Information on the processing of personal data and Social media Policy for company pages

Information on the use of our Fan Pages and on the processing of personal data

Premise

In thanking you for joining our communities, Seipee S.p.A. (hereinafter “Company“) we draw your attention to the risks you may incur by entering personal data, photos, videos, images and/or comments within the Fan Pages.

Therefore, take a few moments to read our Social Media Policy which must be respected when you interact with our Fan Pages.

When you interact with our social network accounts, via web or app, we and the providers of social media technology platforms collect information and personal data about you. For this reason, in accordance with the provisions of articles 13 and 14 of European Regulation 679/2016 (hereinafter “GDPR“), we have created this document in order to describe which personal data we collect, the purposes and methods of processing them and the security measures we adopt to protect them.

This Social Media Policy constitutes the information to data subjects issued pursuant to the applicable legislation on the protection of personal data and applies exclusively to the following Fan Pages:

Facebook: https://www.facebook.com/seipeemotorielettrici

Instagram: https://www.instagram.com/seipeemotorielettrici/

Linkedin: https://www.linkedin.com/company/seipee-spa

(hereinafter, collectively, “Fan Pages“).

This Social Media Policy does not apply to third-party fan pages that may be referred to via links or banners within the Fan Pages.

Source of data and purpose of data processing

Navigation data

The computer systems used to operate the Services acquire, during their normal operation, some of your personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected for the purpose of identifying you, but could lead to your identification if, for example, it is combined with data held by third parties. This category of data includes the IP address and domain name of your device, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server and other parameters relating to your operating system. We use this data for the sole purpose of obtaining anonymous statistical information on the use of the Services and to check their correct functioning. The data could be used to ascertain responsibility in the event of computer crimes committed against the Services.

Data relating to your accounts on social networks

When you follow our Fan Pages within social networks, your data is processed to find information regarding our Company and to receive our updates, we learn about the data you have shared with the social network. Such data may include your name and surname, your email address, the interests you have expressed within the social network as well as the posts and messages you send to our Fan Pages.

Should you collect, process and communicate information relating to third parties to us, you must do so in compliance with the provisions of the GDPR and, therefore, you must give them prior information on the treatment and, if necessary, you must obtain their free and express consent before carrying out the treatment .

For more information on the processing of personal data and on the conditions of use of the Fan Pages:

Facebook: https://www.facebook.com/terms.php

Instagram: https://help.instagram.com/581066165581870

Linkedin: https://www.linkedin.com/legal/user-agreement?_l=it_IT

Purpose of the processing and nature of the provision

The treatment is aimed at ensuring new channels of information, communication and dialogue with users, with methods of interaction and participation, in order to allow the strengthening of the means of communication in order to strengthen a relationship with you.
We treat your personal data only for the management of our Fan Pages, to respond to any requests and to check that your messages and/or posts on the page are in line with the indications set out in this Social Media Policy.
The provision of your personal data is optional and failing that, you will not be able to view the content of our Fan Pages or even interact with them. The moment he decides to follow our Fan Pages, and can therefore interact with them and receive our updates directly in your home page, you give us your personal data associated with your account on the social network. If you do not want to give us your personal data, we invite you to stop or refrain from following our Fan Pages.

Methods of data processing and data retention

The “Company” processes your personal data through electronic means and through the tools provided by the companies supplying the social media technological platform that host our Fan Pages, in compliance with the security requirements required by the applicable legislation. Our security measures include contractual tools with third party data processors in order to ensure the protection of the security and confidentiality of your personal data in compliance with the provisions dictated by the applicable legislation on personal data protection.

We keep your personal data for as long as you follow our Fan Pages. Even after you have chosen not to follow our Fan Pages, we will process your data with reference to your activity and interactions with our Fan Pages that took place before that date, in accordance with the policies of the social networks hosting our Fan Pages . We will also keep your data to the extent that this is necessary to comply with the obligations imposed by laws or regulations, to protect our rights, to prevent fraud or to enforce this Social Media Policy.

Communication scope

Your collected data will be communicated exclusively to the third-party company that manages the corporate social pages on behalf of Seipee S.p.A., with the specification that with the use of communication systems and digital platforms not owned by the “Company”, you communicate your data also to the owners of the systems and platforms, joint data controllers.

Your data processed by the “Company” are accessible to our duly authorized personnel (e.g. Management) on the basis of necessity criteria

Spread

Your data will not be disclosed by us. For more information, we invite you to read the Privacy Policies of the social platforms.

Data transfer abroad

Your personal data will not be transferred by the “Company” outside the European Union or in countries that do not guarantee an adequate level of data protection.

With regard to the data processed by the companies supplying the social media technological platform, we invite you to read the following:

Facebook: https://www.facebook.com/terms.php

Instagram: https://help.instagram.com/581066165581870

Linkedin: https://www.linkedin.com/legal/user-agreement?_l=it_IT

Rights of the interested party.

