Privacy Policy
PRIVACY NOTICE
DATA PROCESSING THROUGH SOCIAL MEDIA
This notice provides the data subjects with information about the processing of personal data carried out through the Social Media platforms used by BKT Europe Srl (hereinafter also the “Company”), as a processing controller or joint controller, in accordance with the following specifications.
WHO IS THE CONTROLLER AND HOW TO CONTACT THEM
The data processed through social media platforms is processed by BKT Europe Srl, in the person of its pro tempore legal representative, with registered office at Viale Bianca Maria 25, 20122 Milan, and operational headquarters at Viale della Repubblica 133, 20831 Seregno (MB), VAT number 05404270968, email privacy@bkt-tires.com
The Company processes user data in its capacity as controller or joint controller with the operator of the social network indicated below, depending on the platform used.
The information is processed by BKT Europe Srl jointly with Meta Platforms Ireland Ltd (Ireland/EU - "META"), the operator of Instagram and Facebook.
BKT Europe Srl has entered into a joint controller agreement with META that establishes the division of data protection obligations between BKT Europe Srl and META. Details on the processing of personal data for the generation of statistics and the agreement between BKT Europe Srl and META can be found at: https://www.facebook.com/legal/controller_addendum
The personal data processing not attributed to BKT Europe Srl in this notice is independently controlled by Meta Platforms Ireland Ltd. Further information on the processing of personal data by META can be found at https://privacycenter.instagram.com with regard to Instagram, and at https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0
with regard to Facebook.
The processing of personal data, unless otherwise specified in this notice, is controlled by META as specified in the policy https://www.facebook.com/privacy/policy
BKT Europe Srl has a LinkedIn profile where it presents the company and individual services. The processing of personal data, unless otherwise specified in this notice, is controlled by LinkedIn Ireland Unlimited Company ("LinkedIn Ireland") Ireland/EU. Further information on the processing of personal data by LINKEDIN can be found at https://www.linkedin.com/legal/privacy-policy
LINKEDIN provides the Company with anonymized statistics and insights for the profile, to allow the Company to evaluate the types of actions people take on the profile. This data is created based on specific information about the users who have visited it. BKT Europe Srl is a joint data controller with respect to such data.
A joint controller agreement has been entered into with LINKEDIN that establishes the distribution of protection obligations between the Data Controller and LINKEDIN. Details on the processing of personal data and the agreement with LINKEDIN can be found at:
https://legal.linkedin.com/pages-joint-controller-addendum
BKT Europe Srl has a YouTube channel. The Service allows you to discover, watch and share videos and other content, and provides a platform for creators and advertisers, large and small, to distribute original content.
The provider of the YouTube service in the European Economic Area is Google Ireland Limited, a company incorporated and operating under the laws of Ireland (Registration number: 368047), located at Gordon House, Barrow Street, Dublin 4, Ireland, and is part of the Alphabet Inc. group.
Google processes the personal data of YouTube visitors and users as an independent controller. When a user logs in to YouTube, they agree to YouTube's terms of use, privacy standards and cookie policy as well as Google's processing of their personal data, over which the Company has no control. If the user is not registered with YouTube, Google may still perform statistical analyses of your personal data when you access the Company's YouTube channel and provide the Company with anonymous statistics about this. Therefore, only certain aggregated information (such as the number of profile or media clicks and the watch time of a specific video) is visible to the Company through its account. In addition, the Company does not have the ability to prevent or stop the use of such tools on your Google account. To find out more about the processing carried out by Google, please refer to the relevant notice: https://policies.google.com/privacy?hl=it
The company operates a Twitter profile. The service provider is: Twitter International Unlimited Company One Cumberland Place, Fenian Street Dublin 2, D02 AX07 IRELAND
Twitter and the Company operate as independent controllers and have entered into a controller agreement
available at the following link https://gdpr.twitter.com/en/controller-to-controller-transfers.html
To find out more about the processing carried out by Twitter, you can consult the relevant policy: https://twitter.com/it/privacy/previous/version_14
The company operates a TIKTOK profile. The TIKTOK provider for the EU is TikTok Technology Limited, Irish company no. 635755, with registered office at 10 Earlsfort Terrace, Dublin, D02 T380, Ireland.
TIKTOK and the Data Controller operate as independent data controllers and for promotional profiles they have signed a Data Controllers agreement, which can be consulted at the following link https://ads.tiktok.com/i18n/official/article?aid=893639991572679936
To find out more about the processing carried out by TIK TOK, you can consult the relevant policy: https://www.tiktok.com/legal/page/eea/privacy-policy/it-IT
WHAT DATA IS PROCESSED
When data is processed under joint controllership:
When the data subject interacts on the Instagram page of BKT Europe Srl, the Company may process various data: those that the data subject makes public, those that he or she transmits with comments or messages, and those relating to the statistics processed by META.
META provides the Company with anonymized statistics (Insights) for the Instagram and Facebook pages to help the Company understand the type of actions that users take on the pages and allow it to offer content that is increasingly in line with public interests and that may be improved based on certain information about users who have visited the pages or who may be interested in them. This processing of personal data is carried out by the Company and META as joint controllers. The Company is not able to attribute the information obtained through statistics and sponsored emails to individual Instagram or Facebook profiles that interact with its Instagram or Facebook page.
