Privacy Policy

This Privacy Policy (“Privacy Policy”) is aimed at illustrating the means and purposes of the processing of personal data carried out by DMR S.r.l through the websites dmr.st (“Website”).

When we refer to “DMR”, “we”, “us” or “our”, we mean DMR S.r.l. In accordance with the applicable legislation on data protection, DMR is the entity responsible for the privacy of this Website: the Controller pursuant to the EU General Data Protection Regulation 2016/679 (“GDPR”) or the Business under the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA” and CCPA are jointly referred to as “California Privacy Laws”) of the Personal Data referred to in this Privacy Policy.

Our Privacy Policy is applicable to anyone who accesses and visits the Website or otherwise interacts with the web services offered on the Website (“User”, “you” or “your”). The Processing of the Personal Data carried out by DMR for the development and management of the Website is made in compliance with the applicable laws, and is based on the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and accountability.

Any term indicated in capital letters shall have the meaning attributed to it within the GDPR or in the California Privacy Laws, or otherwise provided hereto. We invite you to read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it, and in case of doubts or questions please feel free to contact us at [email protected]

Data Controller and Data Processors

The Controller of your Personal Data processed through the Website is: DMR S.r.l., a company incorporated in Italy having its principal offices at Via Brera 17, 20121, Milan, Italy.
For the purposes of satisfying Users’ requests made through the Website, the Controller may share or disclose User’s Personal Data to its affiliates.
In such events, and on a case by case basis, each affiliate will be considered a Processor for the purposes of GDPR.The full list of the entities affiliated to DMR can be found here below.

What Does This Privacy Policy Cover?

This Privacy Policy covers the processing of Users’ Personal Data gathered when they are using, accessing or otherwise interacting with the Website (e.g., customer services inquiries).
This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third-party websites, services and applications (“Third-Party Services”) that you elect to access through the Website or to individuals that we do not manage or employ.
While we attempt to facilitate access only to those Third-Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third-Party Services.
We encourage you to carefully review the privacy policies of any Third-Party Services you access. Please consider that the Website incorporate links and/or QR code which allow you to connect to other websites run by third parties. We do not assume any responsibility regarding the processing of Personal Data which may take place through and/or in connection with third-parties’ websites.
Therefore, whenever you access such web pages and/or social media platforms through the Website, you must carefully read the relevant privacy policies in order to better understand how your Personal Data will be processed by the third parties which, as autonomous controllers, will provide and manage such websitesFinally, our Privacy Policy does not cover the processing operations of your Personal Data practices conducted by other companies and organizations who advertise our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

What Data Do We Collect and Receive?

The data we gather and process through the Website enables us to personalize, improve and continue to operate the Website.
In connection with certain aspects of the Website, we may request, collect and/or display some of your Personal Data.
In particular, we collect the following types of information from our Users:

Usage Information

IP Address Information and Other Information Collected Automatically.
We automatically receive and record information from your web browser when you interact with the Website, including your IP address and cookie information.
The Website automatically collects usage information, such as the number and frequency of visitors to the Website.
We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally.
This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Website so that we can analyze and improve them.
We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.
However, please consider that we do not publish it or indiscriminately share it with third parties.

Aggregate Information.
In addition to the above, we collect statistical information about how, collectively, users use the Website (“Aggregate Information”).
Some of this information is derived from Personal Data. This statistical information cannot be tied back to you or your web browser.
We share Aggregate Information with our partners, service providers and other persons with whom we conduct business.
We share this type of statistical data so that our partners can understand how and how often people use the Website and their services or websites, which facilitates improving both their services and how the Website interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non-Personal Data about you that they have independently developed or acquired.

Device Identifiers.
When you access the Website by or through a device (including but not limited to smart-phones or tablets), we may access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier.
Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device.
A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the Website.
A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Website.
Some features of the Website may not function properly if use or availability of device identifiers is impaired or disabled.

