PERSONAL DATA PROCESSING DISCLAIMER
INFORMATION ON PERSONAL DATA PROCESSING

The following “Information on personal data processing (also known as “Privacy Policy”) describes the policies and practices of West12 SRL (hereinafter also referred to as “West12”), in relation to the collection and use of personal data for Users of our West12 sites (or for a User within corporate social media for example Instagram) and clarifies their rights.

Within the principles of the code of ethics of West12, there is also that of Privacy and with respect to European Legislation (Reg. EU 679/16, hereafter also refers to “GDPR”), the topic of personal data protection. West12 continuously strive to pursue these values, therefore from time to time this policy is updated and changes to the processing of your personal data are likely to be applied. The latest update of this policy (month and year) is always indicated at the bottom of the document.

The following policy is applicable in particular to the following internet sites for which West12 is the Data Controller:
www.gallura.com
www.gallurarugs.com

For simplicity, whenever we refer to the Site in this Privacy Policy, it is intended to be one of those sites listed above.
Moreover, this information is also provided for the purpose of the social media action buttons that are present in the pages of WEST12 Site and in relation to WEST12 corporate accounts within the following social media platforms: Instagram, Facebook, LinkedIn.
(The information is not to be considered valid for other web sites that can be accessed through links present in the internet domain(s) of the Data Controller, who is not to be considered in any way responsible for the websites of third parties).

WHAT PERSONAL DATA DO WE COLLECT AND PROCESS?

The West12 Site is structured in different sections allowing the user to browse depending on their needs (e.g. searching products, downloading technical spec sheets, locating reps, etc.) as well as getting in contact with the company or to submit an application for a job opportunity. For the sake of clarity, here below we summarize the data that are collected dividing them by purpose.

1. DATA COLLECTED FROM BROWSING THE SITE
By simply browsing the site, West12 website collects personal data relating to the user’s navigation (such as IP addresses or domain names of the computers used by the Users who connect to the Site, addresses in URI (Uniform Resource Identifier) notation of the requested resources, time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the User’s computer environment) as well as keeping track of the user’s consent and all that is expressly provided for in the Cookie Policy information to which reference is made.

2. CONTACTS
Furthermore, in the “Contacts” section of the Site, each User, even though not yet a customer of West12, can fill out a form to get in touch with the company. For this purpose, some personal data of the User are required and in particular: name, surname, company they belong to (if applicable), address, zip code, city, country, email address and telephone number, which will be processed in compliance with the purposes specified below and on the basis of what is specified in this document.

3. COOKIE
When a user visits the West12 website, their browser is asked to store a small data file (text file) called a “cookie” on their device to remember certain information processed by the user, such as the preferences they have expressed (e.g. when selecting a product). The complete policy and details on cookies are available here as well as information on how a user can accept or reject cookies and change the setting of their preferences at any time.

4. LINKS TO COMPANY’S ACCOUNTS ON SOCIAL MEDIA PLATFORMS
At the bottom of the pages of the WEST12 Site are displayed two buttons that, once clicked, redirects the user to the WEST12 Instagram and Facebook accounts. The Instagram and Facebook action buttons simply redirects the user to such social media platforms and no data of the User is transmitted when the buttons are clicked.
WEST12 has chosen to be present on these platforms to better communicate with its clients as well as making its brand and products known to new Users who could potentially be interested in them. Users can share texts, photos, videos and other types of information and/or content within some social media platforms and it is their responsibility to ensure that the content they publish complies with the current regulations in place and, in general, maintaining courtesy and respect towards other users and the community of such social media platforms.
Typically, social media platforms, upon accessing their pages, collect cookies and data related to the User’s navigation. Therefore, upon accessing their pages, it is advisable that the User carefully reads and understands their Privacy Policy as they often process personal data abroad, considering that they are not necessarily on European platforms due to their international reach. As a result, the data collecting and processing of such social media platforms might not be subject to the same regulations and guidelines as per Reg. EU 679/16.

