Privacy Policy • Lugli Group

Last updated: August 2021

ABOUT LUGLI GROUP AND THIS PRIVACY POLICY

In this Privacy Policy, we use the term LUGLI GROUP (and ‘we’, ‘us’ and ‘our’) to refer to any LUGLI GROUP company and affiliates.

Please take a moment to read the following policy, including its Cookie Policy section, that explains how we collect, use, disclose and transfer the personal information that you provide to us on our websites, mobile applications and other digital platforms (together referred to as the ‘Platforms’), when you visit a LUGLI GROUP office, contact LUGLI GROUP by telephone, or when you interact with us over social media platforms.

Our Cookie Policy section explains how we collect information through the use of cookies and related technologies when you use our Platforms.

UPDATES TO THIS PRIVACY POLICY

From time to time, we may update this Privacy Policy. When we do, we will publish the changes on this Platform.

INFORMATION YOU PROVIDE TO US AND HOW WE USE IT

We collect the information from you as detailed below:

To access certain areas of our Platform, you may need to register with us. During the registration process you will be asked to submit personal information about yourself (including your name and address, date of birth, e-mail address and telephone number). By entering your details in the fields requested, you enable LUGLI GROUP to provide you with the services you select;
When you purchase services online or by phone, we may collect information such as your purchase details and relevant payment information. In addition, we will also collect personal information from you when you correspond with us (for example, if you contact us with a query about one of our services), when you provide your details when you visit a LUGLI GROUP office or contact LUGLI GROUP by telephone. Please note that phone calls could on occasion be recorded for security, training and development purposes;
If you choose to interact with LUGLI GROUP via a social media platform or other third-party service, we will collect the information you have provided to us through that platform;
We also collect certain information automatically about visitors to our Platform, described in the Cookie Policy section of this Policy;
We may also collect information about your location, to the extent that we provide any location services, described in the section headed ‘Location Services’ below.

We will use the information we collect from you to:

Manage and fulfill purchase orders and eventually to provide after-sales services;
Manage our accounts and records;
Deal with your inquiries and requests;
Send service-related communications, including announcements and administrative messages such as order confirmation;
Identify services we think you might be interested in based on your information, such as your purchase history and your previous interactions with us;
Send you marketing communications (including e-mails and social media audience matching) relating to us and other third-party partners and that we think may be of interest to you where we have a legitimate basis to do so (please see the ’Your choices’ section below for further information about how you can control these updates);
Conduct market research so that we can continuously improve the services we provide to our customers;
Undertake credit checking, prevention of fraud and other prohibited or illegal activities as part of our efforts to keep our Platform and services secure;
Understand how our Platform is used so that we can continuously improve our Platform and services and other offerings.

Where you have agreed to a particular use of your information, we process it on the basis of your consent. You may withdraw that consent at any time (for example, for us to send you marketing communications) by contacting us (see the section headed ‘Contact us’ below). We also process your information where this is necessary for the performance of a contract with you or where it is necessary for our legitimate interests of operating, protecting and improving our business.

COOKIES AND OTHER INFORMATION THAT WE AUTOMATICALLY COLLECT

Our websites (‘lugli.group’, ‘lugli.training’, ‘luminor.ai’) use cookies according to our Cookie Policy. This Cookie Policy is available to users on each information banner regarding cookies.

IP addresses

We will collect information about your computer or mobile device, including where available your IP address, operating system, log-in times and browser type. We use this information to better understand how visitors use our Platform and for internal reporting purposes. We will anonymise and share this information with advertisers, sponsors or other businesses.

COOKIE POLICY

The following information concerning the use of cookies and similar technologies on our websites (‘Site’), is provided to the user/visitor (‘you’) in compliance with the most embracing international legislation on the processing of personal data and electronic communications.

WHAT ARE COOKIES?

Cookies are small text files that are sent to you and saved on your computer or mobile device, which are then retransmitted to the same sites the next time you visit. Thanks to cookies, the site remembers the user's actions and preferences (such as login details, preferred language, font size, other display settings, etc.) so that they do not have to be indicated again when the user returns to the site or navigates from one page of it to another. Cookies, therefore, are used to perform digital authentication, session tracking and storage of information regarding users’ activities when accessing a site and may also contain a unique identification code that tracks a user’s navigation within the site itself for statistical or, eventually, advertising purposes. While browsing a site, you may also receive cookies from sites or web servers other than the one you are visiting (third party cookies) on your computer or mobile device. Certain actions cannot be carried out without the use of cookies, which in certain cases are technically necessary for the site to function properly.

