Privacy Policy
Italy Made Clear Last updated: [DATE]
1. Who is responsible for your data (Data Controller)
The data controller for Italy Made Clear is:
[LEGAL ENTITY / P.IVA / registered address — to confirm before go-live] Email: hello@christaudien.me (update to privacy@italymadeclear.com or dpo@italymadeclear.com before launch)
"Data controller" means the person or entity that determines why and how your personal data is processed. That is us.
If you have questions about how we handle your data, or wish to exercise any of your rights, contact us at the email above.
2. The short version
We collect the minimum data we need to run the Service. We do not sell your data. We do not share it with advertisers. Our processors (Supabase, Stripe, Vercel, Resend) receive only what they need to do their job. You can ask us to delete your data at any time.
3. What data we collect and why
3.1 Account data
When you create an account, we collect:
| Data | Why we collect it | Legal basis |
|---|---|---|
| Email address | To identify your account, send subscription and service communications | Performance of contract (Article 6(1)(b) GDPR) |
| Name (optional) | To personalise communications | Performance of contract |
| Password (hashed) | Account authentication | Performance of contract |
3.2 Subscription and billing data
| Data | Why we collect it | Legal basis |
|---|---|---|
| Subscription plan and status | To provide access to the correct features | Performance of contract |
| Subscription dates and renewal dates | To manage billing cycles and send renewal reminders | Performance of contract |
| Payment transaction ID (from Stripe) | To match refund requests to payments | Performance of contract; legitimate interests |
| Country of billing address | For applicable tax determination | Legal obligation |
We do not store your card number, CVV, or full payment details. These are processed and held by Stripe. See Section 6 for more on Stripe.
3.3 Preference data
When you use the Service, you may provide:
| Data | Why we collect it | Legal basis |
|---|---|---|
| Home country (e.g., US, UK) | To tailor content to your home-system frame of reference | Performance of contract; consent where preference is optional |
| Italian destination/region | To provide region-specific rate data (e.g., Comune IMU rates) | Performance of contract; consent where preference is optional |
| Journey stage (e.g., "planning to buy", "already resident") | To surface relevant tools and alerts | Performance of contract; consent where preference is optional |
This preference data is stored in our database (Supabase — see Section 6) and used solely to personalise your experience within the Service. It is not used for advertising.
3.4 Usage analytics
We use Vercel Web Analytics, a privacy-focused analytics tool, to understand how the Service is used. Vercel Web Analytics does not use cookies, does not fingerprint individual users, and does not track you across other sites. Data collected is aggregated and anonymous. See Section 6 for more on Vercel.
If we add any additional analytics tools in future, this policy will be updated and, where required, your consent will be sought.
3.5 Tool usage data
When you use the interactive tools (e.g., IMU calculator, TARI estimator), the inputs you provide are used to generate your result. These inputs may be stored temporarily to allow the tool to function during your session. We may retain anonymised, aggregated inputs to improve tool accuracy (e.g., to identify Comuni where our data is missing).
3.6 Communications
When you contact us by email, we retain that correspondence in order to handle your query and for our records. We process this on the basis of legitimate interests (managing our business and responding to users).
3.7 Saved scenarios (members)
As a member you can save up to three scenarios — named research bundles ("dossiers") collecting your work across the tools so you can print it, compare places, or share it with your household. A saved scenario stores:
| Data | Why we store it | Legal basis |
|---|---|---|
| The answers you gave in each tool (e.g., citizenship, income bands, property details, ownership share) | So your saved work can be reopened, resumed, and printed exactly as you left it | Performance of contract |
| The computed results (e.g., IMU estimates, regime verdicts) | So your dossier prints the numbers you saw, stamped with the rules version they were computed under | Performance of contract |
| Your notes and any advisor answers you chose to pin | They are part of the dossier you built | Performance of contract |
| Household details you chose to add (up to two adults: label, citizenships, income type) | To run the tools per person and per household | Performance of contract |
A scenario may therefore include financial details you chose to enter. You are always in control of what goes in.