4.1. INFORMATION ON INSTAGRAM PROCESSING PERSONAL DATA
The data the User enters on the Social Media platforms, such as comments, videos, photos, likes, public messages, etc., are published by the Social Media platform and are never used or processed by West12 for other purposes. West12 reserves the right to delete contents at its own discretion in case WEST12 believes certain contents are against commonly accepted moral principles or if such contents could harm the company’s image or the rights of others. If applicable, West12 might share content on its own Site if such function is offered by the Social Media platform and West12 communicates with the Users through the platform. The data are processed in the interest of West12’s work in the area of public relations and communication.

If a User wishes to restrict a specific type of data processing that is under the control of West12, the User can send a communication to West12 (see contacts for Data Controller) in order to allow West12 to evaluate the matter and possibly take further actions.
If the request were to be made on the Social Media platform, West12 can direct it to other secure communication channels that guarantee confidentiality and ensure a more effective communication method. Confidential requests can always be forwarded to West12 by sending them to the contact details and email address indicated in this document.
West12 has limited power of influencing and cannot disable the statistics that the Social Media platform provider puts in place. However, it should be noted that they are aggregate data.
In the interest of transparency, it should be noted that these platforms usually collect cookies and navigation and usage data. This is a summary of official accounts and the information provided by the platforms themselves.
Here below a summary WEST12’s presence on Social Media.

4.1.1. PERSONAL DATA PROCESSING ON THE WEST12 FACEBOOK PAGE
If the user is registered with Facebook having their own account, they can send a message to WEST12 on Facebook by clicking on the “send message” button. These messages cannot be seen by other Facebook users. WEST12 uses the personal data that are contained and associated with these messages exclusively to respond to User’s messages. The legal basis for the processing of this data is the legitimate interest according to art. 6, Paragrapgh 1, Letter f) of the GDPR. The message is deleted once your request has been answered unless it is kept for legitimate corporate interest to protect its rights.
WEST12 also uses the “Facebook Insights” feature, which offers statistical information relating to the use (tracking accesses and browsing activity for example) of the WEST12 Facebook page by the User. This feature is provided by Facebook (refer to section 8.2 for more details).
In addition to the processing of personal data specified here, WEST12 has no influence or power over the processing of personal data in relation to the use of the WEST12 Facebook page. Therefore, it should be noted that the User uses the WEST12 Facebook site and its functions under their own responsibility. This applies in particular to the use of interactive functions (e.g., comment, share, like, etc.).

4.1.2. FACEBOOK INFORMATION ON THE PROCESSING OF PERSONAL DATA
When the User visits the WEST12 Facebook page, Facebook keeps track of certain information (in particular as part of the “Facebook Insights” function) that are collected in relation to simply accessing the platform or by interacting with other users or with the WEST12 Facebook page and its content. Details of the specific data collected and information about Facebook’s “Page Insights Data” can be found here.
To comply with GDPR requirements, Facebook has defined here, that the manager of the Site (which is WEST12 in this case) is a Joint Data Controller together with Facebook Ireland. It is also confirmed that Facebook Ireland assumes primary responsibility under the GDPR (EU Reg. 679/16) for the processing of personal data and they are responsible for fulfilling the obligations associated with the rights of the data subjects.
The Policy on Facebook’s cookies can be viewed at this address: https://www.facebook.com/policies/cookies/
Facebook’s information on personal data can be viewed at this address: https://www.facebook.com/privacy/explanation

4.2. INSTAGRAM INFORMATION ON THE PROCESSING OF PERSONAL DATA
The official Instagram account of West12 is:
Instagram Gallura
Personal data collected: Cookies and browsing and usage data.
Place of processing: USA https://help.instagram.com/1896641480634370?ref=ig&cms_id=1896641480634370

Any content or opinions other than the above specified accounts are the responsibility of the individual author and do not reflect the opinion of West12. West12 is not responsible for such third-party content. As Social Media posts may contain links, please note that WEST12 is not responsible for the content of websites that are not under West12’s immediate control and management.

Moreover, West12 cannot be held responsible for any information provided on its Social Media channels that are incorrect and incomplete.
The activity of West12 on Social Media platforms is generally carried out during the company’s working hours (Rome – Italy time zone). Therefore, there may be delays in replying to message(s) received by Users based at different time zones.

