PERSONAL DATA INFORMATION CLAUSE
(fulfilments related to the Law Decree dated June 30th 2003, no. 196 - Privacy Code)
This information on privacy rights describes the processing of the personal data uploaded to or collected on the website www.juventus.com (“Website”) and any other site on which it is published. This information provides also information on the processing of the personal data which were uploaded to or collected through Applications which are made available by Juventus on third-party platforms or websites.
- Type of personal data collected
- Method of collection of the personal data
- Purpose of the processing
- Soft Spamming
- Disclosure and diffusion of the data
- Method of data processing
- Possible disclosure by the interested party of third party personal data
- International transfer, storing and processing of the personal data
- The privacy rights of minors
- Data Controller and Data Processor
- Rights of the interested party
- Amendments to this privacy information
Aggregate Data. Aggregate data means the information on groups or categories of users, which do not identify and cannot be reasonably used to identify an individual user.
Anonymous data. Anonymous data means the information which do not identify and cannot be reasonably employed to identify an individual user.
Application. Application means a program or a service managed by Juventus (or on behalf of Juventus) which can be displayed in different environments and on-line platforms, mobile or otherwise, including those managed by third parties which allows us to directly interact with our users.
Minors. Minors mean the individuals identified by us as minors who are not able, according to the Law, to grant their consent to the collection and the processing of personal data.
Data Controller. Means the personal data controller responsible for the personal information collected by the Website and the Applications, i.e. Juventus Football Club S.p.A. with registered office in C.so Galileo Ferraris n. 32 – 10128 Turin (Italy).
Data Processor. The personal data processor is an individual or entity which carries out the processing of personal data on behalf of one or more data controllers, authorised to carry out the data processing only according to the instructions of the controller.
IP Address. The IP address is associated to the access point through which the internet connection is carried out and it is usually controlled by the Internet Service Provider (ISP) of the user.
Notice. A notice may be sent by e-mail to the user at the last e-mail address indicated, through the publishing of amendment notices on the Website or the Application or using other means according to the current laws.
Parents. The parents term refers to a parent or a legal guardian.
Personal data. Personal data means the information which identify (directly or indirectly) a specific individual, for example the name, the postal address, the e-mail address, the telephone number, the navigation data, the IP address. When they are directly or indirectly associated to personal data, the anonymous data are also processed as personal data.
Public forums. The Websites and the Applications may offer message walls, conversation pages, chat rooms, social community environments, profile pages and other forums where the public is not limited. If personal data are provided during the use of such functions, such information may be made public or otherwise disclosed without any limit to their use by us or any third party. To request the removal of your data from a public forum or one of our websites or applications, please contact……[pg1] .
Website. the website www.juventus.com
2. Type of personal data collected
We collect two basic types of information: personal data and anonymous data; furthermore, we may use either personal or anonymous data for the creation of a third type of information: aggregate data. We collect the following categories of personal data:
- registration data uploaded when the user creates an account, which include name and surname, home address, sex, date of birth, state of birth, e-mail address, username and password;
- data of the transaction uploaded when one of our products or services is purchased on our Website or through our Applications, which include information on the purchased products/services, the postal address, the telephone number and the payment information;
- data uploaded in public forums on the Website and Applications;
- personal data sent by an user to another one within a close group, through messaging, chat, message publication or similar functions, provided that the service is active AND allowed by the applicable legislation;
- personal data uploaded while using the Website, our Applications, our Applications on third party platforms or websites, such as social networking sites or when the user links his profile on one third party website or platform through his registration account;
- information on the location of the user at the moment of the visit to our Website or the use of our Application, including the location information provided by a mobile device which interacts with our Website or Applications, or related do the IP address of the user, provided that the processing of such data is allowed by the applicable legislation;
- use, display and technical data, including the device identification code or the IP address of the user, the moment in which the user visits the Website, uses our Applications on third-party websites and platforms, or opens our e-mail messages.
3. Method of collection of the personal data
- We collect the personal data uploaded by the user when products, services or information are requested or when the user signs up on the Website, takes part in public forums or other activities on our Website and Applications, contacts our customer care, replies to questionnaires or surveys, takes part in a promotion, a game or a competition or otherwise interacts with us. Please acknowledge that when the user provides personal data to third party platforms or websites (for example, through our Applications), the data sent may be collected separately by the third-party website or platform. We collect personal data complying with the provisions of the current legislation on privacy; furthermore, the personal data collected by third party websites and platforms are subject to the directives on privacy of such third-party websites and platforms. The decisions concerning privacy made by the user on third party websites and platforms shall not apply to the use by us of the personal data directly collected by use through our Applications.
- The IT systems and the software procedures employed for running the Website collect, during their normal course of operation, some personal data whose transmission is implied by the use of the Internet communication protocols. Such information are not collected to be associated to identified concerned persons, but, due to their own nature, may, through processing and the association with data held by third parties, allow the identification of the users. This category of data includes IP addresses or domain names of computers used by users who connect to the site, URI addresses (Uniform Resource Identifier) of requested resources, the time of the request, the method utilized to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc..) and other parameters related to the operating system and the IT environment of the user. Such data are used only to obtain anonymous statistical information on the Site and to check its correct functioning and are stored for the time defined by the relevant legislation. The data may be used to ascertain responsibility in case of hypothetical computer crimes against the Website.
