This privacy policy governs the handling of personal information in the online store located at www.thehomeholiday.com (referred to as the "store").

By using the store, you are considered a user ("user") and are deemed to be aware of and, if applicable, agree to all the conditions outlined in this privacy policy. The provision of store services is limited to when the user is connected to the store or any of its provided services. Therefore, it is important for the user to carefully read this privacy policy each time the store intends to use it, as it may be subject to modifications.

Collection, Processing, and Use of Personal Data

As of May 25, 2016, the General Data Protection Regulations (GDPR) have been in effect, replacing the current regulations, and will be applied starting May 25, 2018:

Lusana Pty Ltd is an organization involved in the processing of personal data and assumes a significant responsibility in designing and organizing procedures to comply with legal requirements in this matter.

To fulfill these responsibilities and establish the general principles guiding the processing of personal data within the company, Lusana Pty Ltd has approved this personal data protection policy, which is communicated to its employees and made available to all relevant stakeholders.

1. Purpose

The purpose of this personal data protection policy is to proactively ensure compliance with applicable legislation and respect the rights to privacy and honor in the handling of personal data for individuals associated with the company. The policy establishes the principles governing data processing within the organization, including procedures, organizational measures, and security measures. This policy is committed to being implemented within the scope of its responsibilities. The personnel involved in data processing operations will be assigned corresponding responsibilities by the management.

2. Scope of Application

This personal data protection policy applies to the company, its administrators, managers, employees, and all individuals associated with it, including service providers who have access to data ("data processors").

3. Principles of Personal Data Processing

The company is committed to strictly adhering to personal data protection legislation and being able to demonstrate this compliance ("proactive liability"). Special attention will be given to treatments that may pose higher risks to the rights of individuals affected ("risk approach"). In relation to this, Lusana Pty Ltd ensures compliance with the following principles:

• Legality, fairness, transparency, and purpose limitation: Data processing should be informed to the affected parties through clauses and other procedures. It will only be considered legitimate if consent is obtained (especially from minors) or if there is another valid legal basis in accordance with the regulations.
• Data minimization: The processed data must be adequate, relevant, and limited to what is necessary for the intended purposes.
• Accuracy: The data must be accurate and, if necessary, updated. Measures will be taken to rectify or delete inaccurate personal data without delay.
• Limitation of retention period: Data will be retained for as long as necessary for the intended purposes.
• Integrity and confidentiality: Appropriate technical and organizational measures will be applied to ensure adequate security and protection against unauthorized or unlawful processing, loss, destruction, or accidental damage of personal data.
• Data transfers: Acquiring or obtaining personal data from illegitimate sources or data collected or transferred in violation of the law or without sufficient legitimacy is prohibited.
• Engagement of data access providers: Only suppliers that offer sufficient guarantees in applying appropriate technical and security measures will be selected for hiring. Agreements will be documented with these third parties to ensure compliance.
• International data transfers: Any processing of personal data subject to European Union regulations that involves transferring data outside the European Economic Area must strictly comply with the applicable legal requirements.
• Rights of affected individuals: The company will facilitate the exercise of rights such as access, rectification, erasure, restriction of processing, objection, and portability. The necessary internal procedures and forms for exercising these rights will be provided, ensuring compliance with legal requirements.

The principles outlined in this personal data protection policy should be considered in the design and implementation of work procedures, products and services, contracts and obligations, and any systems or platforms allowing access or collection of personal data by employees or third parties.

4. Employee Commitment

Employees are informed of this policy and acknowledge that personal information is an asset of the company. They commit to:

• Participating in data protection awareness training provided by the company.
• Implementing security measures relevant to their role and responsibilities within Lusana Pty Ltd, in addition to any designated design and implementation duties.
• Using the established formats for exercising the rights of affected individuals and promptly informing the company for effective response.
• Immediately reporting any deviations from this policy, particularly regarding personal data security breaches, using the designated reporting format.

5. Monitoring and Evaluation

An annual verification, evaluation, and assessment will be conducted, or whenever significant changes occur in data processing, to ensure the effectiveness of technical and organizational measures for data security.

The following are the current data processing activities in the store:

• "New Customer" section: To make online purchases in our store, registration as a customer is required. Lusana Pty Ltd, as the data controller, collects personal data through a registration form for the purpose of enabling online purchases and fulfilling orders. This data, along with purchase details, will be processed to manage orders, handle incidents, prevent fraud, and conduct surveys on product and service quality. Additionally, Lusana Pty Ltd may create commercial profiles based on users' store purchases for advertising purposes, offering products and services under Lusana Pty Ltd. By selecting the option "I want to receive communications by email or equivalent means," users explicitly consent to receiving commercial communications from Lusana Pty Ltd through email or equivalent means (SMS or MMS). During registration, consent may also be requested for additional purposes unrelated to purchases. Users can opt in or out of these treatments as appropriate.
• "Newsletter" section: By submitting the corresponding form, users expressly consent to receiving our corporate newsletter and being offered products and services marketed under Lusana Pty Ltd through any means, including electronic communication.
• "Press" section: By submitting the corresponding form, users expressly consent to receiving press releases related to commercial relationships involving the retail sale of fashion and textile equipment, footwear, and accessories, among other products and consumer services offered by Lusana Pty Ltd through any means, including electronic communication.
• "Do You Want to Work With Us?" section: By submitting a CV via email, users agree to have their CV data and any collected information during phone calls or selection tests processed for the purpose of evaluating their candidacy for current or future selection processes conducted by Lusana Pty Ltd.

By submitting data through provided forms or via email, users confirm that the information provided is accurate and true, and that they are at least 16 years old. The store's services are not intended for children under 16 years old, and parental consent is not obtained in any case.

Lusana Pty Ltd will retain the data for legally established periods, without prejudice to its right to delete the data.

Communications and Data Transfers

Data collected on the website may be shared with other companies within Lusana Pty Ltd, engaged in commercial relationships for the retail sale of fashion and textile equipment, footwear, accessories, cosmetics, hygiene products, household items, consumer electronics, and other products and consumer services marketed by Lusana Pty Ltd. This is done for the same purposes outlined in this data protection policy.

Exercising Rights of Access, Rectification, Erasure, and Objection

Users have the right to access, rectify, erase, and object to the processing of their data, as well as the right to revoke consent in accordance with legal provisions. These rights can be exercised by contacting the provided postal address or the following email address: hi@thehomeholiday.com, accompanied by a copy of a document proving identity.