Last Updated: April 22, 2025
Alexander Maffei Ltd ("we", "our", or "Matera City Pass") is committed to protecting the privacy of users accessing the materacitypass.com website and using our informational and promotional services. This Privacy Policy explains how we collect, use, retain, and protect personal data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation – GDPR).
1. Data Controller
Alexander Maffei Ltd
71 Stapleton Road, Orpington, BR6 9TQ, United Kingdom
Email: materacitypass2024@gmail.com
Unique Taxpayer Reference: 1512541943
2. Categories of Personal Data Collected
a) Users (Tourists/Visitors)
- First and last name
- Gender
- Date of birth
- Country of origin
- Phone number
- Email address
- Navigation and interaction data via cookies and analytics
- QR code usage data
- Payment data (via Stripe)
b) Business Clients (Partner Merchants)
- Business name, address, location
- Contact and login information for dashboard access
- Aggregated usage statistics (e.g. scans, customer demographics)
We do not process special categories of personal data (e.g. health, religion).
3. Purposes and Legal Bases of Processing
Issuing passes and QR codes, service access
Legal Basis (Art. 6 GDPR): Contractual necessity (Art. 6.1.b)
Billing and payment processing
Legal Basis (Art. 6 GDPR): Legal obligation (Art. 6.1.c)
Aggregated analytics for partner businesses
Legal Basis (Art. 6 GDPR): Legitimate interest (Art. 6.1.f)
Sending promotional newsletters
Legal Basis (Art. 6 GDPR): Consent (Art. 6.1.a)
Website analytics and service improvement
Legal Basis (Art. 6 GDPR): Legitimate interest (Art. 6.1.f)
Security and access credential management
Legal Basis (Art. 6 GDPR): Legal obligation and legitimate interest (Art- 6.1.c/f)
4. Data Recipients
Personal data may be accessed by:
- Authorized personnel of Alexander Maffei Ltd
- Technical service providers (e.g., Stripe, Google, hosting platforms, email tools)
- Partner merchants (only aggregated and anonymized data)
All recipients operate within the European Union or the United Kingdom.
5. Cookies and Tracking Technologies
We use technical cookies and analytics tools (e.g. Google Analytics) for statistical and performance purposes, in compliance with the ePrivacy Directive (2002/58/EC). Consent is requested for non-essential cookies via a banner on the website.
6. International Data Transfers
Personal data collected on the Matera City Pass website is processed and stored in the United Kingdom, where the data controller is based.
This transfer is lawfully permitted under the European Commission’s adequacy decision of June 28, 2021, which recognizes the UK as providing a level of personal data protection essentially equivalent to that of the EU (Art. 45 GDPR).
Should this decision be withdrawn or invalidated in the future, we will adopt alternative safeguards such as Standard Contractual Clauses (SCCs) as required.
7. Data Retention Period
- Users: Data is stored for 2 years from last activity
- Business clients: Data is retained for 2 years after the contract ends
- Billing and accounting data is kept for the legally required duration
8. Data Security Measures
We adopt appropriate technical and organizational safeguards:
- QR codes and credentials are encrypted
- Data access is restricted to authorized users via secure login
- Analytical data is anonymized before being shown to partner merchants
9. Your Rights
As a data subject, you may:
- Access your data
- Request rectification or erasure
- Object to marketing communications
- Withdraw consent where applicable
- Request data portability
- Lodge a complaint with the relevant authority
Supervisory authority in Italy:
Garante per la protezione dei dati personali – www.garanteprivacy.it
10. Policy Updates
We may update this policy. Substantial changes will be communicated via the website.
Contact Us
If you have questions or comments about this notice, you may email us at hello@materacitypass.com.