(pursuant to D. Lgs.196/03 and Regulation (EU) 2016/679)
“DATA CONTROLLER”, DATA SUPERVISOR AND DATA PROCESSORS
With regard to Privacy, consultation of this site by the user entails the acquisition of information in the nature of personal data. For these purposes, the Data Controller of the personal data you provide is RSG GROUP Italia s.r.l., in the person of its legal representatives pro tempore, with registered office (not open to the public) at Piazza della Mostra 2, 39100 Bolzano BZ and operational headquarters (not open to the public) at Viale Fulvio Testi 29 – 20162 Milan, Italy, and a co-owner of the processing RSG GROUP GMBH – Germany (single member). A DPO (Data Protection Officer) has been appointed and can be reached at firstname.lastname@example.org. Within the Company itself, the personal data collected are processed by employees who act as “Data Processors”, following the specific instructions and indications given to them.
Place of data processing
Processing related to the web services of the site www.mcfit.com, takes place at the company headquarters in Milan, by the Data Controller and is handled only by technical personnel of the Office in charge of processing, or by any persons in charge of occasional maintenance operations. No data deriving from the web service is communicated or disseminated (art. 90 GDPR). Personal data provided by users who forward requests for the sending of informative material are used for the sole purpose of performing the service or provision requested and are communicated to third parties only if this is necessary for that purpose (art 3 GDPR).
What is meant by personal data and the processing of personal data
The processing of personal data constitutes any operation or set of operations, carried out even without the aid of electronic instruments, concerning the collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, cancellation and destruction of data, even if not registered in a database.
Type of data processed and purpose of processing
1) Navigation data
The computer systems and software procedures responsible for the operation of this site acquire, in the normal course of operation, some personal data that are then implicitly transmitted in the use of Internet communication protocols.
This information is not collected to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified.
All our activities are governed by strict ethical principles and we are committed to protecting the privacy of all visitors to our website. For this reason, the way we collect and store data is closely related to how you use our website and related services.
2) Data voluntarily provided by users/visitors
If users/visitors, connecting to this site, send their personal data to access certain services, or to make requests by e-mail, this involves the acquisition by RSG GROUP Italia s.r.l. of the sender’s address and/or any other personal data that will be processed exclusively to respond to the request.
The personal data provided by users/visitors will be communicated to third parties only if the communication is necessary to comply with the requests of the users/visitors themselves.
3) Utility for the user
The Possibility of data collection through special forms for requesting information of the services provided, to follow up on this activity the user must give consent.
4) Cookies Various technologies may be used on our website to improve it and make it more user-friendly, effective and secure. These technologies allow us, or third parties working for us, to collect data automatically. Examples of such technological solutions are cookies.
No use is made of cookies to transmit information of a personal nature, nor are so-called persistent cookies of any kind, i.e. systems for tracking users, used.
The use of c.d. session cookies (which are not stored persistently on the user’s computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to enable the safe and efficient exploration of the site.
The so-called session cookies used in this site avoid the use of other computer techniques potentially prejudicial to the privacy of users’ browsing and do not allow the acquisition of personal identification data of the user. (http://www.mcfit.com/it/mcfitcom/cookie-policy/)
In addition to automatically collected data, we also process data you provide. The following is an illustrative but not exhaustive list:
your contact information, first and last name and social security number, address (to be indicated on the invoice), e-mail address and date of birth, your telephone number or cell phone number, should there be a need to ask you questions or for any inquiries regarding the subscription you have subscribed to;
other information necessary to administer the service: for example, information about how to activate a subscription you have subscribed to, bank account information, iban and swift;
if he has contacted customer service, related information and the history of these contacts.
All these data have in common that they were provided by you. This information will be used for the purposes described in this Notice. You have the right to rectify, at any time, your personal data or to prevent its processing. (See Section Rights of the Data Subject).
How the data collected is used: purposes
We will use your personal data for purposes related to the requested services: for example, to notify you of the status of your subscription. It is possible the use of your data to verify by using the information of third parties, your creditworthiness.
If you have provided us with your personal data, for example in connection with a promotional initiative, an event, it is possible that we may send you e-mails or other messages relevant to the service you have requested.
If you have filled out our form on the website for inquiries, we will use your information to contact you.
If you have contacted customer service, we will use your personal information (including your contact and call history) so that we can facilitate the processing of your requests and provide you with the best possible service.
If necessary, we will contact you after the sale of the service to inquire about its status and satisfaction. You can unsubscribe at any time, free of charge and with immediate effect, from the list of recipients of these communications: just send us an e-mail (see Data Subject Rights Section).
Subject to your explicit consent, we may contact you via the contact information provided by you (by regular mail, e-mail, SMS, telephone or other electronic means) for marketing, advertising and survey purposes on behalf of RSG GROUP Italia s.r.l. This will be, for example, information about services, special offers, promotional initiatives, or about the opening of new RSG GROUP Italia s.r.l. gyms in your area and their activities, as well as sporting events. In order to be able to communicate information of interest to you, data on your participation in loyalty programs, your ratings and reviews of the service, the history of your contacts with customer service, what you clicked/opened from the newsletter, the types of newsletters you requested to receive, your participation in promotions or events will be analyzed and used, combined. In the Data Subject Rights Section you can read about your rights, for example how to revoke your consent or how to correct your personal data.
