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:
a. 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;
b. 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:
- “product sent by…”.
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…”.