Introduction
PENNELLIFICIO OMEGA SPA (hereinafter referred to as “Company”) publishes institutional content on its website www.omegabrush.com, a virtual place where all information of public interest and in-depth activities offered to users of the institution are stored, which are often accessible directly online.
To involve more and more people in the activity of institutional communication, the Company is also on social media (Twitter, Facebook, LinkedIn, YouTube, etc.) with the aim of institutional purposes and general interest, listen to opinions and inform users in real time of the initiatives and services offered, which they can deepen on the site.
Policy for the Processing of Personal Data – regarding the use of social networks and communication and digital interaction channels – compliant to the European Regulation n. 2016/679 (GDPR)
Data Controller
Data Controllers are
PENNELLIFICIO OMEGA S.p.A., whose contact details are omega@omegabrush.com, ph. +39 051 530165 as administrator of “social” pages;
and the following co-owners as providers of the social media technology platform:
- for Facebook and Instagram, Facebook Ireland Limited, Hanover Reach, 5-7 Hanover Quay, Dublin 2, Ireland.
- for Twitter, Twitter International Company, an Irish company with registered office at The Academy, 42 Pearse Street, Dublin 2, Ireland.
The Company prescribes that co-owners must be established within the EU and accepts that they may make and implement decisions on the processing of Statistical Data. Any disputes will be handled with jurisdiction in Italy.
If the Company is contacted by the data subjects or by the Italian Personal Data Protection Authority regarding the processing carried out on the social pages, it must promptly notify the co-owner within 7 calendar days.
Data Protection Officer
The Company is not obliged to appoint the Data Protection Officer.
For the other co-owners, the contact details of the Data Protection Officer are available on the respective institutional websites.
Purpose of data processing
The processing is aimed at ensuring new channels of information, communication and dialogue with users, with immediate interaction and participation, in order to allow the strengthening of an active relationship between users and the Company, in line with the fundamental functions and objectives of corporate action.
Legal basis of data processing
Data processing takes place:
- for the execution of requests made through the service (art. 6, paragraph 1, lit. b) of GDPR);
- in the legitimate interest of the data controller, consisting in the need to verify and manage the contents of the services and products offered, also as moderator and controller of compliance with the use of the services policies (art. 6, paragraph 1 lett. f) of GDPR).
Processed data categories
Personal data are provided directly by the data subject and consist of personal identification and contact data; any other data provided voluntarily by users may be processed in order to ensure the fulfillment of the made requests, in compliance with art. 6, paragraph 1, lett. b) of GDPR, as well as, with regard to data belonging to particular categories of data provided for by art. 9 Paragraph 1 of GDPR, in compliance with paragraph 2 below, paragraphs a) and e).
Processed data recipients
The data collected will not be transferred to third parties, with the clarification that with the use of communication systems and digital platforms not owned by the Company, the user communicates his data also to the owners of the aforementioned systems and platforms, joint data controllers.
Any collected cookies are used as user session identifiers and serve exclusively to the system to ensure the correct pages navigation without any storage of personal data.
However, by using “social” services, you may also receive cookies from sites operated by other organizations (“third parties”), such as Facebook Insight, Twitter, Google+, Google Analytics, etc. The most common use of these cookies is aimed at the sharing of content on social networks and the navigation analysis by the aforementioned third parties. These cookies presence involves the transmission of information to and from all sites operated by third parties. The management of the information collected by these subjects is governed by the relevant policies to which we please ask you to refer.
Data Transfer
The collected data will not be transferred to third countries or organizations located outside the GDPR application space.
Data retention period
Data will be stored at least one calendar year and will be obscured as soon as the operations of use and internal statistics of the Company have been completed.
Data subject’s rights
The data subject may at any time ask the Company for access to personal data, rectification, cancellation or limitation of the processing of personal data or to object to their processing in addition to the right to data portability. The procedures for the rights exercising set out in articles 15 to 21 of GDPR are published on the Company’s institutional website or can be requested by writing to the Company’s institutional address.
Consent withdrawal: the data subject may at any time withdraw their consent to their data processing without prejudice to the lawfulness of the processing based on consent prior to revocation. The consent revoked to those data necessary for the services supply involves the interruption of the same ones. The data subject may lodge a complaint with a supervisory authority.
