Privacy Policy

OWNER AND DATA CONTROLLER

Heritage Trade Company srl
Via Col Parans 5, 24023 Clusone (BG), Italia
VAT: IT04286680162

Owner contact email: [email protected]

Following “Shangri-La Heritage”

TYPES OF DATA COLLECTED

Among the types of Personal Data that Shangri-La Heritage collects, by itself or through third parties, there are: Cookies, Usage Data, email address, Various types of Data, first name, last name, phone number, address, password, date of birth, Email, gender, company name, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and geographic position.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Shangri-La Heritage.
Unless specified otherwise, all Data requested by Shangri-La Heritage is mandatory and failure to provide this Data may make it impossible for Shangri-La Heritage to provide its services. In cases where Shangri-La Heritage specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Shangri-La Heritage or by the owners of third-party services used by Shangri-La Heritage serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through Shangri-La Heritage and confirm that they have the third party’s consent to provide the Data to the Owner.

MODE AND PLACE OF PROCESSING DATA

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Shangri-La Heritage (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

THE PURPOSE OF PROCESSING

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Registration and authentication, Remarketing and behavioral targeting, Access to third party services’ accounts, Analytics, Contacting the User, Advertising, Managing contacts and sending messages, Hosting and backend infrastructure, Social features, Handling payments, Managing support and contact requests, Displaying content from external platforms, Content performance and features testing (A/B testing), Interaction with external social networks and platforms, Platform services and hosting, Backup saving and management, Content commenting, Interaction with data collection platforms and other third parties, User database management, Location-based interactions and SPAM protection.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Facebook permissions asked by Shangri-La Heritage

Shangri-La Heritage may ask for some Facebook permissions allowing it to perform actions with the User’s Facebook account and to retrieve information, including Personal Data, from it. This service allows Shangri-La Heritage to connect with the User’s account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information

By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

Contact email

Access the user’s contact email address.

DETAILED INFORMATION OF THE PROCESSING PERSONAL DATA

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

• Access to third party services’ accounts

  This type of services allows Shangri-La Heritage to access Data from your account on a third party service and perform actions with it.
  These services are not activated automatically, but require explicit authorization by the User.

  Access to the Facebook account (Shangri-La Heritage)

  This service allows Shangri-La Heritage to connect with the User’s account on the Facebook social network, provided by Facebook, Inc.

  Permissions asked: Contact email.

  Place of processing: US – Privacy Policy.

  Access to the Twitter account (Twitter, Inc.)

  This service allows Shangri-La Heritage to connect with the User’s account on the Twitter social network, provided by Twitter, Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

• Advertising

  This type of services allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on Shangri-La Heritage, possibly based on User interests.
  This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
  Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside Shangri-La Heritage. For more information, please check the privacy policies of the relevant services.

  Direct Email Marketing (DEM) (Shangri-La Heritage)

  Shangri-La Heritage uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by Shangri-La Heritage.

  Personal Data collected: email address.

  Bing Ads (Microsoft Corporation)

  Bing Ads is an advertising service provided by Microsoft Corporation.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

  Criteo (Criteo SA)

  Criteo is an advertising service provided by Criteo SA.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: France – Privacy Policy – Opt Out.

  Ligatus (Ligatus GmbH)

  Ligatus is an advertising service provided by Ligatus GmbH.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: Germany – Privacy Policy – Opt Out.

  Outbrain (Outbrain Inc.)

  Outbrain is an advertising service provided by Outbrain Inc.

  Personal Data collected: Cookies and various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy – Opt Out.

  Tradedoubler (Tradedoubler)

  Tradedoubler is an advertising service provided by TradeDoubler AG.
  For more information on the use of TradeDoubler Cookies and how to block them, please visit: Tradedoubler’s targeting technologies.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: Sweden – Privacy Policy – Opt Out.

  DoubleClick for Publishers (Google Ireland Limited)

  DoubleClick for Publishers is an advertising service provided by Google Ireland Limited that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with. In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google’s use of data, consult Google’s partner policy.
  This service uses the “Doubleclick” Cookie, which tracks use of Shangri-La Heritage and User behavior concerning ads, products and services offered.
  Users may decide to disable all the Doubleclick Cookies by clicking on: www.google.com/settings/ads/onweb/optout?hl=en.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  Yahoo App Publishing Advertising (Yahoo! Inc.)

  Yahoo App Publishing is an advertising service provided by Yahoo! Inc.
  If the User chooses to opt-out, Yahoo App Publishing will stop tracking data for the device identified by the provided MAC address and/or device identifier going forward.
  Yahoo App Publishing will stop providing ads and/or recommendations to that MAC address and/or device identifier across all publishers.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

  Facebook Audience Network (Facebook, Inc.)

  Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook’s use of Data, consult Facebook’s data policy.

