PRIVACY POLICY

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.