SOCIAL MEDIA POLICY

Nuova S.M.I. srl (hereinafter also: “Company”), with headquarter in Via Pavia, 39 – CAP 27039 – Sannazzaro De’ Burgondi (PV) – Italy, in compliance with art. 28 of Legislative Decree 196/2003 on the processing of its personal data, refers you to this Social Media Policy. In relation to the aforementioned treatments, the Owner provides, among other things, the following information.

This Social Media Policy (“Social Media Policy”) must be considered as an attachment to the Privacy Policy document which can be consulted, in a separate document, in the Privacy section on the home page at the internet address http://www.nuovasmi.it

Such Social Media Policy aims to describe the norms of conduct that users should comply with when using the website and the spaces activated by Nuova S.M.I. srl on social technological platforms.

Purpose
New S.M.I. srl uses the website and the social technological platforms below (“Social Media”) for purposes of general interest to communicate with users through the network, give access to services provided and promote its activities. The social pages / channels are also used by the Data Controller to encourage participation, discussion, dialogue with users with a view to transparency and sharing.

Contents
The site of Nuova S.M.I. srl offers and will offer access doors to the various Social Media (which may include without limitation, among others, Facebook, Twitter etc., even if at the moment it only includes Facebook), these services, provide comment areas, message boards and public forums. The contents are published by users and may include: communications concerning the activities and services provided by the Owner, information concerning ongoing projects, social initiatives, images, and videos relating to events organized by the Owner. On the various pages / channels of these platforms, response services to requests for information and assistance are activated. Comments, questions, criticisms and suggestions from users are also collected.

By using Social Media, the user accepts the fact that the published data (including text, images, videos) are freely visible to everyone and, therefore, the Owner cannot guarantee the “Privacy” of the same.

Social Media Comments and Answers
The objective of the Social Media services proposed by the Owner, in addition to making itself present as another communication channel on the network, is to respond to the requests received publicly on the pages / channels, forward them to the competent structures in order to be able to respond in a relevant manner. Response times may vary depending on the type of request.

Risk warnings
The user is advised to carefully evaluate the opportunity, in their interventions, to enter personal data or not, (including e-mail address, mobile phone number), which may reveal, even indirectly, the identity. The same precaution applies to data considered sensitive. It is also necessary to evaluate the opportunity to publish audio, photographic and video-graphic material that allow people to be identified without having asked their consent to process such datas.

Attention should also be paid to the eventuality of including data in one’s interventions that may reveal, even indirectly, the identity of third parties. Please note that the data and interventions on social networks can be publicly visible and accessible by any user of the network who accesses the website or from Social Media, indexed and also available from general search engines (Google, Yahoo, etc.).

Rules of use
The various pages / channels of Nuova S.M.I. srl on the various Social Media, can be freely followed by all the attempts of the network, without asking for any authorization from the Owner; for this reason Nuova S.M.I. srl advises to pay attention regarding the dissemination of personal (and sensitive) data when using these platforms. The terms of use and the privacy policies applicable to each Social Medium are published on their respective sites and rule the information provided by the user. The Owner does not perform any form of control on the use of personal information communicated in a public forum, a comment area, making the user of the platform solely responsible for any disclosure. The Data Controller hopes that all participants in the social life express their opinions (where possible) with correctness and measure; for this reason insults and vulgarity will not be tolerated.
Nuova S.M.I. srl reserves the right to report foul language, insults, threats and attitudes that may evoke violence to the Social Media manager.

Privacy and processing of personal data
We remind you that the processing of users’ personal data will comply with the policies in use on the platforms used. Privacy in Social Media is guaranteed to the extent that the user knows how to use the platform, the service and its potential. As a consequence the information generated will actually be shared “voluntarily” by users who, therefore, will not be able to complain about any possible violation of their personal sphere. Article 21 of the Italian Constitution protects the freedom of expression of thought, putting in place some limits. Among these, little respected, is that relating to the reputation of others. When a judgment is expressed against a user, in fact, it is useful to remember that in the use of “too strong or colorful” expressions the perpetrator could be called to answer for the crime of defamation. Everyone has the right to intervene and express their free opinion.

Any personal data published by users are processed by Nuova S.M.I. srl in compliance with the legislation referred to in Legislative Decree 196/2003 and with the provisions (with particular reference to the purposes and methods of data processing) of the Privacy Policy published on the Nuova S.M.I. srl in the Privacy Policy section, which the user is required to check before the Social Media Policy.

Furthermore, personal data are published spontaneously by users and the processing of the same by the Owner is carried out solely to perform these services.

The data controller is Nuova S.M.I. srl, which is based in Sannazzaro De’ Burgondi (PV) – ZIP code 27039 – Via Pavia, 39 – VAT number. and Tax Code 01337590184. – ITALY, further information regarding the processing and communication of data provided directly or otherwise acquired may be requested from the person in charge of data processing, at the Company’s headquarters. This warning of course does not exclude that other information is also given orally.