Privacy policy on the processing of personal data.

Effective as of 01/01/2024

INTRODUCTION to Privacy Policy of personal data

This information takes into account the provisions of the Regulation (EU) 2016/679 about Privacy Policy of Personal Data of the European Parliament and of the Council of 27 April 2016 (GDPR) and of the Privacy Code (Legislative Decree 30 June 2003 n. 196). The document has also been drafted in accordance with the Guidelines of the Privacy Guarantor (especially the Guidelines for combating spam issued by the Privacy Guarantor on July 4, 2013).

Data Controller: ARNIA – Società Cooperativa Sociale MADE IN ITALY / Via Gabrio Serbelloni, 1 – 20122 – MILANO – MI – ITALY / VAT ID# 12644350964 / REA MI-2674779 / info.arnia@madeinitaly.social / Capitale sociale euro 275 / Iscritta ALBO COOPERATIVE C139245 / NO PROFIT – Cooperativa sociale TIPO B(Site Owner or Owner of the Site). Site to which these terms of use apply: https://madeinitaly.social/

Site to which this privacy policy refers:https://madeinitaly.social/ (Sito).

The Data Controller has not appointed a DPO. Therefore, you may send any inquiries directly to the Data Controller.

GENERAL INFORMATION about Privacy Policy

This document describes how the Data Controller processes your personal data.

The following describes the main processing of your personal data. In particular, we explain the legal basis of the processing, whether the provision of personal data is compulsory and the consequences of not providing personal data. To better describe your rights, if necessary, we have specified if and when a certain processing of personal data is not carried out.

Site registration

The information and data requested in case of registration will be used to allow you both to access the private area of the Site and to use the online services offered by the Data Controller to registered users. The legal basis of the processing is the need for the Data Controller to execute pre-contractual measures taken at the request of the data subject. The conferment of data is optional. However, your refusal to provide the data will make it impossible to register on the Site.You can also register on the Site using external services. In this case, your registration data will be shared with the companies of these external services for the sole purpose of enabling registration on the Site. The legal basis for this processing is the legitimate interest of the Data Controller in enabling registration on the Site via external services. The provision of personal data for this purpose is purely optional. However, failure to consent to the processing of data will make it impossible to register through external services.

Purchases on the Site

Your personal data will be processed to allow you to make purchases on the Site. in the case of making an online purchase order, to allow the conclusion of the purchase contract and the proper execution of transactions related to the same (and, if necessary under the legislation, to fulfill tax obligations). This treatment of personal data also includes the possibility of sending communications (e.g. tracking and order information) via automated tools such as SMS and/or WhatsApp. The legal basis for the processing is the obligation of the Data Controller to execute the contract with the data subject or to comply with legal obligations. Apart from the above (and therefore your consent), the Data Controller may process your data for the purpose of so-called “soft-spam”, governed by art. 130 of the Privacy Code. This means that limited to the email you provided in the context of a purchase through the Site, the Data Controller will process the email to allow direct offers from similar products/services, unless you object to such processing in the manner provided by this policy. The legal basis for processing is the legitimate interest of the Data Controller to send this type of communication. This legitimate interest can be considered equivalent to the interest of the data subject in receiving “soft-spam” communications.The Data Controller does not process the user’s data to send “reminder” emails to purchase products and/or services from the Data Controller.

Answering your requests

Your data will be processed to respond to your requests for information. The conferment is optional, but your refusal will make it impossible for the Data Controller to answer your questions. The legal basis for the processing is the legitimate interest of the Data Controller in fulfilling your requests. This legitimate interest is equivalent to the user’s interest in receiving a response to communications sent to the Data Controller. If you fill in the appropriate form on the Website, the Data Controller may use your personal data to process your request for a quote and/or intervention. Providing your data is optional, but without it, the Data Controller will not be able to process your request. The legal basis for the processing is the Data Controller’s legitimate interest in responding to user requests, which corresponds to the user’s interest in receiving a reply. The Data Controller may also process personal data for the purpose of managing support requests (tickets). In this case too, the legal basis is the legitimate interest of the Data Controller in providing a response, in line with the user’s interest in receiving assistance.