How long we keep scenarios:
- While you are subscribed: kept until you delete them.
- When your subscription ends: kept for 30 days, then automatically and permanently deleted — scenarios, in-progress tool answers, and household details alike. Around day 23 we send you one reminder email. If you resubscribe within the 30 days, everything is intact.
- If you delete your account: deleted immediately, along with the rest of your account data.
Before you leave: deletion after the 30-day window cannot be undone. If you cancel and don't plan to return, print your dossiers or download your data (Section 8 — you can export everything, including scenarios, at any time from your account page, even during the 30-day window).
Your controls: view or print any scenario at any time, download everything as JSON, and delete any scenario individually whenever you like. We never share scenario content with third parties — the only way anyone else sees it is a share link you create (below). Scenario data is stored in our EU-region database (Section 6).
Share links (optional, member-initiated). You can create a read-only web link for a scenario's dossier to show it to someone — a partner, a geometra, a lawyer. If you use this feature:
- The link exposes the full dossier: your tool answers, the computed estimates, your notes, and any pinned advisor answers. It does not show your email address, name, or anything about your account.
- Recipients need no account. The link shows the dossier as it is now — if you update the scenario, the shared view updates too (it is not a frozen copy).
- Each scenario has one link at a time. Links expire automatically (you choose 7, 30, or 90 days — 90 is the maximum), you can revoke a link at any time, and regenerating a link immediately kills the old one.
- Access also ends automatically when the link expires, when you delete the scenario or your account, and while your subscription is inactive.
- We store only a cryptographic hash of the link's secret — we cannot recover or re-show a link; if you lose it, regenerate it.
- Links are unlisted and marked non-indexable for search engines, but anyone who obtains the URL can view the dossier until it expires or you revoke it. Treat a share link like a document you hand over, not like a password.
3.8 Data we do not collect
We do not collect:
- Sensitive personal data (health, political opinions, religion, etc.)
- Government identification numbers (passport, National Insurance, Social Security)
- Details about your specific Italian property beyond what you voluntarily input into tools
- Location data beyond what you tell us in your preferences
4. Legal bases for processing
We rely on the following legal bases under GDPR:
| Basis | When we use it |
|---|---|
| Performance of contract (Art. 6(1)(b)) | Processing necessary to provide the subscription service you have signed up for |
| Legitimate interests (Art. 6(1)(f)) | Internal analytics, fraud prevention, service improvement, handling correspondence |
| Legal obligation (Art. 6(1)(c)) | Tax and accounting records where required by Italian law |
| Consent (Art. 6(1)(a)) | Non-essential cookies and analytics where consent is required; optional preference fields |
Where we rely on consent, you have the right to withdraw it at any time without affecting the lawfulness of processing before withdrawal.
5. How long we keep your data
| Data type | Retention period |
|---|---|
| Account and subscription data | Duration of your subscription + 2 years after account closure (for dispute resolution and legal compliance) |
| Billing records | 10 years (Italian legal requirement for accounting records) |
| Preference data | Duration of your subscription; deleted on account closure or on request |
| Saved scenarios, in-progress tool answers, and household details | Duration of your subscription + 30 days after it ends (so you can resubscribe or export), then automatically and permanently deleted; deleted immediately if you delete your account (Section 3.7) |
| Email correspondence | 2 years from the date of correspondence |
| Aggregated, anonymised usage/tool data | Indefinite (no longer personal data once anonymised) |
When a retention period ends, we securely delete or anonymise the data.
6. Processors: who handles your data on our behalf
We use the following third-party processors. A processor handles data on our instructions — they do not have their own rights to use it.
Supabase, Inc. (United States)
What they process: Account data, preference data, subscription status, tool inputs. Why: Database hosting and authentication infrastructure. Safeguards: Supabase stores data in EU infrastructure when configured for EU regions. Our database is hosted in [EU region — confirm before go-live]. Supabase is GDPR-compliant. Data Processing Agreement in place. See: supabase.com/privacy.
