Privacy & Cookies Policy
ISM Italy srl (ISM) is sensitive to your concerns about how we use the personal information we collect from you through ISM’s website (the “Website”) and other plug-ins exchanging information with ISM (“Applications”). The Website and Applications are sometimes collectively referred to as “Online Services” for simplicity. ISM takes your privacy seriously, and has implemented this privacy policy (the “Privacy Policy”) and internal policies and practices to keep your personal information secure. The Privacy Policy covers ISM’s treatment of the Personally Identifiable Information we collect when you use the Online Services. This Privacy notice describes how we collect and use personal information about you during and after your working relationship with us, in accordance with the General Data Protection Regulation (GDPR) (UE) 2016/679. This Privacy Policy is incorporated into our Terms and Condition of Service and therefore governs your use of the Online Services. By using ISM Online Services, you accept the terms of this Privacy Policy. If you have questions or concerns about the Privacy Policy, please contact ISM using the Contact Us page.
DEFINITIONS
- Data Subject: The legal or natural person to whom the Personal Data refers.
- Data Processor (or Data Supervisor): The natural person, legal person, public administration or any other body, association or organization authorized by the Data Controller to process the Personal Data in compliance with this privacy policy.
- Data Controller (or Owner): The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application (ISM).
This Privacy Policy only applies to ISM’s Website. If you leave ISM’s Website via a link or otherwise, you will be subject to the policy of that website provider. ISM has no control over that policy or the terms of that website and you should check their policy before continuing to access the site.
1. Your Intellectual Property Rights
Any information or technology shared by Clients (any person or company requesting any of the Services offered by ISM) and necessary to enable ISM to deliver the Consulting services (“Speak with an expert”) and digital contents (“Industry guides”) will be taken under ISM’s custody and not shared with third Parties except ISM’s partners that may be required for delivering the Services.
2. Information ISM collects from you
Traffic Data. ISM may collect a variety of visitor data such as IP addresses, browser settings, internet service provider (ISP) information, referring/exit pages, operating systems, date/time stamps, and clickstream data (collectively “Visitor Data”). ISM’s internal servers and software automatically recognize Visitor Data. No Personally Identifiable Information is collected in this process. The Website may use Visitor Data to compile traffic data about the types of visitors who use the Website at specific intervals (collectively “Traffic Data”). ISM may use Traffic Data to analyze the Website traffic, but this information is not examined for Personally Identifiable Information. ISM may also use Traffic Data to diagnose problems with ISM’s servers, administer ISM’s Website, or display content according to your preferences. Visitor Data and Traffic Data may also be shared with business partners, affiliates, or advertisers on an aggregated and anonymous basis.
Cookies. ISM may use the standard cookie feature of major browser applications and third-party providers, or employ internally developed cookies and tracking codes, that allow ISM to store a small piece of data on a visitor’s computer, or any other device a visitor uses to access Online Services, about his or her visit to the Website or use of Applications. For more information, consult our Cookies Policy (paragraph 2.1 below).
Personal Information. ISM may require Clients (any person or company requesting any of the Services offered by ISM) to provide ISM with personal information (collectively “Personally Identifiable Information”). When the Client wants to purchase a Service on the ISM Website such as Consulting services (“Speak with an expert”), the Clients may decide to register on the Website for future purchase. Personally Identifiable Information is captured only when the Clients accesses Online Services, or speaks on the phone with a ISM employee, and willingly discloses that information. This disclosure may occur when the Clients registers with an Online Service, engages in transactions, contacts customer service, or participates in contests, promotions, surveys, forums, content submissions, requests for suggestions, or other aspects of services offered by ISM.
Personally Identifiable Information includes:
- Contact Information (such as first name, last name, username, password to access your account, your name, address, city, state, zip code, phone number, and email address);
- Company name, Brand name
- Product Profile (style name, shoe category, materials, etc.)
ISM uses Elementor (plugin for WordPress) to create the website forms. Client data is stored in WordPress under the Elmentor Submission plugin.
Terms & Conditions plus Privacy policy of this provider can be reviewed at the following link:
All our website financial transactions are handled through WooCommerce (which is an open source e-commerce plugin for WordPress) and our payment services provider, PayPal. You can review the privacy policies of these providers at the following links:
We will share information with PayPal as appropriate to the transaction been carried out only to the extent necessary for the purposes of processing payments you make via our website and dealing with complaints and queries relating to such payments.