Marketing

Subject to your consent, the Data Controller may process the personal data provided by you in order to send you advertising material and/or newsletters relating to its own products or those of third parties. The legal basis of this treatment is your consent. The provision of personal data for this purpose is purely optional. Failure to consent to the processing of data for marketing purposes will make it impossible for you to receive advertising material relating to products/services of the Data Controller and/or third parties, as well as making it impossible for the Data Controller to carry out market surveys, also aimed at assessing the degree of user satisfaction, and to send you newsletters. These communications will be sent to your e-mail. We use Google services, such as Google Ads and Google Analytics, to personalize advertisements and enhance user experience. This includes the collection of personal data and cookies, used to show you ads that match your preferences. Upon consent, you will be asked to authorize the use of this data. More details on cookie usage and consent management can be found in this website’s cookie policy.

Profiling

Subject to your consent, the Data Controller may process your personal data for profiling purposes, i.e. for the analysis of your consumption choices by revealing the type and frequency of purchases made by you, in order to send you advertising material and/or newsletters relating to its own products or third parties, of your specific interest. The legal basis of this treatment is your consent. The provision of data for this purpose is purely optional. Failure to consent to the processing of your personal data for profiling purposes will make it impossible for the Data Controller to elaborate your commercial profile, through the detection of your choices and buying habits and to send you advertising material about products of the Data Controller and/or third parties, of your specific interest. These communications will be sent to your e-mail.

Data transfer

The Data Controller does not transfer your personal data to third parties.

Geolocalization

In case of access to the Site you may receive a notification on your device (fixed and/or mobile) that will give you the possibility to allow or deny the identification of the device itself (so-called geo-localization). You may freely allow or deny this setting, without this resulting in substantial changes to the functionality of the Site. You can change your geolocation settings at any time through the settings of your device. The legal basis for the processing is the legitimate interest of the Data Controller to provide services relevant to your location. This legitimate interest is equal to the user’s interest in receiving services as relevant as possible to their location.

Curriculum Vitae

It is not possible to send CVs via the Website. Your data will therefore not be processed for these purposes.

Booking Service

There are no third-party appointment booking systems active on the Site. Therefore, your data will not be processed for this purpose. In any case, you can always contact the Data Controller at the contacts indicated in the heading.

Photographs and videos

The Data Controller does not request the publication of photographs and/or videos of you. Therefore, your data will not be processed for these purposes.

Web scraping

The Data Controller allows the use of web scraping techniques, provided that such activities are carried out in compliance with the following terms and conditions: (i) Legal and Ethical Access. Web scraping must be carried out in a legal and ethical manner. Users must comply with all applicable laws and regulations when performing scraping activities; (ii) Responsible Use. Users must ensure that scraping techniques do not compromise the functionality of our website, overload the Site’s servers or interfere with other users’ experience; (iii) Respect for Personal Data. Users must respect the privacy and protection of personal data on the Site. Any collection of personal data must be done in accordance with applicable data protection legislation; (iv) Attribution. It is required that any data or content collected from the Site through web scraping is properly attributed to the Site as the original source; (v) Limitations. The Data Controller reserves the right to impose limitations or restrictions on web scraping, including requiring prior written agreement in certain cases. Users must be prepared to stop scraping activities at the request of the Data Controller. By using the Site and carrying out web scraping activities, you agree to comply with the above terms and conditions. Failure to comply with these terms and conditions may result in the revocation of your permission to carry out web scraping and the adoption of appropriate measures to protect the rights and interests of the Data Controller.

Communication of personal data

As part of its ordinary business, the Data Controller may communicate your personal data to certain categories of subjects. In article 2 you can find the list of subjects to which the Data Controller communicates your personal data. In order to facilitate the protection of your rights, Article 2 may specify in certain cases when your data is not communicated to third parties.