Personal data will be processed for the following purposes:
- functional for the fulfillment of legal, regulatory or EU obligations;
- contract execution or to fulfill, prior to the completion of the contract, Your specific requests in connection with subscription.
- customer management and related administrative activities, with related processing, in accordance with the relevant regulations, billing and shipping.
- preparation of measures aimed at protection against credit risk, including activities aimed at identifying the economic reliability/solvency of the Customer, before or during the contractual relationship. RSG GROUP Italia s.r.l. may verify that the bank/postal data provided is correct.
- relating to the performance, of activities aimed at the elaboration of studies and market research, the performance of direct sales activities, for the sending of commercial information, as well as for the sending of advertising/information material, carried out by “traditional” means (by way of example, paper mail and/or call with operator) or by means of “automated” contact systems (by way of example, SMS and/or MMS, telephone calls e-mail, fax) pursuant to Article 130, c. 4, Privacy Code and Regulation (EU) 2016/679 . The data subject may at any time object to the processing by sending a request to the dedicated mailbox mentioned in the email: email@example.com.
- Litigation management (contractual defaults, warnings, settlements, debt collection, arbitrations, judicial disputes).
Processing of personal data: mandatory consent and optional consent
As a rule, the processing of personal data is permitted only with the consent of the data subjects, which must be free, informed, expressed in a specific form and documented in writing. The data subject is free to provide the personal data requested from time to time; failure to provide, partial or inaccurate provision of such data may make it impossible to provide the services requested (Art. 7 GDPR).
The acquisition of consent to the processing of personal data is necessary for all the above-mentioned processing related and/or necessary to comply with legal obligations, EU regulations, to perform obligations arising from a contract to which the data subject is a party or to fulfill, prior to the conclusion of the contract, specific requests of the data subject (purposes: points 1-2-3-4-5).
Consent to the processing of personal data for the purposes referred to in point 5, on the other hand, is optional and may be revoked at any time in the manner described in the “Rights of the data subject” section of this notice. Any refusal by the data subject to respond to point 5 will result in our inability to send advertising material and carry out promotional activities.
At any time you may revoke the consent to receive commercial communications previously issued, by RSG GROUP Italia s.r.l., in the following ways:
By sending a request to firstname.lastname@example.org.
Method of processing and storage
Personal data are processed using paper, computer, telematic, automated tools including profiling (art 22 GDPR); Profiling can be done using individual or identification data (e.g., master data), or aggregate data derived from individual personal data. All in compliance with the guarantees of confidentiality and security measures provided for by current legislation, with logics strictly related to the purposes̀ of the processing.
Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access.
The data retention period is related to the purpose of the current processing. RSG GROUP Italia s.r.l. will not retain personal information longer than is necessary to fulfill the purposes for which such information was processed, including the security of our processing procedure in accordance with regulatory and legal obligations (e.g., auditing, accounting, and legal retention periods), dispute management, and for the determination, practice, or defense of legal rights in those countries where we conduct business.
Disclosure of information
One of our core principles is our commitment to treat your data with care and confidentiality. We will never sell your data to third parties. Your data may be disclosed to third parties only in the event that the Law requires it and under the condition that it is permitted by applicable Laws.
It is possible that we use service providers and data processors who work on behalf of RSG GROUP Italia s.r.l.
These are service providers who provide hosting and maintenance services, analytics services, email messaging services, delivery services, payment processing, solvency verification, address verification, etc. Such third parties are allowed access to those personal data they need for the purposes of their specific services. Service providers and data processors have a contractual obligation to treat such information as strictly confidential. The contract prohibits them from using the data for purposes other than those stipulated in the contract. RSG GROUP Italia s.r.l. has taken the necessary steps to ensure that our service providers and data processors working for RSG GROUP Italia s.r.l. protect the confidentiality of your data.
CATEGORIES OF PARTIES THAT MAY BECOME AWARE OF USER DATA
In addition to the employees of RSG GROUP Italia s.r.l. some processing of the user’s personal data may also be processed by third parties, including companies to which RSG GROUP Italia s.r.l. entrusts or may entrust certain activities functional to the consultation of the site. These subjects will operate as autonomous Data Controllers or as Data Processors. In the latter case, the Data Controller will give the Processors adequate operating instructions with particular reference to the adoption of minimum security measures in order to be able to guarantee the confidentiality, integrity and security of the data. The user’s data may also be communicated to the Judicial, administrative or other public authorities entitled to request them, in the cases provided for by law.
For the pursuit of the above-mentioned purposes, RSG GROUP Italia s.r.l. may communicate and have your personal data processed, in Italy and abroad, including countries outside the European Union, to third parties with whom it has dealings: the latter will only provide them with the information necessary to carry out the requested services taking all measures to protect your personal data (art 44 GDPR).