There are different types of cookies and their functions vary according to their characteristics. They can stay on the user's computer or mobile device for different periods of time. For example, session cookies are automatically deleted when the browser is closed, whereas persistent cookies remain on the user's device for a predetermined amount of time.

According to current legislation, the use of cookies does not always require the express consent of the user. In particular, technical cookies do not require such consent; in other words, they are cookies that are essential for the operation of the site or necessary to perform activities requested by the user.

On the other hand, the user's prior consent is required for functionality cookies, i.e. used to activate specific Site features and a number of selected criteria (e.g. language, products selected for purchase) in order to improve the service provided; for analytical cookies, including third party cookies, which allow us to understand how you and others use the Site; for advertising cookies, i.e. those aimed at creating profiles related to the user and used to send advertising messages in line with the preferences expressed by the user when surfing the web and for social cookies (e.g. Facebook), that allow your interaction with the social media platform.

WHICH COOKIES ARE USED ON THE SITE?

Our Site may use all of the above-mentioned types of cookies in order to: operate the Site and for the provision of the services, understand and improve the user's browsing experience, as well as send you advertisements in line with your preferences when surfing the web and use other types of cookies.

We can divide the various types of cookies into:

technical cookies, i.e. browsing or session cookies which are strictly necessary for the operation of the Site or to allow you to take advantage of the content and services requested by you;
functionality cookies, i.e. used to activate specific Site features and a number of selected criteria (e.g. language, services selected for purchase) in order to improve the service provided;
analytical cookies, including third-party cookies, which allow us to understand how you and other users use the Site;
advertising cookies, including those from third parties, i.e. cookies aimed at creating profiles related to the user and used in order to send you adverts in line with your preferences expressed while surfing the web;
social cookies are third-party cookies (e.g. Facebook) that allow your interaction with the social media platform.

Functional cookies, analytical cookies, advertising cookies and social cookies are activated and used by the Site only if you give your prior consent for such use.

Third-party cookies, i.e. cookies from websites or web servers, are also used for purposes specific to these third parties.

HOW TO ENABLE OR DISABLE COOKIES

Browser

You can authorize, block or delete (in whole or in part) cookies through the specific functions of your browser. In the event that some or all of the cookies (technical or functional cookies, even including third-party cookies) are disabled, the Site: may not be available; some services or certain functions of the Site might not be available or will not function correctly; you may be forced to modify or manually enter certain information or preferences each time you visit the Site.

For details on how to set preferences for the use of cookies through your browser, please refer to the relevant instructions.

Below are links to settings regarding cookies for the major browsers:

Please remember that:

since technical cookies (including those of any third parties) are strictly necessary for the functioning of the Site or to use the content and services requested, it is not possible to disable this type of cookie, as this would compromise the correct functioning of the Site or the use of its content and services;
not authorizing functional cookies (including cookies from any third parties) may result in some services or functions on the Site not being available or not working properly and you may be forced to modify or manually enter certain information or preferences each time you visit the Site;
not authorising analytical, advertising or social cookies (including those of any third parties) will not affect the operation of the Site.

Your cookie preferences will need to be reset if you use different devices or browsers to access the Site or delete cookies from your device.

MORE INFORMATION

More information and details on the various types of cookies, the way they work and their characteristics can be found on the following sites (completely independent and not affiliated) www.AllAboutCookies.org and www.youronlinechoices.eu.

ABOUT ADVERTISING

The Platforms may use third parties such as network advertisers and ad exchanges to eventually serve you ads on third party platforms after you leave our Platforms, and we may use third party analytics and other service providers to evaluate and provide us and/or third parties with information about the use of the Platforms and viewing of ads and of our content. Network advertisers are third parties that display advertisements, which are based on your visits to the Platforms and other apps and sites you have visited. Third party ad serving enables us to target advertisements to you for products and services that you might be interested in.

Third party tracking technologies are not controlled by us, even if they are associated with our Platforms or our ads. Statements regarding our practices do not apply to the methods for collecting information used by these third parties and others or the use of the information that such third parties collect. The relevant third party’s terms of service, privacy policy, permissions, notices and choices should be reviewed regarding their collection, storage and sharing practices. We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties.