The “communication” of personal data to third parties is different from the “transfer” (governed by the preceding point). In fact, in the communication the third party to whom the data is transmitted can use it only for the specific purposes described in the relationship with the Data Controller. In the transfer, instead, the third party becomes the autonomous Data Controller. Moreover, to transfer your personal data to third parties is always required your consent.

Without prejudice to the foregoing, it is understood that the Data Controller may still use your personal data in order to correctly fulfill the obligations provided for by the laws in force.

PRIVACY POLICY

Art. 1 Method of processing

1.1 The processing of your personal data will be mainly carried out with the help of electronic or automated means, according to the methods and with the tools suitable to ensure their security and confidentiality.

1.2 The information acquired and the methods of treatment will be relevant and not excessive in relation to the type of services rendered. Your data will also be managed and protected in secure computer environments appropriate to the circumstances.

1.3 Through the Site are not processed “special data”. Particular data are those that can reveal racial and ethnic origin, religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade union, health and sex life.

1.4 No judicial data is processed through the Site.

Art. 2 Communication of personal data

The Data Controller may communicate your personal data to certain categories of subjects. The Data Controller wishes to inform users that, in the context of using the YouTube service (managed and owned by Google LLC), some personal data may be collected and shared. This data collection is essential to provide and enhance the user experience on our Site and to enable viewing of video content integrated through the YouTube API. In detail, when a user views a video content through the YouTube API on our Site, the following information may be collected: IP Address: Used to connect the user’s device to YouTube for video transmission. Behavioral Data: Includes information on how the user interacts with videos, such as which videos are viewed and for how long. Location Information: Used to provide relevant content based on the user’s geographical location. These data are automatically collected by the system and, in some cases, may be stored to improve user experience and for internal analytical purposes at YouTube. It is specified that our Site uses YouTube’s API services and, by viewing content through these APIs, the user accepts YouTube’s Terms of Service available at https://www.youtube.com/t/terms. For further details on data management by Google LLC, users are invited to consult Google LLC’s privacy policy at http://www.google.com/policies/privacy and YouTube’s at https://www.youtube.com/intl/ALL_it/howyoutubeworks/our-commitments/protecting-user-data/. Details on the use of User API Data User API Data: When a user interacts with YouTube videos embedded in our Site, data such as viewing preferences, video viewing history, and interactions with video content (likes, comments, shares) may be collected. These data are made available through the YouTube API and help to understand how users interact with video content. Access to data via the Client API: Our Site may use specific API calls to request and receive data from YouTube. This may occur when a user views a video, with the system automatically recording relevant information. Data Collection: Data are automatically collected by the YouTube system when users interact with YouTube videos on our Site. This process is essential to provide a smooth and personalized user experience. Data Storage: The collected data are securely stored in YouTube’s systems for a period that does not exceed the necessity of use. YouTube adopts all necessary security measures to protect these data from unauthorized access or illicit uses. Use of Data: YouTube uses these data for various purposes, including: Internal Analysis: To better understand user interactions with video content and improve the quality of YouTube services. Content Personalization: To offer users a more personalized experience, based on their preferences and interaction history. User Experience Improvement: To identify and resolve any technical issues and optimize the usability of video content. The subjects to whom the Data Controller reserves the right to communicate your data are indicated below:

• The Data Controller may communicate your personal data to all those subjects (including Public Authorities) who have access to personal data by virtue of regulatory or administrative measures.
• Your personal data may also be disclosed to all those public and / or private individuals and / or legal entities (legal, administrative and tax, judicial offices, Chambers of Commerce, Chambers and Offices of Labor, etc..), if the communication is necessary or functional to the proper fulfillment of obligations under the law.
• The Data Controller does not make use of employees and/or collaborators in any capacity. Therefore, your personal data will not be communicated to this category of subjects.
• The Data Controller does not use companies, consultants or professionals in charge of the installation, maintenance, updating and, in general, the management of the Data Controller’s hardware and software. Therefore, your data will not be communicated to these categories of subjects.
• The Data Controller does not use CRM platforms (companies that carry out the activity of sending automated communications to users. Therefore, your personal data are not communicated to these companies.
• The Data Controller does not use external companies to provide customer care services. Therefore, your personal data will not be processed for this purpose.
• The Data Controller utilizes banking institutions and companies that manage national and international payment networks for online payments of products and services purchased through the Website.
• The purchaser’s personal data may be communicated to post offices, couriers or forwarding agents responsible for the delivery of the Products purchased through the Site.

