Privacy policy
Introduction
This Privacy notice provides information regarding the Data processing by
BKOOL S.L. with Tax Identification Number ESB98125024 and address Ed. Madroños, 3 Pl. 0, Ctra. de la Coruña, A6 - KM 17,800 (Vía de Servicio) - Las Rozas, 28231, Madrid, Spain, (hereinafter, “BKOOL”)
And
RCS Sports & Events S.r.l. with registered offices at A. Rizzoli 8 Street, 20132, Milan, Italy, (hereinafter, “RCS”)
As autonomous Data Controllers.
Aim to respect your privacy and protect the personal data that you may provide to the Data Controllers in the provision of their respective Services through the Website and/or GIV Platform.
In compliance with the Spanish Organic Law 3/2018, of 5 December, on the Protection of Personal Data and guarantee of digital rights (hereinafter, "LOPDGDD"), and the Italian legislative Decree 196/2003 as modified by Italian Legislative Decree 101/2018 (hereinafter, cumulatively, “Codice Privacy”), and the General Data Protection Regulation of the European Union (hereinafter, "GDPR") the collection and processing of your personal data from our GIV Platform will be regulated by the terms described below in this Privacy Policy
If you have any questions about the processing of your personal data, please contact:
- BKOOL at dpogiv@bkool.com;
- RCS at dpo@rcs.it;
1. Data Collected, Purposes, Legal Basis and Storage Period
BKOOL and RCS may collect and process the personal data indicated in accordance with the purposes, legal basis and retention periods set out below:
Data Collected by BKOOL
| Data Collected | Purpose | Legal Basis | Storage Period |
|---|---|---|---|
| Name, Surname, e-mail address, credit card data: credit card number, expiry date and CVV | To join on the BKOOL Platform and take the Virtual Stages | Performance of a Contract | The personal data indicated will be kept for as long as you are registered on the Platform, i.e. until you inform us your wish to deregister or we proceed to deregister you. |
| E-mail address | Manage enquiries about the Services through our BKOOL Platform. | Legitimate interest | The personal data processed for this purpose will be kept the time necessary to deal with your consultation, enquiry or petition. |
| E-mail address | To send advertising communications; as well as newsletters. | Consent(1) | The data collected will be retained until you decide to withdraw your consent. In the case of the Newsletter, you can unsubscribe from the Service at any time by clicking on the link at the end of the update message you receive by email. |
| Browsing: IP and other browsing characteristics (e.g. location and/or device) derived from the use of cookies or similar technologies used on the Website/Platform. You can find more information in our Cookies Policy. | To carry out browsing activity and statistical analysis. The information collected through cookies and other similar tracking technologies that allow us to analyse the browsing activity of our visitors on the Website/Platform. | Consent given through the cookie banner when you start browsing. You can withdraw your consent by following the steps indicated in the Cookies Policy. | The storage periods of the information indicated depend on each specific cookie. You can find more information on the information storage periods for each type of cookie in our Cookies Policy. |
(1) You should note that even if you opt out from receiving promotional communications, BKOOL may continue to send you non-promotional emails and other kinds of communications, as permitted by law, such as service emails related to our ongoing business relationship. Those service emails contain information related to service, billings, payment updates, password security issues, etc.
Data Collected by RCS
| Data Collected | Purpose | Legal Basis | Storage Period |
|---|---|---|---|
| E-mail address | To send service communications about the start of GIV and other communications related to the event. | Consent | For the duration on GIV Initative |
| Common identifying data: name, surname, gender, date of birth, nationality, e-mail. | To register to the GIV Event and take part in the Initiative; | Performance of a Contract | For the duration on GIV Initative |
| Performance data relating to the cycling activity you engaged in while taking part in the race. | to determine partial and total racing times, along with time gaps, and to elaborate the rankings. | Performance of a Contract | For the duration on GIV Initative |
| Identifying data | To send marketing e-mails, promotions, regarding RCS’ products and activities via e-mail, sms, messaging apps, phone. | Consent | For the duration of the Services and for the additional times imposed by the Law |
| Identifying data | To analyse your Data and behaviour in order to offer personalised contents and improve our products and services. | Consent | For the duration of the Services and for the additional times imposed by the Law |
| Identifying data | To send marketing e-mails, promotions, regarding third parties’ products and activities via e-mail, sms, messaging apps, phone or to communicate your data to third parties for the same purpose. | Consent | For the duration of the Services and for the additional times imposed by the Law. |
The Data Controllers may also keep your personal data stored during the period of time in which civil, commercial, administrative, criminal or fiscal liabilities may arise, in compliance with the applicable regulations in force, as the case may be. Once these periods have expired, we will delete your personal data.
The Data Controllers, under the basis of a legitimate Interest, may also process your Personal Data including sporting performances on the Platform or during the GIV Competition for the purpose of anti-fraud checking.
