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PRIVACY POLICY
1 - Introduction
This is a privacy policy covering your use of the website [rentluxury.online] (the “site”) and the services provided by the owner of this website, Nichola Portelli, trading as Rent Luxury. Kindly read this privacy policy carefully as it contains important information regarding Rent Luxury’s processing of your personal data (that is information that may identify you as an individual).
For the purposes of the General Data Protection Regulation (Regulation (EU) 2016/679, the ‘GDPR’), as applicable, amended and replaced from time to time (“Data Protection Law”): -
The data controller shall be Nichola Portelli (the “data controller”)
The leasing of luxury handbags and other luxury accessories for a predetermined time shall refer to the “service”.
2 - Data that can be collected about you
In order to provide the service, the data controller shall collect and process the following categories of personal data: name, surname, email address, date of birth, country, password, identification number, profile picture, address of ordinary residence, phone number(s), IP address, login and navigation data, order history, transactions, complaints, incidents, delivery information and correspondence on the site. For bank details, refer to paragraph 10 of this policy.
This information will be collected by us whenever you complete an online form provided on this site (or as submitted by you via other means from time to time). When completing such online form, you will notice that some data fields will be highlighted in red if these are left blank. Any data fields highlighted in red indicate that such data is obligatory and must be filled in. The data controller may not be able to provide the service if you do not provide the obligatory information.
Your data may also be collected through the use of cookies and any other tracking technologies. This data data is collected automatically because of your use of or actions on the site (refer to the section on cookies and pixels in paragraph 5 below).
As stated above, the data controller collects your personal data initially during onboarding once you request the service.
Certain data shall also be collected at the following times: -
Creation of the customer account;
Completion of a transaction on the site;
Browsing the site and consulting products;
Participation in a give away, offer, lottery or a contest;
Contacting customer service;
Corresponding with Rent Luxury;
Accepting the installation of certain cookies when using the site.
The categories of personal data that the data controller processes are ordinarily collected directly from you. However, in certain instances the data controller may also collect personal data from other third parties such as publicly accessible databases, joint marketing partners, social media platforms and other third parties.
Information about other individuals.
It may be the case that you provide us with information on behalf of individuals other than yourself. Should this be the case you agree that the other person has validly appointed you to act in his/her stead and act on your behalf to perform such actions including: giving consent on his/her behalf; receiving important information about the service and/or the site or any other action required to be performed in order for us to perform the service efficiently and in compliance with this privacy policy.
3 - Recipients of the data
The data controller shall not, except with your explicit consent: -
sell or rent your data to third parties
share your data with third parties for marketing purposes
Your data may be shared with third parties only in the following circumstances:
to the extent necessary to enable the fulfilment of your orders and execution of the service, such as Rent Luxury’s IT providers or payment service providers;
if Rent Luxury or a substantial part of its assets are acquired by a third party, in which case personal data held by the data controller may be one of the transferred assets;
if the data controller is obliged to do so by law or competent authority, such as in order to comply with any anti-money laundering legislation;
to the extent necessary to protect the rights, property or safety of Rent Luxury, suppliers, customers or others;
to otherwise comply with any legal obligations or as otherwise may be specifically required or allowed by any applicable law.
As a general rule, Rent Luxury does not share any of your personal data with entities outside the European Union/European Economic Area or to any country which is “white-listed” by the European Commission (i.e., those countries deemed to offer an adequate/equivalent protection to the data protection law). Should it be necessary to share your information with non-EEA entities, such as any foreign banks or national authorities, Rent Luxury strives to adopt the necessary appropriate safeguards in order to protect your personal data, such as by ensuring that EU Standard Contractual Clauses are in place between the parties. For more information see Section 6 “Data Storage” below.
4 - Purpose
The main purpose of collecting your personal data is to offer a safe, optimal, efficient and personalised experience. The data controller may use your personal data to:
provide the service and that of Rent Luxury’s partners, including when Rent Luxury acts as an agent;
manage the relationship with customers, both existing and prospective;
manage membership relations and customer service;
resolve any problems, issues and disputes;
conduct research, statistical and behavioural analytics to study, personalise, evaluate and improve the service and content;
inform you about the service, by targeted marketing and/or promotional offers, as well as about any updating of the terms and conditions of the service;
prevent, detect and investigate all potentially prohibited and illegal activities and enforce Rent Luxury’s Terms and Conditions;
comply with the data controller's and/or Rent Luxury’s legal and regulatory obligations.
Data Protection Law requires the data controller to fulfil at least one “legal ground” for processing data that contains personally identifiable information, currently set out in Article 6 of the GDPR. The grounds applicable to the personal data to which this notice relates to are:
processing is necessary for the performance of the contract between yourself and Rent Luxury in fulfilment of the service or in order to take steps at your request prior to entering into a contract – when such personal data, including but not limited to your name, address, email address and identification number is necessary to perform the service (normally indicated by an asterisk in the online form), when setting up an account managing Rent Luxury’s relationship with you etc.;
processing is necessary for compliance with a legal obligation to which the data controller is subject including when the data controller needs to investigate any suspicious behaviour in order to protect the business from risk and fraud or when complying with any orders from national competent authorities or judicial bodies;
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. Rent Luxury’s legitimate interests consist in the management, marketing and promotion of the service, the administration of the customers’ memberships, and the recruitment and management of staff;
the data subject has given consent to the processing of his or her personal data for one or more specific purposes. This legal basis is only relied upon where the data controller cannot or opts not to rely on another legal ground. In those cases that the data controller does rely on consent, please note that you have the right to withdraw your consent at any time.
If more than one of the above grounds apply to the processing of data in question, the applicable ground will be the first one listed.