Profile Preferences
In order to improve the type of content you receive through our subscription channels, and to contact us more efficiently, we use in our contact & content forms a feature that is called ‘Progressive Profiling’.
It is the tool we use for marketing automation and it records your visit (also on third parties websites) through session cookies.
Once your IP is identified, the type of information (including your business profile information) that we ask you through our forms may vary when you access or download content two or more times on our Website, or when you fill in contact forms.
In this way, your profile in our database platform is progressively enriched and allows us to offer you a unique and personalized experience through our emails according to your profile and interests.
To avoid features such as the ‘Progressive Profiling’ of our forms, you can always perform your browsing in incognito mode (more info here) or deactivate your browser cookies (Check our Cookies Policy here)

Location Data.
When you access the Website by or through a device, we may access, collect, monitor and/or remotely store “location data,” which may include GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.
Location data may convey to us information about how you browse and use the Website.
Some features of the Website, particularly location-based services, may not function properly if use or availability of location data is impaired or disabled.
Implementation of location-based services may vary depending on where you are accessing the Website from.

Personal Data Provided by You

If you submit an inquiry through the Website, or you fill in a contact or subscription form provided in the Website, we may collect Personal Data such as your first and last name, your current job and employer, your email address and telephone number and the country where you are currently located, as well as your message.
Before you submit an inquiry providing for your Personal Data you will be asked to tick a checkbox providing your consent so we are sure that you understand the reason why we may collect such information and you will also be provided with a link to this Privacy Policy.
Moreover, when you submit an inquiry, you will always be asked for permission before we send marketing communication (e.g. newsletters).
Please consider that if you DO NOT wish anymore to receive marketing communication from DMR, please send us an email at: [email protected]
Without prejudice to the above, you are free to explore the Website without providing directly any Personal Data about yourself but some information may be collected automatically through the use of cookies.

Cookies

The Website uses first and third parties cookies and similar tracking technologies (including web beacons to analyze which emails are opened, or links clicked), which may collect information about you via the Website and across other websites and online services.
For more details about how we use these technologies, please see our Cookies Policy)

Why We Collect Personal Data and Lawful Basis to Do So.

Your Personal Data will be processed by DMR in accordance with your instructions, and as required by any applicable laws.

In particular, we will process your Personal Data,
•   to fulfill any request made by you through the Website. This processing is needed to provide you with the information you have directly requested, by granting your freely and informed consent;
•   for marketing purposes provided that you granted your consent to this specific purpose;
•   for our legitimate interest, for example to improve the Website, to prevent frauds, ensure cyber security of the Website, or to defend ourselves in case of disputes or claims, provided that your interests do not overridden ours;
•   to comply with obligations set forth by applicable laws and regulations and to ascertain responsibilities in case of any computer crimes against the Website. As this processing is mandatory by law, User’s consent is not required.

Please also remember that if you choose to provide Personal Data using certain network features of the Website, then that information is governed by the privacy settings of those particular features and may be available to others.
Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge.
We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Website.

Is Information About Me Secured?

We work hard to secure your Personal Data from any unauthorized access to or unauthorized processing, alteration, disclosure or destruction of Personal Data we hold by taking appropriate technical and organizational security measures, having regard to the state of the technological development and the cost of implementing any measures. Where appropriate, for example, we might implement pseudonymization and encryption of Personal Data.
Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.
We store all of our information, including your IP address information, using industry-standard techniques.
We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Data or otherwise.
Where it is likely that a breach results in a risk to the rights and freedoms of individuals, we will notify the relevant supervisory authority within 72 hours of becoming aware of it.
This information can be provided in phases to facilitate fast and efficient reporting.
Where a breach is likely to result in a high risk to the rights and freedoms of individuals, we will notify those concerned directly.
If you have any questions or concerns regarding security using the Website, please send a detailed message to [email protected] or to [email protected].

How Long Do We Conserve Your Data?

DMR will retain your Personal Data in accordance with your instructions, and as required by applicable laws and only for the period of time necessary to fulfill the specific purposes for which the Personal Data were collected or further processed, if for compatible purposes.

What Happens When There are International Data Transfers?

