Policy on personal data processing
This information is made available to anyone participating in the initiative CMP Trail – Bassano del Grappa, which will take place on 5-6 October 2019 in Bassano del Grappa (the “Initiative”). Participation in the initiative involves the ASA (as defined here below) collecting the information, in the form of personal data, pursuant to the Italian Privacy Code and the GDPR.
1.Identity and contact data of the data controller. Data Processor.
The data controller is the Amateur Sporting Association, CMP4SPORT, with registered offices in Romano D’Ezzelino (VI), 36060, Via Merlo n. 2 (the “ASA”). The ASA can be contacted at any time at the email address [info@cmptrail.it].
2. Types of data processed
Biographical data
The initiative requires that the participants provide the ASA with certain information, such as name, surname, place and date of birth, tax identification number, gender, residential address, e-mail, telephone number, emergency number (the “Biographical Data”). These data are necessary to legally sign the release form and identify any participants in the initiative by linking them individually to the images.
Images (photos and videos) of participants in the initiative
During participation in the activities included in the initiative, the staff nominated by the ASA and/or the designated data processor may take photos of the participants or make videos which feature them (jointly referred to as the “Images”) which will be used internally by the ASA and disseminated through publication and transmission using various means (via wireless systems, satellite, cable, television advertising, advertising posters, flyers, roll-ups, newspaper advertising, the internet, and social networks, such as Facebook®, Instagram®, Twitter® e YouTube®, etc.). These are personal data which may then be associated with the subjects identified and which, in any case, by their very nature, might allow participants, in the initiative and featured in the images, to be identified.
3. Purposes of and legal basis for processing
The images and biographical data (herein after, jointly referred to as the “Data”) provided to the ASA will be used exclusively: (i) to collect, organise and conscientiously store the release forms related to the images; (ii) with reference the images alone, to disseminate the images by publishing, disseminating and transferring them using various means and communications channels (via wireless systems and/or satellite and/or cable, advertising posters, flyers, roll-ups, television advertising, internet, newspaper advertising and social networks such as, Facebook®, Instagram®, Twitter® and YouTube®, etc.) of the ASA as a way of reporting the initiative and to carry out advertising-promotional activities, including individual links between personal data and images; (iii) to transfer the images to the company, F.lli Campagnolo S.p.A., the main sponsor of the initiative, with registered offices in Romano D’Ezzelino (VI) 36060 Via Merlo 2, that will process them as independent data controller for the purposes indicated in point (ii) above and, in any case, for activities related to the organization and promotion of the initiative; (iv) to send communications about the competition organisation (timetables, place, changes, etc.) including information about all the innovations of CMP4SPORT and its sponsors.
The legal basis, on which the processing by the ASA is founded, is the implementation of pre-contractual and contractual measures requested by the data subject in relation to the registration of said data subject to the initiative and the signing of the release form.
4. Data Recipients
The Data will be communicated and may be made known (i) to employees and collaborators of the ASA, duly designated to perform the processing; (ii) to third parties who provide ancillary services required for the activities of the ASA and the initiative (such as, by way of example, the online platforms necessary to manage the process of registration for the Initiative and to provide participants with Images and other official photos of the race), who are appointed as external processors and (iii) to the company, F.lli Campagnolo S.p.A., as main sponsor of the initiative.
In no other case shall the Data be disclosed to third parties, unless this is necessary to comply with requests from the Judicial Authority, Public Security requests, or requests from another Public Authority.
5. Place of Data Processing: not outside of the EU
The data processing will take place in the above-mentioned offices of the ASA. The Data will be stored on servers and/or physical archives located exclusively within the European Union. Here again, the data will be handled by personnel, duly appointed as data processors and, for management and maintenance operations, by external technicians appointed as external data processors. The ASA will not carry out process or transfer any data outside the area of the European Union or in countries which do not give adequate guarantees for safeguarding personal data.
With regard to publication on social networks: the companies which manages these platforms (Facebook®, Instagram®, Twitter® and YouTube®) come under the so-called Privacy Shield, a system which safeguards European citizens when their data are transferred to the USA
6.Processing methods, data storage period and security measures
The ASA will process the Data with and without the aid of electronic, IT or automated instruments. Specific suitable security measures – logical, organisational and technical – have been adopted by the ASA to prevent the loss of Data, the illegal or unauthorised use of Data, and unauthorised access.
The Data shall not be processed and stored for a longer period of time than that strictly necessary to fulfil the purposes for which it was collected (see Paragraph 3 of this policy), namely, a period which allows: (i) the Data to be collected, organised, properly stored and processed in order to implement and adequately promote the initiative; as well as (ii) promotional activities to be carried out, including at a later date, using the images linked to the biographical data.
The Biographical Data contained in the release form shall be stored for a time equal to the limited period prescribed by law.
7. Rights of the data subject. Contact details for the exercise of rights
The participants in the initiative, such as the data subjects (i.e. the subjects to whom the data refers), are the holders of the rights conferred by the GDPR. In particular, pursuant to articles 12-23 of the GDPR, they have the right to request and obtain, at any time, access to their personal data, information on the processing carried out, the rectification and/or updating of the personal data, the erasure and restriction of the processing. In addition, they also have the right to oppose the processing and to request data portability. Finally, the data subjects always have the right to lodge a complaint with a supervisory authority (in Italy: the Guarantor for the Protection of Personal Data).
To exercise your rights, you can contact the company at the following addresses at any time:
– email address: [info@cmptrail.it]
– Address: Via Merlo 2, 36060, Romano D’Ezzelino (VI), Italy.