The “Company” prescribes that the joint controller companies must be based within the EU and accepts that they can make and implement decisions on the processing of Statistical Data. Any disputes will be handled with jurisdiction in Italy.

In the event that the “Company” is contacted by the interested parties or by the Guarantor Authority regarding the treatments carried out on the social pages, it must promptly notify the co-owner company

The interested party may at any time ask (COMPANY NAME) S.r.l. access to personal data, rectification, cancellation or limitation of the processing of personal data or to oppose their treatment in addition to the right to data portability. The procedures for exercising the rights referred to in articles 15 to 21 of the GDPR are published on the Company’s institutional website or can be requested by writing to the Company’s institutional address.

Revocation of consent: the interested party can revoke consent to the processing of his data at any time without prejudice to the lawfulness of the treatment based on the consent before the revocation. The revoked consent in relation to the data necessary for the provision of the services involves the interruption of the same. The interested party can lodge a complaint with a supervisory authority.

Joint data controllers and personal data protection managers

The co-owners of the processing of personal data are:

The companies providing the social media technology platform.

For Facebook and Instagram, the company Meta Platforms Ireland Limited, 4 Grand Canal Square, Ghent Canal Harbour, Dublin 2, Ireland.

For Youtube, the company Google Ireland Limited, a company incorporated and operating under Irish law (Registration number: 368047), with registered office at Gordon House, Barrow Street, Dublin 4, Ireland.

For Twitter, Twitter International Company, an Irish company having its registered office at The Academy, 42 Pearse Street, Dublin 2, Ireland.

For LinkedIn, LinkedIn Ireland Unlimited Company Attn: Legal Dept. (Privacy Policy and License Agreement) Wilton Plaza Wilton Place, Dublin 2 Ireland

For Pinterest, the company Pinterest Europe Ltd., an Irish company having its registered office at Palmerston House, 2nd Floor, Fenian Street, Dublin 2, Ireland

As administrator of the social page

Seipee S.p.A., with registered office in Viottolo Croce, 1 – 41011 – Campogalliano (MO) – Italy – Tel: +39 059 850108 – e-mail: [email protected]

The Data Protection Officers pursuant to art. 37 of the GDPR are:

for the companies supplying the social media technological platform, the references are indicated on the respective institutional sites

SOCIAL MEDIA POLICIES

The Social Media Policy is the code of conduct, formally adopted, which regulates the relationship on the internet, and in particular on social media, between the Company and its users (External Social Media Policy).

The Company’s social channels are managed by the Marketing Office.

The Company reserves the right to create Pages or Groups dedicated to the promotion of specific projects, identifiable through the title of the page itself by specifically authorized persons.

The comments and posts of users, who are invited to always introduce themselves with their first and last name, represent the opinion of individuals and not that of the Company which cannot be held responsible for what is posted on its channels by third parties.

Moderation

The Company’s social media channels are normally moderated during business hours via notifications only.

We invite you to have a polite, pertinent and respectful conversation: on the Company’s social channels everyone can intervene to express their free opinion, always following the good rules of education and respect for others.

Comments and posts that violate the conditions set out in this document will be moderated, even in advance, and will be promptly removed.

Insults, bad language, threats or attitudes that harm the dignity of people and the decorum of institutions, the rights of minorities and minors, the principles of freedom and equality and in particular: will not be tolerated:

– content that promotes, facilitates, or perpetuates discrimination on the basis of sex, race, language, religion, political opinion, creed, age, marital status, status in relation to public assistance, national origin, physical or mental disability or sexual orientation

– sexual content or links to sexual content

– solicitations for trade

– conducting or encouraging illegal activity

– information that may tend to compromise public safety

– contents that violate the interest of a legal property or of third parties

– comments or posts that present particular categories of personal data (so-called sensitive data) in violation of the Privacy Law.

Comments and content of the following genres are also discouraged and in any case subject to moderation:

– comments not pertinent to that particular published topic (off topic)

– remarks for or against political campaigns or voting indications

– offensive language or content

– comments and posts written to disturb the discussion or offend those who manage and moderate social channels

– spam

– Interventions inserted repeatedly.

The Company reserves the right to remove any content that it deems to be in violation of this social media policy or any applicable law.

For those who violate these conditions or those contained in the policies of the tools adopted, we reserve the right to use the ban or block to prevent further interventions and possibly to report the user to the appropriate law enforcement agencies.

Privacy

Please note that the processing of users’ personal data complies with the policies in use on the platforms used (Facebook, Instagram and Linkedin). Please note that sensitive data posted in comments or public posts within the Company’s social channels will be removed (see Moderation section). The data shared by users through private messages sent directly to the Company’s channels will be treated in compliance with Italian and European privacy laws.

