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Privacy Policy

INDEX
 

•    INTRODUCTION
Before we begin, what is personal data?
Who is the data controller of the collected data?
Why do we collect and process your personal data?
How long do we keep your personal data for?
Who do we share your personal data with?
How do we protect your rights?
Data safety
Contacts

•    PRIVACY POLICY - WEBSITES
Personal data subject to processing
Personal data processing methods
Purposes of subjects’ personal data processing

•    OUR APPS MY REAL VIDEO PRIVACY POLICY
Entities involved in the processing 
Personal data subject to processing

• ID and contact details
• Location data

Personal data processing methods
Purposes of subjects’ personal data processing

• Use of the app
• Marketing

•    MY ETRAINING
Entities involved in the processing of personal data
Personal data subject to processing.
ID and contact details
Data suitable to disclose the health status
Location data
Personal data processing methods

•     PURPOSES OF SUBJECTS’ PERSONAL DATA PROCESSING

• Use of the app
• Marketing

Introduction
We at ELITE want to offer customers the best possible experience by researching the most advanced technical solutions for a competent and innovative service.
One of our goals is also to be as transparent as possible towards our customers and users about the data we collect, including data we process to continuously improve the service, so that it’s increasingly more adequate to satisfy the customers needs.
In that regard, in accordance with the entry into force and direct applicability of the new European Regulation (Reg. EU 197/2016) on personal data protection (General Data Protection Regulation - GDPR) we made all the changes and supplements to our data processing system directed towards improving the protection of the personal data we process.
Such changes and improvements specifically reflect the requisites of improved transparency, simplicity, accessibility and correct design introduced by the GDPR. 
This is why we feel it's important for all users to know all the information regarding the managing of personal data collected and processed that have been indicated in our new Personal data processing statement, wherein there'll be more info regarding: 

• privacy rights and how to exercise them,
• personal data collection, use, share and protection methods and 
• legal bases on which personal data is processed.

This page outlines personal data processing methods for users that use our apps (My Real Video and My E-Training) and visit our websites, which are electronically accessible at these addresses:

• www.elite-it.com
• https://myetraining-download.realaxiom.com/
• myrealvideo.elite-it.com
• forum.elite-it.com   
• support.elite-it.com
• www.fuoripista.it
• http://indoorrace.elite-it.com/
• https://novecolli.elite-it.com/

These info are not about other websites, pages or online services that can be reached via hyperlinks posted on the websites that refer to sources external to ELITE domains.

Before we begin, what is personal data?
The law defines “personal data” as any info regarding a natural person, identified or identifiable, directly or indirectly, via any reference or any other info, including a personal identification number. 

Who is the data controller of the collected data?
Data controller is the Elite S.r.l. company. (Companies Register Padova/Tax Code/VAT ID Intrastat IT 04342350289), with registered office in Fontaniva (PD), via Fornaci, 4/1, in the person of its legal representative; e-mail: privacy@elite-it.com .

Why do we collect and process your personal data? 
Your personal data is processed to perform the contract you subscribed with Elite, after a direct request from you to obtain info on the services or based on law provisions, including those concerning data protection.

How long do we keep your personal data for?
Your personal data is processed only for the necessary time to fulfill the purposes mentioned below and pursuant to the applicable law.

Who do we share your personal data with?
Your personal data might be shared with certain suppliers or agents and with IT services providers. Any third party supplier used by Elite srl will be obliged to process your personal data in full respect of the current regulations.

How do we protect your rights?  
As described in detail in the policies, you have the right to access your personal data being processed and receive a copy of them, subject to certain exceptions provided for by law. Moreover, you can oppose to the collection and subsequent processing of your personal data. You also have the right to require a limitation to possible processing and editing, if necessary, of your personal data or, under certain circumstances, their deletion. 
You can oppose the processing of personal data for direct marketing purposes.
Data safety
Whilst noting that there is no absolutely 100% safe data processing system, Elite constantly works to uphold the highest technical safety standards via the use of firewalls, appropriate software, antivirus, filtered navigation, encryption and any other available way depending on current technology. 

Who can you contact?
If you wish to exercise any of your rights or if you have any question about this personal data processing statement, please write to privacy@elite-it.com.
The full text of the statements can also be read at the following links:

• Websites contact information;
• My ETraining Information;
• My REal Video Information;

PRIVACY POLICY - WEBSITES
Entities involved in the processing of personal data
The entities "involved" in the aforementioned processing, pursuant to the law, are all users of the aforementioned websites that use the contact forms provided in the same websites. 