4. Purpose of the processing
Access to and browsing the site are free, but the possibility to receive certain online services offered by the Website is allowed only subject to registration by the user. The registration process consist of the filling of an on-line form in which the user is requested to state his personal data – some of them are required – for activating the authentication credentials (email + password) through which, then, the interested party person will access to all the areas and the services of the Website which are reserved to the registered users. Thus, firstly, the primary purpose of the processing is the need to allow that the requested procedures of prior online registration and for the creation of an account are carried out and to enable the operators of the Website the generation and the subsequent technical and administrative management (including the provision of technical support and assistance upon request) of the account, of the activation codes, of the passwords and similar authentication credentials to be employed on the Website as created by the users within the registration process.
Once they have signed in the Website, registered users are then enabled to receive all the services offered online by the Website Such services are organised in the following areas and can be received based on the separate contractual terms available on the Website:
- Legends area for the on-line purchase of the tickets for the Legends Stand;
- Parking area for the on-line purchase of the Stadium parkings;
- My Season Pass area for receiving the services connected to the season pass;
- Membership area;
- www.juvestore.com e-commerce website for the purchase of Juventus official products.
Thus the processing of the personal data (including their recording in the Juventus database) seeks to achieve the following primary purposes:
a) guarantee the registration to the Website, enable the user to access to the web pages of the Website where it is possible to receive the online services, guarantee the correct provisions of the services requested from Juventus through the Website, and, therefore, perform in a correct and a timely manner all the obligations arising from the contractual relationship established, and also the obligations provided for the current legislation or regulations, in particular obligation related to tax or public security purposes;
b) for administrative and accounting purposes, including the transmission, if any, by e-mail of business invoices by Juventus and/or any company connected thereto during the supply of the service, for the delivery of notices to the user which regard the account or the transactions carried out with Juventus;
In all the cases under points a), b) and c) above, Juventus shall not be obliged to procure any specific consent from the user. All the processing detailed above seek, actually, primary purposes for which art. 24 of the Privacy Code excludes the need to procure a specific consent from the interested party, either because the processing is required for complying with a obligation set by the Law, by a regulation or by the EC legislation, or because the processing is required for carrying out any duty arising from a agreement in which the concerned person is one of the parties, or for meeting, before the execution of the agreement, specific requests of the concerned person.
In the case where the user does not intent do provide in any case the requested personal data, which are required based on the above, this would lead to the impossibility to complete the registration to the Website and to receive all the services for which the registration and the provision of the data are in any case required based on technical and contractual reasons.
It would remain in any case possible to browse the Website as a non registered and anonymous user and to display only the contents and the materials available without registration.
Complying with the Privacy Code and the user's choices, the data may be also processed for the following secondary purposes:
d) for registering to the mailing lists held by our Company, for carrying out market surveys and polls (also by telephone, online, and using forms), the delivery of advertising and information material on the products and services offered by Juventus by the Juventus partners, solicitations of purchase, through automated systems, such as e-mail, fax, sms or MMS, or traditional methods (for example: traditional post letters), or by telephone with an operator (hereinafter, globally “Processing for Marketing purposes”);
e) for the processing of the user's market profile (by sampling the consumption patterns), seeking, both to monitor the satisfaction degree of customers for ensuring the best satisfaction of their needs, both to send customer specific information and/or advertising material, using automated systems, such as e-mail, fax, SMS or MMS or by ordinary post.
In all the cases detailed under points d) and e) above, the data may be processed only if a specific consent is granted. The lack of any declaration of consent shall be held as a denial.
Then, by granting the optional consent, the interested party specifically acknowledges and authorises such further possible processing. In any case, even if the concerned person granted his consent to seek the purposes listed under points d) and e), he shell remain in any case free to cancel it in any moment, by sending a clear notice on the matter to Juventus at the following e-mail/postal address….....[pg2]
The denial will not involve any consequence, except for the impossibility of being included in statistical analysis and/or profiling and to receive promotions, discounts and focused communications, based on the provided data, or to be informed on any marketing and promotional/advertisement initiatives. Therefore, for such further purposes, the processing shall be carried out only according to the purposes and based on the specific consent granted by the concerned person upon registration to the Website.
5. Soft Spamming
Limited to the e-mail address provided by the user while purchasing a service through the Website, the provided data may be employed for allowing the direct offer by Juventus of similar products and services (so-called soft spamming), without prejudice for the right of the user to oppose such processing.
