I.PRIVACY POLICY

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 privacy@wplavori.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: privacy@wplavori.com.

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:

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:

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.

If our Company does not provide you with a reply within the time allowed by law, or the response to a request to exercise your rights is not deemed acceptable, you may appeal to the Guarantor for the protection of personal data. If you believe that our Company has committed a violation of the Privacy Code and/or the Privacy Policy, you may appeal to the Guarantor for the protection of personal data. Contact details for the Guarantor of Privacy: Guarantor for the protection of personal data, www.gpdp.it - www.garanteprivacy.it, Email: garante@gpdp.it, Fax: (+39) 06.69677.3785, Telephone: (+39) 06.69677.1.

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.

8. CHANGES TO THE PRIVACY POLICY

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

1.PURPOSE

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).

2.SOCIAL NETWORKS

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:

  1. 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;
  2. 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:

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:

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:

and/or the following as one of the first three hashtags:

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.


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