DATA CONTROLLER AND DATA PROCESSOR AND OTHER RECIPIENTS

The Data Controller is West12 SRL, a limited liability company incorporated in Italy, with registered address in Italy, 28010 Pella (NO) – Via Michelangelo Buonarroti, 37, REA NO – 308316 VAT no. 02368000226. Any request in related to the processing of personal data through its Site should be addressed to the Data Controller by way of e-mail to the following address: legalmail@west12.it.
The data may also be processed, on behalf of West12, by external parties designated as Data Processor and sub-Processor, to whom adequate operating instructions are given. These entities belong to one (or more) of the following categories:

– Hosting service providers for the Site
– IT service providers for maintenance and management of the Site and Social Media communications
– Data analytics and statistics service providers in relation to the service of tracing of visits (please refer to “Information on cookie” and the paragraph “Targeting and referral and Data analytics” of this Information
– Consulting service providers for the management of the Site

The personal data provided may also be disclosed to other recipients, as Processors acting under the authority of the Data Controller and the Data Processor, for the purposes set out in the “legal basis of the processing and purpose” section).

In particular, personal data may be disclosed to subjects within the Company for the execution of the following activities:
– Maintenance and development of the network and IT infrastructure
– Management of e-mails
– Management of websites
– Various marketing initiatives aimed at the promotion and sale of West12 products (e.g. newsletters)
– Fulfilling inquiries and request relating to West12 products (e.g. estimates) as well as production of orders
– Administrative department for the fulfillment of reporting and tax obligations resulting from Users’ requests (e.g. orders, payments, etc.)
– Legal department as per compliance with guidelines and regulations imposed by competent authorities.

At its discretion and depending on their needs, West12 might be assisted in the fulfillment of the above activities by external entities who are not under the immediate control and management of West12.

ACTION BUTTONS FOR SOCIAL MEDIA PLATFORMS

West12 uses action buttons for social media platform on its Site (i.e. digital buttons or links for redirecting the User to the Social Media platforms configured in each “button”). By clicking these buttons, it is possible to access and interact with the accounts (social pages) of West12. The managers of the Social Media platforms to which the buttons refer to are the independent Data Controllers.
If the services of these third-party platforms are activated (e.g. social buttons of Instagram and Facebook), the User is advised to be aware of their privacy policies before accessing and/or requesting services not controlled by West12. Information on how to manage and disable the related cookies can be found on the Social Media platforms and with regards to those on the West12 Site, in the “Cookie Policy” dedicated section. To comply with GDPR requirements, Meta (owner of Facebook) has established that the manager of the Site, WEST12 in this case, is a Joint Data Controller together with Facebook Ireland. The above can be reviewed here.
It is also confirmed that Facebook Ireland assumes primary responsibility under the GDPR (EU Reg. 679/16) for the processing of personal data and is responsible for fulfilling the obligations related to the rights of the data subjects. WEST12 considers other platforms independent Data Controllers (it is possible to find detailed information for each use of the platforms in this information).

LEGAL BASIS OF THE PROCESSING AND PURPOSE

The legal basis for the processing of Personal Data differs depending on the purpose. In particular:
1. CONTRACT
Job Application
If West12 responds to a spontaneous job application and curriculum vitae submission, all the personal data that are indicated by the candidate will be processed for pre-contractual and contractual purposes for the sole purpose of evaluating a potential recruitment.
West12 does kindly request a candidate to indicate only the necessary data in their CV for the purpose of evaluating their application, refraining from entering personal data relating to health or, in general, other data belonging to the so-called “special categories”, such as, for example, data revealing your religious beliefs, political opinions, etc., which are to be indicated only where it is strictly necessary. If the candidate submits such data along with other documents that are sent voluntarily, West12 will requests the candidate to express their written consent to the processing of these data.
If the candidate might choose to insert images or videos with links to an external platform (YouTube, Dropbox, etc.), West12 is not liable in any way for the choice of the platforms used. West12 invites applicants to choose platforms that are compliant with GDPR and secure.
Purchases made through the Internet site or email
In the case of a purchase by means of an order made through the Site by sending an email or filling out a form, the personal data collected (typically name, surname, email, physical address, company, role, telephone number and type of purchase the client wish to make) will be processed to fulfill the contractual supply that you have requested from us as well as to carry out the related administrative, accounting and tax obligations (mandatory data for the final execution of the purchase).

