Privacy Policy EN – Sherasade

This Website collects some Personal Data of its Users.

Data Controller

LP S.R.L.S. Viale Aventino 76, 00153 Rome IT

Email address of the Data Controller: lorenzotermini@sherasade.it

Types of Data Collected

Among the Personal Data collected by this Website, either independently or through third parties, there are: Cookies, Usage Data, name, email, geographical location, phone number, and surname.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed before the data collection. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Website. If not otherwise specified, all data requested by this Website are mandatory. If the User refuses to provide them, it may be impossible for this Website to provide the Service. In cases where this Website indicates some data as optional, Users are free to refrain from providing such data, without any consequence on the availability of the Service or its operation. Users who are unsure about which data are mandatory are encouraged to contact the Data Controller. The potential use of Cookies – or other tracking tools – by this Website or the owners of third-party services used by this Website, unless otherwise specified, is aimed at providing the Service requested by the User, as well as for other purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Website and guarantees that they have the right to communicate or disclose them, holding the Data Controller harmless from any liability towards third parties.

Methods and Location of Data Processing

Processing Methods

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data. Processing is carried out using computer and/or telematic tools, with organizational methods and logical structures strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organization of this Website (administrative, commercial, marketing, legal personnel, system administrators) or external entities (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data, and they may also be appointed as Data Processors by the Data Controller, if necessary. An updated list of Data Processors can always be requested from the Data Controller.

Legal Basis for Processing

The Data Controller processes Personal Data related to the User if one of the following conditions applies:

The User has given consent for one or more specific purposes;
Note: In some jurisdictions, the Data Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such processing. However, this does not apply when the processing of Personal Data is governed by European data protection legislation.
The processing is necessary for the performance of a contract with the User and/or for the implementation of pre-contractual measures;
The processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
The processing is necessary for the performance of a task of public interest or for the exercise of official authority vested in the Data Controller;
The processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

It is always possible to request the Data Controller to clarify the specific legal basis of each processing activity, particularly to specify whether the processing is based on the law, a contract, or necessary to conclude a contract.

Location

Data is processed at the Data Controller’s operational locations and at any other location where the parties involved in the processing are located. For more information, contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information about the location of the processing, the User can refer to the section on the details of Personal Data processing.

The User has the right to obtain information about the legal basis for the transfer of Data outside the European Union or to an international organization under international law.

Public or Consisting of Two or More Countries, such as the UN, and Information Regarding the Security Measures Adopted by the Data Controller to Protect the Data.

If one of the transfers described above takes place, the User may refer to the respective sections of this document or request information from the Data Controller by contacting them using the details provided at the beginning.

Retention Period

The Data is processed and stored for the time necessary to fulfill the purposes for which it was collected.

Therefore:

Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be retained until the completion of the execution of that contract.
Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information about the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the processing is based on the User’s consent, the Data Controller may retain the Personal Data for a longer period until such consent is revoked. Additionally, the Data Controller may be required to retain Personal Data for a longer period to comply with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiration of such period, the right of access, deletion, correction, and the right to data portability can no longer be exercised.

Purposes of Data Processing

The User’s Data is collected to allow the Data Controller to provide their Services, as well as for the following purposes: Statistics, Contacting the User, Remarketing and behavioral targeting, Content commenting, Location-based interactions, Advertising, Display of content from external platforms, Protection from SPAM, Tag management, Registration and authentication, Contact management and message sending, Payment management, and Interaction with social networks and external platforms.

For more detailed information on the purposes of processing and the Personal Data relevant to each purpose, the User may refer to the corresponding sections of this document.

Details on the Processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Content commenting

Comment Services

Comment services allow Users to post and publicly share their comments regarding the content of this Website. Depending on the settings decided by the Data Controller, Users may leave comments anonymously. If the User provides their email as part of the Personal Data, it may be used to send notifications about comments related to the same content. Users are responsible for the content of their comments. If a third-party comment service is installed, it is possible that, even if Users do not use the comment service, the service may collect traffic data related to the pages where the comment service is installed.