You have choices in respect of the delivery of ads. You can opt-out of receiving certain types of behavioral ads by visiting the third-party websites described in the sub-section headed ‘How to control or delete cookies’ in the section Cookie Policy of this document. We are not responsible for effectiveness of or compliance with any third parties’ opt-out options.

LOCATION SERVICES

Some of the services that we provide may be able to use information about your location. For these services, which are typically available on mobile devices or applications, you are provided with the opportunity to provide your consent to the use of location services, which, for example, process information deriving from GPS, sensors, beacons or Wi-Fi access points in order to allow you to benefit from a more personalized service. Your device will have settings that allow you to turn off these services should you no longer wish to benefit from them.

SHARING YOUR INFORMATION

We do not share personal information about you with other people or non-affiliated companies except under the following circumstances:

we will disclose your personal information to third party providers for the purposes of providing online and other payment services, handling credit checks and fraud prevention, and any other services required in order for us to use your information for the purposes specified in the section entitled ‘Information you provide us and how we use it’;
we will disclose your personal information to any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party; and
we will disclose your personal information to any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Privacy Policy.

INTERNATIONAL TRANSFERS

We have implemented standard contractual clauses to ensure adequate safeguards are in place to protect your information where it is transferred to our affiliated companies and offices in territories outside the European Economic Area, Confederazione Svizzera, Principauté de Monaco or Fürstentum Liechtenstein. Where we share your information with a third-party service provider outside of the European Economic Area, Confederazione Svizzera, Principauté de Monaco and Fürstentum Liechtenstein (as detailed in the section entitled ‘Sharing your information’), we contractually oblige the third-party service provider to implement adequate safeguards to protect your information.

PROTECTING YOUR INFORMATION

We want you to feel confident about using our Platform, and we are committed to protecting the personal information we collect. We limit access to personal information about you to employees who reasonably need access to it, to provide products or services to you or in order to do their jobs. We have appropriate technical and organizational, physical, electronic, and procedural safeguards to protect the personal information that you provide to us against unauthorized or unlawful processing and against accidental loss, damage or destruction. However, where we might ask you to choose a password in order to access certain parts of our Platform, you would be responsible for selecting a secure password and keeping that password confidential. You should choose a password which you do not use on any other site, and you should not share it with anyone else.

RETAINING YOUR INFORMATION

We keep your information for only as long as is necessary for our purposes, and in particular to protect ourselves in the event of a legal claim (for example, information relating to a contract with you will be kept for the lifetime of the contract and up to five years after). After this period, it will be deleted or in some cases anonymized. Where we sought your consent to process your personal information and we have no other lawful basis to continue with that processing, if you subsequently withdraw your consent, we will delete your personal information.

If you request that we no longer send you direct marketing communications, we will keep a record of your request and contact details to ensure that your request is respected.

YOUR CHOICES

You have the right to ask for access to any personal information that we hold about you in our records, to correct any inaccuracies and to update any out-of-date information. In some circumstances, you have the right to request the erasure of your personal information or a restriction of its use.

You have the right to object to us processing your personal information in some cases. In particular, you can ask us to stop sending you direct marketing communications at any time (however please note that we may continue to send you service-related (i.e. non-marketing) communications, such as e-mail updates on your order status). If you wish to exercise any of these rights, please write to us at the address listed below.

You may unsubscribe from e-mail marketing communications at any time by e-mailing the address below in the section headed ‘Contact us’ or clicking on the ‘unsubscribe’ link in any of our marketing e-mails.

If you have a concern about how we use your information, as a first step please contact us using the details set out below and we will do our best to resolve your concern. After investigating your concern, we will respond to you in writing within a reasonable time setting out our proposed remedial action. If you think we have processed your personal information in a manner which is unlawful or breaches your rights, you also have the right to complain to the Data Protection Authority in your place of residence or work, or the jurisdiction in which the processing took place.

If you have any questions or comments about this Privacy Policy, including its Cookie Policy section, or privacy matters generally, please contact us at the address provided below. You can also use this address if you wish to request access to the personal information we hold about you, or to unsubscribe from any further e-mail marketing communications.

If you have any questions about this Privacy Policy or the manner in which your information may be processed, please contact us in the language of your choice at: [email protected]