2. CONSENT
Generally, the User can choose the setting of their data collection and processing by West12 as they wish. Only exception applies to some technical information (“technical cookies”) which, if not provided, would result in the inability for the User to access and browse the Site. (For more details on cookies, please refer to the “Cookie Policy” dedicated section).

2.1. PERSONAL DATA PROVIDED THROUGH THE WEST12 CONTACT FORM
At the “Contact” section of the Site, the User, even though not yet a West12 customer, can fill out a form to get in touch with the company. For this purpose, some personal data of the User are required and in particular: name, last name, company to which they belong to (if applicable), address, zip code, city, country, email address and telephone number, which will be processed solely for the purpose of responding to their request. In the event the User has omitted the provision of one or more mandatory Personal data, an error message from West12 will appear with a list of the missing mandatory Personal data. The provision of the data is optional, however, failure to provide such data will make it impossible for the Data Controller to process the User’s data and consequently, preventing the successful submission of the inquiry through the contact form of the West12 Site. The personal data the User voluntarily enters by filling in the on-line form will be stored in a database exclusively for the purposes indicated above and for a period permitted by the law. Moreover, the access to these data will be allowed only to the company personnel in charge and the Data Processors for support services (e.g. companies that offer technological platform services, software maintainers, etc.), bound by confidentiality and security of the data by means of a contract. Data processing will take place exclusively within the European Union.

2.2. BY BROWSING THE SITE WHEN IT REQUIRES SPECIFIC SERVICES (NON-TECHNICAL COOKIES)
By browsing on the Site and/or accessing certain sections of the Site, the collection and subsequent further processing of the User’s Personal Data by West12 might occur. In fact, when connecting to the Site, the computer system and the software necessary for their functioning, administer cookies when the User requests certain services (e.g. to view a video on our Site or through YouTube). As a result, the Site requires the installation of an explicit “cookie”. More details on cookies can be found in the “Cookie Policy” at the bottom of each page of the Site.

2.3. BY BROWSING THE SITE TO IMPROVE THE PERFORMANCE OF THE WEST12 SITE (NON-TECHNICAL COOKIES)
West12 uses Google Analytics to install, subject to your consent, IP address and analytical cookies which permit West12 to track the number of visits and traffic sources to be able to measure and improve the performance of the Site. These cookies provide information on which pages are the most popular as well as those that are least visited. Moreover, these cookies provide information on how visitors navigate the Site.
Google Analytics is an application for tracking online visits to our websites and display reports on these visits for analysis.

The data processed by Google Analytics also include:
– IP address (by default the IP address is stored anonymously)
– Location of the user: country, region, city, approximate latitude and longitude (geolocation may only be possible by cross-referencing other information. West12 does not perform this type of analysis)
– Browser, browser version, device type, operating system
– Date, time and time zone of the local user
– Pages visited (page URLs and page titles)
– Resolution of the screen being used
– URL of the page that was viewed before the current page (Referrer URL)
– Parameters in the URL referring to the marketing campaign
– files that were clicked and downloaded (Downloads)
– links to an external domain that was clicked on (outlinks)
– screen resolution
– Page generation time (the time it takes for web pages to be generated by the web server and then downloaded by the user: page speed)
– User ID
– User Agent of the browser used (User-Agent header) and are only processed by West12 and its web hosting platform.

