Art. 13 of EU Regulation 679/2016 General Data Protection Regulation
a) Who processes your personal data?
- A.S. Roma S.p.A., with registered office in Rome, Italy, at P.le Dino Viola No. 1 - Tax Code and entry in the Register of Companies of Rome under No. 03294210582, VAT No. 01180281006 (“AS Roma”).
- Soccer S.a.s. di Brand Management S.r.l., with registered office in Rome (Italy), at Via Emilia 47 - Tax Code, VAT Number and entry in the Register of Companies of Rome under No. 09305501000, the company holding the rights to exploit the AS Roma trademarks (“Soccer”);
- Stadio TdV S.p.A., with registered office in Milan (Italy), at Via Montenapoleone, 29 - Tax Code, VAT Number and entry in the Register of Companies of Milan under No. 08732500965, www.stadiodellaroma.com (“Stadio TdV ”);
(hereinafter referred to jointly as the “Companies”) are the companies, which, as Data Controllers - each for the purposes indicated under b) - collect and process your personal data in accordance with EU Regulation 2016/679 General Data Protection Regulation (the “Regulation”) and provide you with the following information.
b) Why do we process your data?
If you give your consent, the data you provide us and the data relating to participation in our initiatives related to the Fan Zone “La Magica Land” will be used by the Companies:
- to allow you to subscribe to the Fan Zone “La Magica Land”
- to analyse your participation participation in entertainment activities at La Magica Land, in our competitions and initiatives, your preferences and purchases, and your browsing on the website, in order to improve our commercial offer and you Fan Zone experience.
- to send you advertising and promotional material, also customised according to your preferences, and to update you, (through newsletters, e-mails, phone calls, instant messaging, posts, messages or communications of initiatives on social networks and apps, etc.), with regard to products, services or initiatives (e.g. promotions, competitions, games, activities and events), which the Companies and their business Partners reserve to members, and for the purposes of carrying out market research.
The legal basis for the processing of your data will be your consent. Your consent can be withdrawn at any time from one or all of the Data Controllers by writing to email@example.com. Please note that in case of withdrawal of consent for sending updates, advertising/promotional communications or market research (purpose 3), you will no longer be the recipient of any type of communication, in no form. If you wish, you can withdraw your consent only as the receipt of communications sent by electronic means (e.g. e-mail, text messages and instant messages) and can continue to receive commercial communications only by post or through telephone contact with the operator, if required.
c) Is the requested data necessary?
The data requested as “mandatory” (*) is required for subscribing to the Newsletter. Failure to fill in the “optional” data will simply not allow us to use that data for the purposes for which you have given your consent (e.g. to analyse your preferences or send you commercial communications).
d) How do we process your data?
Your data will mostly be processed electronically. If you give us your consent we can analyse your data (e.g. data relating to our initiatives and competitions in which you have taken part, your purchases and use of the website - including which pages you visited, etc.), to try to understand your tastes and desires (e.g. verifying which products you have purchased or which events you have taken part in), in order to adapt our commercial offer so we can send you the best offers and promotions, even customised ones in our products and initiatives (e.g. new competitions or reserved prize-giving operations).
Please note that all our analysis of your data and your preferences will not be performed using exclusively automated methods, but will always involve the intervention and evaluation of persons authorized to the processing.
e) How long do we keep your data?
Your data will be processed for the entire duration of your subscription to the Newsletter. However, data relating to the details of any of your purchases of our products or services will be processed for analysis or commercial communications for a maximum of 12 or 24 months, respectively, from the time of its registration.
f) Who are the recipients of your data?
Your data will not be disclosed and may only be communicated to persons authorised to the processing from the Marketing Department of AS Roma and Soccer as well as the following recipients, as External Data Processors:
- companies responsible for processing, managing and sending newsletters and advertising as well as promotional material;
- companies in charge of the organisation and management of competitions and our initiatives;
- companies, which on our behalf perform the analysis of your participation in our competitions/initiatives, any purchases you make and your use of our website;
- companies that organise and manage market research on our behalf;
- companies entrusted with the management of the website and related electronic archives;
- companies responsible for the management of our CRM system.
The names of all the external Processors can be requested by sending a communication to firstname.lastname@example.org.
g) Is your data transmitted outside the European Union?
In order for us to properly manage our website and carry out our marketing and analysis activities, your personal data will be sent to countries outside the European Union, such as the USA.
The applicable privacy legislation requires that your specific consent is not necessary for the transfer of your data to third countries, provided the transfer of your data is made to a country that guarantees an adequate level of protection (Art. 45 of the Regulation) or on the basis of the adoption of adequate safeguards ((articles 46 and 47 of the Regulations), and in particular on the basis of the adoption of binding corporate rules for groups of companies, the adoption of standard contractual data protection clauses adopted by the European Commission, or the adherence to safeguards required by the Privacy Shield agreement with the USA.
Therefore, your data to the third countries will be transferred in full compliance with the safeguards, measures and rights as provided for in the aforementioned acts. In any case, by simple request to email@example.com, you may receive information on the existence of an adequacy decision or on the appropriate safeguards adopted to allow your data to be transferred, as well as on the method of obtaining such data or the place where it was made available.
Your data will be transferred in full compliance with the safeguards, measures and rights provided by the Privacy Shield agreement, to which the supplier of our CRM system adheres.
By writing to firstname.lastname@example.org, you can receive further information on the transfer of your data and the safeguards provided for its protection.
h) What are your rights?
By writing to email@example.com, you can at any time exercise the rights referred to in articles 15 to 22 of the Regulation, including:
- Obtaining confirmation that processing of personal data is or is not in progress
- Obtaining access to personal data and information indicated in Art. 15 of the Regulation
- Correcting personal data, if inaccurate, without unjustified delay or the integration of incomplete personal data
- Deleting personal data without undue delay
- Restricting the processing of your personal data
- Being informed of any correction, deletion or restriction of the processing performed in relation to personal data
- Receiving personal data in a structured, commonly used form that can be read by an automatic device
- Opposing the processing of personal data, at any time, for reasons connected to your particular situation
In particular, it is understood that you may withdraw the consent to any processing provided and to oppose our analysis activities.
i) Who can be contacted to lodge a complaint?
Should you consider the processing of your data infringes the Regulation, you may in any event lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it), or, if different, to the Data Protection Authority of the Member State of your habitual residence, place of work or place of the alleged infringement.
j) How can the Data Protection Officer be contacted?
The Data Protection Officer appointed by AS Roma can be contacted at the e-mail address firstname.lastname@example.org.
AS Roma S.p.A.
Soccer S.a.s. di Brand Management S.r.l.
Stadio TdV S.p.A.