ISM uses the Fatture in Cloud (https://www.fattureincloud.it/) accounting software, where Personally Identifiable Information is stored only for accountancy purpose (https://www.fattureincloud.it/privacy/).
Calls/Electronic Communications. In the regular course of our business, ISM may monitor and record phone conversations or email communications between you and ISM employees for training and quality assurance purposes. ISM may receive a confirmation when you open or click on content in an email from ISM, which helps ISM make communications to you more useful and interesting. If you do not wish to receive emails from ISM, you may unsubscribe from ISM’s mailing list on any of the emails ISM sends you.
2.1 Cookies Policy
As is common practice with almost all professional Websites, this website uses cookies, which are tiny files that are downloaded to your computer, to improve your experience. This paragraph describes what information they gather, how we use it and why we sometimes need to store these cookies. We will also share how you can prevent these cookies from being stored however this may downgrade or ‘break’ certain elements of the Websites functionality.
For more general information on cookies see the Wikipedia article on HTTP Cookies.
How We Use Cookies
We use cookies for a variety of reasons detailed below. Unfortunately in most cases there are no industry standard options for disabling cookies without completely disabling the functionality and features they add to this Website.
Disabling Cookies
You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies will affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the Website.
The Cookies We Set
- Account related cookies:If you create an account with us then we will use cookies for the management of the signup process and general administration. These cookies will usually be deleted when you log out however in some cases they may remain afterwards to remember your Website preferences when logged out.
- Login related cookies:We use cookies when you are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in.
- Email newsletters related cookies:This Website offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users.
- Orders processing related cookies:This Website offers e-commerce or payment facilities and some cookies are essential to ensure that your order is remembered between pages so that we can process it properly.
- Surveys related cookies:From time to time we offer user surveys and questionnaires to provide you with interesting insights, helpful tools, or to understand our user base more accurately. These surveys may use cookies to remember who has already taken part in a survey or to provide you with accurate results after you change pages.
- Forms related cookies:When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence.
Third Party Cookies
In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this Website.
- This Website uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the Website and ways that we can improve your experience. These cookies may track things such as how long you spend on the Website and the pages that you visit so we can continue to produce engaging content.For more information on Google Analytics cookies, see the official Google Analytics page.
- From time to time we test new features and make changes to the way that the Website is delivered. When we are still testing new features these cookies may be used to ensure that you receive a consistent experience whilst on the Website whilst ensuring we understand which optimisations our users appreciate the most.
- We also use social media buttons and/or plugins on this Website that allow you to connect with your social network in various ways. For these to work the following social media Websites and Applications (including Instagram, Facebook, Twitter, Whatsapp, Pinterest, Linkedin, Gmail, Reddit) will set cookies through our Website which may be used to enhance your profile on their Website or contribute to the data they hold for various purposes outlined in their respective privacy policies.
Control of Cookies
Most browsers are set to accept cookies by default. However, you can remove or reject cookies in your browser’s settings. Please be aware that such action could affect the availability and functionality of the Website.
For more information on how to control cookies, check your browser or device’s settings for how you can control or reject cookies, or visit the following links:
3. How ISM uses the information collected from you
ISM uses information collected through ‘Contact Us’ page or if you register to the ISM Website to communicate with you, providing your with tailored consultancy and quotes, process your orders, and inform you of offers and discounts. For example, you may receive a welcome email that confirms your username and password, and later receive communications responding to your inquiries, providing services you request, and managing your account. ISM occasionally sends service-related announcements, for example, to alert you if ISM needs to temporarily suspend the Website for maintenance.
ISM does not share your Personally Identifiable Information for 3rd Party Marketing Purposes.
Account Removal. You may decide at any time to close your account with ISM by using the Contact Us page. ISM will remove all your personal data from the database.
Promotional Communication / Email marketing. ISM may send follow-up emails and newsletters from time to time to users who have registered on the Website or have downloaded one of our industry guide or free guides. ISM uses MailChimp to store information and as email marketing provider. MailChimp’s privacy policies can be found at the following link:
Generally, you may not opt-out of service-related or transactional communications, which are not promotional. If you do not wish to receive service-related communications, you can opt-out of promotional communications by following the unsubscribe instructions in any communication or by using the Contact Us page.