2. Communication of Data by BKOOL To Third Parties
In general, and without prejudice to what is specifically contemplated in this Privacy Policy, BKOOL will not share your personal data with third parties. However, BKOOL informs you that, in order to comply with the purposes described above, it will be necessary to give access to personal data that you have provided to our hosting and payment service providers. Below, BKOOL will indicate those providers that will be able to carry out international transfers:
- PayPal (Europe) S.à r.l. ("PayPal"): for the purpose of contracting instant payment services. PayPal has implemented appropriate warranties ("BCRs") for international data transfers outside the EEA. For more information about how PayPal may process your personal data, please visit: https://www.paypal.com/uk/webapps/mpp/ua/bcr
- Paycomet, S.L.U. ("Paycomet"): for the purpose to contract the payment gateway services for the provision of the services. Paycomet processes the bank details provided directly within the EEA. For more information on how Paycomet may process your personal data, please visit: https://www.paycomet.com/en/privacy-policy
- Amazon Web Services (“AWS”): Amazon Web Services ("AWS"): for the purpose of providing hosting services for the Website/Platform. AWS may transfer your personal data outside the EEA, for which it has provided appropriate legal guarantees. For more information about how AWS may process your personal data, please visit: https://aws.amazon.com/privacy/
3. Communication of Data by RCS To Third Parties
Your personal data shall not be disclosed, but they may be communicated when necessary, for the performance of the Services to third parties (as third-party technical service providers, postal couriers, hosting providers, IT companies), appointed, if necessary, as Data Processors by RCS for the technical or organisational tasks that are instrumental for the performance of the services.
Access to the data is also allowed to categories of the Controller appointees involved in the organisation for data processing (administrative, sales, marketing, customer service personnel, system administrators).
The updated list of Data processors may always be requested from RCS.
We shall retain the right to communicate the data to third parties if you have given your specific, optional consent.
RCS informs you that your personal data shall be processed by RCS within the territory of the European Union. If technical and/or operational issues make it necessary to rely on parties located outside the European Union, or if it becomes necessary to transfer some of the data gathered to technical systems and services managed in clouds and located outside the area of the European Union, the processing activities shall be regulated in accordance with the provisions of Chapter V of the Regulation and authorised on the basis of specific decisions by the European Union. Hence, all precautions necessary to assure the most comprehensive protection of personal data shall be adopted, basing said transfer: a) on decision of adequacy of the recipient third party countries expressed by the European Commission; b) on adequate guarantees expressed by the recipient third party in accordance with Article 46 of the Regulation; c) on the adoption of Corporate binding rules.
4. Security And Privacy
BKOOL and RCS are committed to adopt the necessary technical and organisational measures in accordance with the regulations in place to ensure the security of personal data and to prevent the unintentional or unlawful destruction, loss or alteration of personal data transmitted, stored or otherwise processed, or the unauthorised communication of or access to such data. The personal data the Parties process will be treated as confidential, and we undertake to inform you and to ensure by means of a legal or contractual obligation that such confidentiality is respected by our employees, partners, and any other person to whom we make the information accessible.
5. Your Rights
The Data Controllers hereby guarantee to you that you may exercise, at any time, the rights specified by Article 12 of the GDPR. In particular, you have the right:
- to know whether the Controllers hold and/or process personal data about you and to access them in full, also obtaining copies thereof (Article 15 Right of access by the data subject),
- to the rectification of inaccurate personal data or to the completion of incomplete personal data (Article 16 Right to rectification);
- to the erasure of personal data in the Controllers' possession if one of the reasons specified by the GDPR applies (Right to erasure, Article 17);
- to ask the Controllers to limit processing only to some personal data, if one of the reasons specified by the Regulation (Article 18 Right to restriction of processing);
- to request and receive all your personal data processed by the Controllers, in a structured, commonly used and machine-readable format or to request transmission to another controller without hindrance (Article 20, Right to data portability);
- to object to all or part of the data processing for the purposes of transmitting advertising material and market surveys (“Consent”) (Article 21 Right to object)
- to object to all or part of the data processing in automatic or semiautomatic mode for profiling purposes (“Consent”)
These rights may be exercised by communication to the Data Controller/Data Protection Officer whose addresses are indicated in the dedicated section of this disclosure.
RCS
RCS has identified and appointed a Data Protection Officer, in accordance with Article 37 of the GDPR, and has established an office for the management of requests pertaining to the privacy of their users and customers.
To exercise your guaranteed rights, you may contact us at the following addresses:
- Ufficio Protezione Dati c/o RCS Via A. Rizzoli 8, 20132 Milano, Italia
- or by sending an email to the address: privacy@rcsdigital.it;
Moreover, you always have the right to file a complaint with the Italian Authority for the Protection of Personal Data, at the address garante@gpdp.it or through the Website http://www.gpdp.it
BKOOL
You may execute your rights by sending an email to our Data Protection Officer to dpo@bkool.com with the reference "RGPD", enclosing a copy of your ID card or equivalent supporting document. In cases where representation is admitted, it will also be necessary to identify the person who represents you by the same way, as well as the document proving the representation.
You also have the right to submit a dispute to a competent authority, to the Spanish Data Protection Agency (www.aepd.es)if you consider that the rights set out in this Privacy Policy have been infringed or if you consider that the processing of personal data concerning you is in breach of applicable law.
6. Changes in the Privacy Policy
The Data Controllers reserve the right to modify this Privacy Policy at any time. Changes or updates to the Privacy Policy will be explicitly notified to you, without prejudice to the publication of a notice on the Website and/or Platform, together with the updated version of the Privacy Policy.
Updated: 06 10 2022