Scope of these policies

This information on the processing of personal data applies if using the content published on the madeinitaly.gov.it domain allows ICE to acquire information that enables (also indirectly) the identification of a natural person.

Processing carried out by third parties (access operators, hosting providers, social networking platform operators, statistical services) is governed by their respective data protection policies, which users should consult before continuing the access:

1. Cloudflare (https://www.cloudflare.com/trust-hub/privacy-and-data-protection/)
2. Hetzner (https://www.hetzner.com/legal/privacy-policy)
3. Spotify (https://www.spotify.com/us/legal/privacy-policy/)
4. Facebook (https://www.facebook.com/privacy/explanation)
5. Instagram (https://help.instagram.com/1896641480634370?ref=ig)
6. Twitter (https://twitter.com/privacy?lang=it)
7. Google/Youtube (https://www.google.it/intl/it_it/policies/technologies/cookies/)
8. Linkedin (https://www.linkedin.com/legal/privacy-policy)

Identification of the data controller

The data controller is ICE – Agency for the promotion abroad and the internationalisation of Italian enterprises. The address of its registered office is Via Liszt, 21 – 00144 Rome (IT), Tel. 06 59921.

Contact details of the Data Protection Officer

The Data Protection Officer contact details are:

1. ordinary mail: ICE – Agenzia per la promozione all’estero e l’internazionalizzazione delle imprese italiane, via Liszt, 21 – 00144 Roma;
2. e-mail to: [email protected]

Categories of data, purpose and legal basis for processing

1. Anonymous access

This website can be accessed anonymously and therefore does not process personal data.

2. Purpose and legal basis of processing
3. Direct processing of anonymous data generated by access to the site

ICE processes traffic data automatically generated by the systems (IP, user agent, date and time of connection, pages consulted) and those generated by the site usage statistics software. It does so solely to check the regular operation of the service, carry out maintenance work (including evolutionary maintenance), protect the data controller’s rights, and comply with legal obligations.

4. Processing by third party providers of anonymous data generated by accessing  the site

As previously stated, ICE uses analytics services provided by third parties. The purpose of these services is to fulfil regulatory obligations (for example, international regulations on data localisation), to verify the correct fulfilment by suppliers of their respective duties (reporting on the effectiveness of communication campaigns, improving the quality of content, management control and cost adequacy), and to protect the rights of the Data Controller. These services work through cookies and trackers inserted in the pages that convey the contents of the madeinitaly.gov.it site. The same anonymous data referred to in point a) above may therefore be made available to providers of analytics services who return aggregate analyses to ICE. ICE cannot identify users who connect to madeinitaly.gov.it. Still, it might be possible that the analytics service provider has other information available that allows him and only him to identify the user personally. ICE does not have access to this further data. In the cases set forth by the law, it is up to the third-party provider to inform the data-subejct directly and obtain consent to the processing where necessary. It is also the sole responsibility of the user to read ICE’s policy on the processing of personal data and then decide whether to continue to use the site.

5. Processing of personal data relating to e-mails
6. Newsletter subscription: whoever accesses the madeinitaly.gov.it website has the opportunity to enter an e-mail address to be informed about updates and initiatives associated with ICE projects. If the address entered by users makes them identifiable (e.g., because of a particular domain and/or user name) and therefore constitutes personal data, ICE (also through data processors) will process the address only to send the requested information. ICE shall use the address until expressly revoked by the holder.
7. received communications: all communications sent to ICE via the institutional e-mail addresses are processed to respond to questions raised, to protect ICE’s rights, and to comply with legal and regulatory obligations (e.g., providing evidence of response times in case of requests for access by data subjects).
8. Data processing deriving from access to official pages and profiles on social networks: ICE has its official pages and profiles on various social networks, each of which has its policy on processing its users’ data. When a user connects to an official ICE page or profile, the social network that hosts them may also independently collect and analyse personal data. ICE does not have access to this data and, where available, only receives aggregate data that does not personally identify the user or create an individualised profile.
9. Processing of personal data posted by users accessing official pages and profiles on social networks: Although ICE does not encourage this option, users might post content on ICE’s official pages and profiles that might involve their own personal data or that of third parties. If this were to happen, ICE would not perform any processing on these data, but for collecting, storing and deleting contents to protect its rights.

10. Categories of personal data subject to processing

If it is necessary to identify or make identifiable the user who accesses the site (for example, because of a registration process), ICE shall collect only the data strictly necessary to interact with the user. These data may include name, surname and e-mail address. Should more personal data be required, ICE will ask for consent before their collection. Only an e-mail address (which need not necessarily be a nominative one) is required to send the person concerned updates on the new contents of the site as highlighted in point 2.c.i above.

11. Purposes and legal basis of the processing

The data referred to in point 3, associated with network traffic data, where available, are processed for the same purposes and on the same legal basis as those referred to in point 2 of this article.

Processing methods

ICE processes personal and non-personal data collected through this site electronically. It uses systems for logging connections (as regards the use of the site), for analysis, including automated analysis (to identify and solve technical problems, to generate statistical analysis), and automated systems for sending communications and messages (for the management of e-mails and newsletters).