Personal data subject to processing
The processing covered by this statement will cover the following categories of personal data that the interested entities may freely provide and collect by filling out the forms in the registration screen of the aforementioned app:

• ID and contact details currently include: name, surname and email address, town and city, as data essential to manage the request for information contained in the form.

Personal data processing methods.
For the purposes indicated in the paragraph Purposes of personal data processing, personal data is processed by means of IT, manual and telematic tools (for instance, on paper), in accordance with rationales that are strictly related to the purposes themselves and with instruments that ensure data safety and confidentiality.
The processing is carried out by individuals authorized to perform such tasks, constantly identified, taught and instructed on the constraints set by the personal data protection framework and with the adoption of safety measures suited to avoid accidental data loss, destruction, illicit or incorrect use and unauthorized access.
Personal data will be stored until the subject files a request for deletion.
Processing personal data implies the assessment of such data by those authorized to process it (for instance: computer systems employees, administrative, marketing, communication and logistics employees).
Personal data can be transferred, exclusively in Italy, to third parties to which the communication of the same is necessary to technically pursue the purposes described in detail in the paragraph Purposes of personal data processing. 
A complete list of these subjects is available by contacting the data processing controller at the privacy@elite-it.com address. 
In no case personal data of the subjects will be transferred or distributed outside the EU territory.

Purposes of subjects’ personal data processing.
Personal data supplied might be processed for the following purposes, which are all legitimate pursuant to the current regulations of the discipline on personal data protection.

• Managing the request for information: Data collection necessary for such purposes is optional. Any refusal to supply them, in those fields marked as “Required”, results in the inability to obtain the requested info.
   
• Marketing: Sending advertising material and information on products, services and activities of Elite S.r.l., by way of automated or computerized communication via emails or messages such as texts, IS or MMS; market and client satisfaction surveys on the services to the subjects. Providing data needed for such purposes is optional. Any refusal to supply them, in those fields that are not marked as “Required” does not involve any consequence regarding the access to products and services by Elite S.r.l., but does exclude the possibility of processing data for marketing purposes. By consenting to these purposes, the subject also consents to receiving such information, promotional and advertising communications via traditional methods of contact (regular mail or phone calls). Under no circumstances, in any way, shape or form, subjects' consumption patterns will be profiled.

OUR APPS

MY REAL VIDEO APP
Entities involved in the processing of personal data.
The entities "involved" in the aforementioned processing, pursuant to the law, are all customers or potential customers of the Company identified in the following paragraph, as well as the users of the "My Real Video" app, available for the Android and iOS operating systems.  

Personal data subject to processing
The processing covered by this statement will cover the following categories of personal data that the interested entities may freely provide and collect by filling out the forms in the registration screen of the aforementioned app.

• ID and contact details: name, surname and email address as data necessary to use the app.
• Location data: such data processed by the controller exclusively to allow the user to use the App include route control while training to rebuild the elevation profile and for the toponymy display on the map. 

The App does not pick up, process or transmit to servers any data regarding the position of devices outside of training sessions. 
Indeed, the App does not track constantly the devices’ position.
Only the user can transmit location data when posting App-related content to be shared with other users. 

Personal data processing methods.
For the purposes indicated in the paragraph Purposes of personal data processing, personal data is processed by means of IT, manual and telematic tools (for instance, on paper), in accordance with rationales that are strictly related to the purposes themselves and with instruments that ensure data safety and confidentiality.
The processing is carried out by individuals authorized to perform such tasks, constantly identified, taught and instructed on the constraints set by the personal data protection framework and with the adoption of safety measures suited to avoid accidental data loss, destruction, illicit or incorrect use and unauthorized access.
The systems that will process data regarding health status have been configured in order to avoid using personal data or, as the case may be, the identifiability of the subjects, except when strictly necessary in relation to the objective pursued by the processing, with their consent.
Personal data will be stored until the subject files a request for deletion.
Processing personal data implies the assessment of such data by those authorized to process it (for instance: computer systems employees, administrative, marketing, communication and logistics employees).
Personal data can be transferred to third parties to which the communication of the same is necessary to technically pursue the purposes described in detail in the paragraph Purposes of personal data processing. 
In the event that among them there are subjects whose information infrastructure is located, even in part, outside the EU territory, the communication will be subject to the presence of appropriate safeguards for their transfer (even considering possible international conventions), that is prior approval by the competent authority that checks on the use of binding corporate rules applicable to the subject.
A complete list of these subjects is available by contacting the co-controllers of the data processing at the address given above.  
In no case personal data of the subjects will be transferred or distributed outside the EU territory.

Purposes of subjects’ personal data processing
Personal data supplied might be processed for the following purposes, which are all legitimate pursuant to the current regulations of the discipline on personal data protection.