3. LEGITIMATE INTERESTS
Personal data are processed for the legitimate interest of West12 and for the following purposes:

3.1. USER’S NAVIGATION ON THE WEST12 SITE AND TECHNICAL COOKIES
By browsing on the Site and/or accessing certain sections of the Site, the collection and subsequent further processing of the User’s Personal Data by West12 might occur. In fact, when connecting to the Site, the computer systems and software necessary for their functioning automatically and indirectly administer and/or acquire certain information (such as, for example, so-called “Technical cookies”, as specified in the “Cookie Policy”, “IP” addresses, domain names of the computers used by Users who connect to the Site, the addresses of the requested resources in “Url” notation, the time of the request to the server).

3.2. WEST12’S RESPONSE TO USERS’ REQUEST THROUGH THE SOCIAL MEDIA ACCOUNTS OF WEST12
When West12 responds to a User’s explicit request for information regarding West12’s products and activity, West12 acts in its own legitimate interest and that includes marketing and promotional efforts aimed at adequately assisting existing or potential customers who have expressed interest in West12’s brand and products. Specifically, West12 will process the User’s Personal Data exclusively to contact the User in relation to their request processed through any social platform in which West12 is present (Facebook, Instagram, etc.). Such requests might come in the form of a comment or post made by the User (the content of which may include Personal Data provided directly by the User), on Social Media platforms managed independently by third parties (independent Data Controllers), such as, by way of example and not exhaustive, Facebook, Instagram, etc. (hereinafter “Social Media”). Comments and posts on Social Media are intended as contributions by way of images, statements, etc. related to the subject matter of the Site or other West12 contributions published through the aforementioned Social Media as well as the contents and any other information produced by the User and published on the Social Media pages dedicated to West12 brand and products. The publication of such contributions can also take place through a pseudonym (“nickname”) chosen by the User in the aforementioned Social Media. Together with the nickname, the User’s account could also be displaying an image.
Through their own Data Processors, the data processing carried out by West12 might include the User name (or nickname used), the profile picture, the description of the profile, gender, language, and possibly the “likes” inserted, the contributions published (comments and posts) as well as some personal data the transmission of which is implicit in the use of Internet communication protocols and that computer systems acquire during their normal functioning, such as IP addresses and other parameters relating to the device used by the User and how the User became aware of the brand profile (referral). These data are used in order to obtain anonymous statistical information on the use of the web page and to allow it to function correctly.
Without prejudice to the provisions elsewhere in this Privacy Information, in no case will West12 make the personal data of Users accessible to other Users and/or third parties.

3.3. DIRECT MARKETING
The User’s personal data may be processed for the necessary activities and the fullfilment of certain obligations required by the law in relation to purchase preferences expressed by the User’s explicit request(s) through the filling of the contact form on the West12 Site and/or through messages sent by the User through Social Media platforms to which West12 will respond accordingly.
The User’s personal data may be the subject of statistical activities carried out based on the User’s previous purchase choices and/or based on the User’s interest in West12 products and services expressed by browsing the West12 Site (aggregate data relating to the pages visited) or by means of direct and explicit requests received by filling the dedicated contact form or other messages received via social media.

3.4. TO ASCERTAIN, EXERCISE OR DEFEND THE RIGHTS OF WEST12
If necessary, to ascertain, exercise and/or defend the rights of the Company in court (also with reference to credit recovery relating to a purchase initiated with the submission of an order by filling in a form on the Site or sending an e-mail message or any other contact made through other social media platforms utilized to communicate with West12) and in the case of legal disputes, West12 may also process the User’s personal data for legitimate interest (and keep them in the case of judicial dispute, for the entire duration of the same, until the deadlines for appealing actions are exhausted). Moreover, personal data (e.g. log files) could also be used to ascertain responsibility in the event of hypothetical cyber-crimes against the Site.

