Privacy Policy
Recitals:
A - The Italian Pass is a platform exclusively owned and operated by Made of Italy Pty Ltd. For this agreement, all references to 'Made of Italy' include and encompass The Italian Pass, its associated logos, brand elements, and copyrights. Any use, reproduction, or distribution of these elements without prior written consent from Made of Italy Pty Ltd is strictly prohibited and may result in legal action.
B - The subsequent clauses and provisions within this contract explicitly pertain to The Italian Pass, herein referred to as 'Made of Italy.' All rights, obligations, and terms outlined herein are applicable to the operations, services, and assets associated with The Italian Pass, under the ownership of Made of Italy Pty Ltd.
This Privacy Policy applies to the processing of personal data concerning the users ("Users" also “Subscribers”) of services provided by Made Of Italy ("Service(s)"). This policy explains what personal data we collect and how we use it. The Users can be Made Of Italy's customers ("Partner"), who operate their own businesses, representatives of Customer or Partner's customers ("End-Users"). The business operated by the Partner is subject to its own privacy policy. Made Of Italy does not take any responsibility of its Partners' or other third parties' privacy policies or processing of personal data in its Partners' or third parties' operations.
Data controller
The data controller in accordance with the applicable data protection law is Made Of Italy Oy ("Made Of Italy", "we", "us", "our"). Made Of Italy is responsible for ensuring that the processing of personal data complies with this Privacy Policy and the applicable data protection laws.
Contact details of the data controller:
- Made Of Italy Pty Ltd
- ABN (Australia): 63 669 319 724
- Address: 5/225 Oxford St, Leederville WA 6007 AUSTRALIA
- Internet: www.madeofitaly.com.au
- Email: info@madeofitaly.com.au
Collection of Personal Data
We collect Users' personal data through different means, which are explained below:
Most of the personal data we process is collected directly from the Users. Made Of Italy may collect following personal data in the process of providing the Service:
Basic information such as name, age, postal address, email address and phone number Details about User’s employer (name, address, phone number, ID, ABN and VAT ID) should such information be considered to be personal data Authentication information such as Made Of Italy username and password, and if any third party service (e.g. Facebook) is used to sign in, the user ID of that service Information relating to the customer relationship such as bought services, their start and end times and information on their use.
Billing information
Following data is processed by Made Of Italy's payments processor (currently Joinit and Stripe, subject to change):
Payment data, such as credit card number and expiration date Made Of Italy automatically collects and processes the following technical data about the User:
IP address Geographical location data based on the IP address Service access times Statistics on page views Any other automatically collected technical data
Furthermore, Made Of Italy may also collect other anonymized statistics about the way the User uses the Services provided by Made Of Italy.
Legal basis and purpose of processing personal data
Made Of Italy processes personal data for three main purposes:
Service
The primary purpose of collecting personal data is to provide the website Made Of Italy and Services, to issue accurate charges for the use of the Services and to manage the customer relationship. The processing of personal data in this case is based on the agreement between the Customer and Made Of Italy. This concerns, for example, the data collected during the signing up for the Service, during the use of the Service and the technical data needed to run the Service in a secure manner and communications with Users.
Marketing and other communications
Made Of Italy may occasionally send its Customers (and End-Users when the relevant personal data has been collected by Made Of Italy itself) email to inform about new features, solicit feedback, or provide information on what is going on with Made Of Italy and its products. We base this on our legitimate interest to provide Users with relevant information as part of the Services and to promote our Services.
Service development and research
We always work to make our Services better. Therefore, we may use the User's data to improve the Services. We base this processing on our legitimate interest to grow and develop. Made Of Italy may also collect technical data for statistical purposes to compile anonymous, aggregated statistics, such as about the most popular Partners. Made Of Italy may display information publicly to others in an aggregate format that does not reveal statistics of any single Partner. Made Of Italy does not disclose personal data other than as described below.
Disclosures of Personal Data
We may disclose personal data to third parties in the following cases:
Made Of Italy may use subcontractors when providing its Services. Our trusted subcontractors work on our behalf, and do not have an independent right to use the personal data we disclose to them. Made Of Italy discloses personal data to its subcontractors on a need to know basis when necessary to process such data on Made Of Italy’s behalf in order to provide Services. Subcontractors are subject to appropriate security and confidentiality requirements. When required by law such as to comply with requests by competent authorities or in response to a subpoena, court order or other governmental request; When we believe in good faith that disclosure is necessary to protect our rights, investigate fraud or to protect our Users’ safety or rights. If Made Of Italy, or substantially all of its assets, are acquired, or in the unlikely event that Made Of Italy goes out of business or enters bankruptcy, User information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Made Of Italy may continue to use your personal data as set forth in this Privacy Policy.
Transfer of personal data outside of Australia
When necessary and to the extent required for the successful provision of the Services, personal data may be transferred to third parties outside of Australia. Made Of Italy or its subcontractors shall not transfer personal data outside of Australia without adequate safeguards required by applicable data protection law, such as standard contractual clauses.
