Personal Data

PRIVACY POLICY AND PROTECTION OF PERSONAL DATA

The Website Owner undertakes to take the necessary technical and organizational measures according to the level of security adapted to the risk of the data collected.

Laws incorporating this privacy policy

This privacy policy is adapted to the Andorran and European laws and regulations in force concerning the protection of personal data on the Internet. Specifically, it complies with the following texts and provisions:
- Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (GDPR)
- Andorran Law 15/2003, of December 18, called "Protection of Personal Data".

Identity of the person responsible for the processing of personal data

The person responsible for the processing of personal data collected through the Website is the Andorran company "SHANGTI STUDIO, SLU". (i.e. the Website Owner).
Address: Av. del Ravell, Nau 4 - Planta 1 - Local 1, AD400 La Massana - PRINCIPALITY OF ANDORRA

Phone: + 376 727 785
Email: [email protected]

Register of personal data

In accordance with the provisions of the GDPR and the Andorran Personal Data Protection Act, we inform you that the personal data collected by the Website Owner via the forms on the Website will be incorporated and processed in our files to be able to facilitate, rationalise and comply with the commitments established between the Website Owner and the User or the maintenance of the relationship established in the forms he fills in, or to respond to a request from the User. Likewise, in accordance with the provisions of the GDPR and Andorran law, unless the exception provided for in article 30.5 of the RGPD is applicable, a record of processing activities is kept which specifies, according to its purposes, the processing activities carried out and the other circumstances established in the GDPR Regulations.

Principles applicable to the processing of personal data

The processing of the User's personal data will be subject, depending on his or her place of residence, to the following principles set out in Article 5 of the GDPR or to the principles set out in the Andorran Law qualified for the protection of personal data:
- Principle of legality, fairness and transparency: the User's consent will be required at all times, with fully transparent information on the purposes for which personal data is collected.
- Purpose limitation principle: personal data will be collected for specific, explicit and legitimate purposes.
- Principle of data minimization: personal data collected will only be that which is strictly necessary for the purposes for which it is processed.
- Accuracy principle: personal data must be accurate and up-to-date.
- Principle of limitation of the storage period: personal data will be kept only in such a way as to allow the identification of the User for the time necessary for the purposes of processing.
- Principle of Integrity and Confidentiality: Personal data will be treated in such a way as to guarantee their security and confidentiality.
- Principle of proactive responsibility: the data controller will be responsible for ensuring that the above principles are duly respected.

Categories of personal data

The categories of personal data processed on the Website are only identification data. Under no circumstances will special categories of personal data be processed within the meaning of Article 9 of the GDPR.

Legal basis for the processing of personal data

The legal basis for the processing of personal data is consent. The Website Owner undertakes to obtain the express and verifiable consent of the User for the processing of his/her personal data for one or more specific purposes.

The User has the right to withdraw his consent at any time. Withdrawing consent is as easy as providing such consent. As a general rule, withdrawal of consent will not condition the use of the Website.

In cases where the User must or may provide his or her data through forms to request information or for reasons related to the content of the Website, the User will be informed of the mandatory nature of providing such personal data.

Purposes of the processing for which the personal data is intended

Personal data is collected and managed by the Site Owner in order to facilitate, streamline and fulfil the commitments established between the Website and the User or to maintain the relationship established in the forms that the latter fulfils or to respond to a request or query.

Likewise, the data may be used for commercial purposes of personalization, exploitation and statistics, and for activities corresponding to the Website Owner's social objective, as well as for data extraction, storage and marketing studies to adapt the Content and Services offered to the User, as well as to improve the quality, functioning and navigation of the Website.

At the time the personal data is obtained, the User will be informed of the specific purpose or purposes of the processing for which the personal data will be used; that is, the use or uses that will be made of the information collected.

Periods of retention of personal data

Personal data will be kept only for the minimum time necessary for the purposes of processing and, in any case, until the User requests their deletion.

At the time the personal data is obtained, the User will be informed of the length of time the personal data will be kept or, when this is not possible, the criteria used to determine this length of time.

