Privacy Policy

Information pursuant to Article 13 of Regulation (EU) 2016/679 on the protection of personal data (GDPR) and request for consent for the processing of personal data collected through web services This Application collects certain Personal Data from its Users.

Data Controller

Luce Capital Srl – Foro Buonaparte 70, Milano luca.todesco@lucecapital.com

Types of Data Collected

Among the Personal Data collected by this Application, either independently or through third parties, are: Cookies, Usage Data, and email addresses. Other Personal Data collected may be described in other sections of this privacy policy or through informational texts displayed at the time the Data is collected. Personal Data may be provided voluntarily by the User, or, in the case of Usage Data, collected automatically when using this Application. The use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application, unless otherwise stated, serves the purpose of identifying the User and recording their preferences for purposes strictly related to the provision of the service requested by the User. Failure to provide certain Personal Data may make it impossible for this Application to provide its services. The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Application and declares that they have the right to communicate or disclose them, thereby releasing the Data Controller from any liability towards third parties.

Methods and Place of Data Processing

Methods of Processing The Data Controller processes Users’ Personal Data by adopting appropriate security measures aimed at preventing unauthorized access, disclosure, modification, or destruction of Personal Data. Processing is carried out using computer and/or telematic tools, with organizational methods and logic strictly related to the purposes outlined. In addition to the Data Controller, in some cases, categories of authorized personnel involved in the organization of the site (administrative, commercial, marketing, legal staff, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data. These external parties may also be appointed as Data Processors, if necessary, by the Data Controller. An updated list of Data Processors can always be requested from the Data Controller. Location The Data is processed at the Data Controller’s operational offices and in any other location where the parties involved in the processing are located. For further information, please contact the Data Controller. Retention Period The Data is processed for the time necessary to fulfill the service requested by the User or for the purposes described in this document. The User can always request the interruption of the processing or the deletion of their Data.

Purposes of the processing

The User’s Data is collected to allow the Data Controller to provide their services, as well as for the following purposes: Statistics and Contacting the User. The types of Personal Data used for each purpose are specified in the relevant sections of this document

Details on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Contact Form

Provider This Application Purpose Contacting the User Privacy Policy By filling out the contact form with their Data, the User consents to their use for responding to information requests, quotes, or any other nature specified in the form header. Personal Data Collected First Name, Last Name, Email, Phone Number, Various types of Data

Google Maps

Provider Google Inc. Purpose Displaying content from external platforms Personal Data collected Cookies Usage Data Privacy Policy Google Maps is a map viewing service managed by Google Inc. that allows this Application to integrate such content within its pages.

Google Analytics

Provider Google Inc. Purpose Statistics Personal Data collected Cookie Usage Data Privacy Policy Google Analytics is a web analytics service provided by Google Inc. (Google). Google uses the Personal Data collected for the purpose of tracking and analyzing the use of this Application, compiling reports, and sharing them with other services developed by Google. Google may use the Personal Data to contextualize and personalize the ads of its advertising network.

Cookies Policy

This Application uses Cookies. To learn more and for detailed information, you can refer to the Cookie Policy.

Further information on the processin

Defense in legal proceedings The User’s Personal Data may be used by the Data Controller for defense purposes in legal proceedings or in the preparatory stages of potential litigation, including cases of misuse of the application or related services by the User. The User acknowledges that the Data Controller may be required to disclose the Data upon request from public authorities. Specific information Upon the User’s request, in addition to the information contained in this privacy policy, this Application 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 operational and maintenance purposes, this Application and any third-party services it uses may collect system logs, which are files that record interactions and may contain Personal Data, such as the User’s IP address. Information not contained in this policy Further information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact details. Exercise of User rights Individuals to whom the Personal Data refers have the right, at any time, to obtain confirmation of the existence or non-existence of their data with the Data Controller, to know its content and origin, to verify its accuracy, or to request its integration, deletion, updating, correction, transformation into anonymous form, or blocking of Personal Data processed in violation of the law, as well as to oppose the processing of their data for legitimate reasons. Requests should be directed to the Data Controller. This Application does not support ‘Do Not Track’ requests. To find out if any third-party services used by this Application support them, the User is encouraged to consult the respective privacy policies. Changes to this privacy policy The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to Users on this page. Therefore, please check this page frequently, referring to the last modified date indicated at the bottom. If the User does not accept the changes made to this privacy policy, they must cease using this Application and may request the Data Controller to remove their Personal Data. Unless otherwise specified, the previous privacy policy will continue to apply to Personal Data collected up to that point. Information about this privacy policy The Data Controller is responsible for this privacy policy, which was created using templates provided by Garoo and stored on its servers.

