Privacy e social media policy

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This page describes the management procedures used to process personal data of users consulting the official website of the Western Ligurian Sea Port Authority. The normative references are (i) Recommendation 2/2001 adopted by the European Data Protection Authorities to identify certain minimum requirements for the collection of personal data online, specifically regarding the methods, timing and nature of the information that data controllers must provide to users when they visit web pages, regardless of the purposes of the connection, as well as (ii) Articles 13 et seq. of EU Regulation 2016/679.

The following notice concerns the website of the Western Ligurian Sea Port Authority, but it does not refer to sites that may be visited via links.

Data Controller
The Data Controller is the Western Ligurian Sea Port Authority, with registered office in Via della Mercanzia 2 - 16124 Genoa. PEC: segreteria.generale@pec.portsofgenoa.com.

Legal basis for processing
Personal data mentioned on this page are processed by the Port Authority in the performance of its public interest tasks or in any case related to the exercise of its public powers (Art. 57 par. 1, lett. b) and d) of the Regulation).

Data Processor
Pursuant to Article 28 of EU Regulation 2016/679, the Data Processors are Liguria Digitale S.p.A., responsible for the technological maintenance of the website, and Mailup S.p.A., responsible for managing the CDP (Customer Data Platform) used for the automated dispatch of newsletters and email communications.

Data processing location
The data processing related to web services takes place at the offices of the Western Ligurian Sea Port Authority and is handled by the technical staff of the department responsible for processing.. If necessary, data related to the services may also be processed by the staff of the company responsible for the website's technological maintenance, Liguria Digitale S.p.A., at its premises.

Browsing Data
In the course of their normal operation, the IT systems and software procedures responsible for the operation acquire certain personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes IP addresses or domain names of the computers used by users connecting to the site, URI addresses (Uniform Resource Identifier) of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (success, error, etc.) and other parameters related to the user’s operating system and computing environment. These data are used solely to ensure the proper functioning of the sites. They are typically deleted fifteen days after processing, but may be retained on the servers for up to one month.
The data could be used to ascertain liability in the event of potential cybercrimes against the site.

Processing of personal data through Social Media platforms used by the Western Ligurian Sea Port Authority
With regard to the processing of personal data carried out by the operators of the Social Media platforms used by the Authority, including the direct posting of multimedia content on its own site, please refer to the information provided by them through their respective privacy policies. The Authority processes personal data provided by users through the dedicated social media pages for its institutional purposes, exclusively to manage interactions with users in compliance with current regulations.
For further details, please refer to the social media policy at the end of this document.

Data provided voluntarily by the user
The optional, explicit and voluntary sending of e-mails to the addresses provided on this site entails the subsequent acquisition of the sender’s address, which is necessary to reply to requests, as well as any other personal data included in the e-mail.

Technical and third-party cookies
The Western Ligurian Sea Port Authority website uses technical cookies to improve the service. In particular, the Authority uses navigation and session cookies, which ensure normal browsing and use of the website, functionality cookies, which allow users to navigate according to a set of selected criteria (e.g. language). The installation of technical cookies does not require prior consent of users, whereas the obligation to provide information pursuant to Art. 13 of the Code remains.

When using YouTube or Google Maps via content or links available directly on the Authority’s site, user browsing data will be transmitted to Google Inc.

While browsing, users may also receive cookies sent by third parties:

Youtube
This is a video content display service operated by Google Inc. that allows this application to integrate its content within the pages of the Authority. The privacy policy and terms of service can be found at the following link: https://developers.google.com/youtube/terms.

For information on the privacy policy of Google Inc., the independent data controller for YouTube services, please visit http://www.google.com/policies/privacy/.

Google Maps
This is a map service provided by Google Inc. which uses cookies that are also stored on the user’s computer to save information and viewing preferences. The privacy policy, including information about data transfer abroad, and the terms of service can be found at the following link: https://developers.google.com/maps/terms.

For information on the privacy policy of Google Inc., the independent data controller for Google Maps services, please visit at http://www.google.com/policies/privacy/.

If you wish to disable one or more types of cookies for this site, you need to access the settings of the browser you are using. In order to optimise the information and services offered, the sites of the regional network use Matomo Analytics, a service that allows to track and analyse the behaviour of online users including time, geographical location and behaviour on the site. In order to protect the privacy of its users, Liguria Digitale has chosen to discard the fourth byte of the IP address, ensuring that only information related to the Class C portion is retained.

How to disable cookies
If you accept cookies, you can later refuse them by changing the settings of your web browser.

In Google Chrome:
select “Settings” and go to “Show advanced settings”, then click on the “Content settings” tab and choose the desired settings.

In Firefox:
select “Options” and click on the “Privacy” tab, then choose the desired settings.

In Internet Explorer:
select “Tools” and go to “Internet Options”, then click on the “Privacy” tab to choose the desired settings.

Data Provision
With the exception of what’s specified for browsing data, the user is free to provide the personal data contained in the request forms to the Western Ligurian Sea Port Authority, or otherwise indicated within contacts with the office to request dispatching informative material or other communications. Failure to provide them may cause the impossibility of obtaining what has been requested.

