Legislative Decree no. 24/2023 – Whistleblowing

Mobil Plastic has implemented Legislative Decree no. 24/2023 and complies with the regulations known as “Whistleblowing”, aimed at establishing a secure reporting channel in order to protect individuals who intend to report violations of European Union law.

Protection of the reporting person is ensured through the guarantee of anonymity and protection against any form of retaliation.

Protective measures shall not apply in cases where the reporting person’s criminal or civil liability for offences such as defamation or false accusations is established.

Below is the link to access the platform dedicated to the submission of reports:

https://mobilplastic.whistletech.online

MOBIL PLASTIC SpA, with registered office at Via S. Gregorio, 55 – 20124 MILANO (MI) – registered with the Pavia Companies Register, VAT and Tax Code no. 00186030185 – e-mail: info@mobilplastic.it – in its capacity as Data Controller of your personal data, refers you to this Social Media Policy. With regard to the processing activities described herein, the Data Controller provides, among other things, the following information.

This Social Media Policy (“Social Media Policy”) shall be considered an annex to the Privacy & Cookie Policy, available in a separate document at the website https://www.mobilplastic.it.

The purpose of this Social Media Policy is to describe the rules of conduct that users should observe when using the website and the spaces activated by MOBIL PLASTIC SpA on social media platforms.

Purpose

MOBIL PLASTIC SpA uses its website and the social media platforms (hereinafter “Social Media”) for purposes of general interest, to communicate with users online, provide access to services, and promote its activities.
Social media pages/channels are also used by the Data Controller to encourage participation, discussion, and dialogue with users, in a spirit of transparency and sharing.

Content

The MOBIL PLASTIC SpA website provides access points to Facebook and Instagram. These services offer comment areas, message boards, and public forums.
Content is published by users and may include: communications regarding the activities and services provided by the Data Controller, information relating to ongoing projects, social initiatives, images, and videos related to events organized by the Data Controller.
On the various pages/channels of these platforms, services are enabled to respond to requests for information and assistance. Comments, questions, criticisms, and suggestions posted by users are also collected.
By using Social Media, users accept that the published data (including text, images, and videos) may be freely visible to anyone; therefore, the Data Controller cannot guarantee the “privacy” of such content.

Comments and responses on Social Media

In addition to serving as an additional online communication channel, the purpose of the Data Controller’s Social Media services is to respond to requests received publicly on its pages/channels and forward them to the relevant internal departments in order to provide appropriate responses.
Response times may vary depending on the type of request.

Risk warnings

Users are advised to carefully consider whether or not to include personal data (including email addresses and mobile phone numbers) in their posts that may reveal, even indirectly, their identity.
The same caution applies in particular to sensitive data. Users should also consider carefully whether to publish audio, photographic, or video material that allows individuals to be identified without having obtained their consent to the processing of such data.
Attention should also be paid to the possibility of including data that may reveal, even indirectly, the identity of third parties.
Please note that data and content posted may be publicly visible and accessible by any Internet user accessing the website or Social Media, and may be indexed and retrieved by general search engines (Google, Yahoo, etc.).

Rules of use

The various MOBIL PLASTIC SpA pages on Social Media platforms may be freely followed by all Internet users without requiring authorization from the Data Controller. For this reason, MOBIL PLASTIC SpA recommends exercising caution when sharing personal data on these platforms.
The terms of use and privacy policies applicable to each Social Media platform are published on their respective websites and govern the information provided by users.
The Data Controller does not carry out any form of control over the use of personal information disclosed in public forums or comment areas, making the platform user solely responsible for any disclosure.
MOBIL PLASTIC SpA expects all participants in social interactions to express their opinions with correctness and moderation; therefore, insults and vulgar language will not be tolerated. MOBIL PLASTIC SpA reserves the right to report obscene language, insults, threats, and behaviors that may incite violence to the Social Media platform operators.

