Pursuant to the Legislative Decree of 30 June 2003, no. 196 and following edits (hereinafter "Privacy Code") and the European Regulation no. 2016/679 (hereinafter "Privacy Regulation"), WP Lavori in corso S.r.l. intends to inform you about the loyalty program "WP Club" on the use of personal data collected.
1. Data Controller, Data Processors and Data Protection Manager.
The Data Controller for the processing of personal data is WP Lavori in corso S.r.l. (Italian Tax Code and VAT no. IT02370420370), with registered office in 40129 Bologna, Via dell’Arcoveggio n. 59/5, e-mail email@example.com, (hereafter referred to as “Data Controller”).
The updated list of designated Data Processors may be provided following a request on the part of the parties concerned and/or Users.
The Data Protection Manager (designated pursuant to art. 37 of the GDPR) can be contacted by writing to the following email address: firstname.lastname@example.org
2. The personal data you provide: purposes for processing
Your personal data is used to allow you, following your registration with WP Club, to activate the customer loyalty programme and allow us to send you information regarding the relative promotions and discounts of interest to you.
Your data is processed for the following purposes:
- to carry out activities of "loyalty in the strictest sense" connected to the registration to the WP Club program, which cannot be carried out in an anonymous form, and are necessary for assigning the advantages inherent to its use. These include the use and recognition of promotions, the offer and sending of rewards, participation in the collection of points, as well as promotional events reserved for loyal customers, etc.;
- to update you, subject to your express consent, on all our promotional and direct marketing initiatives, also by sending advertising and/or promotional material, using automated tools and/or traditional methods of contact, such as e-mail, SMS, MMS, instant multimedia messaging applications (“Marketing”);
- to carry out, subject to your express consent, customer profiling based on purchasing choices and information provided as an optional during registration to the loyalty program, in order to create personalised promotions based on your profile (hereafter referred to as “Profiling Activities”).
The processing of personal data for the above stated purposes will be carried out in compliance with the Privacy Code, the Privacy Regulation and all specific sector regulations, including the provisions of the "Guarantor Rules for loyalty programs" of 24 February 2005.
In compliance with the “Guidelines on promotional activity and action against spam” of 4 July 2013, please note that any consent given by you for sending commercial, promotional and marketing communications through automated tools will also extend to traditional methods of contact.
The personal data you provide will be processed mainly using IT tools under the authority of the Data Controller, by persons specifically appointed, authorised and trained in processing in accordance with articles 28 and 29 of the Privacy Regulation. We inform you that suitable security measures are observed also pursuant to articles 5 and 32 of the Privacy Regulations to prevent the loss of data, illicit use or misuse and unauthorised access.
3. Consent of a necessary or optional nature for the provision of personal data, the consequences of refusal to provide data and the legal basis for processing.
Please be aware that for the purposes referred to in point (i) of art. 2 above, the provision of your personal data is compulsory as by failing to provide the required information, you will not be able to register and activate the WP Club loyalty programme, enjoy the advantages associated with it, including the use and recognition of promotions, the offer and sending of rewards, participation in collection points and promotional events reserved for loyal customers, etc.
The provision of your personal data is not mandatory, but rather optional for the purposes referred to in points (ii) and (iii) of art. 2 above. Failure to provide data for the abovementioned purposes will not allow us to carry out Marketing activities and Profiling Activities. To this end, you can also freely decide whether or not to give your consent for these purposes, without this affecting the possibility of using the services offered through the WP Club program.
Remember that, for any reason and at any time, you can ask the Data Controller to delete your personal data simply by sending a request, without particular formalities, to the addresses indicated in art. 1 above.
With reference to the purposes referred to in point (i) of art. 2 above, the legal basis for processing is, in fact, the implementation of the services provided through the WP Club loyalty program (pursuant to article 6, paragraph 1, letter b of the Privacy Regulation) instead, with reference to the purposes referred to in points (ii) and (iii) of art. 2 above, the legal basis of the processing is your freely expressed consent (pursuant to article 6, paragraph 1, letter a of the Privacy Regulation).
4. To whom and where we may send your personal data.
Your data may be communicated, within the EU, in full compliance with the provisions of the Privacy Code and the Privacy Regulation, to the following subjects:
- to the financial and/or other public authorities, where this is required by law or at their request;
- to the structures, subjects and external companies that the Data Controller employs to carry out activities which are instrumental and/or ancillary to the management of the WP Club program or the provision of the services and benefits connected to it; these include software solution providers, web applications and storage services also provided through Cloud Computing systems (all data will be stored on servers located within the European Community);
- to the structures, subjects and external companies that the Data Controller employs to carry out activities which are instrumental and/or ancillary to the performance of Marketing and/or Profiling activities to which you have given your express consent to these purposes for processing your data;
- where you have given your express consent for specific marketing purposes, to the partner companies, to which the Data Controller is a part;
- to external third party consultants (for example, for the management of tax obligations), if not designated in writing, Data processors.
5. Rights of the Data Subject
Remember that you can exercise your rights at any time, pursuant to articles 15, 16, 17, 18, 20 and 21 of the Privacy Regulation, in the manner established by article 12 of the Privacy Regulation.
6. DURATION OF THE processing
Without prejudice to legal obligations, personal data will be kept for the duration of your participation in the WP Club program.
In any event, the data relating to the details of purchases with reference to identifiable customers can be stored for Profiling and Marketing purposes for a period not exceeding 12 and 24 months, respectively, from the time of customer registration, excluding the actual transformation into anonymous form that does not make it possible to identify you, even indirectly or by connecting to other data banks.
The data necessary for the provision of Marketing services will be processed through an "OPT-OUT" management model, that is until the explicit declaration by the interested party to unsubscribe to the aforementioned services is received.
