For the intents and purposes of art. 13 and 14, Regulation (EU) 2016/679 (hereafter abbreviated to “GDPR”) and the Italian personal data protection Code (legislative decree 196/2003) insofar as it is compatible, AUREA S.R.L., whose registered office is at 37, Via G. Watt, 20143 – Milan (MI), VAT no. 09209240960, in its capacity as data controller, provides you with the following information about the processing of your data as transmitted by means of the form on the contact page for the purpose of subsequent payment and delivery of the Gift Card on the website www.lumemilano.com.
Regarding the entering of your data for the purposes of formulating requests and sending communications by filling out the appropriate form on the website www.lumemilano.com/gift-card/, please note the following.
The processing that the personal data provided by you and/or requested and/or acquired from you is exclusively for the purpose of sending requests and/or communications to Aurea S.r.l. in relation to the provision of food services following the purchase of a Gift Card.
For the purposes of the foregoing, consent granted by accepting this privacy statement authorizes Aurea S.r.l. to send to the e-mail address indicated on filling out the form communications, information and messages from the data controller and/or its subsidiaries, parent companies or companies in any way connected with the data controller for the purpose of answering your requests conveyed by said form, all direct marketing activities being excluded.
The processing of personal data will be carried out by operations or sets of operations which may also entail the use of digital processes and, according to the definition in art. 4, par. 1, n. 2), GDPR, “recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction”; the whole within the limits and for the purposes described above. Please note that the “personal data” provided by you and/or requested and/or acquired from you will be processed in paper form and/or using electronic, digital and/or telecom devices and in any case with logics and procedures strictly indispensable for the purposes of the processing. “Personal data” is defined by current legislation (art. 4, par. 1, n. 1, GDPR) as “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
Adequate technical and organizational measures have been taken by the data controller to prevent the destruction, modification, illicit or incorrect use, unauthorized dissemination or accidental or illegal access to the personal data transmitted, stored or in any way processed.
Your personal data will be stored and processed by the data controller in full compliance with the principles of fairness, lawfulness and transparency and the safeguarding of confidentiality, with logics strictly correlated with the purposes indicated in this privacy statement. In particular, such processing will be carried out in compliance with the processing security requirements of GDPR (art. 25 and 32-35) for the assessment of which the data controller has performed risk analysis and taken the measures deemed adequate for the risks.
The data controller declines all responsibility regarding the truthfulness and consent to processing of data relative to the 3rd parties indicated by you to identify the beneficiary of the Gift Card. Regarding the rights of such 3rd parties, you declare that you have fulfilled the obligations provided for in current law on the protection of personal data, including any special data, and expressly hold Aurea S.r.l. harmless against all liability arising from acquisition of consent on the part of said parties and any further obligations and/or actions. The data controller undertakes to protect the data of 3rd parties provided by the Client with the same level of diligence it applies to protecting the Client’s data, with the additional limitation that the processing will be carried out within the limits of what is strictly necessary for providing the contractual services.
Provision of your personal data is strictly necessary for correctly and fully satisfying the request you made and transmitted using the contact form on the website www.lumemilano.com/en/gift-card-en/.
You may in any case withdraw your consent to processing at any time by sending notice thereof to the data controller at the following address: email@example.com. This e-mail address may also be used by you to exercise all the rights indicated hereunder (see section E of this privacy statement).
Your refusal to provide the data and/or your provision of inexact and/or incomplete information as described in B) will make it impossible for our Company to correctly and fully satisfy your request.
Your personal data will be processed exclusively by subjects appointed for the purpose by the data controller as responsible for the processing of data and/or as subjects engaged to process the data; such subjects will process your data only when necessary for the purposes for which it was provided and only in the context of performing the tasks assigned to them by the data controller, and will only process the data necessary for carrying out such tasks and perform only the operations necessary for carrying out same.
Your personal data will not be disseminated.
