Policy
USER INFORMATION WEBSITE REGISTRATION
Pursuant to articles 13 and 14 of the EU General Regulation n.679/16 on the protection of personal data, updated to Legislative Decree n. 101/2018.
The Data Controller is:
Walcor Srl
We inform you that when you register as a user by creating your account, we collect and process your personal data. For this reason we explain the purposes and methods of their processing.
In compliance with the provisions of articles 13 and 14 of the EU General Regulation n.679/16 on the protection of personal data and the legislation of the "Privacy Decree" - Legislative Decree n. 101/2018:
·Data being processed:
Personal data voluntarily indicated by you in the site registration form (name, surname, e-mail address, telephone number, etc.);
- Computer data, such as the user's IP address.
·Purpose of processing:
1. CREATION OF THE ACCOUNT FOR PAYMENT-INVOICING-SHIPPING PURPOSES
Personal data are processed in order to create a personal account, following a request from the interested party, useful for the use of our services and to be able to fulfill the sales contract for our products via the website's e-shop;
2.MARKETING
Personal data can also be used for the purpose of so-called "soft spam".
Data such as e-mail address and telephone number, if permitted by the interested party, are processed for the sending of information messages and commercial and promotional communications relating to the Data Controller's activities and services, through automated means (e- email, sms) as well as traditional means (such as telephone contact with an operator or without an operator), in full compliance with the principles of lawfulness and correctness and the provisions of the law.
The user's e-mail address and telephone number, if consented, may also be communicated to third-party companies (belonging to the group to which the owner belongs, or third-party companies supplying products relating to the owner's activity:
eg companies selling clothing and accessories products) for marketing purposes (traditional or automatic) of the latter.
In any case, the processing takes place in full compliance with the principle of correctness and lawfulness and with the provisions of the law.
3. FUNCTIONALITY OF THE SITE AND NAVIGATION
The computer data acquired, for example the IP address, are processed to allow access to the services offered by the owner through this website and reserved for registered users, or, by way of example but not limited to, access to the area reserved, the collection and management of orders sent by users through the website, payment of products, delivery of purchased products.
NB The provision of your personal data is optional and cancellation can be requested at any time by writing to our e-mail address privacy@walcor.it,
·Legal basis of processing
By using or consulting our site you explicitly approve our Privacy Policy and consent to the processing of your personal data in relation to the methods and purposes described below, but explicit consent will be requested from you only by ticking the box not pre-filled which you will find in the individual forms.
CONTRACTUAL BASIS:
The provision of your data is optional but in some cases necessary , as any refusal to release it makes it impossible for us to create a personal account useful for using the services offered through the website and making online purchases (payment, invoicing, shipping etc.)
CONSENSUAL BASIS:
As regards the provision of data for marketing purposes, it is optional and any refusal will not have any interference and/or consequences on your personal account.
In this last case, the processing of your personal data is lawful, subject to your consent, pursuant to art. 6, paragraph 1, letter. a) of EU Regulation 679/2016. Your consent is considered freely given by ticking the box with the relevant flag.
nb In any case and exclusively with reference to the use of the email you provided us at the time of registration, we inform you that we will still be able to send one-off information and advertising material and not on a periodical newsletter basis only exclusively in reference to products similar to those for which purchased.
In this particular case, the interested party has the right to object to the processing at any time (to the email online@mirtaeccessori.it) upon receipt.
Consent , according to the new General Regulation (art. 4 GDPR), is any free, specific, informed and unequivocal expression of will , following our clear and concise request.
Your consent provided applies to all processing activities carried out for the same purpose(s).
LEGAL OBLIGATION
When we need to process some of your data to comply with legal obligations to which we ourselves are subject (billing etc.)
·Treatment methods
The data processing is carried out through IT and telematic media by specially appointed internal subjects. The data is stored in electronic archives with full assurance of the security measures required by the legislator.
