LAMPOO PRIVACY NOTICE

We inform you that, in agreement with EU Regulation 2016/679 ("Regulation" or "GDPR"), your Personal Data will be processed by Lampoo S.r.l., with registered office in Milan, Via Albricci n. 9, and Lampoo Ltd, with registered office in First Floor 34 St. James Street London SW1AHD, as co-owners of the processing under a co-ownership agreement, version of 15/06/2023. 

How do we collect your personal data?

Lampoo processes your personal data in the following circumstances:

• if you contact us directly, for example through our website, by e-mail or by telephone through our hotline, or at our stores to request information about our services;
• if you buy or sell a product through our website, our stores, our offices or our Luxury Managers;
• if you register an account on our website;
• if you respond to our marketing campaigns, for example, by registering for a commercial newsletter;
• if your contact details are disclosed to us by a Luxury Manager, subject to your consent where necessary;
• if we acquire your personal data from other sources (e.g., from intermediaries), in full compliance with applicable law;
• if you attend an event organized by Lampoo;
• if you browse our websites.

Please note that this Privacy Notice applies to the website www.lampoo.com and all other domains used by Lampoo Srl.

If you provide personal information on behalf of someone else is your responsibility to ensure, even before doing so, that the person concerned has read this Privacy Notice.

If you are under 18 years of age, you may not provide us with any personal information. 

What personal data about you may be collected?

The following categories of personal data may be collected through the services and contact channels described in this Privacy Notice:

• Contact data - first and last name, address, phone number, email address.
• Other data - date of birth, gender.
• Interests - information you provide to us about your interests, including the type of products in which you are interested.
• Other Personal Data - information you provide to us regarding the completion of anti-money laundering documentation.
• Payment Data - credit/debit card and/or service numbers (including payment instalments), Paypal account, IBAN.
• Site and Communications Usage - information about how you use our site, open or forward our communications, including information collected through cookies and other tracking technologies.
• Online Account Information - Account ID and account information.
• Sales, Purchase and Support Information - information related to purchases and sales, support and service, including complaints.
• Images - images of you collected through photos and / or videos taken at events organized by Lampoo.
• Social Log-In - personal data necessary to register on our sites that provide this option (user-ID and password), as well as other data you provide to the social network through which you log-in, which may be disclosed according to the privacy preferences you have set on that social network.

Cookies

We automatically collect information using "cookies". Cookies may be set by us or by third parties. A cookie is a text file that contains small amounts of information that a website can send to your browser and that may be stored on your computer as a tag, which identifies your computer but not you. Some of the pages on our website use cookies to provide users with better service when they return to the website. Cookies allow us to store information about visitors' preferences, they are used to verify the proper functioning of the site and to improve its functionality by customizing the content of the pages according to the type of browser used, or to simplify navigation by automating procedures (eg. Login, site language), and finally for the analysis of the use of the site by visitors. You can decide which cookies to activate in the  Cookie settings , where you’ll find additional information on cookies of the website.

We also share information about how you use our site with our web analytics, advertising and social media partners, who may combine it with other information you have provided to them or that they have collected from your use of their services.

 

For what purposes can your personal data be used?

1. Direct communications to customers for marketing and remarketing purposes - to provide you with news and offers about our products and / or services by sending e-mail and / or telephone. Lampoo collects Contact Information, Interests, Account ID and may use the information on Sales, Purchase and Service that it receives from you through interaction with the website Lampoo.com, the Lampoo account or through Luxury Manager to contact you about general commercial offers, or in line with your preferences or to invite you to promotional events, as well as to conduct market research.

Prerequisite for processing: consent 

Revocation: Consent may be revoked at any time by pressing the "unsubscribe" button, present in every email sent by Lampoo for these purposes, or by direct communication to the contact details in the Information Notice.

Choice: the provision of your data is optional

2. Sending newsletters with commercial content - to allow the periodic sending of newsletters about services, promotions and offers Lampoo.

Lampoo collects through specific pop-up or sections of the site Lampoo.com Contact Information. The newsletter is sent by e-mail to send periodic communications with informative content on products, news, events concerning Lampoo. 

Prerequisite for processing: consent

Options: unsubscribe from the newsletter portal.

Choice: the provision of your data is optional

3. Profiling - the processing of navigation data and personal data of users aimed at the analysis and personalization of services and marketing activities based on the tastes, preferences, habits, needs and consumption choices of customers. We use third party services for the above processing. These treatments will also be used to perform analysis and statistical processing regarding the personal characteristics of Lampoo customers and for activities of so-called "clustering", or for the creation of so-called "target groups" for internal analysis and monitoring of market trends and consumption, for the creation of new "clusters" of users based on similar browsing habits and interests.

The data collected for profiling purposes will be stored for a period of 24 months from the time they were collected.

Prerequisite for processing: consent 

Revocation: Consent may be revoked at any time by pressing the "unsubscribe" button, present in every email sent by Lampoo for these purposes, or by direct communication to the contact details in the Information Notice.