  Shangri-La Heritage may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User’s ad preferences. The User can control this in the Facebook ad settings.

  Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

  Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

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

• Analytics

  The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  Google Analytics (Google Ireland Limited)

  Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of Shangri-La Heritage, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

  Google AdWords conversion tracking (Google Ireland Limited)

  Google AdWords conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google AdWords advertising network with actions performed on Shangri-La Heritage.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  Facebook Ads conversion tracking (Facebook, Inc.)

  Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on Shangri-La Heritage.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  Google Tag Manager (Google Ireland Limited)

  Google Tag Manager is an analytics service provided by Google Ireland Limited

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  Twitter Ads conversion tracking (Twitter, Inc.)

  Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on Shangri-La Heritage.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  User ID extension for Google Analytics (Google Ireland Limited)

  Google Analytics on Shangri-La Heritage makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device.
  The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by Shangri-La Heritage.
  The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.

  Personal Data collected: Cookies.

  Place of processing: US – Privacy Policy – Opt Out.

  Yahoo Advertising conversion tracking (Yahoo! Inc.)

  Yahoo Advertising conversion tracking is an analytics service provided by Yahoo! Inc. that connects data from the Yahoo advertising network with actions performed on Shangri-La Heritage.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  Display Advertising extension for Google Analytics (Google Ireland Limited)

  Google Analytics on Shangri-La Heritage might use Google’s Interest-based advertising, 3rd-party audience data and information from the DoubleClick Cookie to extend analytics with demographics, interests and ads interaction data.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

  KISSmetrics (KISSmetrics)

  KISSmetrics is an analytics service provided by Kissmetrics Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

  WordPress Stats (Automattic Inc.)

  WordPress Stats is an analytics service provided by Automattic Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  HubSpot Analytics (HubSpot, Inc.)

  HubSpot Analytics is an analytics service provided by HubSpot, Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out .

  LinkedIn conversion tracking (LinkedIn Corporation)

  LinkedIn conversion tracking is an analytics service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on Shangri-La Heritage.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  Salesforce Analytics Cloud (salesforce.com, inc.)

  Salesforce Analytics Cloud is an analytics service provided by salesforce.com, inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

• Backup saving and management

  This type of service allows the Owner to save and manage backups of Shangri-La Heritage on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to Shangri-La Heritage.

  Backup on Google Drive (Google Ireland Limited)

  Google Drive is a service to save and manage backups provided by Google Ireland Limited.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  Backup on Dropbox (Dropbox, Inc.)

  Dropbox is a service to save and manage backups provided by Dropbox Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

• Contacting the User

  Mailing List or Newsletter (Shangri-La Heritage)

  By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Shangri-La Heritage. Your email address might also be added to this list as a result of signing up to Shangri-La Heritage or after making a purchase.

  Personal Data collected: email address.

  Phone contact (Shangri-La Heritage)

  Users that provided their phone number might be contacted for commercial or promotional purposes related to Shangri-La Heritage, as well as for fulfilling support requests.

  Personal Data collected: phone number.

• Content commenting

  Content commenting services allow Users to make and publish their comments on the contents of Shangri-La Heritage.
  Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
  If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

  Comment system managed directly (Shangri-La Heritage)

  Shangri-La Heritage has its own internal content comment system.

  Personal Data collected: Cookies, email address, first name and last name.

• Content performance and features testing (A/B testing)

  The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of Shangri-La Heritage.

  Google Website Optimizer (Google Ireland Limited)

  Google Website Optimizer is an A/B testing service provided by Google Ireland Limited.
  Google may use Personal Data to contextualize and personalize the ads of its own advertising network.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

• Displaying content from external platforms

  This type of services allows you to view content hosted on external platforms directly from the pages of Shangri-La Heritage and interact with them.
  This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  Google Fonts (Google Ireland Limited)

  Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows Shangri-La Heritage to incorporate content of this kind on its pages.

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

  Place of processing: US – Privacy Policy.

  Google Maps widget (Google Ireland Limited)

  Google Maps is a maps visualization service provided by Google Ireland Limited that allows Shangri-La Heritage to incorporate content of this kind on its pages.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  Vimeo video (Vimeo, LLC)

  Vimeo is a video content visualization service provided by Vimeo, LLC that allows Shangri-La Heritage to incorporate content of this kind on its pages.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  Instagram widget (Instagram, Inc.)

  Instagram is an image visualization service provided by Instagram, Inc. that allows Shangri-La Heritage to incorporate content of this kind on its pages.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  YouTube video widget (Google Ireland Limited)

  YouTube is a video content visualization service provided by Google Ireland Limited that allows Shangri-La Heritage to incorporate content of this kind on its pages.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

• Handling payments

  Payment processing services enable Shangri-La Heritage to process payments by credit card, bank transfer or other means. To ensure greater security, Shangri-La Heritage shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
  Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.

