INFORMATION ON THE PROCESSING OF PERSONAL DATA
1. Introduction
Pursuant to Articles 13 and 14 of the General Data Protection Regulation 2016/679, Sport Experience S.R.L., VAT No. and Tax Code: 12332530018, REA No.: Turin 1281997, with registered office in Turin (TO), postal code 10143, Corso Lecce 54, email address: info@skirank.it, certified email (PEC): sportexperience@pec.it, in its capacity as Data Controller, provides users with information concerning the processing of their personal data in connection with the use of the Skirank App (hereinafter the “App”).
The user may contact the Data Controller at any time to receive information regarding the processing of their personal data by writing to the email address: info@skirank.it. Processing may be carried out manually or by electronic means. The processing activities carried out by the Data Controller will be based on the principles of lawfulness, fairness, transparency, purpose and storage limitation, data minimization, accuracy, integrity, and confidentiality.
2. Type of Data Processed and Purpose of Processing
The personal data processed by the Data Controller include:
- Data voluntarily provided by the user: All personal data freely provided by the user on the App. In the case of minors under the age of 16, personal data must be provided by a parent or the person exercising parental responsibility.
- Data collected during navigation of the App: Such as IP addresses, individual session identifiers, device ID, device brand and model, parameters related to the device’s operating system, type and quality of connection used (e.g., mobile, Wi-Fi). This information is used by the Data Controller to produce aggregate statistics and to verify the correct functioning of the App.
- Push notifications and activity tracking data: With the User’s consent, the App may send notifications. The user may revoke this consent at any time through their device settings.
Personal data collected include: first name, last name, email, date of birth, phone number. Providing certain personal data, marked with an asterisk (first name, last name, date of birth, email), is necessary to complete the user’s personal profile and to access the services provided by the App.
Data will be processed for all activities related or instrumental to the provision of the services offered through the App (activation, access to reports, content upload, etc.).
The processing of credentials provided by the User is necessary to recognize the user within the Skirank App and their affiliation with the registered school or ski club indicated during registration.
Providing an email address also allows the Controller to contact the user for service communications and, with express consent, to send newsletters.
3. Legal Basis
The legal basis for processing personal data is the performance of a contract to which the User is a party. For any additional processing carried out by the Controller, optional and revocable consent is always required.
The User may at any time object to or restrict processing to specific contact methods by writing to the Data Controller at: info@skirank.it
4. Data Sharing
User personal data may be shared, for the purposes described above, with:
- Persons authorized by the Controller to process personal data, necessary for performing activities strictly related to the provision of Services, who have committed to confidentiality or are under an appropriate legal obligation of confidentiality (e.g., employees, collaborators, system administrators);
- Third parties possibly assigned to manage the Sites who typically act as Data Processors. A complete list of Processors may be requested by writing to: info@skirank.it
- Entities, authorities, or third parties to whom it is mandatory to disclose the user’s personal data under legal obligations or authority orders.
Personal data are also processed through the creation of a centralized database using IT and telematic tools. The database containing users’ personal data is accessible only to authorized and specifically appointed individuals—such as employees or other collaborators—who may become aware of the data for purposes necessary or related to the sending of advertising material or order fulfillment. Third-party service providers strictly functional to the execution of the contractual relationship may also become aware of the data. Each appointee is given specific data processing instructions that suppliers are required to follow to avoid disciplinary and/or legal consequences.
Firebase: Personal data are automatically synchronized, saved, and transferred using Firebase services provided by Google. For more information, Users can consult Firebase’s website https://firebase.google.com/, read the terms and conditions, and access the privacy policy. Users can delete their Account at any time via their profile; in that case, all personal and synchronized data will be permanently deleted from the device and from Firebase. Simply uninstalling the App does not delete the data from Firebase.
Notifications: With consent, Users can enable in-App notifications. Such data will be acquired only in-App. Notifications may include: App-related notices (e.g., updates, new features), and product/service offers from the Controller.
5. Transfer of Personal Data
User personal data will be processed by the Data Controller within the European Union. For technical and/or operational reasons, it may be necessary to use entities located outside the EU. If these entities process personal data on behalf of the Controller, they will be appointed as Data Processors pursuant to Article 28 of the Regulation, and the transfer of personal data will be carried out in accordance with Chapter V of the Regulation. All necessary precautions will be taken to ensure full protection of personal data, including: (a) adequacy decisions by the European Commission; (b) standard contractual clauses adopted by the Commission; (c) adoption of binding corporate rules.
The User may request further details and evidence of the specific guarantees in place by contacting the Controller.
6. Data Retention
The Data Controller retains user personal data for the duration of the contractual relationship and, afterward, only as long as strictly necessary depending on the purposes for which the data were collected. Once expired, personal data will be deleted, destroyed, or anonymized in accordance with technical deletion and backup procedures. Data processed to comply with legal obligations will be retained for the period required by specific legal or regulatory obligations. Once consent is withdrawn, data use for such purposes will cease, although the Controller may retain the data to protect its interests against potential liability.
The Controller will stop storing and processing the user’s data upon account deletion. Additionally, the Controller will periodically review the need to archive or delete personal data if the account has been inactive for at least two years.
For newsletter subscriptions, data will be processed with the user’s express consent, which can be withdrawn at any time by clicking the “unsubscribe” button.
Users may revoke consent or restrict it for specific purposes at any time by writing to the Data Controller: Sport Experience S.R.L., Corso Lecce 54, 10143 Turin (TO), email: info@skirank.it, PEC: sportexperience@pec.it
Data processed to prevent abuse and/or fraud will be retained for as long as necessary for that purpose.
7. Data Subject Rights – Complaint to Supervisory Authority
As provided by Articles 15–22 of the Regulation, the data subject may access their personal data, request rectification or updates if incomplete or incorrect, request deletion if the data were collected in violation of the law, and object to processing for legitimate and specific reasons. These rights may be exercised at any time by writing to the Data Controller: Sport Experience S.R.L., Corso Lecce 54, 10143 Turin (TO), email: info@skirank.it, PEC: sportexperience@pec.it.
The user also has the right to lodge a complaint with the Data Protection Authority (in Italy: Garante Privacy, http://www.garanteprivacy.it).
8. Data Security and Liability
Personal data will be processed using paper or automated tools for the time strictly necessary to achieve the purposes for which they were collected, in accordance with the principles of necessity and proportionality, avoiding the processing of personal data where anonymous data or other methods would suffice.
The Data Controller has adopted specific security measures to prevent the loss, unlawful or incorrect use, and unauthorized access to personal data.
In no event shall the Data Controller be held liable for damages of any kind directly or indirectly caused by access to the App or the use of the information contained therein. The Controller reserves the right to modify the content of the App at any time. The Controller is not responsible for the content of external websites accessed via links in the App, and disclaims any liability for their information, graphics, updates, or references. Users are advised to carefully review the privacy policies of any external websites.
9. Statistics
The computer systems and software procedures used for the operation of this App acquire, during their normal operation, some anonymous aggregated data whose transmission is implicit in Internet communication protocols. These are not collected to be associated with identified users but could be used to:
- count unique visitors to the App,
- process aggregate statistics, including App functionality and service performance.
10. Changes to this Privacy Policy
The Data Controller periodically reviews its privacy and security policy and, where necessary, updates it to reflect regulatory, organizational, or technological changes. In the event of changes, the new version will be published in this document.
Users may contact the Controller at any time for further information: Sport Experience S.R.L., Corso Lecce 54, 10143 Turin (TO), email: info@skirank.it, PEC: sportexperience@pec.it
Last revised: November 3, 2023