Social Media Policy

SO.GE.MI (hereinafter also “the Company” and/or “SOGEMI”), with registered office in Milan (MI), via Lombrosio n. 54 – 20137 – Italy, is the Data Controller pursuant to Article 4 of EU Regulation 2016/679 regarding the processing of your personal data and refers you to this Social Media Policy. In relation to such processing, the Data Controller provides, among other things, the following information. 

This Social Media Policy (“Social Media Policy”) should be read together with the Privacy Policy, available as a separate document in the Privacy section of the homepage at http://www.sogemispa.it. This Social Media Policy aims to describe the rules of conduct that users should follow when using the Company’s website and the social media channels managed by SO.GE.MI S.p.A. on technological social platforms. 

SO.GE.MI S.p.A. uses the website and social media platforms (hereinafter, “Social Media”) for general interest purposes: to communicate with users online, provide access to its services, and promote its activities. Social pages/channels are also used by the Data Controller to encourage participation, dialogue, and engagement with users, fostering transparency and sharing. 

SO.GE.MI S.p.A.’s website provides access to various Social Media (including, without limitation, Facebook, Twitter, etc.), which offer comment areas, bulletin boards, and public forums. Content may be published by users and can include: communications about the Company’s activities and services, information about ongoing projects, social initiatives, images, and videos related to events organised by the Company. The social pages/channels also offer services to respond to information and support requests. Comments, questions, criticisms, and suggestions from users are also collected. 

By using Social Media, the user acknowledges that data published (including text, images, videos) are publicly visible, and therefore the Data Controller cannot guarantee their privacy.

The purpose of the Social Media services provided by the Data Controller, in addition to being an additional communication channel, is to respond to requests submitted publicly on the pages/channels and forward them to the relevant Company departments for an appropriate reply. Response times may vary depending on the type of request. 

Users are advised to carefully consider whether to include personal data (including email addresses or mobile phone numbers) that could, even indirectly, reveal their identity. The same caution applies to sensitive data. Users should also evaluate whether to publish audio, photographic, or video material that could identify individuals without their consent. Additionally, users should be cautious about including data that could indirectly reveal the identity of third parties, such as others sharing the same medical condition, experience, or procedure. Data and contributions may be publicly visible and accessible by any internet user via general search engines (Google, Yahoo, etc.).

The various pages/channels of SO.GE.MI S.p.A. on Social Media may be freely followed by all internet users without any authorisation from the Data Controller. Therefore, SO.GE.MI S.p.A. advises caution when sharing personal (and sensitive) data on these platforms. The terms of use and privacy policies of each Social Media platform apply and govern the information provided by the user. The Data Controller does not monitor the use of personal information shared in public forums or comment areas, making the user solely responsible for any disclosure. 

The Company expects all participants to express their opinions courteously and reasonably. Insults, offensive language, and threats will not be tolerated. SO.GE.MI S.p.A. reserves the right to report any abusive behaviour, threats, or violent conduct to the platform operators.

Please note that the processing of users’ personal data will comply with the policies of the platforms used (Facebook, Twitter, YouTube, etc.). Privacy on Social Media is guaranteed to the extent that the user is aware of how they are using the platform, its service, and its functionalities. Currently, user awareness regarding Social Media is generally very low. Therefore, the information generated is voluntarily shared by users, who cannot later claim a violation of their personal privacy. 

Article 21 of the Italian Constitution protects freedom of expression, with certain limits. The most common limitation concerns the reputation of others; if strong language is used, users may be held liable for defamation. Everyone has the right to participate and express their free opinion. 

Personal data published by users are processed by SO.GE.MI S.p.A. in compliance with Legislative Decree 196/2003 and the provisions regarding the purposes and methods of data processing outlined in the Privacy Policy, available on the SO.GE.MI S.p.A. website in the Privacy section, which users should consult before reading this Social Media Policy. 

Personal data are also voluntarily published by users, and the Company processes them solely to provide the above-described services. 

The Data Controller is SO.GE.MI S.p.A., via Lombroso, n. 54 – 20137 – Milan (MI), Italy. Further information regarding the processing and communication of personal data, whether provided directly or otherwise acquired, can be requested from the Data Protection Officer at the Company’s registered office. This notice does not preclude the provision of additional information orally.