INFORMATION ON THE PROCESSING OF PERSONAL DATA WEBSITE LUCID TUNES LTD

This information is provided in accordance with Regulation (EU) No. 2016/679 (“GDPR”) and the currently applicable rules of Legislative Decree 196/2003 (so-called Privacy Code) in order to make the User-Interested of the site https://humsmusic.com hereinafter the “Site” or “Website”) aware of the processing of personal data that is carried out in the course of navigation itself. 

This document may be subject to changes due to possible variations in the purposes of processing or due to changes in data protection legislation and technological evolutions that may have occurred. In this case, the updated versions will be publicized on this Site.

Data Controller. The Data Controller is LUCID TUNES LTD with its registered office at 27 Old Gloucester Street, London, United Kingdom, WC1N 3AX (hereafter identified as “LUCID” or “Data Controller”), and can be contacted at the e-mail address: legal@humsmusic.com

WEBSITE

Type of Data Collected. The computer systems and software procedures used to operate the Site may, during their normal operation, acquire some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes information such as IP address, device type, unique device identification numbers, browser type, general geographic location (e.g., country or city level location), and other technical information. We may also collect information about how the User’s device interacts with our Web site, including pages visited and links clicked, date and time of the request, type and size of the requested resource, and other operating system data.

Purpose of data processing. We do not perform covert processing or record personal data or preferences related to the use of the Website content; we do not identify or track the personal identity of those who access the Website.

The processing of personal navigation data is used in order to obtain anonymous statistical information on the use of the Web Site, to check its correct functioning, to improve the quality of the services offered and to optimize the functionality of the Web Site.

These data are processed with computer tools (including portable devices) to the extent strictly necessary and proportionate to ensure the security of the networks and the information passing through them and in compliance with the confidentiality obligations to which the Data Controller is bound, as well as adopting technical and organizational security measures appropriate to the type of data processed

The provision of such data is not mandatory, at the moment in which the User decides not to provide such data, he/she must not navigate on the Website and will not be able to access the functionalities made available by the same.

Legal basis for processing. The legal basis is the legitimate interest of the Data Controller in maintaining the security of the Site and that it is not used in ways that infringe the rights of others or as a conduit for the commission of unlawful acts or possible fraud (see Art. 6 (1) (f) GDPR and Recital 47 of the GDPR).

Data Retention. LUCID retains the above personal data only for a maximum period of twelve months, except for the exercise of the Holder’s rights of defence for which the aforementioned period may be longer.

WEBSITE – “CONTACTS” and/or “CONTACTS” FORM

Type of Data Collected. The Web Site has a “Contact” area to allow the User to submit a contact request to LUCID; this area collects the following types of data: name, email address and may contain a free field for entering the request.

LUCID cannot perform any kind of prior control in relation to the information entered within the User’s freely fillable fields. LUCID begs Users not to enter information from which, even indirectly, data belonging to special categories referred to in Article 9 of the GDPR may be known. If such types of data are entered, LUCID will not take such information into account in the feedback formulated and will proceed to delete such data in a secure manner that does not allow its recovery.

Purpose of data processing. The purpose is to respond to contact requests forwarded by Users to LUCID. These data are processed with computer tools (including portable devices) to the extent strictly necessary and proportionate to ensure the security of the networks and the information passing through them and in compliance with the confidentiality obligations to which the Data Controller is bound, as well as adopting technical and organizational security measures appropriate to the type of data processed.

The provision of such data is optional; when the User decides not to provide such data, the same will not be able to forward contact requests to LUCID, which will thus find itself unable to give appropriate feedback.

Legal basis of the processing. The processing is necessary for the execution of pre-contractual measures taken at the request of the Data Subject/User (see Art. 6 (1) (b) GDPR).

Data Retention. LUCID retains personal data for as long as necessary to respond to requests made by Users and to properly handle any subsequent requests from the same User; the Data Controller may retain the data for a longer period in the case of exercising its rights of defence. 

WEBSITE – “Sign the Manifesto” 

Type of Data Collected. The Website has a “Sign the Manifesto” area to allow the User to subscribe to the Manifesto and receive a. Email notification upon its launch; this area collects the following types of data: name and email address.

Purpose of data processing. The purpose is to enable the User to subscribe to the Manifesto and receive a notification at its launch. These data are processed with computer tools (including portable devices) to the extent strictly necessary and proportionate to ensure the security of the networks and the information passing through them and in compliance with the obligations of confidentiality to which the Owner is bound, as well as adopting technical and organizational security measures appropriate to the type of data processed.

The provision of such data is optional in nature; when the User decides not to provide such data, the same will not subscribe to the Manifesto.

Legal basis of the processing. The processing is necessary for the execution of pre-contractual measures taken at the request of the Data Subject/User (see Art. 6 (1) (b) GDPR).

Data Retention. LUCID retains the personal data until revocation is requested by the User and in any case for a period not exceeding ten years; the Controller may retain the data for a longer period in the case of exercising its rights of defence. 

This policy is updated to March 2025.