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 (“A.S. 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”).
b) Why do we process your data?
The data you are providing, or the data that we will acquire if you decide to subscribe to the Website via Facebook (first name and surname, profile picture, age group, gender and other information made public on Facebook), as well as any data connected to your possible participation in our initiatives, will be processed by AS Roma and Soccer to:
- create your personal account on the asroma.com website (the “Website”) and allow you to access the corresponding services;
- allow you to participate in our competitions, initiatives and content of the Website reserved for members and comply with legal obligations (in relation to competitions/prizes and tax/accounting transactions).
The legal basis for the processing of your data will be the execution of the contractual agreement and fulfilment of the relevant legal obligations.
Additionally, if you provide your consent, your data (including in relation to any possible purchases of our products or services) will be processed by the Companies to:
- analyze your participation in our competitions and initiatives, your preferences and purchases, and your browsing on the Website to improve our commercial offer;
- send you updated and customized communications (e.g. newsletter, 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 and exclusive benefits reserved for subscribers) as well as advertising and promotional material, relating to exclusive benefits that the Companies and its commercial Partners provide to subscribers, and for the purpose of carrying out market research.
The legal basis for the processing of your data will be your consent. Website subscription, and therefore participation in our competitions and reserved initiatives, is possible even if you do not wish to give us your consent to analyze your preferences and/or to send you commercial communications. Your consent can be freely withdrawn at any time, even in relation to an individual Data Controller.
c) Is the requested data necessary?
The data requested as “mandatory” (*) is required for subscribing and/or participating to competitions ad initiatives. 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 be processed mostly electronically. If you give us your consent, we will be able to analyse your data (e.g. data connected with competitions you have participated in, your purchases, for 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 Website. Data relating to the details of any of your purchases will be processed for analysis or promotional purposes 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. To manage your subscription to the Website, your participation in our competitions or initiatives and to pursue the further purposes for which you have provided your consent, your data may come to knowledge of (limited to the respective field of competence) to the persons authorised to the processing in the Marketing Department of AS Roma, Soccer as well as the following recipients, as External Data Processors:
- 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 responsible for processing, managing and sending newsletters and advertising as well as promotional material;
- companies that organize 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 email@example.com.
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.
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 of articles 15 to 22 of the Regulation, including obtaining access to your personal data, correction of inaccurate personal data or deletion or restriction thereof, requesting to receive your data or transmit it to another data controller, in a structured, commonly used format that can be read by automatic device.
You can also object at any time to the processing of your data, in particular, for marketing purposes or analysis of your habits or preferences.
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 messaging) and can continue to receive commercial communications only by post or through telephone contact with the operator, if required.
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.