Redelfi S.r.l. (hereinafter, “Company”, “Organization” or “Owner”), with registered office in viale Monza 127 – 20125 Milan, operational headquarters in via Scarsellini 119, Torre B – 16149 Genoa, e-mail: privacy@redelfi.com, is the Data Controller of your personal data. In relation to the aforementioned treatment, the Data Controller provides, among other things, the following information. This Social Media Policy has the purpose of describing the rules of conduct that users should comply with when using the website and in the spaces activated by Redelfi Srl on social media platforms. This policy must be understood as an attachment to the privacy information document which can be consulted, in a separate document, in the Privacy section on the home page at the internet address https://redelfi.com/en/privacy-policy/ .

Contents

The theme channels of Redelfi S.r.l. are used to inform users about the Company’s activities, collect comments, requests, questions, criticism and suggestions. They produce their own textual, photographic, videographic and other multimedia material which must always be accredited to Redelfi S.r.l. and to the original reference channel. Comments and posts by users, who should always present themselves with their name and surname, or nickname/username, are associated with the opinions expressed by individuals. Redelfi S.r.l., in fact, cannot be held responsible for verbal content, the substantial content of the facts and the social relevance of the statements made by users.

Dissemination of data

Based on art. 21 of the Constitution, social network platforms are among the means of information dissemination through which it is possible to express opinions, judgments and criticisms. Users, as people, are subject exclusively to civil and criminal regulations that limit freedom of opinion from the outside. These rules are configured as limits to the freedom of expression of thought, also connected to the peculiarities of relationship between employers and employees: these are clarifications of the duties of loyalty and confidentiality, which are incumbent on the worker as they are inferable in work performance.

Moderation

Everyone has the right to intervene and express their free opinion. In the promoted social channels, Redelfi S.r.l. will be able to remove comments and posts that are not relevant to the theme of the channel but not only: it will be able to remove messages and posts deemed harmful, discriminatory and offensive towards the same or other users participating or not in the discussion.

Redelfi S.r.l. ‘s various pages/channels which are present on various social media can be followed freely by all users of the network, without the prior authorization of the Owner; for this reason, Redelfi S.r.l. advises exercising caution regarding the dissemination of personal (and detailed) data when using these platforms. The terms of use and the privacy policies applicable to each social network are published on the respective sites and govern 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 or comment area, making the user of the platform solely responsible for any disclosure.

Insults, vulgar language, threats or behavior that damage personal dignity, the rights of minorities and minors, or the principles of freedom and equality will not be tolerated. The following will also be moderated: comments that are off-topic with respect to the discussion of a specific post (the so-called off-topic); comments or posts that may refer to sensitive data or to a context that limits the freedoms of users; interventions inserted repeatedly or that may disturb the discussion or offend those who manage and moderate social channels, and spam. For those who repeatedly violate these conditions or those contained in the policies of the tools adopted, the staff reserves the right to block the user to prevent further interventions and to report the same, to the managers of the platform and possibly as needed to appropriate law enforcement agencies.

PRIVACY AND PROCESSING OF PERSONAL DATA

Redelfi S.r.l. reminds users that the processing of users’ personal data on so-called social media platforms is guaranteed to the extent that the user is aware of how he or she is using the platform, the service and its potential. It follows that the information generated will actually be shared “voluntarily” by users who, therefore, will not be able to complain about a possible violation of their personal sphere. Personal data are also published spontaneously by users and their processing by Redelfi S.r.l. is carried out solely for the purpose of the service performed.

The data controller is Redelfi S.r.l. (hereinafter, “Company”, “Organization” or “Owner”), with registered office in viale Monza 127 – 20125 Milan, operational headquarters in via Scarsellini 119, Torre B – 16149 Genoa. Further information regarding the processing and communication of data provided directly or otherwise acquired may be requested from the Data Controller at the Company’s headquarters. Further information may also be provided orally.

Genoa, December 14, 2021

The owner

Redelfi S.r.l.