Social media policy

Privacy Policy and Social media Policy for corporate pages

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

Foreword

In thanking you for joining our communities, Sideius S.r.l. (hereinafter “Company”) draws 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 that must be adhered to when you interact with our Fan Pages.

When you interact with our social media 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 the European Regulation 679/2016 (hereinafter “GDPR”), we have created this document in order to describe to you what personal data we collect, the purposes and methods of processing it, and the security measures we take to protect it.

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

Linkedin
YouTube
Instagram
(hereafter, collectively, “Fan Pages”).

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

Data source and purpose of data processing

Navigation data

The computer systems responsible for the operation of the Services acquire, in the course of their normal operation, some of your personal data, the transmission of which 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 in submitting the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server and other parameters related to your operating system. We use this data for the sole purpose of obtaining anonymous statistical information about the use of the Services and to check that they are working properly. The data could be used to ascertain responsibility in case of computer crimes committed against the Services.

Cookies

Data related to your social media accounts

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 first and last name, 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 disclose to us information referring to third parties, you must do so in accordance with the provisions of the GDPR and, therefore, you must give them prior notice of the processing and, if necessary, you must collect their free and express consent before processing.

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

Linkedin

Youtube

Instagram

Purpose of processing and nature of conferral

The purpose of the processing is to ensure new channels of information, communication and dialogue with users, with interaction and participation modes, in order to enable the enhancement of means of communication in order to strengthen a relationship with you. We process 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. Providing your personal data is optional and without it you will not be able to view the content of our Fan Pages or even interact with them. The moment you decide to follow our Fan Pages, and can therefore interact with them and receive our updates directly on your homepage, you give us your personal data associated with your social network account. Should you not wish to give us your personal data, we encourage you to stop or refrain from following our Fan Pages.

Methods of data processing and data storage

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

We retain your personal data for as long as you follow our Fan Pages. Even after you choose to stop following our Fan Pages we will process your data with respect to your activity and interactions with our Fan Pages that occurred before that date, in accordance with the policies of the social networks that host our Fan Pages. We will also retain your data to the extent necessary to comply with obligations imposed by law or regulation, to protect our rights, to prevent fraud, or to enforce this Social Media Policy.

Scope of communication

Your collected data will not be transferred to third parties, with the clarification that with the use of communication systems and digital platforms that are not owned by the “Company,” you also disclose your data to the entities that own the systems and platforms, co-owners of the processing.

Your data processed by the “Company” is accessible to our duly authorized personnel (e.g., management) on a need-to-know basis

Transfer of data abroad

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

With regard to the data processed by the companies providing the social media technology platform, we invite you to review the following:

Linkedin

Youtube

Instagram

Rights of the data subject.

The “Company” prescribes that the co-owner 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 data subjects or the Guarantor Authority regarding the treatments implemented on the social pages, it must promptly notify the co-owner company

The data subject may at any time ask Sideius S.r.l. for access to personal data, rectification, cancellation or restriction of the processing of personal data or object to their processing in addition to the right to data portability. The procedures for exercising the rights under 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 data subject may at any time revoke consent to the processing of his or her data without affecting the lawfulness of the processing based on the consent before revocation. Withdrawn consent with respect to data necessary for the provision of services results in the interruption of services. The data subject may lodge a complaint with a supervisory authority…

Joint Data Controllers and Data Protection Officers

The Co-Processors of personal data are:

The companies providing the social media technology platform.

• For Youtube, the company Google Ireland Limited, a company incorporated and operating under Irish law (Registration Number: 368047), with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland.
• For Linkedin, the LinkedIn Ireland Unlimited Company Attn: Legal Dept. (Privacy Policy and License Agreement) Wilton Plaza Wilton Place, Dublin 2 Ireland
• Sideius S.r.l., headquartered Viale Europa, 40, 41011 Campogalliano (MO) e-mail: info@sideius.com

The Data Protection Officers under Article 37 of the GDPR are:

• For companies providing the social media technology platform, references are given on their respective institutional sites

SOCIAL MEDIA POLICY

The Social Media Policy is the formally adopted code of conduct governing 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 Department.
The Company reserves the right to create Pages or Groups dedicated to the promotion of specific projects, which can be identified through the title of the page itself by specifically authorized persons.
The comments and posts of users, who are encouraged to always introduce themselves by 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 office hours (Monday/Friday from 8:30 a.m. to 4:30 p.m.).
Polite, relevant and respectful conversation is invited: on the Company’s social channels everyone can intervene to express his or her free opinion, always following the good rules of politeness and respect for others.
Comments and posts that violate the conditions set forth in this document will be moderated, even preemptively, and will be promptly removed.
Insults, profanity, threats or attitudes that harm the dignity of persons and the decorum of institutions, the rights of minorities and minors, the principles of freedom and equality, and in particular:

