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Privacy Policy

Last updated: January 4th, 2026

1. Overview and Purpose of This Privacy Policy

This Privacy Policy describes in detail how Serafini Productions (“Serafini Productions”, “we”, “us”, or “our”) collects, uses, stores, protects, and otherwise processes personal data in connection with our application (“the App”) and any related services.

The purpose of this Privacy Policy is to provide transparent information regarding our data processing practices and to explain users’ rights in relation to their personal data, in accordance with applicable data protection laws, including but not limited to the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

2. Identity of the Data Controller

For the purposes of applicable data protection laws, including the GDPR, the data controller responsible for the processing of personal data is:

Serafini Productions
Email: info@serafiniproductions.com
Website: https://serafiniproductions.com
Website developer: Giorgia Bellato

Serafini Productions determines the purposes and means of processing personal data as described in this Privacy Policy.

3. Applicability and Scope

This Privacy Policy applies exclusively to personal data processed directly by Serafini Productions in connection with the App.

It does not apply to:

  • third-party websites

  • third-party platforms or stores

  • external services that may be linked to or accessible from the App

Such third parties operate independently and are governed by their own privacy policies. We encourage users to review the privacy policies of any third-party services before interacting with them.

4. Principles of Data Processing

We process personal data in accordance with the following principles:

  • Lawfulness, fairness, and transparency

  • Purpose limitation

  • Data minimization

  • Accuracy

  • Storage limitation

  • Integrity and confidentiality

We only process personal data to the extent strictly necessary for the purposes explicitly described in this Privacy Policy.

5. Categories of Personal Data

5.1 Personal Data We Do Not Collect

Serafini Productions does not collect, process, or store the following categories of data:

  • user accounts or login credentials

  • usernames or passwords

  • payment, billing, or financial information

  • IP addresses

  • precise or approximate location data

  • device identifiers or hardware information

  • analytics, telemetry, or usage statistics

  • advertising identifiers or tracking technologies

  • gameplay, behavioral, or interaction data

The App can be used fully without providing any personal data.

5.2 Personal Data Collected Voluntarily

The only personal data that may be collected is:

  • Email address, provided voluntarily by the user solely for the purpose of subscribing to a newsletter.

Providing an email address is optional and is not required in order to access or use the App.

6. Methods of Data Collection

Email addresses are collected only when a user:

  • explicitly enters their email address into a newsletter subscription field, and

  • actively confirms their intention to subscribe, where applicable

No personal data is collected automatically or passively through the App.

7. Purposes of Processing

The email address collected for newsletter subscription is processed exclusively for the following purposes:

  • sending newsletters

  • providing updates or announcements related to the App

  • sharing information about Serafini Productions’ activities directly related to the App

We do not use personal data for any unrelated purposes.

8. Legal Basis for Processing

For users located in the European Economic Area (EEA), personal data is processed on the following legal basis:

  • Consent pursuant to Article 6(1)(a) of the GDPR

Consent is freely given, specific, informed, and unambiguous.
Users may withdraw their consent at any time.

9. Consequences of Refusing or Withdrawing Consent

Refusing to provide an email address or withdrawing consent:

  • does not affect the ability to use the App

  • does not result in any limitation of core App functionality

The only consequence is that the user will no longer receive newsletter communications.

10. Data Sharing and Disclosure

Serafini Productions does not sell, rent, lease, or otherwise commercialize personal data.

Personal data may be shared only in the following limited circumstances:

  • with technical service providers strictly necessary for email delivery

  • where required by law, regulation, or valid legal request from competent authorities

In all cases, data sharing is limited to what is strictly necessary.

11. International Data Transfers

Serafini Productions does not intentionally transfer personal data outside the European Union.

Where an email service provider located outside the EU is used, we ensure that appropriate safeguards are implemented in accordance with applicable data protection laws, including:

  • adequacy decisions by the European Commission, or

  • standard contractual clauses approved by the European Commission

12. Data Retention Periods

Email addresses are retained only for as long as the user remains subscribed to the newsletter.

When a user:

  • unsubscribes from the newsletter, or

  • requests deletion of their email address

the email address is permanently deleted within a reasonable timeframe.

13. Data Subject Rights

Depending on applicable law, users may exercise the following rights:

  • right of access

  • right to rectification

  • right to erasure

  • right to restriction of processing

  • right to data portability

  • right to object to processing

  • right to withdraw consent at any time

Requests may be submitted by contacting info@serafiniproductions.com.

14. Verification of Requests

To protect personal data, we may request reasonable information to verify the identity of the individual submitting a data subject request.

15. Children’s Privacy

The App is not intended for children under the age of 13.

We do not knowingly collect personal data from children.
If we become aware that personal data has been collected from a child without appropriate consent, such data will be deleted promptly.

16. Data Security Measures

We implement appropriate technical and organizational measures designed to protect personal data against:

  • unauthorized access

  • accidental loss

  • alteration

  • disclosure or destruction

Access to personal data is restricted to authorized individuals only.

17. Confidentiality Obligations

Any individual who has access to personal data is subject to confidentiality obligations and processes such data only in accordance with this Privacy Policy.

18. Automated Decision-Making and Profiling

Serafini Productions does not engage in:

  • automated decision-making

  • profiling within the meaning of Article 22 GDPR

19. Regulatory Compliance

We process personal data in compliance with applicable data protection laws, including GDPR and other relevant national regulations.

20. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time to reflect legal, regulatory, or operational changes.

The most current version will always be available on our website and will indicate the date of last update.

21. Acceptance of This Privacy Policy

By continuing to use the App or by subscribing to the newsletter, users acknowledge that they have read and understood this Privacy Policy.

22. Contact Information

For any questions, concerns, or requests relating to this Privacy Policy or the processing of personal data, please contact:

info@serafiniproductions.com
Kuwano Building 2F 6-chome-23-4, Jingumae, Shibuya, Tokyo