Privacy Policy

1. Data Controller

The data controller responsible for the processing of personal data collected through this Website and the Shangti Experience mobile application is:

SHANGTI STUDIO, SLU
NRT: L-711881-V
Av. del Ravell, Nau 4 – Planta 1 – Local 1, AD400 La Massana – Principality of Andorra
Phone: +376 727 785
Email: contact@philippeshangti.com

2. Applicable Legislation

This Privacy Policy is adapted to the applicable Andorran and European legislation on personal data protection, and in particular to:

  • Andorran Law 29/2021, of 28 October, qualified for the Protection of Personal Data (LQDP) and its implementing regulations.
  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data (GDPR).

3. Scope of Application

This Privacy Policy applies to:

  • The website philippeshangti.com and all its subpages.
  • The mobile application Shangti Experience (package name: com.undercoverlab.shangtixp), available on the Google Play Store, developed and published by RJ Digital Hub, SLU (Undercoverlab) on behalf of Shangti Studio, SLU.

4. Data Collected

4.1 Website

Through the forms available on the Website, the following personal data may be collected:

  • Identification data: name and surname.
  • Contact data: email address.
  • Any other data voluntarily provided by the User through free-text fields.

In addition, browsing data may be collected automatically through cookies (see Cookie Policy, section 9).

4.2 Shangti Experience App

The Shangti Experience application may collect the following data:

  • Camera access: used exclusively to enable augmented reality (AR) features. No images or video are stored or transmitted outside the device.
  • Device information: device model, operating system version and unique device identifiers, collected for technical compatibility and performance purposes.
  • Anonymous usage data: interactions within the App, session duration and features accessed, collected solely to improve the user experience.

The App does not require user registration and does not collect names, email addresses or any directly identifying personal data unless the User voluntarily provides such data through in-App contact forms.

5. Purposes of Processing and Legal Basis

Shangti Studio, SLU processes personal data for the following purposes. Where the legal basis is consent, the User may accept or refuse each purpose independently:

  • [ ] Responding to queries and contact requests — Management of messages sent through the contact forms on the Website or App. Legal basis: consent of the User.
  • [ ] Sending commercial communications and newsletters — Sending news, exhibitions, events and promotions related to Philippe Shangti's activity. Legal basis: express consent of the User. The User may withdraw this consent at any time.
  • [ ] Website and App analytics and improvement — Anonymous analysis of browsing and usage behaviour to improve content and user experience. Legal basis: legitimate interest of the data controller, provided that the rights and interests of the User are not overridden.
  • [ ] Compliance with legal obligations — Processing necessary to comply with applicable legal or regulatory obligations. Legal basis: legal obligation.

Tick boxes on forms will never be pre-checked. The User will freely and specifically consent to each purpose.

6. Data Retention

Personal data will be kept only for the time strictly necessary for the purposes for which it was collected, and in any case until the User requests its deletion. Once the retention period has expired, data will be securely deleted or anonymised.

Where a legal obligation requires retention beyond this period, data will be blocked and processed exclusively to ensure its conservation.

7. Recipients and Data Transfers

7.1 Third-party recipients

As a general rule, personal data will not be shared with third parties without the User's express consent, except in the following cases:

  • Data processors: third-party service providers who process data on behalf of Shangti Studio, SLU under a data processing agreement and in accordance with this Privacy Policy. These may include hosting providers, email marketing platforms and analytics services.
  • Competent public authorities: where required by law and for the purposes defined therein.

7.2 International transfers

Some of the service providers used (such as Google LLC, for analytics and app distribution services) may process data on servers located outside Andorra and the European Economic Area. In such cases, transfers are made to countries recognised as providing an adequate level of protection, or are subject to appropriate safeguards such as Standard Contractual Clauses approved by the European Commission.

8. User Rights

In accordance with the LQDP and the GDPR, the User has the following rights regarding their personal data:

  • Right of access: to obtain confirmation of whether personal data is being processed and, if so, to access it.
  • Right of rectification: to correct inaccurate or incomplete data.
  • Right of deletion: to request the deletion of data when it is no longer necessary for the purposes for which it was collected, or when consent is withdrawn.
  • Right to restriction of processing: to request the limitation of processing in certain circumstances.
  • Right to data portability: to receive personal data in a structured, commonly used and machine-readable format.
  • Right to object: to object to the processing of personal data, in particular for direct marketing purposes.
  • Right to withdraw consent: consent given for any specific purpose may be withdrawn at any time, without affecting the lawfulness of processing carried out prior to its withdrawal.

To exercise any of these rights, the User must send a written request to contact@philippeshangti.com, attaching a copy of their identity document. The request must specify the right being exercised and the contact address for notifications.

If the User considers that their rights have been violated, they may file a complaint with the supervisory authority: Agència Andorrana de Protecció de Dades (APDA) — www.apda.ad.

9. Cookie Policy

Access to this Website may involve the use of cookies. Cookies are small files stored in the User's browser that allow the server to remember certain information to improve navigation.

9.1 Types of cookies used

  • Own cookies: managed exclusively by Shangti Studio, SLU to ensure the correct functioning of the Website and improve the User's experience.
  • Third-party analytical cookies: provided by services such as Google Analytics, used to obtain anonymous statistical data on Website usage. These cookies may involve the transfer of data to servers outside Andorra (see section 7.2).

9.2 Cookie consent

Upon first access to the Website, the User will be informed of the use of cookies and asked for their consent. The User may accept all cookies, reject non-essential cookies, or configure their preferences individually. This choice can be modified at any time.

9.3 Disabling cookies via browser settings

The User may also configure their browser to block or delete cookies at any time:

  • Google Chrome: Settings → Privacy and security → Cookies and other site data.
  • Mozilla Firefox: Options → Privacy & Security → Cookies and Site Data.
  • Safari: Preferences → Privacy → Manage Website Data.
  • Microsoft Edge: Settings → Cookies and site permissions.

Disabling cookies may limit certain features of the Website.

10. Security Measures

Shangti Studio, SLU has implemented the technical and organisational measures necessary to ensure the security of personal data and prevent its accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. The Website uses an SSL (Secure Socket Layer) certificate to encrypt data transmission.

In the event of a personal data breach that poses a high risk to the rights and freedoms of Users, they will be notified without undue delay in accordance with applicable regulations.

11. Links to Third-Party Websites

The Website may contain links to third-party websites. Shangti Studio, SLU is not responsible for the privacy practices or content of such websites. The User is advised to review the privacy policies of any third-party sites they visit.

12. Modifications to this Privacy Policy

Shangti Studio, SLU reserves the right to modify this Privacy Policy to adapt it to legislative, jurisprudential or technical changes. Any modifications will be communicated to the User in advance through the Website. Continued use of the Website or App following notification of changes will imply acceptance of the updated Privacy Policy.

Last updated: March 2026