We are a global organization, as such, we may share information about you within DMR’s affiliates and transfer it to countries in the world where we do business in connection with the uses identified above, and in accordance with this Privacy Policy.
In some cases, we use suppliers located in various countries to collect, use, analyze, and otherwise process information on its behalf.
It is our practice to require such suppliers to handle information in a manner consistent with our privacy and security policies and applicable laws.
Overall, we commit to comply with any legal requirements provided under any applicable law to transfer Personal Data to third countries.
In particular, for transfers of Personal Data outside of the EEA falling within the scope of application of GDPR, we are making sure that any of these transfers are supported by the strict legal compliance of our suppliers to the GDPR.
Depending on the concrete case, we rely on European Commission Adequacy Decisions, or EU Standard Contractual Clauses (also called Model Clauses) to meet the GDPR requirements.
If you would like to receive more information on the appropriate safeguards we implemented to transfer your Personal Data, please contact us at [email protected].

Who can access my Personal Data?

As a general principle, Your Personal Data will be shared and made available or otherwise processed in strict compliance with the principle of the “need to know”.
Unless upon your specific consent or as otherwise required by applicable laws, your Personal Data shall not be shared with any third parties other than the ones indicated below other organizations.
Without prejudice to the above, Your Personal Data might be shared with:

Entities affiliated to DMR,
which will act as data processor pursuant to GDPR. The complete list of the entities affiliated to DMR and part of the Launchmetrics Group can be found here below.

Analytical Services
We use certain analytics providers (including but not limited to Google Analytics, Inspectlet, Google Optimize, Hotjar) in order to better understand how the Website is used and how it can be improved.
Your IP address information may be accessed by one or more of such analytics providers.
In addition, information regarding the usage activity of a certain portion of users of the Website may be shared, but such information is shared on an anonymous basis and does not reveal the identity of any individual User.
These providers do not collect any personal information or store IP addresses locally on their websites.

Service provider.
We use certain analytics providers (including but not limited to Google Analytics, Inspectlet, Google Optimize, Hotjar) in order to better understand how the Website is used and how it can be improved.
We might share your Personal Data with our service providers (e.g. cloud providers, Website providers) for the purposes of managing your requests/interactions with the Website.

Agents.
We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”).
We may need to share Personal Data with our Agents in order to provide products or services to you.
Unless we tell you differently, our Agents do not have any right to use Personal Data or other information we share with them beyond what is necessary to assist us.
You hereby consent to our sharing of Personal Data with our Agents.

Potential business partner.
In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets.
Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party.
You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.

Event organizer
or third parties involved in online events. DMR periodically organizes online events (like webinars) with event organizers or third parties (“Partners”) as part of strategic partnerships (“Partnership”).
Partners may receive Personal Data processed by DMR for the purpose of the Partnership to provide you the best experience, or simply to allow you to attend the event.
You hereby acknowledge that such data sharing may occur. You have the right to object to such processing anytime by emailing us at [email protected].

We also reserve the right to access, read, preserve, and disclose any information as it reasonably believes is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public.
This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention

Notice for Users located in the People’s Republic of China

The content of this section is intended exclusively for the benefit of Users who are accessing the Website from the People’s Republic of China (“China”), and it must be construed in addition and not in lieu of the full Privacy Policy.
In particular, the purpose of this section is to inform Users accessing the Website in China (“Chinese Users”) that for the purposes indicated in section “Why We Collect Personal Data and Lawful Basis to Do So”, we might transfer Chinese Users’ Personal Data outside China.
Provided that, we will consider to have received Chinese Users explicit consent to the data transfer every time that he or she will interact with the Website (for example, when he/she signs up to the newsletter, requests information through the contact form etc.).
For the sake of clarity, Chinese Users’ Personal Data might be transferred among the companies affiliated to DMR, as well as to its service provider, for the purposes indicated above. We will not sell any Chinese Users Personal Data to third parties.
Any Chinese Users wishing to know which entities received their Personal Data, can contact DMR at [email protected].

