Welcome to Italy Branding & Diffusion Limited’s privacy notice. This notice relates to the use of your personal data for the purposes of our marketing communications. Italy Branding & Diffusion Limited (“We”, “Us”) as a Data Controller, respects your privacy and is committed to protecting your personal data.
This privacy notice will:
- inform you of how we look after your personal data when you visit our website;
- inform you of how we look after your personal data when you use our services;
- inform you of how we look after your personal data when you sign up to receive newsletters, offers and updates and / or other marketing material from us;
- inform you about your privacy rights and how the law protects you.
Purpose of this privacy notice
This privacy notice aims to give you information on how Italy Branding & Diffusion Limited collects and processes your personal data for marketing communication purposes.
The Personal Data we collect about you
Personal data, or personal information, means any information relating to an individual through which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together in the following categories:
- Identity Data includes title, first name, last name
- Employment Data includes job or job description and employer details
- Contact Data includes postal address, email address and telephone numbers.
- Communication and Feedback Data includes the content of any emails you send us and any feedback and survey responses that you may provide us with regarding our services.
- Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) for marketing purposes. Nor do we collect any information about criminal convictions and offences for marketing purposes.
How we collect your Personal Data
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity Data, Contact Data, Employment Data and/or Feedback Data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:
- book our services;
- subscribe to our services;
- request marketing communications to be sent to you;
- enter a competition, promotion, or survey; or give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Identity Data, Contact Data, Employment Data from your Employer or Company when signing you up to one of our offered service
- Technical Data from analytics or cloud providers
How do we use your Personal Data?
Identity Data, Contact Data, Employment Data, Communication and Feedback Data.
For marketing and promotional purposes to keep you updated with relevant services we offer such as events and courses based also on your Employment Data and Feedback Data.
Legitimate Interest Assessment with an objection right of OPT-OUT.
Identity Data, Contact Data.
To offer our services to you or to the company that has registered you to make use of our services.
Performance of a Contract, Legitimate Interest Assessment to prove that you have made use of our services.
When we rely on a legal basis of Legitimate Interests we have carried out a Legitimate Interests Assessments to ensure that we have weighed your interests and any risks posed to you and to ensure that our processing is proportional and appropriate. You have the right to object to such processing.
You can ask us to stop sending you marketing and promotional messages at any time by following the opt-out links on any marketing message sent to you.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Consequences of not providing your Data
You are not obliged to provide your personal data to us however your Identity, Contact and Employment Data will be necessary for us to provide you with our services.
Disclosures of your personal data
We do not share or disclose any of your personal information without your consent, other than for the purposes specified in this notice or where there is a legal requirement. We may use third party providers to send out emails and exercise other business functions and to provide our services; however, all processors acting on our behalf only process your data in accordance with instructions from us and comply fully with this privacy notice, the data protection laws and any other appropriate confidentiality and security measures.
External Third Parties:
- Marketing Agencies;
- Email Processors;
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
International Data Transfers
Personal Data in the European Union is protected by the General Data Protection Regulation (GDPR) but some other countries may not necessarily have the same high standard of protection for your personal data. Sometimes we may have to share your data with third party processors which are based outside of the EU, however when we do so we will ensure that this is done under an adequacy decision or under standard contractual clauses approved by the EU Commission.
We will only retain your personal data for as long as necessary to fulfill its collection purposes including any legal, accounting requirements. We will hold on to your email data for as long as you do not opt-out of our marketing. We will hold on to your Identity, Contact and Employment Data for as long as our relationship subsists or to prove that we provided our services for a period of 5 years.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may have the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
If you wish to exercise any of the rights set out above, please get in touch.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Italy Branding & Diffusion Limited is the controller and responsible for your personal data. You have the right to make a complaint at any time to the Office of the Information and Data Protection Commissioner (IDPC), the Maltese supervisory authority for data protection issues (www.idpc.org.mt). We would, however, appreciate the chance to deal with your concerns before you approach the IDPC so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we hold about you is accurate and current. Please keep us informed if there are any changes to your contact details.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.