Recipients of personal data

The User's personal data will not be shared with third parties.

In any case, at the time of obtaining the personal data, the User will be informed of the recipients or categories of recipients of the personal data.

Secrecy and security of personal data

The Website Owner undertakes to take the necessary technical and organisational measures, according to the level of security appropriate to the risk of the data collected, in order to guarantee the security of the personal data and to avoid the accidental or illegal destruction, loss or alteration of the personal data transmitted, stored or otherwise processed, or the unauthorised communication or access to said data.

The Website has an SSL (Secure Socket Layer) certificate which guarantees that personal data is transmitted securely and confidentially and fully encrypted.

However, because the Website Owner cannot guarantee the total absence of hackers or other persons who fraudulently access personal data, the Data Controller undertakes to communicate to the User, if necessary, without undue delay, an infringement of the security of his/her personal data that may pose a high risk to the rights and freedoms of natural persons. In accordance with the provisions of Article 4 of the GDPR, a breach of security of personal data is understood as a breach of security that causes the accidental or unlawful destruction, loss or alteration of personal data transmitted, stored or processed, or the unauthorized communication or access to such data.

Personal data will be treated confidentially by the Data Controller, who undertakes to inform and guarantee by a legal or contractual obligation that said confidentiality is respected by its employees, associates and any person who has access to the information.

Rights deriving from the processing of personal data

The User, depending on his or her place of residence, may exercise before the Data Controller the following rights recognized in the GDPR or those set forth in the Andorran Law qualified for the protection of personal data:
- Right of access: the User's right to obtain confirmation as to whether or not the Website Owner is processing his or her personal data and, if so, to obtain information on his or her specific personal data and the processing that the Website Owner has carried out or is carrying out, as well as, among other things, the information available on the origin of said data and the recipients of the communications carried out or envisaged.
- Right of rectification: the User's right to modify personal data that may be inaccurate or, given the purposes of the processing, incomplete.
- Right of deletion: the right of the User, unless otherwise provided by current legislation, to obtain the deletion of his/her personal data when it is no longer necessary for the purposes for which it was collected or processed and in particular in the following cases: the User has withdrawn his/her consent to the processing; the User objects to the processing and there is no other legitimate reason for it to continue; the personal data has been processed unlawfully; or the personal data must be deleted in accordance with a legal obligation.
- Right to Limit Processing: The User's right to limit the processing of his or her personal data. The User has the right to obtain the limitation of processing in the following cases: when the User disputes the correctness of his/her personal data; the processing is unlawful; the controller no longer needs the personal data, but the User needs it to make claims; and when the User has objected to the processing.
- Right to data portability: in the event that the processing is carried out by automated means, the User shall have the right to receive from the Data Controller his/her personal data in a structured format, for common use and mechanical reading, and to transmit them to another person in charge of the processing. Whenever technically possible, the Data Controller will transfer the data directly to the other person in charge.
- Right of opposition: the User's right that the processing of his/her personal data is not carried out or that the processing of his/her data by the Website Owner ceases.
- Right not to be subject to a decision based solely on automated processing, including the elaboration of profiles: the User's right not to be subject to an individualized decision based solely on the automated processing of his/her personal data, including the elaboration of profiles, unless otherwise provided by applicable law.

Consequently, the User may exercise his rights by means of a written communication addressed to the Data Controller specifying:
- Name and surname of the User and a photocopy of his/her identity card. In cases where legal representation is required, a photocopy of the identity card of the legal representative, as well as the document proving said representation, will also be required. The photocopy of the identity card may be replaced by any other legal means that proves the identity of the User.
- Specific reasons for the request.
- Address for notifications.
- Date and signature of the applicant.
- Any document proving the request made.

This request and any other attached document can be sent to the company SHANGTI STUDIO, SLU at the following address and/or email:
Address: Av. del Ravell, Nau 4 - Planta 1 - Local 1, AD400 La Massana - PRINCIPALITY OF ANDORRA
Phone: + 376 727 785
Email: [email protected]

Links to Third Party Sites

The Website may include hyperlinks or links to third party web pages. The owners of such websites will have their own data protection policies, being responsible for their own files and privacy practices.