Privacy and processing of personal data

Users are reminded that the processing of their personal data is governed by the policies applied by the respective platforms used. Privacy on Social Media is ensured to the extent that users are aware of how they use the platform, the service, and its functionalities.
Consequently, the information generated is considered to be “voluntarily” shared by users, who therefore cannot claim any violation of their personal sphere.
Article 21 of the Italian Constitution protects freedom of expression, subject to certain limitations, including the protection of the reputation of others. When expressing opinions about other users, it should be remembered that the use of excessively strong or offensive expressions may expose the author to liability for defamation.
Everyone has the right to participate and express their opinion freely.
Any personal data published by users are processed by MOBIL PLASTIC SpA in compliance with Regulation (EU) 2016/679 and in accordance with the provisions (particularly regarding purposes and methods of data processing) set out in the Privacy & Cookie Policy published on the MOBIL PLASTIC SpA website, which users are required to review prior to this Social Media Policy.
Personal data are voluntarily published by users, and any processing by the Data Controller is carried out solely for the provision of these services.
The Data Controller is MOBIL PLASTIC SpA, with registered office at Via S. Gregorio, 55 – 20124 MILANO (MI)– registered with the Pavia Companies Register, VAT and Tax Code no. 00186030185 – e-mail: info@mobilplastic.it.
Further information regarding the processing and communication of personal data, whether directly provided or otherwise acquired, may be requested from the appointed Data Protection Officer or data processing representative.
This notice does not exclude that additional information may also be provided orally.

INFORMATION PURSUANT TO ARTICLE 13 OF THE GENERAL DATA PROTECTION REGULATION
(Regulation (EU) 2016/679 – “GDPR”)

Mobil Plastic Spa, with registered office in Via S. Gregorio, 55 – 20124 MILANO (MI), in its capacity as Data Controller of your personal data, pursuant to and for the purposes of Regulation (EU) 2016/679 (hereinafter “GDPR”), hereby informs you that the aforementioned legislation provides for the protection of data subjects with regard to the processing of personal data and that such processing shall be carried out in accordance with the principles of fairness, lawfulness, transparency, and protection of your privacy and rights.

Your personal data will be processed in compliance with the provisions of the aforementioned legislation and the confidentiality obligations therein.

Identity and contact details of the Data Controller

Mobil Plastic Spa
Registered office: Via S. Gregorio, 55 – 20124 MILANO (MI)
Tel. +39.0384674692
E-mail: amministrazione@pec.mobilplastic.it

Purposes of processing and legal basis

Personal data may be processed by Mobil Plastic Spa for the following purpose:

• To respond to requests for information regarding the services and products offered by the Data Controller.

The processing is carried out on the basis of the existence of a legitimate interest, as the data subject expresses the wish to be contacted by the Data Controller.

Categories of Personal Data

The following personal data are processed:

• Name

• Contact email address

The provision of data is optional; however, it is necessary to achieve the above-mentioned purposes. Failure to provide such data will make it impossible to process the user’s contact request.

Recipients or categories of recipients of personal data

Without prejudice to disclosures required by law, all collected and processed data may be disclosed, for the purposes indicated above, to:

• Third parties appointed by Mobil Plastic Spa to carry out activities directly connected or instrumental to the processing;

• Entities belonging to our commercial network;

• Persons who may become aware of the data in their capacity as “processors” or “authorized persons” of Mobil Plastic Spa, such as personnel from administrative, commercial, production, technical, and IT departments.

The updated list of recipients is available upon request at Mobil Plastic Spa’s offices. Personal data shall not, in any case, be subject to dissemination.

Transfer of data abroad

Should Mobil Plastic Spa intend to transfer personal data to a third country or an international organization, it shall integrate existing procedures in order to comply with the provisions of Chapter V of Regulation (EU) 2016/679. Data transfers abroad are permitted if the European Commission has decided that the third country, territory, specific sector, or international organization ensures an adequate level of protection.

Rights of the data subject

The data subject may exercise the rights provided for in Articles 15–22 of the EU Regulation, namely: the right of access, rectification, erasure (“right to be forgotten”), restriction of processing, data portability, and the right to object to processing, as set out in detail at the end of this privacy notice.

Requests to exercise these rights must be sent to:
Mobil Plastic Spa, Via S. Gregorio, 55 – 20124 MILANO (MI)
Tel. +39.0384674692
E-mail: amministrazione@pec.mobilplastic.it

Complaint to the Data Protection Authority

Pursuant to Article 77, the data subject who believes that the processing of personal data relating to him or her infringes this Regulation has the right to lodge a complaint with the competent Data Protection Authority, which can be contacted via the website http://www.garanteprivacy.it/