3.5. TARGETING, REFERRAL AND ANALYTICAL DATA
West12 is keen to make all potentially interested Users understand the value of its textiles known for their standards of quality, innovation, authenticity and beauty. Therefore, and for this reason, West12 carries out targeting activities to market its products to specific market segments or to understand the interest and preferences of Users in certain areas related to West12 products or company philosophy and practices (e.g. origin of raw materials, sustainability of the production processes, etc.) through some social media platforms (e.g. Facebook, Instagram, etc.). West12 does not collect personal information on a single individual, but can, through the collection of aggregate data, for example, obtain information relating to the interest of Users after making a new communication transmitted via social media platforms. This information is divided according to the gender, nationality, language utilized by the browser, the interests of the Users, the number of actions, the impressions, the number of people who perform an action and the average of daily impressions.
From social media platforms, West12 also receives statistics on Users’ clicks on a social page that leads them to West12 (referral) through “Google Analytics” functions, to understand how visitors interact with the apps and sites themselves.
It also integrates with Google Ads, allowing the User to review the performance of online advertising campaigns by tracking Site visits and the queries performed by users in the Google search engine. This data can in fact be statistically deduced by the Google Analytics service only from the use of the service itself. More information on the Google Ads service as an independent data controller is available here.
In addition to the pages visited, the collected data may also include, by way of example but not limited to, the domain names and the type of browser of the computers used to connect to the Site, the URI (Uniform Resource Identifier) addresses of the resources. requests, the time of the request, parameters regarding the operating system and the IT environment utilized by the User.
The data collected in the manner set out above are used by Google for the purpose of tracing and examining the use of the Site, compiling reports on its activities which can be viewed by the West12 authorized Site operators and providing other services relating to the activities of the Site and Internet usage.
Google may also use the data to contextualize and personalize the advertisements of its own advertising network. The administrators of our Site and West12 as Data Controller cannot in any way connect the data collected with the User’s identity, either directly or indirectly.
In fact, the information obtained from this service only reports aggregate statistics indicating: sessions, page views, average session duration, pages per session. In addition, such reports might indicate whether the User was directed to the Site via a Social Media platform such as Facebook, Instagram, Pinterest, etc.
On all the platforms used (Google Analytics) West12 receives and processes only statistically aggregated data that do not identify Users.

MANDATORY NATURE OF THE PROVISION OF DATA

The provision of personal data which, on the contact form of the Site are marked with an asterisk, is mandatory. Failing to provide such information will result in West12 not being able to contact the User and process their request.
The provision of personal data is optional with regards to analysis and profiling cookies. Should the User choose not to provide personal data for the purpose of analysis and profiling cookies, West12 will not be able to improve its services because it will not be able to access the statistical information relating to the User’s navigation.

TRANSFERS OF PERSONAL DATA TO THIRD COUNTRIES

The data will be processed exclusively by personnel and collaborators or by those expressly appointed as Data Processor. Apart from these hypotheses, the data will not be disclosed to third parties or disseminated, except in the cases specifically provided for by national or European Union law.
West12 will keep the User’s Personal Data in Italy at its headquarters and will not transfer the User’s personal data to third countries, nor will it be disclosed to third parties, without receiving prior explicit consent by the User. The User’s personal data might be disclosed to third parties without explicit consent only if required by law or to defend our rights, in our legitimate interest and always in compliance with the GDPR.
Countries not belonging to the European Economic Area (EEA, i.e. EU + Norway, Liechtenstein, Iceland) or to an international organization are considered third countries for the purposes of this information, provided that the suitability of the third country or organization is recognized by decision of the European Commission (Article 45 of EU Regulation 2016/679).
The personal data collected through external platforms or social media accounts to which the User is connected are not under the direct control of West12 except when the User voluntarily contacts us through them (e.g. message sent to West12 through Instagram, or a sign of appreciation (so-called “Like”) inserted in a West12 page disclosed through social media). In this case, the transfer of the User’s personal data abroad (United States) by Instagram could take place by means of sharing on the aforementioned social media for which the User has knowingly given prior consent to the processing of the aforementioned owners of platforms in which the relevant information should be found.
The data may be transferred abroad to non-European countries, and in particular to the United States, only after verification of the Standard Contractual Clauses adopted/approved by the European Commission pursuant to Article 46, paragraph 2, letters c) and d) of the GDPR or the binding rules for the company referred to in Article 47 of the GDPR or, in the absence thereof, pursuant to one of the derogatory measures referred to in Article 49 of the GDPR.
It is recommended to read the policies of the various platforms on which West12 may be present, as these platforms often declare – as independent data controllers – both that they may transfer data abroad and that they may share processed personal data with other affiliates and business partners.