Social Media Policy
The Social Media Policy is the code of conduct, formally adopted, that 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 Digital Team, and in particular by authorized employees.
The Company reserves the right to create Pages or Groups dedicated to the promotion of specific projects, identifiable through the page title and managed by other sectors of the organization by specifically authorized people.
Comments and posts of users, who are invited to always show up with first and last name, represent the opinion of individuals and not the one of the Company, which can not be held responsible for what is posted on its channels by third parties.
Moderating
The Company’s social media channels are normally moderated during office hours (Monday/Friday from 8:30 to 16:30).
The Society invites users to a polite, pertinent and respectful conversation: on the Society 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 promptly removed.
Insults, profanity, threats or attitudes affecting the dignity of people and the dignity of the institutions, the minorities and minors rights, the principles of freedom and equality and in particular:
- content that promotes, favours, or perpetuates discrimination on the basis of sex, race, language, religion, political opinion, belief, 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 activities
- information that could likely compromise public safety
- content that violates the interest of a legal property or third parties
- comments or posts that present particular personal data categories in violation of GDPR.
Comments and content of the following genres are also discouraged and in any case subject to moderation:
- comments not relevant to the particular topic published (off topic)
- comments 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
- repeated comments
The Company reserves the right to remove any content that is deemed 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 instruments adopted, the Company reserves the right to ban or block those users with the aim of preventing further action and possibly reporting those users to the police.
Privacy Policy
Please note that the processing of users personal data responds to the policies in use on the platforms used (Twitter, Facebook, LinkedIn, YouTube, etc.). Please note that personal data posted in comments or public 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 processed in compliance with GDPR.
To contact the editorial staff of the Company’s social channels, please send an email to the institutional e-mail address.
Below are the policies for each social media used by the Company, to clarify what type of content is conveyed, who produces them and how the online conversation is handled.
Twitter Policy
The Company’s Twitter account is https://twitter.com/OmegaBrush.
To post messages are not used automatisms, such as tools that generate tweets from RSS feeds: the tweets are made and published exclusively by the people in charge.
Tweets posted by the Company are related to the Company’s activity or in any case related to topics deemed of interest to followers.
Account followers are not automatically tracked. The followers analysis is carried out with the aim of better identifying the recipients of the messages and adopting appropriate communication methods and content.
Comments, proposals and ideas from all followers are appreciated.
Direct response is not guaranteed but, where the topic usefulness and the communicative style adequacy are identified, the Digital Team participates in the conversation and responds to the requests received.
Facebook Policy
The Company has an institutional profile on Facebook https://www.facebook.com/Pennellificio-Omega-SpA-606001372864284/ and other Pages or Groups dedicated to the promotion of specific projects.
The Company followers are not automatically followed.
Users who “like” the page and users who “register” are statistically analyZed with the aim of better identifying the recipients of the messages and adopting appropriate communication methods and content.
Users can post on their Facebook profile texts, photos or videos citing the Company: the posts will be notified as “Mentions” to the Company and the Digital Team will evaluate whether to re-propose them by sharing them on its page.
Users can contribute with a review to the Company in the “Reviews” section, informing their friends of their rating. Users are free to share the Company’s posts on their profiles.
The Company’s Facebook page is not reachable via private messages. For this type of need please refer to the communication via email on the institutional e-mail box. Comments, suggestions and ideas from visitors are appreciated. Direct response is not guaranteed but, where the topic usefulness and the communicative style adequacy are identified, the Digital Team participates in the conversation and responds to the requests received.
Instagram Policy
The Company has an institutional profile on Instagram https://www.instagram.com/omegabrush/ and other profiles dedicated to the promotion of specific projects.
The Company followers are not automatically followed.
Users who “like” posts are statistically analyzed with the aim of better identifying the recipients of the messages and adopting appropriate communication methods and content.
Users can post on their Instagram profile texts, photos or videos citing the Company: the posts will be notified as “Mentions” to the Company and the Digital Team will evaluate whether to re-propose them by sharing them on its page.
Users are free to share the Company’s posts on their profiles.
Comments, suggestions and ideas from visitors are appreciated. Direct response is not guaranteed but, where the topic usefulness and the communicative style adequacy are identified, the Digital Team participates in the conversation and responds to the requests received.