• Use of the app: Data collection necessary for such purposes is optional. Any refusal to supply them, in those fields marked as “Required”, results in the inability to continue using some of all functions of the app. 
• Marketing: Sending advertising material and information on products, services and activities of Elite S.r.l., by way of automated or computerized communication via emails or messages such as texts, IS or MMS; market and client satisfaction surveys on the services to the subjects. Providing data needed for such purposes is optional. Any refusal to supply them, in those fields that are not marked as “Required” does not involve any consequence regarding the access to products and services by Elite S.r.l., but does exclude the possibility of processing data for marketing purposes. By consenting to these purposes, the subject also consents to receiving such information, promotional and advertising communications via traditional methods of contact (regular mail or phone calls). Under no circumstances, in any way, shape or form, subjects' consumption patterns will be profiled.

MY ETRAINING APP
Entities involved in the processing of personal data.
The entities "involved" in the aforementioned processing, pursuant to the law, are all customers or potential customers of the Company identified in the following paragraph, as well as the users of the "My Etraining" app, available for the Android and iOS operating systems. 

Personal data subject to processing
The processing covered by this statement will cover the following categories of personal data that the interested entities may freely provide and collect by filling out the forms in the registration screen of the aforementioned app.
ID and contact details
ID and contact details currently include:
•    name, surname and email address as data necessary to use the app;
•    birth date required for the use of some functionalities of the app;
•    full place of residence or home address as necessary data to directly issue invoices from Elite s.r.l.

Data suitable to disclose the health status
Data suitable to disclose the health status currently include:
•    heart rate;
•    weight.
Location data

Location data processed by the controller exclusively to allow the user to use the App include:
•    Route control while training to rebuild the elevation profile and for the toponymy display on the map. 

The App does not pick up, process or transmit to servers any data regarding the position of devices outside of training sessions.
Indeed, the position of devices isn't constantly tracked by the App. 
Only the user can transmit location data when posting App-related content to be shared with other users. 

Personal data processing methods.
For the purposes indicated in the paragraph Purposes of personal data processing, personal data is processed by means of IT, manual and telematic tools (for instance, on paper), in accordance with rationales that are strictly related to the purposes themselves and with instruments that ensure data safety and confidentiality.
The processing is carried out by individuals authorized to perform such tasks, constantly identified, taught and instructed on the constraints set by the personal data protection framework and with the adoption of safety measures suited to avoid accidental data loss, destruction, illicit or incorrect use and unauthorized access.
The systems that will process data regarding health status have been configured in order to avoid using personal data or, as the case may be, the identifiability of the subjects, except when strictly necessary in relation to the objective pursued by the processing, with their consent.
Personal data will be stored until the subject files a request for deletion.
Processing personal data implies the assessment of such data by those authorized to process it (for instance: computer systems employees, administrative, marketing, communication and logistics employees).
Personal data can be transferred to third parties to which the communication of the same is necessary to technically pursue the purposes described in detail in the paragraph Purposes of personal data processing. 
In the event that among them there are subjects whose information infrastructure is located, even in part, outside the EU territory, the communication will be subject to the presence of appropriate safeguards for their transfer (even considering possible international conventions), that is prior approval by the competent authority that checks on the use of binding corporate rules applicable to the subject.
A complete list of these subjects is available by contacting the co-controllers of the data processing at the address given above.  
In no case personal data of the subjects will be transferred or distributed outside the EU territory.

Purposes of subjects’ personal data processing.
Personal data supplied might be processed for the following purposes, which are all legitimate pursuant to the current regulations of the discipline on personal data protection.

• Use of the app: Providing data needed for such purposes is optional. Any refusal to supply them, in those fields marked as “Required”, results in the inability to continue using some or all functions of the App. 
• Marketing: Sending advertising material and information on products, services and activities of Elite S.r.l., by way of automated or computerized communication via emails or messages such as texts, IS or MMS; market and client satisfaction surveys on the services to the subjects. Providing data needed for such purposes is optional. Any refusal to supply them, in those fields that are not marked as “Required” does not involve any consequence regarding the access to products and services by Elite S.r.l., but does exclude the possibility of processing data for marketing purposes. By consenting to these purposes, the subject also consents to receiving such information, promotional and advertising communications via traditional methods of contact (regular mail or phone calls). Under no circumstances, in any way, shape or form, subjects' consumption patterns will be profiled.

SQUARE APP
Data Collection
The Square app does not collect any personal user data. Only technical data is recorded through the Sentry framework, solely for the purpose of diagnosing and resolving potential malfunctions.