Notice for California residents

The content of this section is aimed solely at providing California residents with relevant information under California Privacy Laws. and may be subject to change. It must be construed in addition and not in lieu of the full Privacy Policy.
California Privacy Laws regulate how we handle personal information of California residents, granting certain rights to their residents with respect to their personal information.
Pursuant to CCPA when it provides the Services, DMR is both a “Business” and a “Service Provider”.
lthough we do not sell personal information in exchange for any monetary consideration, the CCPA defines a sale in a way that may include allowing third parties to receive certain combined Personal Information such as, depending on how you use the Services, when we are sharing device information (such as browser type and version, operating system, preference settings, unique device IDs and language and other regional settings) and identifiers (names, job titles, IP address, email address), commercial information (such as record of the Services purchased or demos requested), usage information and Internet activity such as browsing history (clicks, scrolling, browsing times and load times) or app usage, cookie information and customer feedback with website analytics companies and providers of customer relationship management, consulting, email, product feedback services and security and other operations vendors.

We do share Personal Information as necessary for certain business purposes, as defined by the and as described above and in the section “How Do We Use the Data Collected?” of this Privacy Policy.
You may opt out from the sharing of your Personal Information.
While DMR does not sell personal information in exchange for any monetary consideration, we do share personal information for other benefits that could be deemed a “sale,” as defined by the relevant law.
We wish to provide you with control over how your Personal Information is collected and shared.
If you would like to opt out of DMR use of your Personal Information for such purposes (when considered as a sale), you may do so within the Services and by contacting DMR at [email protected]

Additional disclosure:
In the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of personal information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer:
•   Identifiers (name or alias, online identifier, IP address, email address and cookies);
•   Internet or other electronic network activity information (browsing history and time, search/click history, loads, browser type and version, operating system, preference settings, unique device IDs and language and other regional settings).

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information that we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties.

If you are a California resident and would like a copy of this notice, please submit a written request to the following address:10E 25st Street, Suite 416, New York, NY 10010, USA.
The request should attest to the fact that you are a California resident, and provide a current California address.

If you have additional questions about this section or how to exercise your rights under the California Privacy Laws, please contact us at [email protected].

California Privacy Laws allow California consumers to designate an authorized agent to exercise their rights under California Privacy Laws. If we receive a request from an agent, then we have the right to verify that you indeed want to take the action requested by the agent and will do so by contacting you directly.

Your rights regarding DMR processing of your Personal Data

The right to be informed.
You have the right to be provided with clear, transparent and easily understandable information about how we use your information and about your rights. This is why we are providing the information in this Privacy Policy.

The right of access.
You have the right to obtain access to your Personal Data subject to the data Processing. This will enable you, for example, to check that we are using your Personal Data in accordance with the relevant data protection law. You may access the information we hold about you in this way, using the Contact information section.

The right to rectification
You are entitled to have your Personal Data corrected if it is inaccurate or incomplete. You can request us to rectify any errors in information that we hold by contacting us (please see section How to contact us? here below).

The right to erasure.
Also known as ‘the right to be forgotten’, it enables you to request the deletion or removal of certain Personal Data that we hold about you by contacting us (please see section How to contact us? here below).
Pursuant to applicable laws we may not have all your Personal Data erased.

The right to restrict processing.
You have rights to ‘block’ or ‘suppress’ certain further use of your Personal Data. When processing is restricted, we can still store your Personal Data, but will not use it further.

The right to data portability.
You have the right to obtain your Personal Data in an accessible and transferrable format so that you can re-use it for your own purposes across different service providers. This is not a general right however and there are exceptions.
To learn more please get in touch (please see section How to contact us? here below).

The right to lodge a complaint.
You have the right to lodge a complaint about the way we handle or process your Personal Data with the relevant national Data Protection Authority
(please find here the list of European Data Protection Authorities (ttps://edpb.europa.eu/about-edpb/board/members_en)

The right to withdraw consent.
If you gave your consent to extensive processing that we do with your Personal Data (i.e. we rely on consent as a legal basis for processing your Personal Data), you have the right to withdraw that consent at any time.
You can do this by contacting us (please see section How to contact us? here below). Withdrawing consent will not however make unlawful our use of your information while consent has been apparent.