  PayPal (PayPal Inc.)

  PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments using their PayPal credentials.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  PayPal Carrier Payments (PayPal Inc.)

  PayPal Carrier Payments is a payment service provided by PayPal, Inc., which allows Users to make online payments using their mobile phone operator.

  Personal Data collected: phone number and various types of Data as specified in the privacy policy of the service.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

  PayPal Payments Hub (PayPal Inc.)

  PayPal Payments Hub is a payment service provided by PayPal Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

• Hosting and backend infrastructure

  This type of services has the purpose of hosting data and files that enable Shangri-La Heritage to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Shangri-La Heritage. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  Amazon Web Services (AWS) (Amazon)

  Amazon Web Services is a hosting and backend service provided by Amazon.com Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: See the Amazon privacy policy – Privacy Policy.

• Interaction with data collection platforms and other third parties

  This type of service allows Users to interact with data collection platforms or other services directly from the pages of Shangri-La Heritage for the purpose of saving and reusing data.
  If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

  MailChimp widget (The Rocket Science Group, LLC.)

  The MailChimp widget is a service for interacting with the MailChimp email address management and message sending service provided by The Rocket Science Group LLC.

  Personal Data collected: Cookies, email address, first name and last name.

  Place of processing: USA – Privacy Policy.

• Interaction with external social networks and platforms

  This type of services allows interaction with social networks or other external platforms directly from the pages of Shangri-La Heritage.
  The interaction and information obtained through Shangri-La Heritage are always subject to the User’s privacy settings for each social network.
  This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

  PayPal button and widgets (PayPal Inc.)

  The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

  Facebook Like button and social widgets (Facebook, Inc.)

  The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  LinkedIn button and social widgets (LinkedIn Corporation)

  The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  Google+ +1 button and social widgets (Google Ireland Limited)

  The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google Ireland Limited.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  Twitter Tweet button and social widgets (Twitter, Inc.)

  The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

• Location-based interactions

  Geolocation (Shangri-La Heritage)

  Shangri-La Heritage may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked byShangri-La Heritage.

  Personal Data collected: geographic position.

• Managing contacts and sending messages

  This type of services makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  MailChimp (The Rocket Science Group, LLC.)

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

  Personal Data collected: email address.

  Place of processing: US – Privacy Policy.

  MailUp (MailUp)

  MailUp is an email address management and message sending service provided by MailUp SpA.

  Personal Data collected: email address.

  Place of processing: Italy – Privacy Policy.

  HubSpot Email (HubSpot, Inc.)

  HubSpot Email is an email address management and message sending service provided by HubSpot, Inc.

  Personal Data collected: email address and Usage Data.

  Place of processing: US – Privacy Policy.

• Managing support and contact requests

  This type of services allows Shangri-La Heritage to manage support and contact requests received via email or by other means, such as the contact form.
  The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).

  Freshdesk (Freshworks, Inc.)

  Freshdesk is a support and contact request management service provided by Freshworks, Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  Salesforce Service Cloud (salesforce.com, inc.)

  Salesforce Service Cloud is a support and contact request management service provided by salesforce.com, inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

• Platform services and hosting

  These services have the purpose of hosting and running key components of Shangri-La Heritage, therefore allowing the provision of Shangri-La Heritage from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  WordPress.com (Automattic Inc.)

  WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host Shangri-La Heritage.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: USA – Privacy Policy.

• Registration and authentication

  By registering or authenticating, Users allow Shangri-La Heritage to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, Shangri-La Heritage will be able to access some Data, stored by these third party services, for registration or identification purposes.

  Facebook Authentication (Facebook, Inc.)

  Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  Twitter OAuth (Twitter, Inc.)

  Twitter Oauth is a registration and authentication service provided by Twitter, Inc. and is connected to the Twitter social network.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  Google OAuth (Google Ireland Limited)

  Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  Direct registration (Shangri-La Heritage)

  The User registers by filling out the registration form and providing the Personal Data directly to Shangri-La Heritage.

  Personal Data collected: address, email address, first name, last name, password and phone number.

  Log In with PayPal (PayPal Inc.)

  Log In with PayPal is a registration and authentication service provided by PayPal Inc. and is connected to the PayPal network.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: See the PayPal privacy policy – Privacy Policy.

  Login with Amazon (Amazon)

  Login with Amazon is a registration and authentication service provided by Amazon.com, Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  MailChimp OAuth (The Rocket Science Group, LLC.)

  MailChimp OAuth is a registration and authentication service provided by The Rocket Science Group, LLC and is connected to the MailChimp service.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  Stripe OAuth (Stripe Inc)

  Stripe OAuth is a registration and authentication service provided by Stripe, Inc. and is connected to the Stripe network.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  Linkedin OAuth (LinkedIn Corporation)

  Linkedin Oauth is a registration and authentication service provided by Linkedin Corporation and is connected to the Linkedin social network.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  Instagram Authentication (Instagram, Inc.)