Purposes of the processing

Personal Data (or Data) Personal data refers to any information related to an identified or identifiable natural person, either directly or indirectly, through reference to any other information, including a personal identification number. Usage Data These are the information collected automatically by this Application (or by third-party applications that this Application uses), including: IP addresses or domain names of computers used by the User connecting to this Application, addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, various temporal aspects of the visit (e.g., the time spent on each page), and details regarding the navigation path within the Application, particularly concerning the sequence of pages visited, the parameters related to the operating system, and the computing environment of the User. User The individual who uses this Application, who must coincide with the Data Subject or be authorized by them, and whose Personal Data is subject to processing. Data Subject The natural or legal person to whom the Personal Data refers. Contact Details of the Data Protection Officer (DPO) The natural or legal person, public authority, or any other body, association, or organization appointed by the Data Controller to process Personal Data, as provided for in this privacy policy. Data Controller (or Controller) The natural or legal person, public authority, or any other entity, association, or organization to whom, jointly with another controller, the decisions regarding the purposes, methods of processing personal data, and the tools used, including the security aspects, in relation to the operation and use of this Application, belong. The Data Controller, unless otherwise specified, is the owner of this Application. This Application The hardware or software tool through which the User’s Personal Data is collected. Cookies Small pieces of data stored within the User’s device. Rights of the Data Subject You may, at any time, exercise the rights indicated below: a. Access to personal data: To obtain confirmation of whether or not data processing is being carried out concerning you and, in that case, access to the following information: the purposes, categories of data, recipients, retention period, the right to lodge a complaint with a supervisory authority, the right to request rectification or deletion, or restriction of processing, or to object to processing, as well as the existence of automated decision-making processes; b. Request for rectification or deletion of data or restriction of processing: Restriction means marking the stored data with the aim of limiting its processing in the future; c. Objection to processing: To object, for reasons related to your specific situation, to the processing of data for the performance of a task in the public interest or the pursuit of a legitimate interest of the Data Controllers; d. Data portability: In the case of automated processing based on consent or in the performance of a contract, to receive your data in a structured, commonly used, and machine-readable format; e. Withdrawal of consent to processing for marketing purposes, both direct and indirect: Exercising this right does not affect the lawfulness of processing carried out before the withdrawal; f. Lodging a complaint pursuant to Article 77 of the GDPR with the competent supervisory authority based on your habitual residence, place of work, or location of the violation of your rights: For Italy, the competent authority is the Italian Data Protection Authority (Garante per la protezione dei dati personali), which can be contacted through the contact details provided on the website http://www.garanteprivacy.it. The aforementioned rights can be exercised by sending a specific request to the Data Controller through the contact channels indicated in Article 1 of this policy. Requests to exercise your rights will be processed without undue delay and, in any case, within one month from the request; only in cases of particular complexity or a large number of requests may this period be extended by an additional 2 (two) months. Communication and provision of data The communication of your personal data to the recipients referred to in point 2) of Article 4 of this policy takes place in compliance with a legal obligation, while to the other recipients referred to in points 1), 3), and 4) of the same article, it occurs in compliance with a contractual obligation when necessary to perform the services requested by you. Providing the data is mandatory as it is necessary for the execution of obligations arising from the sales proposal or the provision of services, or for the conclusion of a contract at your request, and in any case, for the fulfillment of legal obligations to which the Data Controllers are subject. Therefore, your refusal to provide the data may result in the non-acceptance of your request for services, to the extent that such data is necessary for these purposes. The eventual communication of your personal data to the recipients referred to in point 6) of Article 4 of this policy occurs in compliance with your explicit consent (marketing consent). Legal References Notice to European Users: This privacy policy is drafted in compliance with the obligations set forth in Article 10 of the Directive and Article 13 of Regulation (EU) 2016/679 on the protection of personal data (GDPR).