Find out more about Instagram insights:
https://www.facebook.com/business/help/441651653251838?id=419087378825961
Learn more about Facebook insights:
https://www.facebook.com/business/help/144825579583746?id=939256796236247
When a LinkedIn user visits, follows, or connects with the Company's Page, LinkedIn processes personal data to provide the Company with Page Insights. In specific, LinkedIn processes the data provided by the subject in their LinkedIn profile, such as job function, country, industry, seniority, company size and employment status. In addition, LinkedIn will process information about how a user interacts with the company page, such as whether a user is a follower.
The Page Insights provided to the Company consist of aggregated data and, despite its joint controller status, LinkedIn will not provide the Company with the users' personal data in connection with Page Insights or allow the Company to link Page Insights to individual users.
Further information on LinkedIn's processing can be found in the relevant policy: https://www.linkedin.com/legal/privacy-policy
When data is processed as an independent controller:
The Company also processes the information that data subjects provide via the company page on the social media platform. This information may include the user name used, contact details or messages sent. The Company carries out these processing operations as the sole data controller.
The Company may access data that followers share publicly, such as username or name.
The categories of data that may be processed in the event of interactions on the Company's social pages or profiles, as followers or through comments or direct messages, are:
WHAT ARE THE PURPOSES AND LEGAL BASES OF THE PROCESSING?
The purposes for which the data is processed through social networks are as follows:
We rely on several legal bases in order to process your data lawfully:
The processing of page or profile statistics is based on the controller's legitimate interest in evaluating the types of actions taken on the page or profile and is aimed at improving the page or profile based on these indications. The legal basis for this processing, therefore, is Art. 6 (1) (f) GDPR.
The data relating to followers of the page or profile and the data relating to comments or messages sent spontaneously by users is processed on the basis of the Data Controller's legitimate interest in contacting the applicants. The legal basis for data processing is Art. 6 (1) (f) GDPR.
Further processing of data may take place with your consent (Art. 6 (1) (a) GDPR) or for compliance with a legal obligation (Art. 6 (1) (c) GDPR).
At the user's request, furthermore, the data sent voluntarily through direct messages may be used to initiate pre-contractual negotiations.
Intra-group communications and the sharing of reports take place in response to the Data Controller's legitimate interest.
Should it be necessary, the data can also be used given a legitimate interest of the controller, which involves verifying the security and correct functioning of the IT systems used and carrying out defensive initiatives.
HOW IS THE DATA MANAGED?
The data collected is processed with IT instruments and only residually with print-based methods. Adequate security measures are adopted to prevent the loss of data, illegal or incorrect use and unauthorized access.
Transferring data abroad
Some processing operations may involve transfers outside the European Economic Area.
In cases of joint controllership:
In cases when the Company is an independent controller:
In cases when the managers of Social Network platforms are the independent controllers:
Storage period
The data is stored for as long as users leave it available on the platforms.
Direct messages are deleted after 2 years.
This is done without prejudice to any defensive needs for which the data can be kept also beyond the indicated deadlines.
WHAT HAPPENS IF THE DATA IS NOT PROVIDED
The provision of data through messaging systems or comments is optional and voluntary. It will not be possible to interact directly on social media in this case, but there will be no consequences for failure to provide it.
As far as META is concerned, the user may avoid providing data for page statistics - given that the provision is optional and there are no consequences for failure to provide it - by objecting to the processing, as indicated in the appropriate section of this notice.
WHO CAN SEE THE DATA
The data will be processed by employees of the Controller who are authorized to process it.
The data can be seen by companies which provide IT supply services and by consultants to manage disputes and for legal assistance should there be any disputes due to which it is necessary to involve them.
Please note that some of the indicated subjects act as controllers and others as data processors and that communication to those who operate as independent controllers is carried out since prescribed by legal obligations or is necessary to fulfil the obligations arising from the pre-contractual relationship or the legitimate interest of the controller in maintaining the security of the IT systems and in adopting defensive initiatives through legal consultants.
In cases of processing carried out under joint controllership, the data will be shared with the joint controllers.
The data subject may request a detailed list of data recipients from the Data Controller, to the extent to which they can be identified specifically.
Please note that communication of the personal data is limited, in any event, to the data categories the transmission of which is necessary to undertake the activities and purposes being pursued.
WHAT ARE THE DATA SUBJECT'S RIGHTS?
The law recognizes for the data subject the right to ask the Data Controller for access to the personal data and its rectification or cancellation or limitation of the processing regarding them or to object to its processing, as well as the right to data portability.
In particular, it is noted that there is the possibility to object to the processing of data done for marketing purposes.
The data subject may assert their rights at any time, without formalities, by contacting the Controller through the email privacy@bkt-tires.com
Here below is a breakdown of the rights recognized by the law in force on the protection of personal data.
Please note the il right to object, in particular, i.e., the right of the data subject to object at any time, on grounds relating to their particular situation, to the processing of their personal data as required for the performance of a task carried out in the public interest or in connection with the exercise of the official authority vested in the controller or for the furtherance of the legitimate interests of the Data Controller or of a third party. Should the personal data be processed for direct marketing purposes, the data subject has the right to oppose at any time the processing of the personal data regarding them undertaken for these purposes, including profiling to the extent this is connected to such direct marketing.
META also offers the possibility to object to certain data processing, including data processing relating to page sites; information and the options for exercising the right to object can be found at https://www.facebook.com/help/contact/367438723733209
Users may exercise their rights as data subjects through their account settings or by contacting LinkedIn directly.
The data subject is then informed that if they believe that the processing of their personal data is violating the provisions of the GDPR, they have the right to file a complaint with a Supervisory Authority (Art. 77 of the Regulation) or to take appropriate legal action (Art. 79 of the Regulation).