Personal data may, moreover, be known by employees, self-employed, project workers, occasional, consultants, temporary workers, collaborators of RSG GROUP Italia s.r.l. who have been specifically appointed/designated as Data Processors or Persons in charge of the processing. Accounting and billing staff; service management staff;
The above data may be transferred and communicated to the following category of subjects: companies operating in the transport sector, our suppliers of sporting goods, our affiliates, our Sponsors, the Italian Post Office and other correspondence delivery companies, banks and credit institutions, debt collection companies, law firms, insurance companies, professional firms and/or companies and/or associations of companies and Entrepreneurs that provide us with certain accounting and/or tax services, social security institutions, etc;
Rights of the interested parties
RSG GROUP Italia s.r.l. reminds the interested party that, in accordance with Article 7 of the Privacy Code, Legislative Decree 196/03 and Regulation 2016/679, it is possible, at any time, to obtain confirmation of the existence or otherwise of the data and to know its content and origin as well as the logic on which the processing is based, verify its accuracy or request its integration or updating, or rectification.
Pursuant to the same article, the interested party has the right to request the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, their processing.
For processing related to direct marketing (in “traditional” and “automated” form), permitted by Legislative Decree 196/2003 art. 130 paragraph 4), it will always be possible to revoke consent and exercise the right to object. The opposition, in the absence of any indication to the contrary, will refer to both traditional and automated communications. For the purpose of exercising the above rights, a request must be sent to the dedicated mailbox email@example.com.
If you provide us with your personal information through our websites or other channels, this is done completely voluntarily. If you choose not to provide the requested information, you may miss several opportunities available to customers. There are instances where only those who have sent us the necessary personal information can order products, take advantage of certain services, and take advantage of activities and offers available on our website. Given the importance to us of transparency and fairness, we offer several options, appropriate to the circumstances, to help you maintain control of your data. These options may include viewing and editing your data online. There may also be the option to unsubscribe or to receive information about the data we maintain by writing to the email: firstname.lastname@example.org.
Right to request information
You have the right to receive information at any time about the personal data stored about you, its origin and recipients, and the purposes for which it was stored. Information about retained personal data can be obtained by contacting us at the e-mail address: email@example.com. The subjects to whom the personal data refer have the right at any time to obtain confirmation of the existence or non-existence of the same data and to know their content and origin, verify their accuracy or request their integration or update (art. 7 of Legislative Decree 196/03 and Regulation 2016/679).
Right of rectification
You have the right to rectify, supplement, update, delete your stored personal data, or to have it blocked. We will notify you within four weeks of receiving your request whether, and if so, to what extent we will comply with your request. If, for some reason, we are unable to comply with your request, we will inform you of the reasons (art. 7 of Legislative Decree 196/03 and art 12 and 16 GDPR).
Right to object and to cancel your registration
According to the same article you have the right to request the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, their processing (art 21 GDPR).
E-mails sent by RSG GROUP Italia s.r.l. that contain, for example, a newsletter or marketing messages, offer the possibility to have the receipt of such e-mails ceased, if you no longer wish to receive promotional information and sales offers in general, not even by regular mail, e-mail, SMS, telephone or other electronic means, or you wish to revoke your consent, you may also do so, at any time, by writing to RSG GROUP s.r.l. Viale Fulvio Testi 29 – 20162 Milan indicating as reference: “data protection officer”, or by sending an e-mail to firstname.lastname@example.org. If there is any doubt about your identity, you may be asked for an identification document (e.g., a photocopy of your ID) (art 17 GDPR).
Information security and data integrity
We have taken appropriate technical and organizational measures to protect personal data from accidental or unlawful events that result in their destruction, loss, alteration, and from unauthorized use, disclosure, or access, especially where the processing involves the transmission of data over a network and against any other form of unlawful processing and abuse.
Protection of children’s personal data
The protection of children’s personal data is of utmost importance. RSG GROUP Italia s.r.l. is aware of its obligation to protect the privacy of minors, and refuses to collect data from children under the age of 16. We urge parents and other guardians to surf the Internet and send e-mails together with their children and to enjoy the Internet responsibly. If a minor under the age of 16 attempts to provide information about his or her own data from the very beginning, he or she must seek the parent’s consent. Data sent by the child, or otherwise concerning the child, collected during the child’s visit (e.g., through cookies) may be used as described above.
If a minor under the age of 16 attempts to submit his or her own data via form/form, it will be rejected, with the notice that we do not accept such requests from minors under the age of 16. For this reason, we ask that parents and other guardians check and monitor minors’ use of the Internet, for their safety (art 8 GDPR).
How to contact us
The owner of the processing of personal data is: RSG GROUP s.r.l. Viale Fulvio Testi 29 – 20162 Milan – e-mail: email@example.com
The co-owner of the processing is: RSG GROUP GMBH – Tannenberg 4, 96132 Schlüsselfeld (Germany), VAT no: DE 185 786 214.
The appointed DPO can be reached at the following e-mail address: firstname.lastname@example.org
You can learn about an updated version of this document and the updated list of data controllers by contacting the Data Controller directly.
Amendments to this policy