Use of cookies and trackers

This site

1. uses only technical cookies necessary for the operation of the site
2. does not use tracking or cross-tracking systems
3. uses cookies required by the Facebook to compile aggregate analyses of site usage.

Security measures

1. Hosting

The hosting service through which ICE publishes the content associated with the domain offers business continuity, backup and network perimeter’s protection.

2. Servers

The operating system, its servers and applications (e.g. databases, script preprocessors) are updated to the latest available versions. Access credentials for administration and traffic data are assigned exclusively to identified persons for the sole purpose of carrying out technical activities.

3. Publishing platform

The platform that runs the site and its plugins are updated as new versions are released; access credentials to the publishing platform are managed following the rules for creating secure passwords,

4. Access management

Staff members accessing the servers and the publication platform receive precise instructions on the content of their tasks and their duties in relationship to personal data processing; access of staff members with administrative privileges is given individually and is monitored.

Localisation of processing

The publication platform’s data centre is located in the European Union.

The processing necessary for the analytics systems follows the localisation policies of Google, Facebook and the suppliers that ICE will use from time to time.

Some countries require storing their citizens’ data processed outside their borders under their jurisdiction. Notwithstanding ICE’s processing is governed by EU law, particularly EU Reg. 679/19 and Dir. 2002/58, ICE might store personal data of foreign nationals in network resources located in their home countries.

Use of Data Processor ex art. 28 GDPR

Where necessary, ICE drafted data processing agreements with concerned service providers.

The management of the server that hosts the publication platform is entrusted to SupportHost.

The management and transport of e-mails are carried out by Hetznet Online GmbH (https://www.hetzner.com/legal/privacy-policy).

The management of the publication platform, the collection of anonymous data on the use of the site contents, the management of e-mails collection and the sending of updates are entrusted to Pomilio Blumm S.r.l. which might use subcontractors for the material execution of some technical activities related to the mailing service.

Data Retention Duration

Any personal data processed will be retained for the most extended period provided for by law on the limitation of civil and criminal proceedings and subsequently deleted.

E-mail addresses communicated directly and spontaneously by the persons concerned are processed within the stated purposes’ limits until the data subject withdraws his consent.

Range of communication and dissemination

The data collected through this site and those sent voluntarily by the data subject are not communicated to third parties except for the technical requirements related to technical needs of the system or arising from national and international legal obligations.

Clicking buttons that allow reaching the official ICE profiles on social networking platforms, and cookies for statistical purposes may imply, on the part of the concerned platforms, the acquisition of data, including traffic data. These platforms may cross-reference these data with other known information, allowing the user to be identified or made identifiable. Before using the buttons or consenting to cookies usage, users should read the information on the processing of personal data of the platform to which he intends to connect.

ICE neither disseminates nor make otherwise available personal data.

Consent to processing 

The following processings do not require data subject’s consent:

1. processing of anonymous data,
2. any processing of personal data for the purposes and legal bases stated in this notice.

The following processings require the express consent

1. the use of the e-mail address (if personal data) for sending newsletters at the request of the person concerned,
2. the use of cookies and trackers (if personal data)
3. for ICE’s use of third-party analytics platforms,
4. to allow linking to the official madeinitaly.gov.it pages on social networking platforms.

Failure to give consent makes it possible to consult the site nonetheless.

Rights guaranteed by law and their enforcement

Data subjects have the right to obtain from ICE access to their personal data and the rectification or cancellation thereof or the limitation of processing concerning them or to object to processing (Art. 15 et seq. of the Regulation). The data subject can file its request to ICE in the following ways:

1. by post, by sending the application to the following address: ICE – Agenzia per la promozione all’estero e l’internazionalizzazione delle imprese italiane, with headquarters in Via Liszt, 21 – 00144 Rome, Tel. 06 59921,
2. by e-mail to: [email protected]

The application must contain an identity document of the data subject and, in the case of a delegation to another person, it must also include the delegated contact details, the identity document of the delegated and an indication as to whether ICE should send the reply to the delegator or the delegated.

Feedback will be provided to the interested party within 30 working days of receipt of the application, by the same means and to the same address as indicated by the interested party in the application.

It is the sole responsibility of the person concerned or his delegate to check that the address or e-mail address indicated are working and operational.

Administrative complaint and judicial protection

Interested parties who believe that the processing of personal data relating to them carried out through this website is in breach of the provisions of the Regulation have the right to lodge a complaint with the Italian Data Protection Authority, as provided for by art. 77 of the Regulation, or to take legal action (art. 79 of the Regulation).

Copyright and Intellectual Property

Ownership of the domain name

ICE is the assignee of the domain name madeinitaly.gov.it.

Copyrights

The contents published on this site are protected by Law 633/41 and are exclusive intellectual property of ICE. Any use is subjected to ICE’s prior authorisation.

Only direct links to pages on this site are permitted. By contrast, it is forbidden their incorporation into other sites.

The content publication platform used is WordPress.

Trademarks and distinctive signs

All trademarks, logos, textual denominations used on this site, unless they belong to third parties, are the property of ICE following Legislative Decree 30/2005 (Industrial Property Code).