· Communication and dissemination of data
The data collected will not be disclosed, sold or exchanged with third parties without express consent, except for any communications to authorized third parties only where necessary and for the purposes of this information. The data may be communicated to the competent authorities, according to the terms of the law.
In any case, the processing by third parties must take place correctly and in compliance with the provisions of the law in force.
Subject to express consent, communication to third-party companies (belonging to the group to which the owner belongs, or third-party companies supplying products relating to the owner's activity: for example companies selling clothing and accessories products) for marketing purposes (traditional or automatic) of the latter.
·Preservation times
Your data is stored exclusively for the time necessary to carry out the purposes of managing the account you created to access our services offered through the company website and in any case the data will be stored until the request to delete the account , or if this will be deactivated by us.
- With reference to the processing for the purpose of sending commercial and promotional communications, if consented, the data will be retained no longer than two years from the first contact, without prejudice to the opposition to the processing by the interested party. In any case, cancellation can be requested by sending an email to online@mirtaccessori.it
With reference instead to personal data subject to Processing for Marketing Purposes or Processing for profiling purposes, the same will be kept in compliance with the principle of proportionality and in any case until the purposes of the processing have been pursued or until - if previously – the revocation of specific consent by the interested party does not occur.
In any case, data of a civil, accounting and fiscal nature will be kept for ten years, as required by law.
·Rights of the interested party
Pursuant to articles 13, paragraph 2, letters (b) and (d), 14, 15, 18, 19 and 21 of the Regulation, we inform you that you have the right to ask MIRTA ACCESSORI MODA SRL, as data controller:
- access to the personal data we hold about you;
- the rectification
- their cancellation
- the limitation of the processing concerning him
- to oppose their treatment, in cases
As interested natural persons, you have the right to lodge a complaint with the Guarantor for the protection of personal data, following the procedures and instructions published on the official website of the Privacy Guarantor.
Any corrections or cancellations or limitations of processing carried out at your request - unless this proves impossible or involves a disproportionate effort - will be communicated by the Data Controller without any formal restriction and is free of charge.
The email address for exercising rights is: privacy@walcor.it
1. Social media policy
1. OBJECTIVES
1.1. The Walcor srl company (hereinafter referred to as the "Company") publishes and disseminates institutional content on the website www.walcorroma.it (hereinafter referred to as the "site"), a virtual place where the following are contained:
a) the main information of public interest that characterizes the Company;
b) the main information on the activities and products offered to customers and partners.
1.2. As part of its institutional communication, the Company has decided to reach and involve an ever-increasing number of people also using the following social media:
a) Facebook;
b) Instagram;
c) YouTube;
1.3. The use of the aforementioned social media concerns both communications of general and product interest, as well as the acquisition, as a means of "listening" to the public opinions of interested parties.
1.4. Through social media, information can also be provided, in real time, on the initiatives and products and services offered by the Company which users can learn more about on the site.
2. PURPOSE OF THE DOCUMENT
2.1. The object of this document is to establish the Policy for the management of content relating to the Company that may be disseminated online, including through social media.
3. ALLOCATION OF RESPONSIBILITY
3.1. For the purposes of this document, responsibilities refer to:
a) to the Company that publishes content on the site;
b) to the Communications Office which: records and administers all the Company's social profiles, animates the institutional ones and coordinates the animation of the profiles created for specific projects. Manages the authorizations, with particular regard to situations involving employees' personal accounts (e.g. Facebook, Instagram) or which require the activation of a specific Google account relating to the Company, in order to maintain the mapping of the authorizations assigned to the employees and know which ones sites/applications must be activated. The Office also monitors the social media in which the Company is present as well as the reputation of the Company and its representatives.
c) to the IT Resources Office which: guarantees the security of the Company's electronic/telematic data and therefore ensures that the network data security systems are updated and that all members of the Company follow the correct security procedures when accessing their respective accounts.
d) to Employees if they wish to participate with their presence in the Company's social media and who must comply with the established rules of conduct.
