Privacy Policy

Privacy Policy

This Privacy Policy regulates the purpose and manner of processing personal data that Luna doo Požarevac, as a controller, collects from users of the site: www.fashion-luna.com (hereinafter: the site). These data are collected and processed in accordance with the Law on Personal Data Protection ("Official Gazette of RS", no. 87/2018) (hereinafter: LPDP) and the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and on repealing the Directive 95/46/EC (General Data Protection Regulation) (hereinafter: GDPR).
The privacy policy applies to the site and all digital marketing channels associated with it.

Meaning of the Terms

In accordance with LPDP and GDPR, the following terms have the following meanings:

"Personal data" (hereinafter: personal data) is any data relating to a natural person whose identity is determined or identifiable, directly or indirectly, in particular on the basis of an identity designation, such as name and identification number, location data, identifiers in electronic communication networks or one or more features of its physical, physiological, genetic, mental, economic, cultural and social identity;

"processing of personal data" is any action or set of actions performed automatically or non- automatically with personal data or their sets, such as collecting, recording, classifying, grouping, i.e. structuring, storing, adjustment or changing, disclosing, inspecting, use, disclosure by transmission or delivery, duplication, dissemination or otherwise making available, comparing, restricting, deleting or destroying;

"controller" is a natural or legal person, i.e. a public authority which independently or together with others determines the purpose and manner of processing;

"processor" is a natural or legal person, i.e. a public authority that processes personal data on behalf of the controller;

"pseudonymization" means processing in such a way as to prevent the attribution of personal data to a specific person without the use of additional data, provided that these additional data are kept separate and that technical, organizational and personnel measures are taken to ensure that personal data cannot be attributed to a specific or identifiable person.

Controller

Below is the responsible controller of the processing of personal data of site users (hereinafter: the users):

LUNA doo Požarevac
Baje Sekulića bb
12,000 Požarevac
RN: 17547879
TIN: 103288293
e-mail address: office@fashion-luna.com (hereinafter: Fashion House Luna).

Types of Personal Data

Fashion House Luna manages the processing of personal data, which users give it when visiting the site. Depending on the purpose of the intended processing, the types of personal data in question include the following personal data: name and surname, e-mail address, telephone number, data on residential address (city, postal code, street and number), gender and shopping data (payment, purchased products, orders, product returns, etc.).

As a rule, Fashion House Luna collects only those data that users give it voluntarily and which are necessary to achieve the purpose of specific processing.

Exceptions may be data collected using "cookies" and other tracking technologies, as explained in more detail in the Cookie Notice which can be found here.

Purpose of Personal Data Processing

Fashion House Luna collects and processes personal data for the following purposes:

• account management of registered users of the site;
• execution of sales contracts;
• resolving customer requests (for: replacement of items, withdrawal from the sales contract, complaint);
• implementation of loyalty programs;
• sending newsletters (periodic emails, sms and Viber messages) to users who have expressed a desire to receive them on topics within the scope of their interests;
• providing information on products from the sales range of the Fashion House Luna;
• personalization of user experience;
• site improvement - adapting its content to the needs of users;
• implementation of promotions, competitions, research or other activities within the site;
• resolving requests, questions and/or other requests of users and
• improving the services of the Fashion House Luna.

The user who entrusts the personal data of third parties to the Fashion House Luna guarantees that these third parties are aware that their personal data will be the subject of processing and that they agree with the purpose and manner of that processing.

Legal Basis for Personal Data Processing

Depending on the purpose of collection and processing, the legal basis for processing of personal data of users may be their consent, execution of the contract or requested service, compliance with legal regulations requiring processing of personal data of users and/or legitimate (justified) interests of Fashion House Luna (processing for the purpose of: managing and maintaining the contractual relationship, responding to special requests, asking feedback from users in order to improve the site and products, as well as to undertake other general marketing activities), unless those interests are overridden by users’ interests and their basic rights and freedoms, i.e. the interests and basic rights and freedoms of the data subject, which require the protection of personal data, especially if the data subject is a minor.

Legitimate interest of Fashion House Luna includes those cases of collection and processing, which the user interested in the products of Fashion House Luna can expect in the regular course of things, as well as those when processing is necessary without the explicit consent of the user.

Fashion House Luna will always try to obtain the consent of the user for the processing of personal data, and it will follow a legitimate interest only when it is necessary and in the interest of the user.

Personal data such as: name and surname, e-mail address, telephone number, residential address data and gender collected during the creation of user accounts on the site are processed based on user consent and/or legitimate interest of Fashion House Luna. When creating an account on the site, the processing of user data is necessary for the purpose of managing their registration. Then, guided by its legitimate interest, Fashion House Luna can process the user's personal data, believing that the user has expressed interest in further offers by registering or using the site, and in that sense can save the list of products that the user has expressed interest in or bought. The above data is also collected for the purpose of issuing Luna Vip/Premium cards, enabling benefits and maintaining the status of a member in Luna Vip or Premium Club, where the Club membership is accessed simultaneously with registration (account creation) on the site because registration on the site is a prerequisite for joining the Club through the site.