You may at any time exercise the rights provided for in Regulation (EU) 2016/679 as fully transcribed hereunder:
Right of access by the data subject (Article 15 – considering 63-64)
1. The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
(a) the purposes of the processing;
(b) the categories of personal data concerned;
(c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
(d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
(e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
(f) the right to lodge a complaint with a supervisory authority;
(g) where the personal data are not collected from the data subject, any available information as to their source;
(h) the existence of automated decision-making, including profiling, referred to in Article 22 (1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
3. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others
Right to rectification (Article 16 – considering 65)
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Right to erasure (‘right to be forgotten’) (Article 17 – considering 65-66)
1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;
(c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
(d) the personal data have been unlawfully processed;
(e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
(f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
(a) for exercising the right of freedom of expression and information;
(b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
(c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
(d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
(e) for the establishment, exercise or defence of legal claims.
Right to restriction of processing (Article 18 – considering 67)
1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
(a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
(b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
(c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
(d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.
2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.
Notification obligation regarding rectification or erasure of personal data or restriction of processing (Article 19 – considering 31)
The controller shall communicate any rectification or erasure of personal data or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject about those recipients if the data subject requests it.
Right to data portability (Article 20 – considering 68)
1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
(a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
(b) the processing is carried out by automated means.
2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
Automated individual decision-making, including profiling (Article 22 – considering 71-72)
1. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.
2. Paragraph 1 shall not apply if the decision:
(a) is necessary for entering into, or performance of, a contract between the data subject and a data controller;
(b) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests; or
(c) is based on the data subject’s explicit consent.
3. In the cases referred to in points (a) and (c) of paragraph 2, the data controller shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.
4. Decisions referred to in paragraph 2 shall not be based on special categories of personal data referred to in Article 9(1), unless point (a) or (g) of Article 9(2) applies and suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests are in place.
Communication of a personal data breach to the data subject (Article 34 – considering 86-88)
1. When the personal data breach is likely to result in a high risk to the rights and freedoms of natural persons, the controller shall communicate the personal data breach to the data subject without undue delay.
2. The communication to the data subject referred to in paragraph 1 of this Article shall describe in clear and plain language the nature of the personal data breach and contain at least the information and measures referred to in points (b), (c) and (d) of Article 33(3).
3. The communication to the data subject referred to in paragraph 1 shall not be required if any of the following conditions are met:
(a) the controller has implemented appropriate technical and organisational protection measures, and those measures were applied to the personal data affected by the personal data breach, in particular those that render the personal data unintelligible to any person who is not authorised to access it, such as encryption;
(b) the controller has taken subsequent measures which ensure that the high risk to the rights and freedoms of data subjects referred to in paragraph 1 is no longer likely to materialise;
(c) it would involve disproportionate effort. In such a case, there shall instead be a public communication or similar measure whereby the data subjects are informed in an equally effective manner.
4. If the controller has not already communicated the personal data breach to the data subject, the supervisory authority, having considered the likelihood of the personal data breach resulting in a high risk, may require it to do so or may decide that any of the conditions referred to in paragraph 3 are met.
Right to object (Article 21 – considering 69 – 70)
1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on Article 6(1) point (e) editor’s note: processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller or (f) editor’s note: processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. The latter point shall not apply to processing carried out by public authorities in the performance of their tasks, including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
Regarding the right to object, the law provides that this may be exercised to object in whole or part to:
a) for legitimate reasons, processing of personal data that concern you, even if relevant to the purpose of collection;
b) processing of personal data that concern you for the purposes of sending advertising or direct sale material or for conducting market research or commercial communication by means of automated calling systems without the intervention of an operator, e-mail and/or traditional marketing methods (phone and/or normal mail) provided you have consented to such processing. Please note that your right to object to processing for direct marketing purposes by means of automated systems, as indicated in the preceding point, extends to traditional methods and that you may in any case also exercise your right to object only partially. You may therefore decide to receive communications only by traditional methods or only automated communications or neither of the two types of communication.
The data you provide will not in any case be used for marketing purposes unless you express free, specific, informed and unequivocal consent.
To exercise the rights detailed in the foregoing articles you may send a specific request to the data controller at the following e-mail address:
The data controller is Aurea S.r.l., whose registered office is in (20143) Milan (MI), Via G. Watt n. 37, VAT no. 09209240960, a wholly owned subsidiary of Carol Invest S.r.l., based in (41124) Modena (MO), via Gaetano Moreali n. 11. For further information about the data controller and/or the subject/s responsible for processing you may send a specific enquiry to the following email address: firstname.lastname@example.org.
Latest update: November 2018