1. Who is responsible
Dien To, an individual residing in Italy without a VAT number, is the independent data controller for DIEN TO GLOBAL enquiries. The website is independent of Queen Time and RIMAN corporate. Privacy contact: dien.riman@gmail.com or WhatsApp +39 328 024 1845.
2. Information requested
The planned form requests name, email, country, preferred language, interests and acknowledgment of this notice. Phone/WhatsApp and a message are optional. Beauty enquiries also require a salon/spa name; role and website/Instagram are optional. A submission ID and time, enquiry type, status and follow-up notes are stored. Do not provide health details, payment data or other sensitive information. Anti-abuse checks use an IP-derived keyed identifier; hosting services may also process technical request data.
3. Why information is used
Lead information is intended to respond to enquiries about independent RIMAN business opportunities and collaborations with beauty professionals, salons and spas, follow up on those conversations, and prevent abuse and duplicate submissions. A request does not register you with RIMAN, create employment, place an order or subscribe you to promotional emails. No automated eligibility or business-result decision is implemented in this form.
4. Legal basis and marketing
The proposed basis for answering information requests and related follow-up is legitimate interests (GDPR Article 6(1)(f)): handling your enquiry and maintaining relevant correspondence. Security and abuse prevention serve the legitimate interest of protecting the service. These bases require a documented assessment and remain unapproved. Article 6(1)(b) applies only to necessary steps you request before a possible contract with Dien To, not automatically to RIMAN enquiries. Reading this notice is not marketing consent. No promotional subscription is offered; any future marketing requires a separate lawful basis and, where required, specific optional consent.
5. Who may receive information
The intended flow uses Vercel for hosting, Google Sheets and Apps Script for private storage and processing, Google email services for notifications to dien.riman@gmail.com, and Upstash Redis for abuse prevention and duplicate protection. Redis holds pseudonymous identifiers and request fingerprints, not plain contact fields; these remain personal data where linkable. Provider roles and applicable processing terms still require verification. Form enquiries are not automatically forwarded to RIMAN.
6. International processing
These providers may process data outside the European Economic Area. Actual locations, recipients and the applicable transfer mechanism have not yet been confirmed. Any required adequacy decision or other lawful safeguards must be verified and described before form collection begins; information on applicable safeguards will be available from Dien To.
7. How long information is kept
The intended retention period is 90 days from the last documented interaction. Automatic notifications and routine administrative changes do not extend it. Longer retention requires a justified legal obligation or legal-claims exception, limited to necessary data and reviewed regularly. CRM records, related emails and technical metadata must be addressed; short-lived security counters have separate expiry periods. Cross-service deletion and log/backup retention remain under review, so complete automatic deletion is not currently guaranteed.
8. Your rights
You may request access, correction, erasure or restriction, object to legitimate-interest processing, and request portability where applicable. If consent is used, you may withdraw it without affecting earlier lawful processing. Contact Dien To using the details above; proportionate identity verification may be needed. Requests must normally be answered within one month; a lawful extension must be explained within that month. You may complain to Italy’s Garante per la protezione dei dati personali or another competent authority, including where you habitually reside, work or an alleged infringement occurred.
9. Providing information is your choice
You do not have to submit a request. Required contact details allow us to understand and reply; without them the form cannot be processed. Optional fields can remain blank. You can instead use email or WhatsApp. A request creates no obligation to register or purchase.
10. Video and external destinations
Pressing Play loads YouTube, which may receive IP/device data and use cookies or other storage. WhatsApp and official RIMAN destinations are separate services governed by their own privacy notices; their providers may act as independent controllers. Website language preferences are stored locally in your browser when selected. The review of third-party technologies and any necessary consent controls is not complete.
11. Status and updates
This policy remains a draft pending legal and operational review. It does not authorise collection through the disabled public form. An approved version and effective date must be published before that form is activated.