Data such as name and surname, e-mail address, telephone number, residential address data and account number that we collect for the following purposes: execution of the sales contract for products purchased through the site, execution of withdrawal from the sales contract, product replacement and resolving complaints on purchased products are processed by Fashion House Luna on the basis of applicable laws in order to fulfil its legal obligations.

Personal data of users collected for the purpose of answering their questions/requests such as: name and surname, telephone and e-mail address are processed based on the consent of the user in each case of their contact with the Fashion House Luna, and in order to meet the user’s request in an appropriate manner.

Fashion House Luna asks for consent to process personal data of users before it starts sending them newsletters. In case the user expresses a wish to receive newsletters, Fashion House Luna collects data from them, such as: e-mail address, residential address and telephone number. The user can stop receiving newsletters by selecting the option - unsubscribe in each message they receive, after which the Fashion House Luna will no longer send them messages with such content, nor will it process their personal data on that basis.

The Fashion House Luna may also store the data of the user who revoked the consent solely for the purpose of proving that the processing before the revocation of their consent was performed in accordance with the law.

Term of Retention of Personal Data

Fashion House Luna stores personal data of users only for as long as it is necessary to achieve the purpose of specific processing, that is.:

• personal data that are processed for the purpose of managing the account of the user of the site are stored for all the time for which the user is registered on the site;
• personal data processed for the purpose of execution of the sales contract for products purchased by the user are stored for as long as it is necessary to implement the purchase, including the time required to act on requests to withdraw from the sales contract or to replace items, except in the case of an explicit request of the user to delete the data before the expiration of the specified deadlines, in which case they will be pseudonymized;
• personal data that are processed for the purpose of dealing with declared complaints are kept for as long as it is necessary to resolve the complaint;
• personal data collected for the purpose of implementing the loyalty program (issuing Luna Vip/Premium cards) are kept for as long as the person is a member of Luna Vip or Premium Club;
• when the user addresses the Fashion House Luna, personal data are kept within the period necessary for processing the request, i.e. until the user requests their deletion;
• personal data processed for the purpose of delivering newsletters, reminders for the purpose of notification or direct advertising are kept by Fashion House Luna until the user unsubscribes or revokes their consent, and
• personal data collected through cookies are stored while serving a purpose.

Fashion House Luna may keep personal data of users after the expiration of the above retention periods for the following purposes: fulfilment of legal obligations or protection of rights of Fashion House Luna (before courts or other competent authorities), in accordance with applicable regulations or collection of statistical data and record keeping.

Fashion House Luna will delete all personal data of users that are no longer used for any of the listed legal processing methods from its storage systems or pseudonymize them.

Who Has Access to Personal Data

Depending on the purpose of processing of personal data of users determined by this policy and to the extent necessary for its implementation, personal data of users are available to employees of Fashion House Luna, its part-time associates, partners involved in implementing loyalty programs and reliable third parties who provide Luna with services related to the performance of its activities, such as:  

• marketing agencies;
• IT agencies or persons who provide assistance to the Fashion House Luna in the form of a platform or accommodation on a server, support and maintenance of the database, as well as software and applications;
• persons who provide product delivery services to the Fashion House Luna (postal services, courier services) and
• persons who provide customer support services to the Fashion House Luna.

All these recipients are obliged to harmonize their operations with the LPDP and/or GDPR, i.e. to take all necessary technical, organizational and personnel measures to protect the personal data of users. In cases when the Fashion House Luna is the controller of personal data, and their processing is performed by a third party as a processor, the contracting parties are obliged to enter into a special agreement on personal data protection which regulates all important aspects of personal data processing. The protection of users' personal data by these third parties must be at the same level as the protection provided by the Fashion House Luna.

Personal data of users can also be disclosed to state authorities when the Fashion House Luna is obliged to do so by law or in order to protect its rights and interests and the rights of users as customers.

Data Controlled by Third Parties

The site may contain links that lead to other Internet sites, as well as objects or elements controlled by a third party.

Examples are "plug-ins" that can connect a site to social networks such as Facebook and which are usually recognized based on the logo of the corresponding social network. By choosing the social network logo on our site, you can start the process of sending certain data, such as: user ID, site information, date and time of site visit and other information related to the social network browser in question. Such information will be processed on social networks owned and operated by third parties, in accordance with their privacy policies.

Fashion House Luna has no access to or control over elements, objects, cookies and other tracking technologies managed by third parties. For their own security, the user should familiarize themselves with the privacy policy of the third-party website accessed from the site in order to familiarize themselves with the conditions applicable to the specific processing of personal data, bearing in mind that this policy applies only to the site.

Protection of Personal Data when Paying with Payment Cards

Fashion House Luna uses SSL technology to transfer all personal data of users, which takes care of encoding all information sent by the purchase order. In case the user chooses to pay by payment card, the payment card data entered by the user in encrypted form are transferred from the user's computer directly to the bank's authorization server.