The Data Controller reserves the right to modify the above list in accordance with its ordinary operations. Therefore, you are invited to regularly access this information to check to which subjects the Data Controller communicates your personal data.

Art. 3 Personal data retention

3.1 This article describes how long the Data Controller reserves the right to retain your personal data.

• For marketing purposes, personal data will be kept until consent is revoked. For inactive users, personal data will be deleted after one year from the sending of the last email eventually viewed.
• For the purpose of executing the sales contract, the data will be kept for 10 years from the date of receipt of the purchase order. This is to allow the Data Controller to exercise its right of defence and to prove the Seller has performed its duties.
• As provided for in Article 2220 of the Civil Code, invoices, as well as all accounting records in general, are kept for a minimum period of ten years from the date of registration, so that they can be presented in the event of an audit.
• The personal data provided through the quote request form will be retained for the time strictly necessary to respond to the request and, in any case, for no longer than 6 months from receipt. After this period, the data will be deleted or anonymised, unless legal obligations require a longer retention period.

3.2 Without prejudice to the provisions of Article 3.1, the Data Controller may retain your personal data for the time required by specific regulations, as amended from time to time.

Art. 4 Transfer of personal data

4.1 The Data Controller is located in a country that has an adequate level of security from a regulatory standpoint. If the transfer of your personal data takes place to a non-EU country and for which the European Commission has expressed a judgment of adequacy, the transfer is deemed safe from a regulatory standpoint in any case. This article 4.1 indicates from time to time the countries where your personal data may possibly be transferred and where the European Commission has expressed a judgment of adequacy.

• You are therefore invited to access this article regularly to check whether the transfer of your personal data takes place in a country with these characteristics.

4.2 Without prejudice to what is stated in article 4.1, your data may also be transferred to countries outside the EU for which the European Commission has not issued an adequacy opinion. You are therefore invited to regularly review this article 4.2 to find out to which of these countries your data may be transferred.

4.3 In this article, the Data Controller indicates the countries in which it may specifically direct its activities. This circumstance may imply the application of the legislation of the reference country, together with that which governs the relationship with the user as indicated in the Preamble.