Choice: the provision of your data is optional

4. Use of Services by Customers - to respond to your requests (regarding any possible sales and / or purchase), shipments, pickups and deliveries, Lampoo collects contact data, interests and other personal data (where required by law), through the website Lampoo.com or physically at the stores or offices or through its call centre, to respond to your requests, including sharing, if necessary, such information with Luxury Manager. With reference to cal centre, it is acknowledged that calls will be recorded for qualitative purposes, i.e. to ascertain the level of service for training purposes. Any interest in collecting and/or recording particular data is excluded; therefore, please do not provide such information during your phone calls with opperators.

Premise for the treatment: execution of pre-contractual and contractual measures

Choice: opposition in the case of legitimate interest, if the conditions are met. 

5. Sales Support, Purchasing and Assistance - to provide support, in the management of the sale and purchase of products through Lampoo, including through the provision of IT infrastructure and / or assistance at points of sale, and / or through a Luxury Manager and/or through its call centre and/or by sending messages via WhatsApp Business. With regard to call centre, please note that calls will be recorded for quality purposes only, i.e. to ascertain the level of service and for training purposes. There is no interest in collecting and/or recording any special data, so please do not provide such information during your calls with operators.

Prerequisite for processing: fulfillment of contractual obligations.

Choice: opposition in the case of legitimate interest, if the conditions are met. 

6. Customer Satisfaction Surveys. The personal data collected for the purpose referred to in paragraph 5 above may be processed for the further purpose of conducting "Surveys of Customer Satisfaction". Lampoo may process such data to conduct surveys to measure the level of customer satisfaction (cd. customer satisfaction) on the services provided, including by Luxury Manager. Lampoo may share your contact details and the results of the survey with the Luxury Manager who has provided the service, so that it can contact you again if you have expressed dissatisfaction, complaints or grievances. If you do not wish to be contacted, it will be sufficient for you to make the survey anonymous, following the instructions that will be given to you together with the relative questionnaire.

Prerequisite for processing: legitimate interest

Legitimate interest: This processing is based on Lampoo's legitimate interest to improve the sales and service.

Choice: opposition in the case of legitimate interest, if the conditions are met.

7. Defence of rights during judicial, administrative or extrajudicial proceedings and disputes arising about the services offered. 

Your personal data may be processed by Lampoo to defend their rights or take legal action or make claims against you or third parties.

Prerequisite for processing: legitimate interest.

Legitimate interest: This processing is based on the legitimate interest of Lampoo to protect and defend their rights.

Choice: opposition in the case of legitimate interest, if the conditions are met.

8. Fulfilment of obligations under laws, regulations or legislation, provisions / requests of authorities empowered by law and / or by supervisory and control bodies.

Lampoo may process your personal data to fulfill its obligations (such as anti-money laundering legislation). 

Prerequisite for processing: legal obligations

9. Registration to websites through the system of Social Log-In (mode to simplify the registration process using the information already made to your Social Network).

Registration on the website Lampoo.com can be done by entering the data necessary for registration itself (such as contact details) directly from the person concerned or, where you voluntarily decide to use it, even with the mechanism of Social Log-In. In this way, you will not have to enter the data necessary for registration (such as contact details) which will be communicated by the Social Network through which the Log-In is carried out. Please note that in this case could be transmitted to Lampoo not only the Contact Information, but also any other personal data that may be made visible according to the preferences you set or according to the privacy Notice of the Social Network itself. We invite you, therefore, to read the privacy Notice of your Social Network, also for more information about these preferences. 

Authentication via Google and Facebook

If you register using your Google Ireland Ltd. (Ireland), Google LLC (USA) ("Google") or Facebook Ireland Ltd. (Ireland), Facebook, Inc. (USA) ("Facebook") or subsequently decide to link your Google and/or Facebook account to your Lampoo account, you will be directed from our website or App to the Facebook or Google website and asked to enter your Facebook or Google account login details.

If you enter your Google login details, Lampoo will receive the following data from your Google account: first and last name; google account picture; email address.

If you enter your Facebook login information, Lampoo will receive the following information from your Facebook account: profile photo; first and last name; email address.

The data we obtain from Facebook or Google will be used to set up your Lampoo account. This means that we will use the associated Facebook or Google account name as the user name for the Lampoo account.

Prerequisite for processing: fulfillment of contractual obligations, to allow you to register on the website, it being understood that you are not obliged to use the Social Log-In to complete your registration

10. Management of the access account to Lampoo.com and use of the site - to provide digital services related to the portal to which you may have access, such as management of the portal itself, viewing and management of the order cart, sales, complaints, etc.

Please see the paragraph above for cookies and respective settings.

Prerequisite for processing: fulfillment of contractual obligations.

Choice: cancellation of online account. 

11. Payment processing - Payments on the portal are made through payment service providers who provide processing and escrow services.

Basis for processing: Fulfilment of our contractual and legal obligations or those of our payment service providers towards portal users.

Choice: revocation, objection, if applicable

Adding a credit/debit card for payment purposes

When you add a credit/debit card for paying for products purchased from us, the payment service provider receives the following data: full name; credit card number; expiration date; security code (CVV/CVC).

You can remove the card at any time from your payment settings.