Processing methods
Personal data are processed by automated and electronic means for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are observed to prevent loss of data, unlawful or incorrect use and unauthorised access.

Rights of data subjects
The rights set out in Articles 15 to 22 of EU Regulation No. 2016/679 may be exercised at any time, including:

  • requesting confirmation of the existence or non-existence of their personal data;
  • obtaining information about the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be disclosed and, if possible, the storage period;
  • obtaining rectification and, if possible, erasure of data;
  • obtaining restriction to processing;
  • if possible, opposing to processing at any time;
  • opposing to an automated decision-making process regarding individuals, including their profiling;
  • requesting the data controller to access and modify personal data or, if possible, erase the data or limiting or opposing their processing;
  • withdrawing consent at any time without affecting the lawfulness of the processing based on the consent given before the withdrawal;
  • filing a complaint with a supervisory authority.

The data subject may assert his/her rights by contacting the Data Controller or the Data Protection Officer.

Data Protection Officer (DPO)
Data Protection Officer (DPO) for the Western Ligurian Sea Port Authority is Attorney Tania Valle, who can be contacted via e-mail at: responsabileprotezionedati@portsofgenoa.com.

SOCIAL MEDIA POLICY
The Western Ligurian Sea Port Authority uses several social media and instant messaging services for institutional communication purposes, in particular to inform citizens on the activities carried out by the Authority, to make publicly available the measures adopted, and to collect comments, general questions and suggestions. Below are the official institutional profiles of the Authority on social media and messaging services:

Institutional profiles on social media and messaging services allow the Authority to share and relay content and messages of public interest and utility, also published by third parties (e.g. institutional subjects, press agencies and newspapers, etc.).
Any comments under Authority’s posts, and in user posts that mention the Authority, represent the opinion of individuals and not that of the Authority, which cannot be held responsible for what is published by third parties.

Management
The Authority’s institutional profiles on social media and messaging services are managed by the Communication and Marketing Staff.
No prior moderation is provided.
For this reason, the Authority asks users who interact with its social channels to respect some simple but important rules:

  1. Expressing their opinions in a polite, fair and respectful manner, and using appropriate language. Insults, vulgarity, offences, threats and, in general, violent or defamatory attitudes and behaviours are not tolerated. Please remember that everyone is responsible, including legally, for the content they publish and the opinions they express.
  2. Content and comments must be relevant to the institutional activity of the Authority (on topic).
  3. Users who provide data, news or opinions on specific facts or issues are invited to express well-founded and unprejudiced arguments and to refer to reliable and verifiable sources.
  4. Published content must always respect people’s privacy. In any case, references to facts or details that are not of public relevance and that may harm the personal sphere of third parties should be avoided.
  5. No advertising, spamming or promotion of private interests or of lawful or unlawful activities is allowed.
  6. Content that infringes copyright or the unauthorised use of registered trademarks is not permitted.

Content
In any case, if possible, we will remove all posts, comments or audio/video materials that:

  • use inappropriate language and/or a threatening, violent, vulgar or offensive tone;
  • contain unlawful content or incitement to commit unlawful activities;
  • have the purpose of promoting products and services;
  • directly or indirectly disclose personal data and information (names, email addresses, telephone numbers, tax numbers, bank account numbers, addresses, protocol numbers of documents or files, videos or photos of recognisable persons, etc.) or which in any way may cause damage or harm the confidentiality or reputation of the persons concerned;
  • report, directly or indirectly, information referring to minors;
  • have discriminatory content based on gender, race, ethnicity, language, religious belief, political opinion, sexual orientation, age, personal and social conditions, health;
  • have spamming purposes;
  • promote or support lawful or unlawful activities, infringe copyright or misuse a registered trademark;
  • appear generally inconsistent with the institutional communication purposes of the Authority and the communication content of its social profiles (off topic).

The Authority reserves the right to ban or block individuals who violate these conditions (if possible, after an initial warning) and, in the most serious cases (e.g. if promoting or supporting illegal activities or committing any form of crime or harming third parties), to report the user to the platform managers and, if necessary, to the appropriate authorities.

The Authority’s social channels may not be used to request (via direct messages, comments, quotes, etc.) personal information or direct assistance (e.g. on files, personal issues, reports, etc.). For such needs, please always reference exclusively the official contact channels and the OPR.

In general, there is no guarantee of a direct reply to quotes, messages or comments, and it should be noted that there is no minimum or maximum response time. The Authority reserves the right to reply to comments and messages or intervene in discussions only when it deems them to be really usable, also in terms of providing correct information to the public, and after assessing the correctness and appropriateness of the communication style adopted by the user.
Individuals who follow an Authority’s social media channel are not automatically followed.

If the Authority follows the accounts of other users, befriends them or includes them in its interest lists, or comments on the content of other users and/or “likes” it, this does not imply that the Authority shares the line of thought of the users concerned or endorses all the content posted by them.

Personal Data Protection
The processing of users’ personal data complies with the policies in use on the platforms used. Personal or sensitive data included in public comments or posts within the Authority’s social media channels may be removed.