carried out by means of the operations indicated in Art. 4 No. 2) GDPR and namely: collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion and destruction of data. Your personal data are subject to both paper and electronic and/or automated processing.

4) Access to data

Data may be made accessible, for the purposes mentioned in 2 above, to employees and staff members of Luminal Agency Limited, in their capacity as appointees and/or handlers.

5) Communication of data

Without express consent (art. 6 lett. b) and c) GDPR), the Data Controllers may still communicate the data for the purposes of art. 2.A) to Supervisory Bodies, Judicial Authorities as well as to all other subjects to whom the communication is compulsory by law for the fulfillment of the said purposes. Your data will not be disseminated.

6) Transfer of data

The management and storage of personal data will take place on servers located within the headquarters of the Data Controller and/or Data Processor. The data will be subject to transfer outside the European Union, by virtue of the registered office of the Data Controller itself.

7) Data dissemination. Data Profiling.

Your personal data are not subject to dissemination.

8) Nature of the disclosure of data and consequences of refusal to respond.

Please note that, taking into account the purposes of the processing as explained above, the provision of data is not mandatory.

9) Rights of the data subject

As a data subject, the rights set forth in Article 15 GDPR are recognized, namely the rights to:

a) obtain confirmation of the existence or otherwise of personal data, even if not yet registered, and their communication in intelligible form;

b) obtain the following information:

- the source of the personal data;

- the purposes and methods of processing;

- the logic applied in case of processing carried out with the aid of electronic instruments;

- of the identification details of the co-owners, data processors and the designated representative pursuant to Article 3 paragraph 1, GDPR 2016/679;

- the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representative in the territory of the State, managers or appointees;

(c) obtain:

- the updating, rectification or, when necessary, the integration of data;

- the cancellation, transformation into an anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept in relation to the purposes for which the data were collected or subsequently processed;

- certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;

d) object, in whole or in part:

- for legitimate reasons to the processing of personal data, if they are not relevant to the purpose of collection;

- to the processing of personal data, for the purpose of sending advertising material through the use of automated calling systems without the intervention of an operator by email and/or through traditional marketing methods by telephone and/or paper mail. It should be noted that the data subject's right to object, set out in point b) above, for direct marketing purposes through automated modalities extends to traditional ones and that, in any case, the possibility for the data subject to exercise the right to object even partially remains unaffected. The data subject may decide to receive only communications by traditional means or only automated communications or neither type of communication.

Where applicable, you have the rights under Articles 16-21 GDPR (Right to rectification, right to be forgotten, right to restrict processing, right to data portability, right to object), as well as the right to complain to the Data Protection Authority.

10) Methods of exercising rights

You may exercise your rights by written request sent to the Holder, to the mailing address of the registered office or to the email address of the corporate CFO privacy@d1milano.com .

11) Minors

The Controller does not intentionally collect personal information referring to minors. In the event that information about minors is unintentionally recorded, the Owner will delete it in a timely manner upon the users' request.

12) Duration of processing.

We inform you that, in accordance with the principles of lawfulness, purpose limitation and data minimization, pursuant to Article 5 of the Regulations, subject to your free and explicit express consent to the processing of your personal data for the purposes referred to in point 2 above at the end of this notice, your personal data will be retained for a period of time not exceeding the achievement of the purposes for which they are processed, or according to the deadlines provided for by the law. A check on the obsolescence of the retained data in relation to the purposes for which they were collected is carried out periodically.

13) Right to complain to a supervisory authority.

You have the right to complain to the supervisory authority (for Italy this is the Garante della Privacy, https://www.garanteprivacy.it) at any time if they believe that their data is being processed in an unorthodox manner; data subjects may alternatively complain to the supervisory authority in their country of residence, or the country where the data subject works, or where the breach occurred.

14) Data Controller, Data Processor and Persons in Charge

The Data Controller is Luminal Agency Limited. The updated list of Data Processors and Processor(s) is kept at the offices of the Data Controller.