Facebook Comments (Facebook, Inc.)

Facebook Comments is a service provided by Facebook, Inc. that allows the User to post comments and share them within the Facebook platform.

Collected Personal Data: Cookies and Usage Data.

Location of Processing: United States – Privacy Policy. Subject to the Privacy Shield.

Contacting the User

Contact Form (This Website)

By filling out the contact form with their Data, the User consents to their use to respond to requests for information, quotes, or any other nature specified in the form’s heading.

Collected Personal Data: Email and Name.

Mailing List or Newsletter (This Website)

By subscribing to the mailing list or newsletter, the User’s email address is automatically added to a contact list to which email messages containing information, including commercial and promotional content related to this Website, will be sent. The User’s email address may also be added to this list as a result of registering on this Website or after making a purchase.

Collected Personal Data: Email.

Contact Management and Message Sending

This type of service allows for the management of an email contact database, phone contacts, or any other type of contact used to communicate with the User. These services may also allow for the collection of data related to the date and time the User viewed messages, as well as the User’s interaction with them, such as information about clicks on links in the messages.

MailChimp (The Rocket Science Group, LLC.)

MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.

Collected Personal Data: Email, Name, and Phone Number.

Location of Processing: United States – Privacy Policy. Subject to the Privacy Shield.

Payment Management

Payment management services allow this Website to process payments via credit card, bank transfer, or other tools. The data used for payment is acquired directly by the payment service provider without being processed by this Website. Some of these services may also allow for the scheduled sending of messages to the User, such as emails containing invoices or payment notifications.

PayPal (PayPal)

PayPal is a payment service provided by PayPal Inc., which allows the User to make payments online.

Collected Personal Data: Various types of Data as specified by the service’s privacy policy.

Location of Processing: See PayPal Privacy Policy – Privacy Policy.

Tag Management

This type of service is useful for the centralized management of tags or scripts used on this Website.

The use of such services involves the flow of User Data through them and, if applicable, their retention.

Google Tag Manager (Google LLC)

Google Tag Manager is a tag management service provided by Google LLC.

Personal Data collected: Cookies and Usage Data.

Location of processing: United States – Privacy Policy. Participant in the Privacy Shield.

Interaction with social networks and external platforms

This type of service allows interactions with social networks or other external platforms directly from the pages of this Website. Interactions and the information acquired from this Website are in any case subject to the User’s privacy settings related to each social network. In the event that an interaction service with social networks is installed, it is possible that, even if Users do not use the service, it collects traffic data related to the pages where it is installed.

PayPal Button and Widgets (Paypal)

The PayPal button and widgets are services for interacting with the PayPal platform, provided by PayPal Inc.

Personal Data collected: Cookies and Usage Data.

Location of processing: See PayPal’s Privacy Policy – Privacy Policy.

YouTube Social Buttons and Widgets (Google Inc.)

The YouTube social buttons and widgets are services for interacting with the YouTube social network, provided by Google Inc.

Personal Data collected: Usage Data.

Location of processing: United States – Privacy Policy. Participant in the Privacy Shield.

Facebook “Like” Button and Social Widgets (Facebook, Inc.)

The “Like” button and Facebook social widgets are services for interacting with the Facebook social network, provided by Facebook, Inc.

Personal Data collected: Cookies and Usage Data.

Location of processing: United States – Privacy Policy. Participant in the Privacy Shield.

Location-Based Interactions

Geolocation (this Website)

Personal Data collected: Geographic location.

Non-continuous Geolocation (this Website)

This Website may collect, use, and share Data regarding the User’s geographic location in order to provide location-based services. Most browsers and devices provide tools to deny geographic tracking by default. If the User has expressly authorized this feature, this Website may receive information about their actual geographic location. The geographic location of the User occurs in a non-continuous manner, upon specific request by the User, or when the User does not specify their location and allows the application to automatically detect the location.