STORAGE PERIOD

The User’s personal data will be kept in the West12 records for the period strictly necessary to manage the request submitted through the contact form of the Site. Subsequently, such personal data may be stored in relation to any purchases made by the User following the initial contact and up to ten years from the date of the invoice. Should the User initial contact be limited to obtaining certain information on West12 products and services and not be followed by a purchase, the User’s personal data will be kept on file for direct marketing purposes so that the User might be informed by West12 about products (or services) similar to those for which they originally contacted the Company through the Site. Such promotional communications (e.g. newsletters) can be stopped at any time by the User. Every e-mail contains a cancellation link.
The curriculum vitae sent to West12 as a result of a spontaneous, unsolicited job application are kept for a period of 5 years. This ensures that potential future employment opportunities with West12 can be brought to the attention of the User.
The log files relating to browsing the West12 Site will be kept for one year.
The data relating to cookies are stored as indicated in the “Cookie Policy”.
All other personal data are stored for a period of time not exceeding the necessary period for the purposes for which they were collected or subsequently processed in accordance with the provisions of legal obligations.

RIGHTS OF THE DATA SUBJECT

The User has the right to request West12, at any time, to access their personal data, to request their rectification, deletion or restrict their processing, to object their processing and to request data portability to keep it or pass them on to third parties.
In relation to the purposes that require consent, the Data Subject has the right to revoke the consent previously given without prejudice to the lawfulness of the treatment provided up to that point.
The User also has the right to file a complaint with the “Garante per la protezione dei dati personali” as the Italian Data Protection Authority. The Italian DPA is an independent administrative authority based in Rome and established by the so-called privacy law (Law No. 675 of 31 December 1996) and regulated subsequently by the Personal Data Protection Code (Legislative Decree No. 196 of 30 June 2003) as amended by Legislative Decree No. 101 of 10 August 2018, which also established that the Italian DPA is the supervisory authority responsible for monitoring application of the General Data Protection Regulation (pursuant to Article 51 of Regulation No. 2016/679).
In relation to the processing of personal data by a Social Media provider, any questions or complaints must be forwarded to the Social Media provider in question.

MINORS

Minors under the age of 18 must not give information or personal data to West12 in the absence of parental consent or those who can exercise parental responsibility over them and of a clear and lawful purpose. In the absence of this consent, it will not be possible to register the minor in the appropriate sections where forms can be filled out (“Contact” section) and in general, in the West12 archives. West12 invites all those who exercise parental responsibility over minors to inform them about the safe and responsible use of the Internet and the Web and to ensure that unauthorized minors do not access West12 services, without the consent of the person exercising their parental authority.

LINKS TO OTHER SITES AND USE OF “SHARE” FUNCTIONS

This Website may, from time to time, provide links to other websites. WEST12 has no control over these sites and is in no way responsible for their content. This Privacy Policy, therefore, does not cover the use of such websites. Users are encouraged to read the privacy policy or the statements of other sites before accessing them. If the User wishes to share a WEST12 article from its websites and by means of other social media platforms (e.g. Facebook, Instagram, etc.), WEST12 invites the User to carefully read the information provided by the owners of the aforementioned social networks over which WEST12 has no control. The above-mentioned platforms are independent Data Controllers of the User’s personal data (if the User has an account with them). The User can deactivate the sharing of their account data with third-party applications by accessing the account settings).

CHANGE OF OWNERSHIP IN THE CORPORATE STRUCTURE

West12 may expand or reduce its business and this may involve the sale and/or transfer of control of all or part of it. The data provided by the Users will, where it is relevant to any branch of our business being transferred, be transferred together with that branch and the new owner or new controlling entity will, under the terms of this Policy, be authorized to use the data for the purposes for which the data was originally provided.
In the event that the data sent by Users must be transferred, West12 will inform the User by means of an official communication via its website of any changes so that the User can contact West12 and decide whether to keep their data with the new owner, have it erased or to exercise any right provided for by the law concerning the processing of personal data.

Version updated March 21st 2024