When entering payment card data, confidential information is transmitted via the public network in a protected (encrypted) form using SSL protocols and PKI systems, as currently the most modern cryptographic technology.

The security of data during the purchase is guaranteed by the payment card processor, so that the complete billing process is performed on the bank's website.

Data verification is performed directly between the customer and Banca Intesa ad Belgrade. Payment card information is not available to the Fashion House Luna system at any time during the transaction.

Payment of all purchase orders in the Republic of Serbia is made in dinars (RSD). If the user decides to pay with payment cards of foreign issuing banks, the amount of the transaction in dinars will be converted into the settlement currency of the Bank (EUR) according to the exchange rate of the National Bank of Serbia. When debiting the user's payment card, the already converted amount will be converted into the user's local currency, according to the exchange rate applied by the payment card operators. The price stated on the site in dinars is fixed, however due to the above-mentioned conversions it is possible to deviate from it when it is translated into local currencies of bank card issuers or when the price in EUR on the site is compared with the price in euros applied in the billing process. , i.e. conversions of euros into dinars.

User Rights in Relation to Personal Data

Fashion House Luna undertakes to keep the personal data of users confidential and to enable them to exercise the rights they have in accordance with the LPDP and GDPR.

The user has the following rights regarding the processing of their personal data:

• the right of access (the user has the right to receive clear, transparent and easily understandable information on the purpose of processing, the types of personal data being processed, the recipient or types of recipients to whom personal data have been or will be disclosed, the planned retention period of personal data, and also has the right to request a copy of the personal data being processed);
• the right to correction and/or amendment (the user has the right to request the correction of personal data if they are incorrect or invalid and/or their amendment if they are incomplete);
• the right to deletion (the user has the right to request that their personal data be deleted to the extent that they are no longer needed for processing purposes or when the Fashion House Luna is not allowed by law to process them anymore);
• the right to object and complain (the user has the right to object the way of processing of their personal data which can be submitted directly to the Fashion House Luna or they can submit a complaint to the Commissioner for Information of Public Importance and Personal Data Protection);
• the right to limit the processing (at any time the user has the right to request a restriction on the processing of their personal data);
• the right to revoke consent to the processing of personal data based on consent at any time, and
• the right to the transferability of personal data (the user has the right to download personal data from the database of the Fashion House Luna for transfer to another database).

If they want to exercise the above rights (except for the complaint to the Commissioner), the user can do so in the following manners: by filling out and submitting the Request for Exercising of Rights Related to the Processing of Personal Data  in any of the retail facilities of Fashion House Luna or sending the Request for Exercising of Rights Related to the Processing of Personal Data or request made in free form by email to the address: office@fashion-luna.com or webshop@fashion-luna.com or by mail to Luna doo Požarevac, Baje Sekulića bb, 12 000 Požarevac.

Use of Cookies

Fashion House Luna uses cookies at every moment of the user's interaction with the site.

Cookies are text documents that are stored on the user's device (computer and/or telephone), and are created during a visit to the site. When the user re-accesses the site, Fashion House Luna downloads the data from the user's device contained in the cookies.

Fashion House Luna uses cookies that collect data needed to improve the site, as well as for maintenance services that use limited cookies. These cookies are aimed at improving the site in order to make it easier for users to access the content as well as the use of that content by other internet services, but also for marketing purposes.

For example, when visiting the site to search, read or download information, Fashion House Luna collects and stores data from users, such as: the name of the Internet browser through which the user accesses the site, the name and type of user device, operating system, domain name, address of Internet Protocol (IP) of the computer, the date and time of access to the site, the Internet address of the pages through which the user accesses the site and other similar information.

Cookies provide the user with a better, more accessible and customized user experience, as well as a display of the site, and the Fashion House Luna can use them to analyse customers, track visits and improve its advertising.

By disabling cookies, the user decides whether to allow them to be stored on the device. The user can make the desired settings regarding cookies in the Internet browser or by selecting the appropriate option when visiting the site.

Read more about cookies here in the Cookie Notice.
 

Acceptance of Conditions

It is in the user's interest to read the Privacy Policy when accessing the site. By using the site, it is assumed that the user agrees to the terms of this policy. Otherwise, the user should not access the site.
 

Privacy Policy Changes

Fashion House Luna reserves the right to change the Privacy Policy, provided that the date of the change will be indicated at the end of the Privacy Policy. Notification of changes is not sent to users. In order to keep the user informed about how to protect their personal data and in order to gain awareness of possible changes, it is recommended to periodically visit this page and review the Privacy Policy. If the user continues with the activities on the site after these changes, it is considered that they have accepted them and that they agree with them.
 

Contact

Additional information and explanations regarding the Privacy Policy and its implementation can be obtained by sending an inquiry by e-mail to: office@fashion-luna.com or webshop@fashion-luna.com or by mail to Luna doo Požarevac, Baje Sekulića bb, 12,000 Požarevac.

Your Fashion House Luna! 
01.03.2021.

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