Personal Data collected: Geographic location.

Spam Protection

This type of service analyzes the traffic of this Website, potentially containing Personal Data of Users, in order to filter it from traffic, messages, and content recognized as SPAM.

Google reCAPTCHA (Google Inc.)

Google reCAPTCHA is a spam protection service provided by Google Inc. The use of the reCAPTCHA system is subject to Google’s Privacy Policy and Terms of Use.

Personal Data collected: Cookies and Usage Data.

Location of processing: United States – Privacy Policy. Participant in the Privacy Shield.

Advertising

This type of service allows the use of the User’s Data for commercial communication purposes in various advertising formats, such as banners, even in relation to the User’s interests. This does not mean that all Personal Data will be used for this purpose. Data and usage conditions are indicated below. Some of the services listed below may use Cookies to identify the User or use behavioral retargeting techniques, i.e., displaying personalized ads based on the User’s interests and behavior, even outside of this Website. For more information, we suggest checking the privacy policies of the respective services. In addition to the opt-out possibilities offered by the services listed below, the User can opt-out from receiving cookies from third-party services by visiting the Network Advertising Initiative opt-out page.

Google AdSense (Google Inc.)

Google AdSense is an advertising service provided by Google Inc. This service uses the “Doubleclick” Cookie, which tracks the use of this Website and the User’s behavior in relation to ads, products, and services offered. The User can decide at any time not to use the Doubleclick Cookie by disabling it: google.com/settings/ads/onweb/optout.

Personal Data collected: Cookies and Usage Data.

Location of processing: United States – Privacy Policy – Opt Out. Participant in the Privacy Shield.

Registration and Authentication

By registering or authenticating, the User allows the Application to identify them and provide access to dedicated services. Depending on what is indicated below, the registration and authentication services may be provided with the help of third parties. If this happens, this application may access certain Data stored by the third-party service used for registration or identification.

Personal Data collected: Various types of Data as specified in the service’s privacy policy.

Location of processing: See PayPal’s Privacy Policy – Privacy Policy.

Direct Registration (this Website)

The User registers by filling out the registration form and providing their Personal Data directly to this Website.

Personal Data collected: Surname, email, and first name.

Remarketing and Behavioral Targeting

This type of service allows this Website and its partners to communicate, optimize, and serve advertisements based on the past use of this Website by the User. This activity is carried out by tracking Usage Data and using Cookies, information that is transferred to the partners involved in remarketing and behavioral targeting activities. In addition to the opt-out possibilities offered by the services listed below, the User can opt-out from receiving cookies from third-party services by visiting the Network Advertising Initiative opt-out page.

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc., linking the activity of this Website with the Facebook advertising network.

Personal Data collected: Cookies and Usage Data.

Location of processing: United States – Privacy Policy – Opt Out. Participant in the Privacy Shield.

AdWords Remarketing (Google Inc.)

AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc., linking the activity of this Website with the Adwords advertising network and the Doubleclick Cookie.

Personal Data collected: Cookies and Usage Data.

Location of processing: United States – Privacy Policy – Opt Out.

Facebook Custom Audience (Facebook, Inc.)

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc., linking the activity of this Website with the Facebook advertising network.

Personal Data collected: Cookies and email.

Location of processing: United States – Privacy Policy – Opt Out. Participant in the Privacy Shield.

Remarketing with Google Analytics for Display Advertising (Google Inc.)

Google Analytics for Display Advertising is a remarketing and behavioral targeting service provided by Google Inc., linking tracking activity done by Google Analytics and its Cookies with the Adwords advertising network and the Doubleclick Cookie.

Personal Data collected: Cookies and Usage Data.

Location of processing: United States – Privacy Policy – Opt Out. Participant in the Privacy Shield.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and track the User’s behavior.

Google Analytics (Google Inc.)

Personal Data collected: Cookies and Usage Data.

Location of processing: USA – Privacy Policy – Opt Out.

