Privacy Policy

POLICY ON THE PERSONAL DATA PROCESSING

The user’s personal data are used by the company PALERMO FOOTBALL CLUB S.P.A., which is the Data Controller, in observance of the principles of personal data protection established by the GDPR 2016/679 Regulation and by the national legislation in force.

SOURCE OF PERSONAL DATA

The collection of personal data is carried out by the company PALERMO FOOTBALL CLUB S.P.A. by registering the data:

– collected directly from the interested party, at the time of initial contact or subsequent communications.

LEGAL BASIS

1.      The legal bases on which the processing for common data is based, according to Art.6 of the GDPR Regulation, are:

– Execution of a contract.

The company procees optional user data on the basis of consent, i.e. explicit approval of this privacy policy and in relation to the methods and purposes described below.

METHODS AND PURPOSES OF DATA PROCESSING

2.      You are informed that your data will be processed by the following means.

Mixed – electronic and paper with the following purposes:

  • Digital marketing;
  • Management of fidelity cards or fidelity cards in any way denominated or similar services;
  • Sending courtesy communications and/or promotional/informative material;
  • Marketing (market analysis and surveys);
  • Offering assets and services through mailing lists;
  • Publication of matches results;
  • Remarketing;
  • Websites and Social Media;
  • Use of your common personal data (e.g. name and surname) for season tickets, fan cards, fidelity cards, etc;
  • Use of one’s common personal data (e.g. name and surname) to label reserved seats;
  • Use of one’s own images (photos/videos) on social networks, the web, apps, for marketing purposes and the management of commercial campaigns for the purposes specified in the aforementioned notice;

In particular, for the purposes specified below the user’s data will be treated ONLY upon specific acceptance of consent:

  • Sending courtesy communications and/or promotional/information material: (Optional)
  • Offer of assets and services through mailing lists: (Optional)
  • Automated profiling activities: (Optional)
  • Use of your common personal data (e.g. first and last name) for season tickets, fan cards, fidelity cards, etc.: (Optional)
  • Use of your common personal data (e.g. name and surname) to mark reserved seats: (Optional)

FACULTATIVE CONSENT AND CONSEQUENCES OF NON-CONSENT

3.      You are informed that failure to provide your data will entail:

    • In relation to personal data processed and stored for the purposes of season tickets, fidelity cards, fan cards and for labelling stadium seats, the provision of personal data is not mandatory. However, if personal data is not provided, it will not be possible to use the above-mentioned services;
    • In relation to personal data processed for marketing, remarketing and digital marketing purposes, the communication of personal data is not a contractual obligation. You are free to provide personal data; however, if you fail to provide such data, no marketing activities will be possible;
    • With regard to personal data processed for profiling purposes, the communication of personal data is not a contractual obligation. There is an option to provide personal data; in the event of non- communication of such data, however, it will not be possible to carry out any profiling activities;
    • In relation to personal data processed for persons under 16 years of age, the communication of personal data is obligatory. Personal data must be authorized by both holders of parental responsibility for the child. If this data is not communicated, however, it will not be possible to provide any kind of service.

METHOD OF PROCESSING AND LOGIC

4.      You are informed that your data will be processed in the following ways:

  • In relation to personal data processed and stored for the purposes relating to season tickets, fidelity cards, supporter cards and for marking stadium seats, the processing will be carried out using paper-based and computerized tools that will allow the best possible management of the fulfilment of services;
  • With regard to personal data processed for the purposes of marketing, digital marketing and remarketing, the processing will be carried out by means of automated commercial information software, and will be carried out if the data subject has consented to the use of the data, or if the data subject has not withdrawn his/her consent for the use of the data;
  • In relation to personal data processed for profiling purposes, the processing will be carried out by means of proprietary tools that enable the definition of tastes and preferences in order to offer personalised services and communications. See next point for further details.

AUTOMATED DECISION-MAKING AND PROFILING

5. In the event that consent is given to the processing of personal data for the purpose of using personalised services by means of profiling, the same may be subject to an automated decision-making process, by means of a specific algorithm that will decide which communications are best suited to your profile or which may be of most interest to you. The processing done in this way has, by way of example, the expected consequences of sending highly profiled commercial communications, sending invitations to events considered to be of interest, etc. The data subject has, in any case, the right to obtain human intervention in the decision-making process on the part of the Holder, to express his or her opinion, to obtain an explanation of the decision reached and to contest that decision.

CATEGORIES OF TARGETS

6. Without prejudice to communications made in fulfilment of legal and contractual obligations, all data collected and processed may be communicated exclusively for the purposes specified above to the following categories of recipients

  • Supervisory and control authorities;
  • Authorised persons;
  • External supervisors;
  • Social Media.

In addition, authorised persons and/or internal and external supervisors identified in writing and to whom specific written instructions concerning the data processing have been provided may become aware of your data.

PERSONAL DATA TRANSFER TO THIRD COUNTRIES

Activity name

Countries

Appropriate UE

Activities and Sports Associations (Users)

United Kingdom; USA

Yes

RETENTION PERIOD

7. The data storage period is: The data collected will be reteined for the time strictly necessary to carry out the specified activities and in any case for a period not exceeding two years. On expiry, the data will be deleted unless there is no further purpose for retaining the data or there is WITHDRAWAL of consent by the data subject.

RIGHTS OF THE DATA SUBJECT

8.      In accordance with European Regulation 679/2016 (GDPR) and the national legislation in force, the data subject may, in the ways and within the limits provided by the legislation in force, exercise the following rights:

  • request confirmation of the existence of personal data concerning him/her (data subject’s right of access – Article 15 of Regulation 679/2016);
  • to know its origin;
  • receive intelligible communication of it;
  • obtain information about the logic, modalities and purposes of the processing;
  • request the updating, rectification, integration, cancellation, transformation into anonymous form, the blocking of data processed in violation of the law, including data no longer necessary to achieve the purposes for which they were collected (right to rectification and erasure – Articles 16 and 17 of Regulation 679/2016)
  • right to restrict and/or object to the processing of data concerning him/her (Art. 18 and Art. 21 of Regulation 679/2016);
  • right to data portability (Art. 20 of Regulation 679/2016);
  • in cases of consent-based processing, to receive their data provided to the data controller, in a structured, machine-readable form and in a format commonly used by an electronic device;
  • the right to lodge a complaint with the Supervisory Authority (data subject’s right of access – Art. 15 of Regulation 679/2016).

The data controller of your personal data is the company PALERMO FOOTBALL CLUB S.P.A., VAT no. 06804260823, C.F. 06804260823

The undersigned company has appointed a DPO (Data Protection Officer) who can be contacted at the following Pec address: [email protected]