The right to object to processing.
You have the right to object to certain types of processing. You can for example object to the publication of pictures taken of you within the context of a conference.
To exercise this right, please get in contact (please see section How to contact us? here below).

The right to not be subject to automated individual decision-making.
You have the right not to be subject to a decision solely based on automated processing, including profiling.
To exercise this right, please get in contact (please see section How to contact us? below).

Where you wish to exercise their rights in the context of one or several specific processing operations, please provide their description in the requests.
Your requests will be handled within a maximum of 30 (thirty) working days.

We will maintain complete and accurate records and information to demonstrate our compliance with our obligations under this Privacy Policy and also for audits conducted by you or on your behalf.

How do you Protect Children’s Privacy?

DMR does not knowingly collect Personal Data from children under the age of thirteen (13).
If you believe we might have any information from or about a child under thirteen (13), please contact us at: [email protected] or at [email protected].

Do you have a Data Protection Officer?

Yes, if you would like to communicate with our Data Protection Officer, please send a message to [email protected].

How to contact us?

If you have any questions or concerns regarding privacy using the Website, please send us a detailed message to [email protected]. We will make every effort to resolve your concerns.

Companies affiliated to DMR part of the Launchmetrics Group

YIf you have any questions or concerns regarding privacy using the Website, please send us a detailed message to [email protected]. We will make every effort to resolve your concerns.

Fashion GPS Inc. d/b/a Launchmetrics
a Delaware corporation having its principal offices at 110 E 25th Street, Suite 416, New York NY 10010.

Fashion GPS Europe Ltd. t/a Launchmetrics
a limited company incorporated in England and Wales under company number 06575966 whose registered office is at Paternoster House, 65 St Paul’s Churchyard, London, EC4M 8AB, United Kingdom.

Launchmetrics France S.A
a limited liability company [a French société anonyme] having its office at 16-18 rue de Londres, 75009 Paris registered with the Commercial Register of Paris under the number 442 748 455.

Visual Box S.r.l.
a limited liability company [società a responsabilità limitata] with registered office in Via Brera 17, Milan, Italy Tax code and VAT number 13078140152.

Fashion Tree S.r.l.
a limited liability company [società a responsabilità limitata] with registered office in Via Andrea Solari 11, Milan, Italy Tax code and VAT number 07535290964.

Launchmetrics Spain, S.L.
a Spanish private limited liability company having its office in Madrid, Spain, at Paseo De La Castellana, no. 163, 28046 and registered with the Commercial Register of Madrid under the number M-380293.

Launchmetrics Germany GmbH
registered with Amtsgericht München HRB 245516.

PARKLU PTE. LTD
a Company incorporated in Singapore whose registered office is situated at 2nd Floor Beach Center, 15 Beach Rd, Singapore.

Park Lu Consulting (Shanghai) Limited
a limited company with registered address 138 HuaiHai Zhong Lu, 3F, Huangpu District, Shanghai.

Park Lu Limited
a Company incorporated in Hong Kong whose registered office is situated at Room 1405, 14/F., 135 Bonham Strand Trade Centre, 135 Bonham Strand, Sheung Wan, Hong Kong.

DMR S.r.l
a limited liability company [società a responsabilità limitata] with registered office in Milan, via Brera n 17, fiscal code and VAT number 12063740968.

DMR USA Inc
a New York corporation, with registered office in 551 Madison Avenue, Ste 450, New York, NY 10022, USA.

DMR Luxury Ltd
a limited company , having its office at 3rd Floor, Fairgate House, 78 New Oxford Street, WC1A 1HB, London, UK.

DMR APAC Ltd
a limited company incorporated in Hong Kong, having its office at 3/F, Laford Centre, Unit 304-7, 838 Lai Chi Kok Rd, Cheung Sha Wan, Hong Kong.

Changes

We have the sole discretion to modify this Privacy Policy, where appropriate, we will notify you of any changes to this Privacy Policy, for example by email.

English Version Controls

Non-English translations of this Privacy Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.