Facebook Analytics for Apps (Facebook, Inc.)

Facebook Analytics for Apps is a statistics service provided by Facebook, Inc.

Personal Data collected: Usage Data and various types of Data as specified by the service’s privacy policy.

Location of processing: United States – Privacy Policy. Subject to Privacy Shield.

Google Analytics with anonymized IP (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the Personal Data collected to track and examine the use of this Website, compile reports, and share them with other services developed by Google. Google may use Personal Data to contextualize and personalize ads from its advertising network. This Google Analytics integration anonymizes your IP address. The anonymization works by shortening the IP address within the boundaries of the European Union member states or other countries adhering to the Agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to Google’s servers and shortened within the United States.

Personal Data collected: Cookies and Usage Data.

Location of processing: United States – Privacy Policy – Opt Out. Subject to Privacy Shield.

Facebook Ads Conversion Tracking (Facebook, Inc.)

Facebook Ads Conversion Tracking is a statistics service provided by Facebook, Inc. that links data from the Facebook advertising network with actions taken on this Website.

Personal Data collected: Cookies and Usage Data.

Location of processing: United States – Privacy Policy. Subject to Privacy Shield.

Google AdWords Conversion Tracking (Google Inc.)

Google AdWords Conversion Tracking is a statistics service provided by Google Inc. that links data from the Google AdWords advertising network with actions taken on this Website.

Personal Data collected: Cookies and Usage Data.

Location of processing: United States – Privacy Policy. Subject to Privacy Shield.

Displaying content from external platforms

This type of service allows you to display content hosted on external platforms directly from the pages of this Website and interact with it. If such a service is installed, it is possible that, even if users do not use the service, it still collects traffic data related to the pages where it is installed.

Google Fonts (Google Inc.)

Google Fonts is a font style display service managed by Google Inc. that allows this Website to integrate such content within its pages.

Personal Data collected: Usage Data and various types of Data as specified by the service’s privacy policy.

Location of processing: United States – Privacy Policy. Subject to Privacy Shield.

Google Maps Widget (Google Inc.)

Google Maps is a map display service managed by Google Inc. that allows this Website to integrate such content within its pages.

Personal Data collected: Cookies and Usage Data.

Location of processing: United States – Privacy Policy. Subject to Privacy Shield.

Instagram Widget (Instagram, Inc.)

Instagram is an image display service managed by Instagram, Inc. that allows this Website to integrate such content within its pages.

Personal Data collected: Cookies and Usage Data.

Location of processing: United States – Privacy Policy.

YouTube Video Widget (Google Inc.)

YouTube is a video content display service managed by Google Inc. that allows this Website to integrate such content within its pages.

Personal Data collected: Cookies and Usage Data.

Location of processing: United States – Privacy Policy. Subject to Privacy Shield.

Additional information about Personal Data

Push Notifications

This Website may send push notifications to the User.

Sale of goods and services online

The Personal Data collected are used to provide services to the User or for the sale of products, including payment and delivery. The Personal Data collected to complete the payment may include credit card details, bank account used for transfers, or other payment methods provided. The payment data collected by this Website depends on the payment system used.

User rights

Users may exercise certain rights regarding the Data processed by the Data Controller.

In particular, the User has the right to:

Withdraw consent at any time. The User can withdraw the consent previously given for the processing of their Personal Data.
Object to the processing of their Data. The User may object to the processing of their Data when it is based on a legal basis other than consent. Further details on the right to object are provided below.
Access their Data. The User has the right to obtain information about the Data processed by the Data Controller, on specific aspects of the processing, and to receive a copy of the processed Data.
Verify and request correction. The User can verify the accuracy of their Data and request its update or correction.
Obtain the restriction of processing. When certain conditions apply, the User can request the restriction of the processing of their Data. In such cases, the Data Controller will not process the Data for any other purpose other than to retain it.
Request the deletion or removal of their Personal Data. When certain conditions apply, the User can request the deletion of their Data by the Data Controller.
Receive their Data or have them transferred to another data controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format, and, where technically feasible, to have them transferred without hindrance to another data controller. This provision is applicable when Data is processed using automated tools and the processing is based on the User’s consent, a contract the User is part of, or contractual measures connected to it.
File a complaint. The User can file a complaint with the competent personal data protection authority or seek judicial remedies.