Stripe, Inc. (United States)
What they process: Payment card data, billing address, transaction history. Why: Payment processing. Safeguards: Stripe is certified to PCI DSS Level 1. Stripe EU Data Processing Agreement covers GDPR compliance. Data may be transferred to the US under Stripe's Standard Contractual Clauses. See: stripe.com/privacy.
Vercel, Inc. (United States)
What they process: Web Analytics (aggregated, non-identifying page view data); infrastructure logs. Why: Hosting the Service and privacy-friendly analytics. Safeguards: Vercel Web Analytics does not set cookies or create individual profiles. Vercel infrastructure for the Service is configured in an EU region [confirm before go-live]. Vercel DPA available at vercel.com/legal/dpa. See: vercel.com/legal/privacy-policy.
Resend, Inc. (United States)
What they process: Your email address and the content of emails we send you. Why: Transactional email delivery (subscription confirmations, renewal reminders, account notifications). Safeguards: Resend operates under a DPA with Standard Contractual Clauses for US transfers. See: resend.com/privacy.
We do not use any processor for advertising targeting or third-party data sharing.
7. International data transfers
You may be based in the US or UK. We are based in Italy (EU). Your data is stored in EU infrastructure as described in Section 6.
Some of our processors are based in or transfer data to the United States. Where this occurs, we rely on:
- Standard Contractual Clauses (SCCs) approved by the European Commission, as incorporated in processor DPAs
- UK International Data Transfer Agreements (IDTAs) where required for UK-origin data
For UK residents: Italy Made Clear processes your data in accordance with UK GDPR. The EU adequacy decision for the UK (adopted June 2021) means data flows from Italy to UK users do not require additional safeguards.
8. Your rights
Under GDPR (and, where applicable, UK GDPR), you have the following rights:
| Right | What it means |
|---|---|
| Access | You can ask us to confirm whether we hold personal data about you and receive a copy of it |
| Rectification | You can ask us to correct inaccurate or incomplete data |
| Erasure ("right to be forgotten") | You can ask us to delete your data. We will comply unless we have a legal obligation to retain it (e.g., accounting records) |
| Restriction | You can ask us to pause processing of your data in certain circumstances |
| Portability | You can ask us to provide your data in a structured, machine-readable format |
| Objection | You can object to processing based on legitimate interests. We will stop unless we have compelling legitimate grounds |
| Withdraw consent | Where processing is based on consent, you can withdraw at any time |
To exercise any of these rights, email hello@christaudien.me with the subject line "Data rights request". We will respond within 30 days. We may ask you to verify your identity before fulfilling the request.
You also have the right to lodge a complaint with the Italian data protection authority:
Garante per la Protezione dei Dati Personali garante.privacy.it Piazza Venezia 11, 00187 Roma
If you are based in the UK, you may also complain to the Information Commissioner's Office (ICO): ico.org.uk.
9. Security
We implement appropriate technical and organisational measures to protect your data:
- All data in transit is encrypted via TLS
- Database access is restricted by role-level permissions
- Passwords are stored as hashed values (Supabase Auth handles this)
- Access to production systems is restricted to authorised personnel
No system is completely secure. In the event of a data breach that poses a high risk to your rights and freedoms, we will notify you and the relevant supervisory authority as required by GDPR.
10. Cookies
For information about the cookies we use and how to manage them, see our Cookie Policy.
11. Changes to this policy
We may update this Privacy Policy from time to time. We will notify you of material changes by email or by a notice on the Service, at least 14 days before they take effect. The "Last updated" date at the top of this page will always reflect the current version.
12. Contact
For privacy-related questions:
Email: hello@christaudien.me (update to privacy@italymadeclear.com before launch)
Data Controller: [LEGAL ENTITY / P.IVA / address — to confirm]
Italy Made Clear — Your Italy, translated.