6. Disclosure and diffusion of the data
Any collected data may be disclosed to:
- external trusted subjects which are entrusted by Juventus with certain task or parts thereof, that are required for supplying or distributing the services offered through he Website (for example: hosting companies, project managers, programmers, system experts and database administrators), or whose activity is connected, instrumental or supportive of that performed by Juventus (for example, subjects to whom Juventus can assign customer care activities; subjects who carry out technical or organizational type of activities, such as press services, mailing, transmission, transport, and sorting of communications; consultants). In such case, these subjects will be appointed as Entities Responsible for or Appointed to perform data processing. The full list of Data Processors is available upon request from the reference Data Processor appointed by the Company to respond to the interested party.
- to any entity (Public Authorities includes) which may access to the personal data based on statutory and administrative provisions;
- to any public and/or private subject, individuals and/or entities (legal, administrative and tax consultancy firms, Judicial Authorities, Chamber of Commerce, Labour Authorities, etc.), if the disclosure is required or functional for the correct performance of the contractual obligations, and also of the statutory obligations;
- to banks and to companies which manage National and International payment circuits through which the on-line payments of the products purchased through the Website are carried out.
In any case, the personal data shall not be disclosed.
7. Method of data processing
The processing of the personal data shall be mainly carried out using electronic or in any case automated means, according to the modes and with the appropriate means for ensuring the safety and the confidentiality of the data themselves, according to the provisions of Legislative Decree 196/2003. In particular, all the technical, IT, organizational, logistic and procedural safety measures, as envisaged by Legislative Decree 196/2003, shall be adopted in order to ensure the minimum level of protection provided for by the law, allowing the access only to the persons appointed for the processing by the Data Controller or by the Data Processors appointed by the Controller.
8. Possible disclosure by the interested party of third party personal data
The user acknowledges that the possible indication (for example in the management of the season pass in the “My Season Pass” section) of personal and contact data of any third party different from the interested person shall be held as a personal data processing, with regards to which he shall act as independent controller, undertaking all the obligations and responsibilities provided for by the Privacy Code. To that effect, the user guarantees to Juventus that any third party data which shall be indicated in such way by the user (and which shall be accordingly handled as if the third party granted his informed consent to the processing and the disclosure of the data to Juventus) was collected by the user himself in full compliance with the Privacy Code. To this regards, the user grants the widest indemnification with regards to any objection, claim, request for compensation of any damage arising from the processing, etc. which may be received by Juventus from any third party interested based on the provision of the data indicated by the user violating the applicable provisions on personal data protection.
9. International transfer, storing and processing of the personal data
The data are stored on servers located in Italy. There is the possibility that Juventus stores personal data on a cloud, that means that the data may be managed by a provider of cloud services on behalf of Juventus and stored in different locations worldwide. If our activity implies the transfer of personal data to third parties located in different places worldwide, for the purposes described in this privacy information, wherever the personal data are transferred, stored or processed by us, we shall adopt suitable organizational and contractual measures for safeguarding the personal data and we shall impose similar requirements, which are not less restrictive, to the providers of the cloud services, including the obligation to process the personal data only for the purposes listed above. Furthermore, when we use or disclose personal data transferred from countries which entered into Safe Harbor Agreements with the USA, we comply with the Safe Harbor principles as defined by the US Department of Commerce, we use standard contractual clauses approved by the European Commission, we adopt other measures under the legislation of the European Union for ensuring an appropriate protection, or we obtain the consent of the user.
10. The privacy rights of Minors
With regards to the functionalities of the Website, we do not intentionally collect personal data of Minors. According to the applicable Laws, the Parent must grant his consent to the collection of the personal data of the Minor; the registration to the Website by the Minor shall be therefore be authorised by the Parent and carried out under the supervision of the Parent himself, for that reason, the e-mail address supplied must be the e-mail address of the Parent. The parent has the right to review and to request the removal of the personal data.
The products/services on the Website can be purchased only by persons over 18 years of age using a valid credit card.
11. Data Controller and Data Processor
The Data Controller is Juventus F.C. S.p.A. with registered office in C.so Galileo Ferraris 32 - Turin; The designated Data Processor is the pro tempore Manager of the Commercial Department appointed by the Holder on behalf of the interested party in the case of exercising the rights referred to in Article 7, which the interested party can consult by contacting the following address: Turin (Italy), Corso Galileo Ferraris 32.
12. Rights of the interested party
It should be noted that art. 7 of Legislative Decree 196/2003 establishes that the interested party has specific rights, among which is the right to get confirmation on the existence of his or her personal data, even if not registered yet, to receive clear communications on such data, its origin, the purposes and modes whereby it shall be processed, as well as on the logic applied in case of data processing performed with the support of electronic means. Furthermore, the interested party can receive updates, amend the data, or, if necessary, integrate it with other data, as well as deleting, making anonymous, or blocking access to said data following legal violations. The interested party may also oppose, in full or in part and for legitimate reasons, the processing of his/her personal data even if pertinent to the purpose of the collection, i.e. for commercial communications, for the mailing of advertisement materials, or for direct selling.
13. Amendments to this privacy information
Occasionally, we may amend this privacy information in order to include new technologies, industry practices and statutory requirements, or other purposes. We shall inform the user through a relevant Notice in the case where such amendments are significant and we shall obtain the consent from the user if so provided by the current laws.
Last update: 1 July 2015