We may collect and process the following data about you:
- Information you give us. You may give us information about you by filling in forms on our site or by corresponding with us by e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey and when you report a problem with our site. The information you give us may include (but is not limited to) your name, address, e-mail address and phone number, personal description or social media usernames.
- Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
- technical information, including the Internet protocol address (also known as an ‘IP address’) used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and/or
- information about your visit, including the full Uniform Resource Locators (also known as a ‘URL’) through and from our site (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
- Information we receive from other sources. We may receive information about you if you use any other website we operate or the other services we provide, or from our shareholders. We are also working closely with third parties and may receive information about you from them.
VELON BUSINESS PARTNERS
If you agree, we will share the information that you have provided to us with our carefully selected partners. These partners will never use this data to contact you for any reason or post, link or make reference to any of your social media accounts.
Our current business partners are the race organiser of the Giro d’Italia (RCS Sport) and our data processor (EY):
For the purpose of the GDPR, RCS Sport S.p.A (“RCS”) of Rizzoli n. 8, Milan, Italy is an independent data controller meaning that they have to carefully look after your data in accordance with the law. RCS will use the information you have provided to us to understand your engagement level in our app or website and where you are from. RCS’ aim is to use this information to improve fan engagement in their races.
If at any time you want to stop RCS from processing your data in the way set out above all you need to do is email “RCS opt-out” to firstname.lastname@example.org. RCS will then remove your data from the database, delete any reference to your data and email you to confirm that they have done so. RCS will never use this data to contact you for any other reason.
General: For the purpose of the GDPR, Ernst & Young LLP (“EY”) of 1 More London Place, London SE1 2AF is an independent data controller meaning that they have to carefully look after your data in accordance with the GDPR. EY will use the information you have provided to us (as to which see the "Information we collect about you" section above) to combine your data with consumer data or database(s) from other sources and process these combined data sets in order to produce insight about consumers generally. EY do not use your data to produce insights on you as an individual. These activities are often referred to as "data analytics".
Ground of Processing: Under GDPR, EY have to inform you of the ground(s) on which it is processing your personal information. The ground on which EY are processing your personal data for the purposes of data analytics is consent.
Data retention: EY will store your personal data which is used for data analytics.
Your rights: EY have certain rights in relation to the personal information EY holds about you. Details of these rights and how to exercise them can be provided on request to email@example.com. References to "We" in this section include EY.
Right to withdraw your consent: If at any time you want to stop EY processing your data in the way set out above, all you need to do is email “EY opt-out” to firstname.lastname@example.org. EY will then remove your data from its analytics databases and email you to confirm that they have done so. EY will never use this data to contact you for any other reason.
Contact details and Data Protection Officer: If you have any enquiries or if you would like to contact EY about the processing of your personal information for data analytics, including to exercise your rights as outlined above, please contact the contact details below.
Data Protection Officer/Chief Information Security Officer: Barbara O’Neill
1 More London Place
London SE1 2AF
International data transfers: EY may transfer your personal data to one or more of its member firms in countries (including Australia) outside the country in which it was originally collected for further processing in accordance with the purposes described in this section. In these circumstances EY will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. Please contact email@example.com for a copy of the safeguards which EY have put in place to protect your personal data and privacy rights in these circumstances.
If you have any questions at all with regard to the Velon business partners, we would love to hear from you. Please feel free to email us at any time at the address listed in ‘Contact’ below.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
- Information you give to us. We will use this information:
- to notify you about changes to our service; and/or
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
- Information we collect about you. We will use this information:
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so; and/or
- as part of our efforts to keep our site safe and secure.
- Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
DISCLOSURE OF YOUR INFORMATION
We may share your personal information with any shareholder of Velon or current/future members of our group.
We may share your information with selected third parties including analytics and search engine providers that assist us in the improvement and optimisation of our site.
We may disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if Velon, or substantially all of its assets, are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; and/or
BASES ON WHICH WE PROCESS YOUR PERSONAL DATA
The GDPR provides people within the EU, and in certain circumstances, others, with numerous rights, including the right to: access, rectify, erase, restrict, transport, and object to the processing of, information about you. You also have the right to lodge a complaint with the relevant data protection authority if you believe that your personal data is not being processed in accordance with applicable data protection law.
- Right to make subject access request (SAR): You may, where permitted by applicable law, request copies of your personal data. If you would like to make a SAR, (i.e. a request for copies of the personal data we hold about you) you may do so by emailing us at firstname.lastname@example.org. The request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and a fee.
- Right to rectification: You may request that we rectify any inaccurate and/or complete any incomplete personal data.
- Right to withdraw consent: You may, as permitted by applicable law, withdraw your consent to the processing of your personal data at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit certain service features for which the processing of your personal data is essential.
- Right to object to processing: including automated processing and profiling. You may, as permitted by applicable law, request that we stop processing your personal data
- Right to erasure: You may request that we erase your personal data and we will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping your personal data, such as, a legal obligation that we have to comply with, or if retention is necessary for us to comply with our legal obligations.
- Right to data portability: In certain circumstances, you may request that we provide your personal data to you in a structured, commonly used and machine readable format and have it transferred to another provider of the same or similar services. We will comply with such transfer as far as it is technically feasible. Please note that a transfer to another provider does not imply erasure of your personal data which may still be required for legitimate and lawful purposes.
- Your right to lodge a complaint with the supervisory authority: We suggest that you contact us about any questions or if you have a complaint in relation to how we process your personal data. However, individuals who are in the EEA have the right to contact our lead supervisory authority in Europe which is currently the Information Commissioner’s Office in the United Kingdom. You can visit the ICO website for instructions.
Our site may, from time to time, contain links to and from other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
INTERNATIONAL TRANSFERS OF DATA
We may transfer your personal data to a third party in countries outside the country in which it was originally collected for further processing in accordance with the purposes set out above. In particular, your personal data may be transferred to our outsourced service providers located abroad. In these circumstances we will, as required by applicable law, ensure that your privacy rights are adequately protected by appropriate technical, organisation, contractual or other lawful means. Please contact email@example.com. For a copy of the safeguards which we have put in place to protect your personal data and privacy rights in these circumstances.
RETENTION OF DATA
We will usually retain your data for as long as needed to provide the services and fulfill the transactions you have requested and for other essential purposes such as complying with legal obligations, resolving disputes and enforcing our agreement. Criteria used to determine the length of retention include:
- How long the data is needed to provide services and operate the business
- Is there the expectation by students and customers that we will retain or maintain data until it is removed by the user?
- Can the customer or user use an automated control to access and delete the personal data at any time?
- Is the personal data of a sensitive nature?
- Has a certain type of data been assigned to a specific retention policy by Velon?
- Has the user consented to a longer period of retention?
- Is there a legal or contractual obligation to retain the data?
We may keep an anonymised form of your personal data, which will no longer refer to you, for statistical purposes without time limits, to the extent that we have a legitimate and lawful interest in doing so.
Please note our website and app are not designed for children under the age of 13.
Last updated: 25 May 2018