7. Security of personal data
Your data is processed in accordance with the applicable law and using adequate security measures in compliance with current applicable legislation, pursuant to the articles 5 and 32 of the Privacy Regulation.
In this regard, we confirm, among other things, the adoption of appropriate security measures to prevent unauthorised access, theft, disclosure, modification or unauthorised cancellation of your data.
The Data Controller reserves the right to make changes to this Privacy Statement: in this case, you will be promptly informed through its publication.
II.EXTERNAL SOCIAL MEDIA POLICY
This policy defines and regulates the methods of interaction with initiatives implemented by WP Lavori in corso S.r.l., with registered offices at Via dell’Arcoveggio no. 59/5, 40129 Bologna, (hereinafter the “Company”), in order to ensure correct procedures in the use of social media by both users and employees and/or associates of the Company, in the light of current legislation regarding copyright (Copyright law 633 of 22 April 1941 and subsequent amendments and additions; Directive (EU) 2019/790 on copyright in the digital single market; the Self-Regulation Code for Commercial Communication and the I.A.P. Digital Chart) alongside the stipulations of data protection legislation (Regulation (EU) 2016/679, Legislative decree 196/2003 and subsequent amendments and additions, and the provisions of the Regulator for Data Protection).
Social networks are used to share text and/or multimedia content among individuals who adhere to a community by creating personal profiles.
In order to better engage users, the Company uses the social media platforms Facebook and Instagram for the promotion of specific projects, events or free gift schemes. These channels are in addition to the websites belonging to the Company, which are listed below:
Content distributed via the social networks must comply with the rules stipulated by the Self-Regulation Code for Commercial Communication and the I.A.P. Digital Chart.
The Company pages on the various social networks have the following functions:
- to provide information about activities and initiatives organised by the Company, in order to stimulate dialogue with users by means of posts, comments on posts, responses to enquiries, questions, criticism and suggestions;
- to produce content in the form of text, photographic images, video and other multimedia material referring to the individual services and/or projects for which the Company page was launched.
Such content may not be freely reused by third parties under any circumstances, except by sharing through the social network itself.
The Company also publishes content, including multimedia content, which is self-produced or whose rights have been acquired from the author in accordance with copyright legislation. Personal data may be published subject to the express content of users, in accordance with data protection legislation.
In particular, the Company undertakes not to publish photographs and/or videos:
- of minors, without prior permission from their parents or carers;
- of individuals whose image entails the processing of specific categories of personal data, without prior consent, in accordance with data protection legislation.
Where this is not possible the Company will conceal the faces of minors or individuals in this category.
Photographic images and/or videos of users are published only where the users have been previously informed by an appropriate statement issued at the time of collecting the stated images, and have given their consent.
The Company’s Marketing department is responsible for the administration of the corporate social media pages.
For the conditions of use of individual social networks, please consult the Terms & Conditions of the relevant platform, which the Company also respects.
Any user may participate in the activities of the Company page by expressing his or her own opinions. Such comments constitute the opinion of the individual and not the Company, which declines all responsibility regarding the truthfulness and correctness of content posted on its corporate pages by users.
The Company reserves the right to delete any posts which:
- are discriminatory or offensive to individuals, groups or categories of people in terms of gender, race, language, ethnicity, religion, political views, personal and social circumstances, sexual orientation and age;
- contain images of minors without the prior permission of their parents or carers;
- are discriminatory or offensive to other users present or otherwise in the discussion, institutions, associations, organisations in general, firms and the Company, or in any other way detrimental to the rights of third parties;
- contain language which is inappropriate, vulgar, licentious, offensive to public decency and/or threatening in tone;
- contain subject matter which is obscene, pornographic or offensive to public morale and sensibility;
- are deceitful and alarmist;
- contain personal data regarding third parties and/or which may injure their reputation and/or cause harm;
- contain particular categories of data concerning third parties, in accordance with data protection legislation;
- contain subject matter which is unlawful or which incites unlawful acts and/or violates copyright law;
- contain advertising or promote profit-making activities;
- contain political opinions, propaganda or spam;
- are not pertinent to the discussion in question, repetitive or intended to disrupt the discussion.
The Company reserves the right to ban and/or block anyone who repeatedly violates these moderation rules and, in the most serious cases - even for one instance - inform the platform and, where necessary, the authorities.
3.INFLUENCERS, CELEBRITIES & BLOGGERS
The Company makes use of influencers, celebrities and bloggers for the online promotion of its brands, products and services, because the direct involvement of such individuals can generate loyalty and approval in end consumers.
Influencers or bloggers are individuals who have the ability to influence consumers in their choice of a product or their opinion of a brand, due to the prestige and authority gained through their experience in a given field or sector.
Celebrities are individuals who belong to the world of entertainment or sport.
In its contractual agreement with influencers, celebrities and bloggers, the Company expressly states that the latter must inform users of the promotional nature of content posted on social media. In particular, such individuals are contractually obliged to insert the following wording in their posts:
- Promoted by/Sponsored by;
- In collaboration with/In partnership with;
and/or the following as one of the first three hashtags:
- #sponsored by;
- #jointly with#brand.
In cases where the relationship between the Company and the influencers, celebrities and bloggers is limited to the occasional sending of free or moderate-value products, the latter are obliged to insert a disclaimer in their posts, as follows:
In the case of live promotional videos posted on social media, the commercial purpose must be made clear by means of appropriate disclaimers in the first and last frames of the video, or by the influencer, celebrity or blogger featured in the video stating verbally:
- “this product was sent to me by…”.
Bologna 20-11-2019, WP Lavori in corso S.r.l.