Privacy Policy

Italian Shoe Manufacturers Limited (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. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information. 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.

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 Services (e.g. run consultancy sessions, design collections, manufacture the Goods etc.) will be taken under ISM’s custody and not shared with third Parties except ISM’s partners that may be required for deliver 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 Site 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. ISM does not capture Personally Identifiable Information in cookies or use cookies to mine Personally Identifiable Information. You can remove persistent cookies by following directions provided in your Internet browser’s “help” directory. If you reject cookies, you may still use our site, but your ability to use some areas of our site, such order forms, will be limited. For the purpose of analysing the use of our website, we use Google Analytics cookies, which privacy policy is available at the following link: http://www.google.com/policies/privacy/

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 Clients wants to download the Free Mini Guide ‘5 Golden Steps’, the Client is required to provide a valid email address. When the Client wants to purchase a Service on the ISM Website, the Clients needs to register to the Website. 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 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.)

All our website financial transactions are handled through our payment services provider, PayPal. You can review the privacy policies of this provider at the following link:
https://www.paypal.com/uk/webapps/mpp/ua/privacy-full
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.

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 email from ISM, you may unsubscribe from ISM’s mailing list on any of the emails ISM sends you.

3. How ISM uses the information collected from you

ISM uses information collected from the Online Services 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 following the ‘Account Removal’ instructions or 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 site or have downloaded one of our educational products or free guides. ISM uses MailChimp (https://mailchimp.com/) as email marketing provider. 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, 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 XERO (https://www.xero.com/us/) accounting software, where Personally Identifiable Information is stored only for accountancy purpose.
  • 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.

ISM currently does not use the Website for any payment transactions therefore ISM will never request your financial / bank account details via the Website. You will be provided with ISM’s Bank Account or PayPal account to use for any payment and transaction.

5. 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.

6. 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.

7. 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 May, 2017