4. RULES OF CONDUCT
4.1. This Social Media Policy, formally adopted by the Board of Directors, constitutes the specific "code of conduct" that regulates relationships on the internet, and in particular on social media, and is divided into:
a) Internal Social Media Policy, with reference to the relationship between the Company and its employees;
b) External Social Media Policy, with reference to the relationships between the Company and its users.
4.2. This Internal Social Media Policy provides the main rules of conduct that all staff, and possibly external professionals appointed, are required to observe when using social media and publishing content and comments, whether this is part of their work and takes place via company account, both when through a personal account you talk directly or indirectly about the Company's activity or your role within it.
4.3. In particular, the following aspects are regulated:
a) method of managing Company accounts;
b) rules and criteria to be applied in the content production and publication process;
c) timing and methods with which to moderate the conversation;
d) language and style;
e) management of company topics with personal accounts/profiles.
5. HOW THE COMPANY ACCOUNTS MANAGEMENT
5.1. The Communications Office:
a) registers and administers all the Company's social profiles, provides for the animation of the institutional ones and coordinates the animation of the profiles created for specific projects;
b) manages the authorizations, with particular regard to situations involving employees' personal accounts (e.g. Facebook, Instagram) or which require the activation of a specific account relating to the Company in order to maintain the mapping of the authorizations assigned to the employees and know which ones sites/applications must be activated;
c) monitors the social media in which the Company is present, as well as the consequences regarding its reputation and that of its representatives.
5.2. For technical functions, the Communications Office avails itself of the collaboration of the IT Resources Office.
6. PUBLICATION OF CONTENTS ON SOCIAL CHANNELS
6.1. With the production and publication of content, the Company promotes textual, photographic and video content on its social channels.
6.2. Said contents, at the time of publication, must always meet all the following criteria:
dissemination of news relating to Company projects, events and services of concrete use to the target audience;
current nature of the news to which the social content must refer, with texts and/or images that testify either to its happening in real time (e.g. a conference, a press conference, a fair, etc.) or to its happening in a short time ( a deadline, the launch of a new product);
links to pages of the institutional website or, where existing, to project sites, where the content is referred to or explored in greater depth.
6.3. Content relating to information that enhances the historical, technical and technological research heritage, or particular curiosities relating to the Company, are also permitted.
6.4. To plan the presence of their news, the offices, services and internal working groups that wish to be covered on institutional social channels must contact the Communications Office in advance, and in any case as soon as possible, to which they will communicate their content, created under the supervision of the General Management or your manager, and the link to the institutional website page to refer to.
6.5. The Communications Office will give the content a form of text consistent with the target social network and respectful of the principles set out here. Whoever produces the content guarantees that there is no personal data (i.e. it is managed in accordance with the GDPR), company materials or information that is confidential or protected by patents/know-how, or by copyright.
6.6. Participation in conferences and initiatives of interest, including abroad, must be reported in advance to the Communications Office for appropriate planning by sending the invitation, poster and useful material. Following participation, testimonials of the event can be sent, such as, for example, photos, accompanied by a short explanatory text.
6.7. Where possible, the Communications Office will carry out events live in the forms deemed most suitable (Facebook, Instagram); it will be necessary to promptly communicate events relevant to the company to the same Team.
6.8. Regardless of specific situations, it is always possible to propose themes, news and posts that could enrich the contents of the Company's social platforms. In these situations, communication must be made exclusively to the following email address: …………..
7. TIMES, METHODS AND STYLE OF CONVERSATION ON THE WEB
7.1. The institutional social channels are managed on the basis of a weekly schedule, supported by a daily schedule when necessary. In the event of events outside working hours, the availability of the Communications Office to participate will be verified from time to time.
7.2. The contents must be processed according to the methods specific to the social network used (retweets, likes, etc.) adopting limited participation in social conversations. Any requests for information not relevant to the message disseminated, reports and complaints, even if received through private messages conveyed via the messaging systems integrated into the various social networks, must be forwarded immediately to the Communications Office.
