Privacy Policy

Privacy Policy pursuant to Regulation (EU) 2016/679 (GDPR)

Last update: 16/05/2025

 

Di Luccia Investment Club S.r.l., with registered office at Corso Sempione 20, 20154 Milan (Italy), as Data Controller (hereinafter also the “Controller”), provides this information pursuant to Article 13 of Regulation (EU) 2016/679 (“GDPR”) to all users who visit the website www.dlclubdeal.com (hereinafter, the “Website”).

 

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1. Types of Data Collected

 

Through the Website, the Controller may collect and process the following categories of personal data:

 

a) Technical navigation data

Collected automatically during browsing:

• IP address,

• browser and device type,

• operating system,

• date/time of access,

• visited pages,

• referring URLs.

This data is collected anonymously or in aggregate form through tools embedded in the Wix.com Ltd. platform.

 

b) Data provided voluntarily via the “Present Your Investment” form

When filling out the contact form on the “Present Your Investment” page, the user provides:

• first name and last name,

• email address,

• phone number,

• description of the proposed project,

• any attached pitch deck or documentation.

 

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2. Purposes of Processing

 

Collected data is processed for the following purposes:

• Ensure the correct functioning and security of the Website;

• Evaluate entrepreneurial projects submitted via the online form;

• Contact applicants for potential follow-up or clarification;

• Keep records of submitted proposals for internal assessment and due diligence;

• Prevent abuse and fraud.

 

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3. Legal Basis of Processing

• Technical data: processed on the basis of the Controller’s legitimate interest (Art. 6(1)(f) GDPR) in ensuring functionality, security, and optimization of the Website.

• Form data: processed for pre-contractual purposes at the request of the data subject (Art. 6(1)(b) GDPR).

 

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4. Processing Methods

 

Personal data is processed using electronic tools and stored on secure systems with appropriate technical and organizational measures. Data will not be disclosed to third parties unless required by law or expressly authorized by the user.

 

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5. Data Transfers Outside the EU

 

The Website is hosted on the Wix.com Ltd. platform, based in Israel, which is recognized as ensuring an adequate level of data protection (Art. 45 GDPR).

Technical and form data may also be processed by third-party providers (e.g., cloud services, email providers) located in third countries. Where applicable, such transfers are governed by Standard Contractual Clauses approved by the European Commission.

 

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6. Data Retention

• Technical data: retained for no longer than 12 months.

• Form submissions and attachments: retained for the time necessary to evaluate the proposal and for internal record-keeping, but no longer than 24 months, unless a longer retention is required due to legal or regulatory obligations.

 

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7. Data Subject Rights

 

Pursuant to Articles 15–22 of the GDPR, users may request at any time:

• access to their data,

• rectification or erasure,

• restriction of processing,

• objection to processing,

• data portability,

• lodge a complaint with the Data Protection Authority (www.garanteprivacy.it).

 

Requests may be addressed to:

giovanni.diluccia@dlclubdeal.com