Date of last update: 07 July 2025
This Privacy Policy describes how the personal data of users consulting and interacting with the website are managed. https://sushi.live (hereinafter, the 'Site').
This information is provided in accordance with Article 13 of Regulation (EU) 2016/679 (hereinafter "GDPR") to those who interact with the web services of the Site.
1. DATA CONTROLLER
The Data Controller is:
La Bussola SRL
- VAT NO: 02499650790
- Share Capital: 100,000 € i.v.
- Registered Office: Viale Giuseppe Berto, Loc. Capo Vaticano, 89866, Ricadi (VV)
- Contact email: info@sushi.live
- PEC: labussolahotel@pec.it
2. TYPES OF DATA COLLECTED
Among the Personal Data collected by this Site, either independently or through third parties, are:
- Navigation Data: Data whose transmission is implicit in the use of Internet communication protocols (e.g. IP addresses, browser type, time of request).
- Data provided voluntarily by the user:
- Contact form via WhatsApp: The use of the WhatsApp contact button or form involves the acquisition of the user's telephone number and any other personal data spontaneously shared in the message.
- Reservation system (Plateform): When reserving a table, the data required to process the request are collected, such as name, surname, email address and telephone number.
- Newsletter subscription: The email address provided to receive commercial communications.
- Data collected via Cookies and Other Tracking Tools: The Site uses tracking tools for different purposes. These tools collect data such as IP address, interactions with the site, device and browser information. Specific tools used include:
- Google Tag Manager: Tag management service.
- Google Analytics: Statistical analysis service.
- Meta Pixel (Facebook/Instagram): Conversion tracking and remarketing tool.
- TikTok Pixel: Conversion tracking and remarketing tool.
For full information on these instruments, please refer to the Cookie Policy of the Site.
3. PURPOSE AND LEGAL BASIS OF PROCESSING
The User Data are collected for the following purposes and on the following legal bases:
| Purpose of Processing | Data Processed | Legal Basis |
| Responding to requests via WhatsApp | Telephone number, message content | Execution of pre-contractual measures taken at the request of the data subject (Art. 6.1.b GDPR). |
| Managing online bookings (via Plateform) | Name, surname, email, telephone number | Performance of a contract to which the data subject is party (Art. 6.1.b GDPR). |
| Website statistics and analysis (with Google Analytics) | Usage data, IP address (potentially anonymised) | Consent of the data subject (Art. 6.1.a GDPR) or, in the case of aggregated and anonymous data, Legitimate interest of the Data Controller. |
| Marketing, remarketing and measurement of advertising campaigns (with Meta Pixel, TikTok Pixel) | Usage data, tracking identifiers (cookies, pixel IDs) | Consent explicitly of the data subject (Art. 6.1.a GDPR). |
| Sending promotional newsletters | Email address | Consent explicitly of the data subject (Art. 6.1.a GDPR). |
| Fulfilling legal obligations (tax, accounting) | Billing and booking data | Legal obligation (Art. 6.1.c GDPR). |
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4. DATA PROCESSING METHODS AND RECIPIENTS
Processing is carried out using IT tools. In addition to the Data Controller, the Data may be processed by external parties appointed, if necessary, as Data Processors (art. 28 GDPR). These include:
- Plateform: for the management of the reservation system.
- Google LLC: for the services of Google Analytics and Google Tag Manager.
- Meta Platforms, Inc: for Meta Pixel services and communication via WhatsApp.
- TikTok Inc: for the TikTok Pixel service.
- Technical service providers (e.g. hosting providers).
An up-to-date list of the Persons in Charge can be obtained from the Controller.
5. TRANSFER OF DATA ABROAD
The use of services provided by Google, Meta and TikTok may involve the transfer of personal data outside the European Economic Area (EEA), in particular to the United States. The Data Controller ensures that such transfer takes place in accordance with applicable law, through the conclusion of Standard Contractual Clauses (SCC) approved by the European Commission or by virtue of other appropriate safeguards pursuant to Articles 44 et seq. of the GDPR.
6. RETENTION PERIOD
Data are kept for the time necessary to fulfil the purposes for which they were collected.
- The data for theperformance of the contract (reservations) are retained for the duration of the relationship and for 10 years thereafter for tax obligations.
- The data collected on the basis of the consent (marketing, profiling trackers) are retained until the user revokes consent. Navigation data collected via trackers have a retention period defined in the settings of the tool itself (e.g. Google Analytics, typically 14-26 months).
- The data for contact requests are kept for the time needed to process the request.
7. RIGHTS OF THE DATA SUBJECT
Users may exercise their rights under Articles 15-22 of the GDPR at any time, including the right of access, rectification, cancellation (right to be forgotten), limitation, portability, objection and withdrawal of consent.
8. HOW TO EXERCISE RIGHTS
To exercise your rights, you can send a request to the email address info@sushi.live or to the Controller's other contacts indicated in point 1.
9. NEED FOR A DETAILED COOKIE POLICY
Given the use of tools such as Google Analytics, Meta Pixel and TikTok Pixel, this site must be equipped with a Cookie Policy separate and detailed. This document must:
- List all third-party cookies and trackers analytically.
- Provide links to the respective privacy policies and opt-out forms.
- Be linked to a cookie banner that allows users to express and manage their consents in a granular manner.
10. CHANGES TO THIS PRIVACY POLICY
The Owner reserves the right to make changes to this policy. Users are requested to consult this page regularly.