Details on the Right to Object

When Personal Data is processed in the public interest, in the exercise of official powers vested in the Data Controller, or to pursue a legitimate interest of the Data Controller, Users have the right to object to processing for reasons related to their specific situation.

Users are informed that if their Data is processed for direct marketing purposes, they can object to the processing without providing any justification. To determine whether the Data Controller processes data for direct marketing purposes, Users can refer to the relevant sections of this document.

How to Exercise Rights

To exercise the User’s rights, Users may send a request to the contact details of the Data Controller provided in this document. Requests are made free of charge and will be processed by the Data Controller as soon as possible, in any case, within one month.

Cookie Policy

This Website uses Cookies. To learn more and view the detailed notice, the User can consult the Cookie Policy.

Further Information on Processing

Defense in Court

The User’s Personal Data may be used by the Data Controller in court or during the preparatory stages of potential legal action to defend against misuse of this Website or related Services by the User. The User acknowledges that the Data Controller may be required to disclose the Data by order of public authorities.

Specific Notices

At the User’s request, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual notices regarding specific Services, or the collection and processing of Personal Data.

System Logs and Maintenance

For operational and maintenance purposes, this Website and any third-party services it uses may collect system logs, which are files that record interactions and may contain Personal Data, such as the User’s IP address.

Information Not Contained in This Policy

Additional information related to the processing of Personal Data can be requested at any time from the Data Controller using the contact details provided.

Response to “Do Not Track” Requests

This Website does not support “Do Not Track” requests. To find out if any third-party services used support them, the User is encouraged to consult their respective privacy policies.

Changes to This Privacy Policy

The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users on this page and, if possible, on this Website, and, where technically and legally feasible, sending a notification to Users via one of the contact details held by the Data Controller. Therefore, Users are encouraged to regularly check this page, referring to the date of the last modification indicated at the bottom. If changes affect processing based on consent, the Data Controller will seek to collect the User’s consent again, if necessary.

Definitions and Legal References

Personal Data (or Data): Any information that, directly or indirectly, including in combination with other information, including a personal identification number, allows the identification or identification of a natural person.
Usage Data: Information collected automatically through this Website (including by third-party applications integrated into this Website), including IP addresses or domain names of the User’s computers connecting to this Website, URIs (Uniform Resource Identifier), request time, request method to the server, file size received in response, numerical code indicating server response status (successful, error, etc.), country of origin, browser and operating system characteristics used by the visitor, time-related features of the visit (such as time spent on each page), and the User’s navigation details, especially the sequence of pages visited and system parameters.
User: The individual using this Website, unless otherwise specified, corresponds to the Data Subject.
Data Subject: The natural person to whom the Personal Data refers.
Data Processor (or Processor): The person, legal entity, public authority, or any other body that processes Personal Data on behalf of the Data Controller, as described in this privacy policy.
Data Controller (or Controller): The person, legal entity, public authority, service, or other body that, individually or jointly with others, determines the purposes and means of the processing of Personal Data and the instruments adopted, including security measures related to the operation and use of this Website. The Data Controller, unless otherwise specified, is the owner of this Website.
This Website (or Application): The hardware or software tool by which the User’s Personal Data is collected and processed.
Service: The Service provided by this Website as defined in the relevant terms (if available) on this website/application.
European Union (or EU): Unless otherwise specified, any reference to the European Union in this document extends to all current member states of the European Union and the European Economic Area.
Cookies: A small amount of data stored within the User’s device.

Legal References

This privacy notice is drafted based on multiple legislative frameworks, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy notice applies only to this Website.