Complaints to the supervisory authority

In the event that the User believes that there is a problem or violation of the laws and regulations in force in the processing of his personal data, he will have the right to effective judicial protection and the right to file a complaint with a supervisory authority in the State where he has his habitual residence, place of work or the place of the alleged violation. In the case of Andorra, the supervisory authority is the "Agència Andorrana de Protecció de Dades".

Acceptance and modifications of this privacy policy

It is necessary that the User has read and complies with the conditions for the protection of personal data contained in this Privacy Policy, as well as agrees to the processing of his or her personal data so that the Data Controller can proceed to process them in the form, for the periods and for the purposes indicated. The use of the Website will imply the acceptance of this Privacy Policy.

The Website Owner reserves the right to modify its privacy policy in accordance with its own criteria or motivated by a legislative, jurisprudential or doctrinal change of "l'Agència Andorrana de Protecció de Dades". The modifications or updates of this Privacy Policy will be explicitly notified to the User.

COOKIE POLICY

Access to this website may involve the use of cookies. Cookies are small amounts of information stored in the browser used by each User -on the different devices that he or she may use to navigate- so that the server remembers certain information that will only be read by the server that set them. Cookies make navigation easier, more user-friendly and do not damage the navigation device.

Information collected via cookies may include the date and time of visits to the Website, the pages viewed, the time spent on the Website and the sites visited just before and just after. However, no cookie enables the Website to contact the User's telephone number or any other means of personal contact. No cookie can extract information from the User's hard drive or steal personal information. The only way the User's private information is part of the cookie is if the User personally gives this information to the server.

Cookies that identify a person are considered personal data. Therefore, the privacy policy described above will apply to them. In this sense, the User's consent will be required for their use. This consent will be communicated, on the basis of a genuine choice, given expressly before any processing.

Own cookies

These are cookies that are sent to the user's computer or device and are managed exclusively by the Website Owner for the best functioning of the Website. The information collected is used to improve the quality of the Website and its Content and Service and the User's experience as a User. These cookies allow the User to be recognized as a recurring visitor to the Website and to adapt the content to offer content in accordance with his or her preferences.

Deactivating, refusing and deleting cookies

The User can deactivate, refuse and delete cookies - in whole or in part - installed on his device via his browser settings (which include, for example, Chrome, Firefox, etc.). In this sense, the procedures for refusing and deleting cookies may differ from one Internet browser to another. Consequently, the User must follow the instructions provided by the Internet browser he or she is using. In the event that he refuses the use of cookies -in whole or in part-, he may continue to use the Website, but he may be limited in the use of certain features of the Website.

Changes in the cookie policy

The Website's cookie policy may change or be updated. For this reason, the User is recommended to review this policy each time he or she accesses the Website in order to be properly informed of how and why we use cookies.

The User may thus oppose the registration of cookies by configuring their browser as follows:

For Microsoft Internet Explorer 6.0 and above :
1. Choose the "Tools" menu (or "Tools"), then "Internet Options" (or "Internet Options").
2. Click on the "Confidentiality" (or "Privacy") tab.
3. Select the desired level using the slider.

For Microsoft Internet Explorer 5 :
1. Choose the "Tools" menu (or "Tools"), then "Internet Options" (or "Internet Options").
2. Click on the "Security" tab (or "Security").
3. Select "Internet" and then "CustomLevel".
4. In the "Cookies" section, choose the option that suits you.

For Netscape 6.X and 7. X :
1. Choose the "Edit">"Preferences" menu.
2. Confidentiality and Security.
3. Cookies.

For Firefox :
1. Choose the "Tools">"Options" menu.
2. Click on the "Privacy" option.

For Safari 3.x for Mac OS X :
1. Choose the "Editions" menu.
2. Click on the "Preferences" option.
3. Click on the "Security" option.
4. Click on "Show Cookies".