• The Site processes personal data of individuals located in Australia. This notice has been prepared taking into account the provisions of Australian national and federal legislation. In particular, reference is made to the Federal Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs).
• The Site also handles personal data of Brazilian users. Brazilian users are informed that this privacy policy complies with the provisions of the Brazilian Law on Personal Data Protection (LGPD), which came into force on September 18, 2020. Therefore, all the above-mentioned regulations apply.
• The Site also handles personal data of Canadian users. Therefore, Canadian users are advised that this privacy policy also complies with the Personal Information Protection and Electronic Documents Act.
• The California Consumer Privacy Act (CCPA) is a California law that was passed in June 2018. The Data Controller processes personal data of California users under this law. The user is informed that the personal data processed are those communicated on the Site to allow the execution of the contract. The user may exercise their rights under the CCPA by contacting the Data Controller at the contact details published in the foreword.
• The Virginia Consumer Data Protection Act (CDPA) is a law in Virginia that was passed in March 2021. The Data Controller processes the personal data of Virginia users in accordance with this law. Users are informed that the personal data processed are those communicated on the Site to allow the execution of the contract. The user can exercise the rights provided by the CDPA by contacting the Data Controller at the contact details published above.
• The Nevada Privacy Law (Senate Bill 220) is a piece of legislation in Nevada, enacted in 2019, aimed at protecting the privacy of user data. The Data Controller manages the personal data of users in Nevada in line with this legislation. Users are notified that the personal data being handled are those provided through the Site to facilitate the contract’s fulfillment. Users can avail themselves of the rights guaranteed by the Nevada Privacy Law by reaching out to the Data Controller using the contact information provided earlier.
• The New Zealand Privacy Act of 2020, which underwent significant amendments in December 2020, governs the protection of users’ personal data. In accordance with this legislation, the Data Controller diligently handles the personal data of New Zealand users that are collected through the Site to ensure the proper execution of the contract. Users are hereby informed that they can exercise the rights set forth by the New Zealand Privacy Act by contacting the Data Controller at the contact details initially provided.
• The Personal Information Protection Law (PIPL) is a Chinese regulation that came into effect on November 1, 2021, and governs the protection of users’ personal data. In compliance with this law, the Data Controller is committed to the responsible and secure management of the personal data of Chinese users that are collected through the Site, in order to ensure the appropriate fulfillment of the contract. Users are informed that they can exercise the rights granted by the Personal Information Protection Law by contacting the Data Controller using the contact details provided earlier.
• The Personal Data Protection Act (PDPA) is a Singaporean regulation that governs the protection of users’ personal data. In compliance with the PDPA, the Data Controller commits to responsibly managing the personal data of Singaporean users collected through the Site, to ensure proper fulfillment of the contract. Users are informed that they can exercise the rights stipulated by the PDPA by contacting the Data Controller using the contact details provided earlier.
• In Malaysia, the protection of users’ personal data is safeguarded by the Personal Data Protection Act of 2010 (PDPA). The Data Controller adheres strictly to the principles and provisions of this law for the management of personal data collected on the Site from Malaysian citizens, in order to satisfactorily conclude the contract. Users are encouraged to note that they have the right to exercise the rights outlined by the PDPA by contacting the Data Controller through the contacts mentioned earlier.
• For users in the Philippines, please be informed that the Data Controller is committed to complying with the Data Privacy Act of 2012 (DPA) in handling personal data collected through the Site. This law aims to protect individuals’ rights and privacy. Users can exercise their rights under the DPA by contacting the Data Controller using the contact details provided.
• We wish to inform South African users that personal data collected through the Site are managed in compliance with South Africa’s Protection of Personal Information Act of 2013 (POPIA). The Data Controller commits to adhering to the provisions of this law. South African users can assert the rights granted by POPIA by reaching out to the Data Controller through the communication channels provided.
• Thai users are advised that the Data Controller closely follows Thailand’s Personal Data Protection Act of 2019 (PDPA) in handling personal data collected on the Site. This is critical for ensuring users’ data privacy and security. To exercise the rights sanctioned by the PDPA, Thai users can contact the Data Controller using the contact details provided.
• Please be informed that for users residing in the State of Connecticut, the Data Controller closely adheres to the Connecticut Consumer Data Privacy Act (CTDPA), which took effect on July 1, 2023, in processing personal data collected through the Site. This law was established to safeguard consumer data privacy. Users residing in Connecticut can exercise the rights guaranteed by the CTDPA by contacting the Data Controller using the contact details provided.

Art. 5. Your rights

The Data Controller informs you that you have the right:

• to request from the Data Controller access to your personal data and the rectification or erasure of the same or the restriction of the processing thereof or to object to the processing thereof, in addition to the right to data portability
• revoke consent at any time without affecting the lawfulness of the processing based on the consent given before revocation
• to lodge a complaint with a supervisory authority (e.g. the Italian Data Protection Authority).

The rights referred to above may be exercised by making a request without formalities to the contacts indicated in the Introduction.

Art. 6. Amendments

The Data Controller reserves the right to make changes to this policy at any time, giving appropriate publicity to users of the Site and ensuring in any case an adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this policy. In case of substantial changes to this privacy policy, the Data Controller may give notice of such changes also by email.

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