Effective as of: August 15, 2023
Notice pursuant to and for the purposes of Article 13 of the EU General Data Protection Regulation (GDPR) 2016/679 and applicable national legislation regarding the protection of personal data processing.
Welcome to our platform for accessing information, services, and video content related to the world of endurance sports.
This Policy aims to explain how and why personal data is processed by Vivilo.ai S.R.L., as the data controller (hereinafter, "Vivilo.ai" or the "Controller"), in providing services through the website www.vivilo.ai (the "Site"). For certain services, Vivilo.ai reserves the right to provide a specific privacy notice that may, from time to time, supplement or amend this Policy; in case of conflict, the terms of the specific privacy notice for that service will prevail.
The provisions set forth herein apply to anyone browsing the Site or interacting with Vivilo.ai services, also accessible via any mobile applications, and more generally to individuals whose personal data is processed within the scope of the Services (the "data subjects").
Processing will be carried out in compliance with EU Regulation 2016/679 (the "Regulation"), national implementing provisions, and the measures issued by the Italian Data Protection Authority.
1. Scope of Application
Every individual has the right to the protection of their personal data. Vivilo.ai is committed to ensuring the confidentiality of data subjects and their right to be informed about the collection and processing methods of their data.
In accordance with the principles of necessity and proportionality, the Services are designed to minimize the collection and use of identifiable data, excluding processing when purposes can be achieved using anonymous data or other methods.
This Privacy Policy refers solely to the Vivilo.ai Services offered by the Controller and does not extend to third-party pages or websites accessible via links; users are invited to consult their respective privacy policies.
2. Purposes and Legal Basis for Processing
a) Contract Performance / Service Provision
User data and data of individuals indicated by the user are processed for the performance of the contractual relationship and the provision of requested Services, specifically to: manage registration, authentication, and platform access; manage requests for goods or services (including photographic and video footage depicting event participants); manage payments; manage interactions with third-party social networks; issue administrative, accounting, and tax documents.
Legal basis: Art. 6, paragraph 1, letter b) of the Regulation (performance of a contract). For any special categories of data (e.g., health-related data), the legal basis is explicit consent pursuant to Art. 9, paragraph 2, letter a); failure to provide or withdrawal of consent makes it impossible to provide the Services. For the publication of photos and videos from events, specific authorization is collected by the organizer at the time of registration.
When, at the user's direction, Vivilo.ai processes third-party data (e.g., a third party registered for an event), the processing is also based on the Controller's legitimate interest pursuant to Art. 6, paragraph 1, letter f); the data subject may object at any time by writing to info@vivilo.ai.
b) Compliance with Legal Obligations
Data is processed to comply with legal obligations, such as tax requirements, related to the performance of the contract. Legal basis: Art. 6, paragraph 1, letter c) of the Regulation.
c) Marketing Purposes
Vivilo.ai may process data using traditional methods (mail, calls with an operator) for commercial and promotional communications about its products and services, and may use the provided email for direct sales of products similar to those purchased, in pursuit of its legitimate interest (Art. 6, paragraph 1, letter f). Users can always object by writing to info@vivilo.ai or by using the link provided in every email.
With explicit consent (Art. 6, paragraph 1, letter a)), Vivilo.ai may also send communications via automated channels (SMS, email, App notifications), invite users to promotional initiatives and loyalty programs, and conduct market research. Consent can be revoked at any time by writing to info@vivilo.ai.
d) Profiling Purposes
With explicit consent (Art. 6, paragraph 1, letter a)), Vivilo.ai may analyze user habits and interests to suggest relevant products, services, and events, also based on participation in previous events and area of residence. Consent can be revoked by writing to info@vivilo.ai.
e) Communication to Third Parties for Marketing Purposes
With explicit consent, Vivilo.ai may communicate certain data (name, surname, date and place of birth, postal code, address, contact details) to event organizers and partner companies for offers of interest to users. Consent can be revoked by writing to info@vivilo.ai.
f) Corporate Operations or Business Transfer
Vivilo.ai may transfer data to entities resulting from corporate operations (mergers, demergers, etc.) or to companies that acquire or lease the business, for the continuation of the Services, based on the Controller's legitimate interest (Art. 6, paragraph 1, letter f). The right to object remains by writing to info@vivilo.ai.
