Privacy Policy

1. Data controller

The data controller is Fabrizio Ciaddu, responsible for the Network Luxury project, located in the Province of Sassari, Sardinia, Italy. For any request concerning your personal data, please email info@network-luxury.com.

2. Data processed

We may process: identification and contact details provided voluntarily, such as name, surname, telephone number and email address; information included in requests sent through forms, WhatsApp or email, such as dates, services of interest and preferences; technical browsing data, such as IP address, device and browser type, pages visited, referral source and approximate geographical area; preferences stored locally on the device, such as language, Analytics choice and any items added to Your Journey.

The website does not request payment details, identity documents or special categories of personal data. Please do not include unnecessary information or sensitive data in your messages.

3. Purposes and legal basis

• Responding to enquiries: taking steps at your request prior to entering into a contract, under Article 6(1)(b) GDPR.
• Website operation and security: the controller’s legitimate interest in ensuring the website’s integrity, security and proper operation, under Article 6(1)(f) GDPR.
• Essential aggregate statistics: the legitimate interest in understanding general website usage through Vercel Web Analytics, without advertising cookies.
• Google Analytics 4: the user’s consent, under Article 6(1)(a) GDPR. Consent may be refused or withdrawn without affecting browsing.

We do not use data for newsletters, personalised advertising or automated marketing.

4. Providing data

Providing data is optional. If you contact us, your contact details and the information essential to your enquiry are required for us to respond; without them, we may be unable to handle the communication. Consent to Google Analytics is always optional.

5. Processing and retention periods

Data is processed electronically using appropriate measures to protect it against unauthorised access, loss or unlawful use. Enquiries that do not lead to a relationship are retained for up to 12 months after the last contact, unless longer retention is required to protect a legal right or comply with the law. Technical preferences remain on the device until deleted; the Analytics choice is retained for up to 6 months. Google Analytics user-level and event-level data is retained for up to 14 months, subject to any shorter periods applied by the browser or provider. Technical security data is retained by providers for as long as necessary for their respective purposes.

6. Recipients and providers

Data may be processed, where necessary, by hosting and security, traffic measurement, web font and email providers, including Vercel and Google. If you choose to use WhatsApp or Instagram, Meta also processes data under its own policies. Where an enquiry requires the involvement of a selected partner, only the necessary information will be shared after informing you. Data may also be disclosed to authorities where required by law. It is not made public, sold or transferred for third-party marketing.

7. International transfers

Some technology providers may also process data outside the European Economic Area. In such cases, transfers are based on a European Commission adequacy decision or appropriate safeguards, such as the standard contractual clauses provided for by the GDPR. Further information is available in the respective providers’ policies or may be requested from the controller.

8. Browsing and measurement data

Vercel Web Analytics produces aggregate statistics without advertising cookies; it uses technical request data and a temporary identifier that Vercel states it deletes within 24 hours. Only with consent does Google Analytics 4 collect technical information and website interaction data. For more details and to change your choice, please see the Cookie Policy.

9. Data subject rights

Where applicable, you may exercise the rights provided for by Articles 15–22 GDPR: access, rectification, erasure, restriction, portability and objection. You may also withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal, by emailing info@network-luxury.com. You also have the right to lodge a complaint with the Italian Data Protection Authority.

10. Automated decisions and updates

No automated decision-making or profiling with legal or similarly significant effects is carried out. This policy may be updated if the project, providers or applicable obligations change. The date shown above identifies the current version.