Surveys, Sweepstakes, and Contests. ISM may provide you the opportunity to participate in surveys on ISM’s Website, to measure customer satisfaction. If you participate, ISM may request certain personally identifiable information from you. Participation in these surveys, sweepstakes, or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. The requested information typically includes name, email address, and mailing address.
ISM shares customer information with third parties only as follows:
- Order Processing. ISM, sometimes with the assistance of a third party, may use your Personally Identifiable Information to process your payment through merchant account services, and to generate the products and services you order. Your Contact Information may be used to follow up with you on transactions you initiate through Online Services such as “Speak with an expert”, respond to inquiries made through Online Services, inform you of changes to Online Services, and send you additional information about ISM and its products and services.
- Accounting. ISM uses the Fatture in Cloud (https://www.fattureincloud.it/) accounting software, where Personally Identifiable Information is stored only for accounting purposes. (https://www.fattureincloud.it/privacy/).
- Required by Law. ISM may also disclose your personal information: as required by law, such as in response to a subpoena or similar legal process, and when ISM believes in good faith that disclosure is necessary to protect ISM’s rights, protect your safety or the safety of others, investigate fraud, or respond to a legal request.
- Visitor Demographics. Personal Information and Traffic Data are used to gather general statistics about our customers and visitors. ISM may use Demographic Data to generate collective information about our users, but not in a way that identifies any user specifically. For example, ISM may inform third parties about the number of registered users and unique visitors, and the pages most frequently browsed.
- Service Providers. ISM may share your Personally Identifiable Information with companies that provide support services to us (such as our Manufactures network), or help ISM market ISM’s products and services. These companies may need information about you in order to perform their functions. These companies are not authorized to use the information we share with them for any other purpose.
- Other Transfers. ISM may share Personally Identifiable Information and other data with businesses controlling, controlled by, or under common control with ISM. If ISM is merged, acquired, or sold, or if some or all of our assets or equity are transferred, we may disclose or transfer Personally Identifiable Information and other data in connection with the associated transactions.
- Bankruptcy. In the event of a ISM bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, ISM may not be able to control how your personal information is treated, transferred, or used. If such an event occurs, your Personally Identifiable Information may be treated like any other ISM’s asset and sold, transferred, or shared with third parties, or used in ways not contemplated or permitted under this Privacy Policy, without notice to you or your consent.
4. Where ISM stores your Personally Identifiable Information
ISM strives to make certain that ISM’s servers and connections incorporate the latest encryption and security devices. ISM has implemented physical, electronic, and managerial procedures to safeguard and secure the information ISM collects. All information you provide to ISM is stored on secure servers.
Where ISM has given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. ISM asks you not to share a password with anyone. As generic recommendation, the following are some suggestions for a strong password:
- Is at least eight characters long;
- Does not contain your user name, real name, or company name;
- Does not contain a complete word;
- Is significantly different from previous passwords;
- Includes special characters, e.g. @, #, $ etc.
Unfortunately, the transmission of information via the internet is not completely secure. Although ISM will do the best to protect your personal data, ISM cannot guarantee the security of your data transmitted to IMS’s Website; any transmission is at your own risk. Once ISM has received your information, ISM will use strict procedures and security features to try to prevent unauthorised access. The data that ISM collects from you may be transferred to, and stored at a destination over all the world. It may also be processed by staff operating in all the world, who work for ISM or for one of ISM’s suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. ISM will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
5. Retention Time
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that ISM (Data Controller) suspend or remove the data.
6. Change to this Privacy Policy
ISM may update this privacy policy to reflect changes to ISM’s Information practices. If ISM makes any material changes a notice will be posted on this page along with the updated Privacy Policy. ISM encourages you to periodically review this page for the latest information on ISM’s privacy practices.
7. Your Concern
ISM periodically reviews this Privacy Policy and ISM’s compliance with it to verify that both are accurate. ISM encourages you to contact us with any concerns, and ISM will investigate and attempt to resolve any complaints and disputes about ISM’s privacy practices.
IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED THROUGH USE OF ISM’S WEBSITE, APPLICATIONS, OR OTHER SERVICES PLEASE CONTACT ISM IMMEDIATELY BY USING THE CONTACT US PAGE.
If you have any concerns about material which appears on ISM’s Website or require any additional information or clarification, please use the Contact Us page.
8. Acknowledgement
By using ISM’s Services or accession the ISM Website, you acknowledge that you have read these Privacy Policy and agree to be bound by them.
Updated January, 2022