  Instagram Authentication is a registration and authentication service provided by Instagram, Inc. and is connected to the Instagram social network.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

• Remarketing and behavioral targeting

  This type of service allows Shangri-La Heritage and its partners to inform, optimize and serve advertising based on past use of Shangri-La Heritage by the User.
  This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
  In addition to any opt out offered by any of the services below, the User may opt out of a third-party service’s use of cookies 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. that connects the activity of Shangri-La Heritage with the Facebook advertising network.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

  AdRoll (Semantic Sugar, Inc.)

  AdRoll is an advertising service provided by Semantic Sugar, Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

  Remarketing through Google Analytics for Display Advertising (Google Ireland Limited)

  Google Analytics for Display Advertising is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the tracking activity performed by Google Analytics and its Cookies with the Adwords advertising network and the Doubleclick Cookie.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

  AdWords Remarketing (Google Ireland Limited)

  AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of Shangri-La Heritage with the Adwords advertising network and the Doubleclick Cookie.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

  Facebook Custom Audience (Facebook, Inc.)

  Facebook Custom Audience is a Remarketing and Behavioral Targeting service provided by Facebook, Inc. that connects the activity of Shangri-La Heritage with the Facebook advertising network.

  Personal Data collected: Cookies and email address.

  Place of processing: US – Privacy Policy – Opt Out.

  Twitter Remarketing (Twitter, Inc.)

  Twitter Remarketing is a Remarketing and Behavioral Targeting service provided by Twitter, Inc. that connects the activity of Shangri-La Heritage with the Twitter advertising network.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

  Twitter Tailored Audiences (Twitter, Inc.)

  Twitter Tailored Audiences is a Remarketing and Behavioral Targeting service provided by Twitter, Inc. that connects the activity of Shangri-La Heritage with the Twitter advertising network.

  Personal Data collected: Cookies and email address.

  Place of processing: US – Privacy Policy – Opt Out.

  DoubleClick for Publishers Audience Extension (Google Ireland Limited)

  DoubleClick for Publishers Audience Extension is a remarketing and behavioral targeting service provided by Google Ireland Limited that tracks the visitors of Shangri-La Heritage and allows selected advertising partners to display targeted ads across the web to them.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

  Criteo Dynamic Retargeting (Criteo SA)

  Criteo Dynamic Retargeting is a remarketing and behavioral targeting service provided by Criteo SA., that connects the activity of Shangri-La Heritage with the Criteo advertising network.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: France – Privacy Policy – Opt Out.

  LinkedIn Website Retargeting (LinkedIn Corporation)

  LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of Shangri-La Heritage with the LinkedIn advertising network.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

• Social features

  Inviting and suggesting friends (Shangri-La Heritage)

  Shangri-La Heritage may use the Personal Data provided to allow Users to invite their friends – for example through the address book, if access has been provided – and to suggest friends or connections inside it.

  Personal Data collected: Various types of Data.

• SPAM protection

  This type of service analyzes the traffic of Shangri-La Heritage, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

  Google reCAPTCHA (Google Ireland Limited)

  Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
  The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

• User database management

  This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to Shangri-La Heritage, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving Shangri-La Heritage.
  Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Shangri-La Heritage.

  FullContact (FullContact Inc.)

  FullContact is a User database management service provided by FullContact Inc.

  Personal Data collected: company name, date of birth, Email, first name, gender, last name and various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  HubSpot CRM (HubSpot, Inc.)

  HubSpot CRM is a User database management service provided by HubSpot, Inc.

  Personal Data collected: email address, phone number and various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  HubSpot Lead Management (HubSpot, Inc.)

  HubSpot Lead Management is a User database management service provided by HubSpot, Inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  Salesforce Marketing Cloud (salesforce.com, inc.)

  Salesforce Marketing Cloud is a User database management service provided by salesforce.com, inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

  Salesforce Sales Cloud (salesforce.com, inc.)

  Salesforce Sales Cloud is a User database management service provided by salesforce.com, inc.

  Personal Data collected: various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

FURTHER INFORMATION ABOUT PERSONAL DATA

• Selling goods and services online

  The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
  The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Shangri-La Heritage depends on the payment system used.

• Unique device identification

  Shangri-La Heritage may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.

• User identification via a universally unique identifier (UUID)

  Shangri-La Heritage may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users’ preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

THE RIGHTS OF USER

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

COOKIE POLICY

Shangri-La Heritage uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

ADDITIONAL INFORMATION ABOUT DATA COLLECTION AND PROCESSING

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Shangri-La Heritage or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, Shangri-La Heritage may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Shangri-La Heritage and any third-party services may collect files that record interaction with Shangri-La Heritage (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

Shangri-La Heritage does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within Shangri-La Heritage and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.