5 - Cookies and Pixels
The site shall use cookies to distinguish a specific user from the other users of the site. This allows for the provision of an optimal and tailored experience when browsing the site. Cookies may also collect personal data. For detailed information on the cookies that shall be used and the purposes for such use, please refer to the Cookie policy on the site.
If you register to receive email updates from Rent Luxury, each email may collect:
Information about you, using industry standard technologies including pixels which will track email opens (if you have images enabled in your email client/mailbox). This is the standard approach for measuring open and click rates, and is used by all email platforms in the market.
All links in emails are proxied through a link redirection service that records data for each link clicked. This can lead to a set of events which may include:
Event type (delivery, bounce, open, click, spam complaint, unsubscribe)
Email address of the recipient (which you will have provided)
IP address of the recipient (in the case of open and click)
GEO location based on IP address (in the case of open and click)
Device type (e.g., mobile/computer/tablet) and browser (e.g., Google Chrome/Safari/Microsoft Edge)
If you do not accept the collection of the above information, you should disable and not open images in your email application.
6 - Data Storage
The data collected by the data controller shall be stored on Rent Luxury’s server or that of a service provider. The data shall not be transferred to, and stored at, a destination outside the European Economic Area ("EEA") unless:
a processor acting on the data controller’s behalf is either (i) within the EEA, or (ii) is in a country that Malta or the European Union (“EU”) has decided has adequate data protection laws in place, or (iii) has provided appropriate data protection safeguards of the manner approved by Malta or the EU and which provide effective rights and remedies for you; or
you have given consent to the data controller to transfer data about you to third parties outside Malta or the EEA.
Although the data controller shall employ its best endeavours to adequately protect your personal data, the data controller cannot guarantee the security of your data transmitted via the internet or other electronic means; any transmission is at your own risk. Once the data controller has received your information, stringent procedures and security features shall be applied to attempt to mitigate unauthorised access.
Personal data will be kept only for as long as is necessary, taking into account the purpose for which they were originally collected:
for customer data (paying members) for purposes of management and furtherance of the commercial relationship: until five years after the termination of the last contract;
for account data of users (registered) on the site: as long as the account is not deleted or terminated by you;
for any other data, for so long as is necessary for the purposes set out in this policy. In determining the period of time, account shall be taken of any legisolation permitting or even obliging us to retain such personal data for a certain period of time, as well as in line with, good industry practice and the guidance from relevant Maltese authorities and/or the EU.
At the end of the aforementioned period(s), and unless otherwise required pursuant to any legal obligations or if otherwise directed by any competent, legal and/or regulatory body, the data shall be deleted or anonymised.
7 - Special categories of personal data
Personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation shall not be processed.
8 - Your rights under Data Protection Law
Your rights under Data Protection Law include:
the right to request for personal data not to be processed for direct marketing purposes, even if consent was previously given;
the right to withdraw any consent given for processing of your data;
the right to access the data held about you (see paragraph 9 below for further details);
the right to request for any data held about you to be rectified should it result that such data is inaccurate or incomplete;
the right to request for the data to be erased in terms of article 17 of the Data Protection Law;
the right to request for the data processing to be restricted in terms of article 18 of the Data Protection Law;
the right to object to the processing of your data in terms of article 21 of the Data Protection Law;
the right to require the data controller to provide the data held about you in a structured, commonly used and machine-readable format in terms of article 20 of the Data Protection Law.
You can exercise any of the rights set out above, free of charge, by contacting us at rentluxuryonline@gmail.com. Further information may be required in order to process the request. Such requirements may include the presentation of an identification document.
If one submits unfounded or excessive requests to exercise any of these rights, Rent Luxury reserves the right to decline the request or make a reasonable charge for fulfilling such request. Rent Luxury also reserves its right to decline any such request should it be necessary to comply with a legal obligation to which Rent Luxury is subject or if complying with such request entails excessive burden.
You also have the right to lodge a complaint with the Information and Data Protection Commissioner (https://idpc.org.mt/) if concerns are raised regarding the data controller’s respect of your rights under Data Protection Law. The Information and Data Protection Commissioner is the authority in Malta which is responsible for overseeing the application of, and enforcing, Data Protection Law.
9 - Accessing your data
One has the right to obtain from the data controller a confirmation as to whether personal data is being processed (including any holding thereof).
If personal data is being processed, you shall be entitled to be provided with:
information as to the purposes for processing of the data;
information as to the categories of the data being processed;
information as to the recipients or categories of recipients to whom the data has or will be disclosed;
information as to the envisaged period for which data shall be stored, or if that has not been determined, the basis on which that period will be determined;
a copy of the data.
10 - Banking data and order analysis system
Your payment details shall be kept securely by the payment processing provider, Stripe. The data controller shall not have access to your payment details. Such payment details shall be collected and processed directly by Stripe. Please see stripe.com for details of how Stripe processes personal data.
Your payment details are kept securely so you do not have to re-enter them for every new transaction. Rent Luxury also uses your registered payment details to process recurring payments in accordance with Rent Luxury’s Terms and Conditions.
The occurrence of an unpaid transaction due to the fraudulent use of a payment method will result in the registration of contact details related to the fraudulent transaction within a payment incident file recorded by the data controller or third-party payment facilitators. An irregular declaration or an anomaly may also be the subject of specific treatment (especially for fraud detection purposes).
11 - Other websites
The site may, from time to time, contain links to and from the websites of partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that the data controller does not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
12 - Changes to this privacy policy
Any changes made to this privacy policy in the future will be posted on this page and, where appropriate, data subjects shall be notified by email. Please ensure you review this privacy policy frequently to be informed of any updates or changes.
13 - Contact
If you have any questions, comments and requests regarding this privacy policy, please email them to rentluxuryonline@gmail.com.