Payment by Klarna Bank AB or Paypal

To offer you the possibility to use the payment methods of Klarna Bank AB/Paypal, during checkout we will send Klarna Bank AB/Paypal your personal data (identification, contact details, order details) so that you can register on the Klarna.com/Paypal.com portal, which is necessary to use this payment method. The data collected by Klarna/Paypal at the time of registration at the portal Klarna.com/Paypal.com will be managed in accordance with the privacy Notice of Klarna Bank AB/Paypal.

 

What are the methods of expressing consent?

The consent may be expressed

- by signing a computerized document, including through specific flag boxes on Lampoo sites;

- by signing a paper document in case of interaction at points of sale or offices Lampoo.

Any renewal of consent may be solicited by email.

 

How do we keep your personal data secure?

We use a variety of security measures, including encryption and authentication tools, to enhance the protection and maintenance of the security, integrity and accessibility of your personal data.

Although it is not possible to guarantee security from intrusion for data transmission over the Internet and websites, we and our subcontractors and business partners strive to provide physical, electronic and procedural safeguards to protect your personal data in accordance with applicable data protection requirements. We take measures such as, among others:

• the strict restriction of access to your personal data, on an as-needed basis and for disclosed purposes only;
• the transfer of collected data only in encrypted form;
• storage of highly confidential information (such as credit card information) only in encrypted form;
• IT firewall systems to prohibit unauthorized access, e.g. by hackers
• permanent monitoring of access to IT systems to detect and stop misuse of personal data.

If we have provided you (or you have chosen) with a password that allows you access to certain sections of our website, you are responsible for maintaining the secrecy of that password and for complying with any other security procedures we tell you about. We ask that you do not share your password with anyone. 

 

How long do we keep your information?

We will only keep your personal data for as long as is necessary for the purposes for which it was collected or for any other related legitimate purpose (for example, where it is relevant to defend against claims made against us or where there is a legitimate interest). Therefore, if personal data is processed for two different purposes, we will retain that data until the purpose with the longer retention period expires; however, we will no longer process personal data for that purpose whose retention period has expired.

We restrict access to your information to those who need to use it for relevant purposes.

If your personal data is no longer required or there is no longer a legal basis for storing it, it will be irreversibly anonymized (and thus stored) or permanently deleted.

For the sake of clarity, below are the retention periods for the main purposes:

Marketing and remarketing purposes: personal data processed for marketing purposes, may be retained for 2 years from the date on which your data was collected for that purpose (except for your objection to receiving further communications).

Fulfillment of contractual obligations: the data processed to fulfill any contractual obligation with you, may be kept for the entire duration of the contract (or the end of the sweepstakes) as well as for a further 10 years from the end of the fiscal year following the year of competence, to deal with any assessment and/or dispute of a fiscal nature.

In the event of litigation: if we need to defend ourselves or act or even make claims against you or any third party, we may retain personal data that we deem reasonably necessary to process for such purposes, for as long as such claim may be pursued.

Sending newsletters: your data will be processed only for the period of subscription to the requested service. In case of cancellation of the service your data will be deleted within 30 days.

 

Who can we share your personal data with and how do we keep it secure?

Your personal data may be accessed by our staff, agents and suppliers (where appointed as third party data controllers) including those located in countries outside the European Economic Area (EEA), for one of the purposes set out, whose data protection laws may be of a lower standard than those of the EEA. In the latter case, we will ensure that all your personal data accessed outside the EEA is treated with appropriate safeguards.

Some countries outside the EEA, such as Canada and Switzerland, have been approved by the European Commission as providing similar protection to the EEA's data protection laws and therefore no additional legal protections are required. In the case of foreign countries that have not been granted such authorization, you will be asked for your consent to the transfer, if applicable, or your personal data will be transferred using contractual clauses approved by the European Commission. These clauses impose similar data protection obligations directly on the recipient, unless we are permitted by applicable data protection law to transfer the data without such formalities.

Please contact us at the references below if you would like to request to see the list of external data controllers.

Exercise of rights and contacts

If you have any questions concerning the processing of your personal data, or if you have any queries, please contact the company at +39 0249462186 (Monday to Friday 10 a.m. - 6 p.m. ) or at this e-mail address compliance@lampoo.com.

In addition, if you are an Italian user, you may also contact the Data Protection Officer, avv. Marco Mittone, at dpo@lampoo.com

In accordance with current legislation, you have the right to ask us for:

• further details on the processing of your personal data,
• a copy of the personal data you have provided us with,
• to update any inaccuracies in the data in our possession,
• to delete any data for which we no longer have any legal basis for processing,
•  to revoke your consent, where the processing is based on consent and relates to direct marketing activities, to cease such processing,
• to restrict the way in which we process your personal data when establishing a claim
• extract from the co-ownership agreement between Lampoo S.r.l. and Lampoo Ltd.

Right to object: in addition to the rights listed above, you have the right to object at any time, for reasons related to your situation, to the processing of your Personal Data carried out by the Controller for the pursuit of its own legitimate interest. You may also object at any time if the Personal Data is processed for marketing purposes.