To contact the editorial staff of the Company’s social channels, send an email to the institutional email address.

Below are the policies for each social media used by the Company, to clarify what type of content is conveyed, who produces it and how online conversation is managed.

Facebook Policy

The Company has an institutional profile on Facebook https://www.facebook.com/seipeemotorielettrici.

Those who follow The Company are not automatically followed.

The analysis of the users who “like” the page and of the users who “register” is carried out, with the aim of better identifying the recipients of the messages and adopting appropriate communication methods and contents.

Users can post texts, photos or videos on their Facebook profile quoting the Company.

Users are free to share the Company’s posts on their profiles.

Comments are appreciated, proposts and ideas from visitors. A direct response is not guaranteed but, where the usefulness of the topic and the adequacy of the communication style are recognized, the Company’s editorial staff participates in the conversation and replies to the comments.

Instagram Policy

The Company has an institutional profile on Instagram: https://www.linkedin.com/company/seipee-spa

Those who follow The Company are not automatically followed.

The analysis of the users who “like” the photos is carried out, with the aim of better identifying the recipients of the messages and adopting appropriate communication methods and contents.

Users can post texts, photos or videos on their Instagram profile quoting the Company.

Users are free to share photos of the Company on their profiles.

Comments, suggestions and ideas from visitors are appreciated. A direct response is not guaranteed but, where the usefulness of the topic and the adequacy of the communication style are recognized, the Company’s editorial staff participates in the conversation and replies to the comments.

LinkedIn Policy

Linkedin is a social network designed for the world of work. It is an excellent tool for very specific or highly qualified professional figures who want to extend their network of contacts or be found by potential recruiters. Linkedin is also an important means of communication for companies, which can acquire great visibility and reach many users interested in a specific sector.

The Company has an institutional profile on Linkedin: https://www.linkedin.com/company/seipee-spa

The page has many purposes, such as being found by industry experts and potential customers, linking the page to the professional profiles of employees, presenting one’s products and services.

Those who follow The Company are not automatically followed.

However, user surveys are periodically carried out with the aim of identifying the recipients of the messages and adopting appropriate communication methods and contents.

Users can post texts, photos or videos on their Linkedin profile, quoting the company.

Users are free to share the Company’s posts on their profiles.

Comments, suggestions and ideas from visitors are appreciated. A direct response is not guaranteed but, where the usefulness of the topic and the adequacy of the communication style are recognized, the Company’s editorial staff participates in the conversation and replies to the comments.

Extract from EU Reg. 2016/679: Articles 15, 16, 17, 18, 19, 20, 21, 22 – Rights of the interested party

The interested party has the right to obtain confirmation of the existence or not of personal data concerning him, even if not yet registered, and the

their communication in an intelligible form and the possibility of making a complaint to the Supervisory Authority.

The interested party has the right to obtain the indication:

the origin of the personal data;

of the purposes and methods of the treatment;

of the logic applied in case of treatment carried out with the aid of electronic instruments;

of the identification details of the owner, of the managers and of the designated representative pursuant to article 5, paragraph 2;

of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as designated representative in the territory of the State, managers or personnel authorized to process personal data.

The interested party has the right to obtain:

updating, rectification or, when interested, integration of data;

the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;

the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment proves impossible o involves the use of means manifestly disproportionate to the protected right;

data portability.

The interested party has the right to object, in whole or in part:

for legitimate reasons, to the processing of personal data concerning him, even if pertinent to the purpose of the collection;

to the processing of personal data concerning him for the purpose of sending advertising material or direct sales or for carrying out market research or commercial communication

Extract from EU Reg. 2016/679: Articles 15, 16, 17, 18, 19, 20, 21, 22 – Rights of the interested party

The interested party has the right to obtain confirmation of the existence or not of personal data concerning him, even if not yet registered, and the

their communication in an intelligible form and the possibility of making a complaint to the Supervisory Authority

The interested party has the right to obtain the indication:

de the origin of the personal data;

of the purposes and methods of the treatment;

of the logic applied in case of treatment carried out with the aid of electronic instruments;

of the identification details of the owner, of the managers and of the designated representative pursuant to article 5, paragraph 2;

of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as designated representative in the territory of the State, managers or personnel authorized to process personal data.

The interested party has the right to obtain:

updating, rectification or, when interested, integration of data;

the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;

the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment proves impossible o involves the use of means manifestly disproportionate to the protected right;

data portability.

The interested party has the right to object, in whole or in part:

for legitimate reasons, to the processing of personal data concerning him, even if pertinent to the purpose of the collection;

to the processing of personal data concerning him for the purpose of sending advertising material or direct sales or for carrying out market research or commercial communication