3. Types of Data Processed
a) Browsing Data
During normal operation, computer systems acquire certain data whose transmission is inherent to Internet protocols (e.g., IP addresses, URIs of requested resources, timestamps, request methods, response status codes, operating system parameters). This data, processed to generate anonymous statistics and ensure proper functioning, is deleted immediately after processing, except when used to investigate responsibility in cases of cybercrime.
b) Data voluntarily provided by the user
This includes: identification and contact data (name, surname, gender, date of birth, company name, address, contact details); payment and billing data; special categories of data required for a requested Service (e.g., data related to disabilities for registration in special categories); information published and shared directly by the data subject. Providing this data is necessary for the provision of Services; failure to provide it may make it impossible to offer these Services.
c) Public data and photographic recordings of events
The Website also acts as an aggregator for recordings of sports events. Participants may be filmed or photographed during events; the organizer may request authorization for publication and distribution, including through third parties such as Vivilo.ai. These recordings are processed to document the event and make photos and videos available on the platform for purchase and sharing. Individuals who do not consent to the use of their image should not participate in events for which organizers acquire such rights; in any case, the data subject may request in writing the removal or obscuring of their image, after identifying the specific photo or video.
d) Data transmitted by third-party providers of the data subject
For the provision of requested Services, Vivilo.ai may process data transmitted, with the data subject's prior authorization, by third parties who provide specific services to them.
4. Public Sharing, Social Networks, and Third-Party Websites
By using the Services for competitions and events, the user chooses to make their participation public. Each user can modify their sharing preferences at any time, creating a public, private, or limited-access profile; it is recommended to carefully consider the data published. Sharing on social networks occurs through providers who act as independent data controllers. For events organized by third parties, the organizer may process data for their own purposes and with their own privacy policy; where applicable, Vivilo.ai may act as a joint controller or an independent controller alongside the organizer.
5. Disclosure of Data to Third Parties
No data will be disseminated or disclosed to third parties without consent, except for data shared by the user themselves through the Services. Providers, consultants, or partners necessary for the provision of Services are appointed as data processors in accordance with Article 28. For hosting, Vivilo.ai uses AWS Amazon Web Services Inc., Google Ireland Limited, and Webflow, Inc., with servers located in the European Union. The complete list of processors is available upon request. Data may be disclosed to competent authorities when permitted by law.
6. Transfer of Data Outside the European Economic Area
Any transfers to third countries are carried out based on an adequacy decision by the European Commission or, in its absence, on appropriate safeguards (standard contractual clauses approved by the Commission or binding corporate rules) or on a derogation applicable to the specific situation. For more information: info@vivilo.ai.
7. Security Measures
Vivilo.ai adopts appropriate technical and organizational measures in accordance with Articles 32 et seq. of the Regulation, including: pseudonymization and encryption; the ability to ensure the confidentiality, integrity, availability, and resilience of systems; the ability to restore data promptly in the event of an incident; and procedures for regularly testing, assessing, and evaluating the effectiveness of the measures. Vivilo.ai uses AWS and Google Ireland Limited, whose services are ISO 27001 certified.
8. Data Subject Rights
Data subjects can: obtain information about and access their data; obtain data portability; request rectification or correction; request erasure (Art. 17); request restriction of processing (Art. 18); object to processing in the cases provided. Requests should be submitted via the vivilo.ai website, from the Privacy section of your account, or by writing to info@vivilo.ai (with a copy of your identification document where necessary for identification). It is also possible to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali), Piazza Venezia 11, 00187 Rome — garante@gpdp.it.
9. Links to Other Websites
The Data Controller does not control the content or policies of third-party websites accessible via links and is not responsible for their data processing activities. Users are encouraged to consult the terms of use and privacy policies of the websites they visit. The presence of links does not imply any recommendation or guarantee from the Data Controller.
10. Cookies
Browsing the site involves the installation of cookies, either by the Data Controller or by third parties, designed to ensure the Website's functionality and improve the browsing experience. For more information, please consult the Cookie Policy.
11. Minors
The use of the Services is reserved for adults. For images of minors captured during an event, Article 3, point c) applies; the related rights are exercised by the person with parental responsibility. Any abuses can be reported to info@vivilo.ai.
12. Data Controller
VIVILO.AI S.R.L.
Cesena (FC), Via Ugo Bassi 3, CAP 47521
Email: info@vivilo.ai
13. Changes to the Policy
The Data Controller reserves the right to make changes and updates at any time; users will be informed of any modifications.
14. Legal References
This policy is prepared in compliance with Article 13 of the GDPR and applies exclusively to the website www.vivilo.ai. For information, please contact: Vivilo.ai S.R.L., Cesena (FC), Via Ugo Bassi 3, CAP 47521 — info@vivilo.ai.
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