7.3. The language must adapt to the style of the social network used. By way of example, please note that on LinkedIn it is elaborate and institutional, while on Facebook and Instagram the style is closer to the public, without losing the authority of the Company.
7.4. The rules for writing texts on the web remain valid:
a) write in correct Italian and/or English;
b) deal only with certain and verified facts;
c) respect the rules of good manners on the web (netiquette).
7.5. In particular, it is necessary that anyone authorized to publish on the Company's social networks:
a) does not offend or disrespect people and/or companies (public or private), groups or categories of people and institutions;
b) avoid any type of argument, avoiding responding to any provocations. In the latter case, it is the duty of the Communications Office to moderate inappropriate or defamatory content posted by private users on institutional channels.
8. USE OF PERSONAL ACCOUNTS
8.1. The Company's staff, when configuring, using and managing their private accounts on social media, are required to respect certain rules of conduct, aimed at guaranteeing the protection of the company and the people who work there.
8.2. The employee who chooses to disclose his/her work activity is required to specify in the personal biographical information that the opinions expressed are of a personal nature and do not in any way engage the Company's liability.
8.3. Staff can freely share the contents disseminated by the Company's social channels on their private profiles: information on services, initiatives, projects, videos, images and/or infographics. The dissemination on your private profile of Company content or events not previously reported on the official social channels or in any case not present on the Company website or on another institutional reference site is prohibited.
8.4. At the same time, staff are required to observe public behavior that is respectful of the organization in which they work. Specifically, the Company's staff:
cannot disclose confidential information through social media, such as internal correspondence, third party information of which it is aware (e.g. partners, institutions, users, stakeholders, etc.) or information on work activities, services, projects and documents not still made public, decisions to be taken and measures relating to ongoing proceedings, before they have been officially decided and formally communicated to the interested parties;
without prejudice to the correct exercise of trade union freedoms and the right to criticize, it is advisable to refrain from transmitting and disseminating threatening or abusive messages, comments and offensive public statements towards the Company, referring to institutional activities and more generally to its operated, which due to their forms and contents could in any case be harmful to the company, damaging its image or compromising its efficiency;
must always remember that their contents, even if private, once put online can have global resonance;
must respect the privacy of colleagues, avoiding references to the work carried out, without prejudice to information in the public domain;
with the exception of public events that take place in the workplace, he cannot disclose photos, videos, or other multimedia material, which capture premises and personnel without the explicit authorization of the structures and people involved;
cannot open blogs, pages or other channels in the name of the Company or which deal with topics relating to the Company's activity.
cannot use the Company brand and the brands of products or projects owned by the company on personal accounts.
9. RESPONSIBILITY
9.1. Even if directly managed by the Communications Office, the Company's presence on social media entails the responsibility of all employees, since the communication strategy must guarantee:
coherence: the presence on social media must be integrated in content and style with the Company's other communication channels, online (web, email, etc.) and offline (telephone, internal communications, etc.);
updating: using social media involves involving users and stakeholders with constantly updated information, even several times a day;
openness: we invite you to behave in the same correct, professional and empathetic manner with online users as in offline contacts.
9.2. The incorrect use of social channels can lead to the following effects:
seriously damage the image and reputation of the Company and consequently, of the professional figures who work there;
expose your profile to suspension or deletion if you do not comply with the terms of service contracts with the social media itself;
expose you to direct damages, such as claims for compensation, if content that violates copyright and intellectual property rights is published.
9.3. Violation of the rules of conduct set out in this Social Media Policy is a source of disciplinary responsibility. This responsibility is ascertained by the outcome of the disciplinary proceedings, in compliance with the principles of graduality and proportionality of sanctions, as provided for by the applicable provisions.
9.4. Employees authorized to use company social networks, who also have personal accounts, are asked to pay the utmost attention when using the profiles, adopting all the necessary precautions, including technical ones, to avoid the exchange of profiles while using the tools.
Procedure for managing requests to exercise the rights of interested parties