• content that promotes, encourages, or perpetuates discrimination on the basis of sex, race, language, religion, political opinion, creed, age, marital status, status in relation to public assistance, nationality, physical or mental disability, or sexual orientation
• Sexual content or links to sexual content
• trade solicitations
• conducting or encouraging illegal activity
• Information that may tend to compromise public safety
• Content that violates the interest of a legal property or third party
• comments or posts that present special 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 otherwise subject to moderation:

• comments not relevant to that particular topic posted (off topic)
• Comments for or against political campaigns or voting directions
• offensive language or content
• Comments and posts written to disrupt discussion or offend those who manage and moderate social channels
• spam
• Repeatedly inserted interventions.

The Company reserves the right to remove any content that is found 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 banning or blocking to prevent further action and possibly 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 (Twitter, Facebook, LinkedIn, YouTube, etc.). Please note that sensitive data posted in public comments or posts within the Company’s social channels will be removed (see Moderation section). 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 kind of content is conveyed, who produces it, and how the online conversation is managed.

YouTube Policy

The Society’s YouTube account is managed by the Marketing Department.

No automatisms are used to post videos (such as tools that generate posts from RSS feeds): videos are uploaded and posted only by the people in charge.
Videos on the channel can be:

• made directly by the team in charge
• carried out by third parties on behalf of the Company
• made by third parties for the purpose of journalistic information on business issues.

Those who subscribe to the channel are not automatically followed. Analysis of subscribers is carried out, with the aim of better identifying the target audience of videos and adopting appropriate communication methods and content.
By default, the Company chooses to disable the addition of comments to videos by visitors.

Instagram Policy

The Society has an institutional profile on Instagram

Those who follow The Company are not automatically followed. The analysis of users a who put “likes” on photos is carried out, with the aim of better identifying the recipients of messages and adopting appropriate communication modes and content. Users can post text, photos or videos on their Instagram profiles mentioning The Company. Users are free to share photos of The Company on their profiles. Comments, proposals and ideas from visitors are appreciated. A direct response is not guaranteed, but where the usefulness of the topic and appropriateness of the communication style are recognized, The Society’s editorial staff participates in the conversation and responds to 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 a relevant medium for companies, which can gain high visibility and reach many users interested in a specific field.
The Company has an institutional profile on Linkedin

The purposes of the page are many, such as getting found by industry experts and potential clients, linking the page to employees’ professional profiles, and presenting their products and services.
Those who follow The Company are not automatically followed.
However, it is user surveys are conducted periodically with the aim of identifying message recipients and adopting appropriate communication methods and content.
Users can post text, photos or videos mentioning The Company on their Linkedin profile.
Users are free to share The Company’s posts on their profiles.
Comments, proposals and ideas from visitors are appreciated. A direct response is not guaranteed, but where the usefulness of the topic and appropriateness of the communication style are recognized, the Society’s editorial staff will participate in the conversation and respond to comments.

Excerpt from EU Reg. 2016/679: Articles 15, 16, 17, 18, 19, 20, 21, 22 – Rights of the Data Subject

The interested party has the right to obtain confirmation of the existence or non-existence of personal data concerning him/her, even if not yet registered, and
their communication in an intelligible form and the possibility of making complaints to the Control Authority.

The data subject has the right to obtain the indication:

1. Of the origin of personal data;
2. Of the purposes and methods of processing;
3. Of the logic applied in the case of processing carried out with the aid of electronic instruments;
4. of the identification details of the owner, managers and designated representative in accordance with Article 5, paragraph 2;
5. Of the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them in their capacity as designated representative in the territory of the State, as managers or staff authorized to process personal data.

The data subject has the right to obtain:

1. updating, rectification or, when interested, integration of data;
2. the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;
3. certification 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 where this proves impossible or involves the use of means manifestly disproportionate to the protected right;
4. data portability.

The data subject has the right to object, in whole or in part:

1. for legitimate reasons to the processing of personal data concerning him/her, even if relevant to the purpose of collection;
2. the processing of personal data concerning him/her for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communications