Cookies and similar technologies
Cookies are pieces of data which are received and transmitted by a User's device when the User is using Made Of Italy's Services or website. Made Of Italy may use cookies and similar techniques to provide functionality of the Services, to enhance the user experience and to identify Users and how they use the Services. We use cookies, for example, to login and logout authentication, to remember session allowing Users to continue the session in case of time-out and to prevent unauthorized use of the Services.
We also use other forms of technology, such as web beacons and pixel tags, which serve a similar purpose to cookies and which allow us to monitor and improve our Services and the website.
We have divided cookies into two groups: (1) necessary cookies and (2) optional cookies. Necessary cookies cannot be disabled as the website cannot function properly without these cookies. Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website.
Other type of cookies, such as statistical and marketing cookies, are not strictly necessary to provide the Services and the website, therefore, they are called “optional cookies”. For optional cookies, we will inform our Users on the use of optional cookies on a cookie banner and ask for a User’s consent. Users can also change their cookie settings at any time by clicking “Edit cookie consent” link in the footer of our website. This allows Users to accept or reject optional cookies. Users can also manage the use of cookies from their browser settings. Users can delete all cookies that are already on their device by clearing the browsing history of the browser and/or block all or some of cookies that are set on Users’ device in the future through browser settings.
Each cookie lasts for a different period of time. Made Of Italy uses both session cookies and persistent cookies. Session cookies will last only while User’s browser is open. When the User closes the browser, session cookies will be deleted automatically. Persistent cookies will survive even after closing the browser. Persistent cookies will for example recognize the Users’ devices when they browse the Internet by opening the browser again. Persistent cookies are placed on the hard drive of their device and stored until they expire, or until the User deletes the cookies. Users are informed of these cookie expiration times through our cookie banner and can also later find these by clicking “Edit cookie consent” link in the footer of our website.
Made Of Italy uses variety of cookies for different purposes. The cookies can be set by us (so called “first-party cookies”) or by a third party (so called “third-party cookies”). We may use third-party cookies for statistical purposes to compile anonymous, aggregated statistics, such as to estimate number of Users and detect which parts of the Service Users find most useful, and identify features that could be improved. For such purposes, we use third-party cookies, such as Google Analytics, to help analyze how our Users use the Service. The technical usage information (including IP address) generated by the cookie about use of the Service is transmitted to such third parties to compile statistical reports.
Made Of Italy may also use third-party cookies for marketing purposes to collect information about Users' browsing habits and to remember visits in order to make advertising more relevant to that User and to their interests. These cookies are usually placed by third party advertising networks and social media providers, such as Doubleclick, Google Adwords and Twitter. A list of used third parties is available here.
The User can at any time edit or withdraw their consent to optional-unnecessary cookies from the cookie declaration on Made Of Italy’s website.
Retention of personal data
The User's personal data will be retained only for as long as necessary to fulfill the purposes defined in this Privacy Policy. When the User's personal data is no longer required by law or rights or obligations by us or the User, we will delete the personal data. In most cases, personal data will be deleted upon termination or expiry of the agreement between the Subscriber/Partner and Made Of Italy or upon the Customer’s written request. Please note that Made Of Italy may have a right to retain some data even after the termination of the agreement for billing purposes.
Exceptionally, Made Of Italy may retain personal data for a longer period if we have a legitimate reason or an obligation to store data for the purposes of criminal investigation or other corresponding reason.
Users' rights
A User has the right to access the data on him/her and upon request, obtain a copy of the data. Such request shall include information that is necessary for retrieving the data and shall be made using a personally signed document which can be addressed to the contact person provided in this Privacy Policy. Made Of Italy rectifies, erases or supplements possibly erroneous, unnecessary, incomplete or obsolete personal data at its own initiative or at the request of the User concerned. The User is advised to contact Made Of Italy’s contact person provided in this Privacy Policy to correct any possibly erroneous data.
Users have the right to prohibit Made Of Italy to process personal data for purposes of direct marketing. Made Of Italy advises the Users to notify Made Of Italy’s contact person provided in this Privacy Policy of such possible prohibitions in writing. Users also have a right to data portability to the extent granted by applicable data protection rules. Data portability refers to a right to receive their own personal data in a structured, commonly used machine-readable format and transmit your personal data to another data controller.
If a User thinks there is a problem with the way Made Of Italy is processing personal data, the User has a right to file a complaint to a data protection authority in Australia. In Australia the competent authority is the Australian Information Commissioner (OAIC).
The contact information for the OAIC is as follows: Address: Level 3, 175 Pitt Street, Sydney, NSW 2000 Phone: 1300 363 992 Email: enquiries@oaic.gov.au Website: https://www.oaic.gov.au/
Privacy Policy Changes
Made Of Italy may change this Privacy Policy from time to time. Made Of Italy recommends that the Users regularly access the Privacy Policy to obtain knowledge of any possible changes to it. We will provide the date of the Privacy Policy to allow Users to see changes. Made Of Italy will inform Users of possible changes by using reasonable and available channels.