MUNICIPALITY OF COMO, MUNICIPALITY OF LECCO AND MUNICIPALITY OF VARESE
PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA PURSUANT TO ARTICLE 13 OF REGULATION (EU) 2016/679
Registration and participation in Open Master Series 2027 – O.M.S. 2027 – Lake Como 2027
Introduction Pursuant to Article 13 of Regulation (EU) 2016/679 (hereinafter also referred to as the “GDPR”), the Municipality of Como, the Municipality of Lecco and the Municipality of Varese, acting as joint controllers (hereinafter also referred to simply as the “joint controllers”), hereby inform data subjects about the use of their personal data in connection with registration for, and related activities concerning, the 2027 edition of Open Master Series 2027 – O.M.S. 2027 – Lake Como 2027 (hereinafter also referred to as the “Open Master Games” or “OMG”).Data controllers and Data Protection Officers (DPOs)
Pursuant to Article 4(7) of the GDPR, the joint controllers are:- The Municipality of Como, with registered office at Via ________________ Tel.: __________ Email: ______________. The Municipality’s Data Protection Officer (DPO) can be contacted at: dpo@trustds.it
- The Municipality of Lecco, with registered office at Via ________________ Tel.: __________ Email: ______________. The Municipality’s Data Protection Officer (DPO) can be contacted at: _______
- The Municipality of Varese, with registered office at Via ________________ Tel.: __________ Email: ______________. The Municipality’s Data Protection Officer (DPO) can be contacted at: _______
Purposes of processing, personal data processed, legal basis for processing, data retention period and nature of data provision
Purpose A): management of participant enrolment, registration and accreditation procedures, as well as processing activities necessary to manage the organisational aspects of the event, in compliance with applicable laws.- Personal data processed: identification data, contact details, other sports-related information (e.g. discipline and relevant category), medical fitness to practise sport;
- Legal basis for processing: Personal data are processed on the following grounds:
- Performance of a task carried out in the public interest pursuant to Article 6(1)(e) of the GDPR, based on Article 13 of Legislative Decree No. 267 of 18 August 2000 (TUEL) and Lombardy Regional Law No. 26 of 1 October 2014, concerning the promotion and development of physical and sporting activities;
- Compliance with a legal obligation pursuant to Article 6(1)(c) of the GDPR, in relation to additional organisational aspects such as accounting obligations and/or document retention obligations;
- Performance of a contract pursuant to Article 6(1)(b) of the GDPR, in accordance with the Terms and Conditions of Open Master Series 2027 – O.M.S. 2027 – Lake Como 2027;
- With regard to data concerning athletes’ health, the legal basis is the performance of tasks carried out for reasons of substantial public interest pursuant to Article 9(2)(g) of the GDPR, read in conjunction with Articles 2-sexies and 2-septies of Legislative Decree No. 196/2003. Specifically, with regard to obtaining and verifying certificates of fitness for competitive sporting activities, the legal basis is the Decree of the Ministry of Health of 18 February 1982 (1715Q063) (Official Gazette, General Series No. 63 of 5 March 1982).
- Data retention period: until the end of the period established for reporting on the activities of Open Master Series 2027 – O.M.S. 2027 – Lake Como 2027, and in any event no later than 30 June 2028, without prejudice to any additional retention obligations imposed by law.
- Nature of data provision: provision of the data is mandatory for participation in the OMG.
- Personal data processed: photographs and video recordings of participants in Open Master Series 2027 – O.M.S. 2027 – Lake Como 2027;
- Legal basis for processing: Personal data are processed on the basis of the legitimate interests of the joint controllers (Article 6(1)(f) of the GDPR), consisting of their interest in promoting the event. To safeguard the rights of data subjects, the controller undertakes to select, from the photographs and videos produced, primarily images and footage depicting the event as a whole rather than individual participants. Participants may also exercise their right to object by using the contact details provided in section 1 of this notice.
- Data retention period: Processing will continue until the end of the period established for reporting on OMG activities and, in any event, until 30 June 2028. This is without prejudice to any further processing carried out by IMGA as an independent data controller, as indicated under Purpose C) below.
- Nature of data provision: provision of the data is necessary insofar as the data subject participates in the OMG. However, any objection to the processing of such data will prevent the joint controllers from continuing the processing to the extent that the data subject’s rights prevail.
- Personal data processed: identification data, contact details, other sports-related information (e.g. discipline and relevant category), and the outcome of the fitness verification. In the case of IMGA, photographs/videos are also included.
- Legal basis for processing: Personal data are processed on the basis of the performance of a contract, pursuant to Article 6(1)(b) of the GDPR, in accordance with the Terms and Conditions of Open Master Series 2027 – O.M.S. 2027 – Lake Como 2027;
- Data retention period: until the end of the period established for reporting on the activities of Open Master Series 2027 – O.M.S. 2027 – Lake Como 2027, and in any event no later than 30 June 2028. This is without prejudice to any further processing carried out by IMGA as an independent data controller, governed by the privacy policy provided by IMGA to registered participants.