PRIVACY POLICY

Updated on 28 January 2023

SC sport for all “Sofia Europe”(hereinafter without distinction SC “Sofia-Europe” or "We"), Data Controller of the Data of Users who browse the site  https://bulgaria.letapebytourdefrance.com/ (hereinafter the "Site") knows how important is for Your the way Your Personal Data is processed and acknowledges the importance of protecting and respecting Your privacy. Therefore, We have put in place all appropriate security measures to guarantee the protection and security of Your Data.

We explain to You in this "Privacy Policy" (hereinafter "Policy") why and how We collect and process Your Data on the Site, with whom and how We are likely to share it and, above all, Your rights relative to the protection of Personal Data and how You can exercise them.
We will refer to the Document, when We refer jointly to the General Conditions of Use of the Site, the Cookies Policy, and the Privacy Policy of the Site, which constitute a whole.
SC “Sofia-Europe” may modify and update the Policy at any time, in particular to take into account the evolutions of the Site, the services proposed and the applicable regulations.

Any changes we make will apply immediately upon notification, by any means, including, but not limited to, by posting a revised version of this Policy. You can find out when it was revised by referring to the "Last Updated" notice at the top of this Policy.

If you have any questions about the Privacy Policy,please contact us at the address letapebulgaria@gmail.com  

I. DEFINITIONS

In this Document, words or expressions beginning with a capital letter refer to the terms defined in the General Conditions of Use and, failing that, will have the definition of Article 4 of Regulation (EU) 2016/679 (known as "GDPR"):

"Consent" means any free, specific, informed and unambiguous expression of will by which the data subject agrees, by a statement or by a clear positive act, that Personal Data concerning him or her may be processed;

"Controller" means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing. In this case, SC “Sofia-Europe” may be considered as Data Controller or Joint Data Controller when You log in through Facebook or Google

"Cookie": text file containing information about the User of the Site, saved by the browser used by the User and which contains certain information about the User on the hard drive of the device used by him. The cookie has a limited lifespan and We will ask For Your consent whenever necessary.

"Data Processing" means any operation or set of operations carried out or not by automated means and applied to Data or sets of Personal Data, such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, communication by transmission, dissemination or any other form of making available, alignment or interconnection, limitation, erasure or destruction;

"Independent Controller" means the legal person, public authority, service, or any other body that independently defines the means of Processing the Personal Data of the Controller, for its specific purposes, limited to a specific context.

"Personal data" means any information relating to an identified or identifiable natural person (hereinafter referred to as "data subject"); is deemed to be an "identifiable natural person" a natural person who can be identified, directly or indirectly, in particular by reference to an identifier, such as a name, an identification number, location Data, an online identifier, or to one or more elements specific to his physical, physiological, genetic, mental, economic, cultural or social identity;

"Pixel": refers to a 1x1 pixel graphic that is loaded when the User opens a web page or an email. The Pixel makes it possible to trace all the activity of a User on the Web, regardless of the pages visited after the one where a Pixel is located.

"Processor" means the natural or legal person who processes Personal Data on behalf of the Data Controller;

"Recipient" means the natural or legal person, public authority, agency, or any other body that receives communication of Personal Data, whether it is a third party. In this case, SC “Sofia-Europe” may send Your data to its Partners or share it with social networks

"Social Networks" means sharing spaces on the Internet that allow the User of the Site to follow the Tour or the other events proposed by the Site in social networks.

"Tag": Refers to an element introduced in each of the pages whose audience we measure, to testify to their diffusion. It is inserted into the source code of the page. The tags that We use allow Us to check the effectiveness of the pages proposed and the operation of the Site, in a completely anonymous way.

"User" means any person browsing the Site.
"You", "Your" means the User of the Site.

II. WHAT DATA DO WE PROCESS AND FOR WHAT PURPOSES?

A. ON THE WEBSITE https://bulgaria.letapebytourdefrance.com/   

We only collect the personal data we need to achieve the following purposes:
- Allow you to:

• Subscribe to the newsletters of SC “Sofia-Europe” and/or Our partners if You have consented to;
• Allow you to follow the Tour on the official pages of the Event in social networks;
• Share Your Videos and Photos content on TikTok;

- Our legitimate interest in ensuring the security of the Site: reCaptcha of the newsletter subscription form;
- Propose to you content or targeted advertising from Third Parties if You consent to the deposit of their Cookies. To learn more about how Cookies work on the Site, we invite You to read the Cookies Policy.

1. DATA COLLECTED DIRECTLY

We collect Your Data directly from You, in order to allow You to subscribe to newsletters.

a) Data collected during Your subscription to newsletters

When You want to follow all the news about the Tour de France, You can subscribe to Our newsletters. If You wish, You can also subscribe to those of Our partners. You will need to give Your consent each time.
To subscribe to newsletters, We need some of Your Data. The Mandatory Data is followed by an asterisk (*).

(1) Mandatory data

We collect so-called Declarative Data of which You are the sole source. The following Data are mandatory:
-Identity data
-Personal life data (language preferences)

(a) Identity data

To subscribe to the Tour de France newsletter, We need the following Identity Data. We will only ask You for Data that is strictly necessary for the purposes We follow:
-Civility
-Email
-Last name
-Name
-Date of birth
-Country

(b) Personal life data

Personal life data allows Us to know the language in which You prefer to receive the Tour de France newsletter or, if You have consented, that of Our partners.
Other Data is optional, and You remain free to provide it or not.

(2) Optional data

To respect for Your privacy, We only collect the Data necessary for sending the newsletter by email. For this reason, the following Identity Data is optional:
- Address
- City
Indeed, We send You the newsletter by email, so We do not need Your home address.

2. DATA COLLECTED INDIRECTLY

Data collected indirectly is generally collected by Third Parties:
- Google: via the reCaptcha at the bottom of the newsletter registration form;
- Social Networks, through the Pixels that they deposit on the Site and that allow You to follow the Tour in the official pages of the Event in said Social Networks.

a) Connection Data : Google's reCaptcha

In order to preserve the security of the newsletter registration form, to fight the misuse of the Tour newsletter registration form by preventing bots (automatic software) and to protect against spam, We use the Google reCAPTCHA service at the bottom of the newsletter registration. In compliance with art. 6, paragraph 1, p. 1, lit. f GDPR, it protects Our legitimate interest in terms of security of our website as well the optimal display of our online presence.
Google reCAPTCHA is an offer from Google LLC: 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, (hereinafter "Google").
Google reCAPTCHA uses a code embedded in the website, called JavaScript, as part of the verification methods to analyze your use of Site, such as cookies. The information automatically collected about your use of this system, including your IP address, is usually transmitted to and stored on a Google server in the USA.
Further information on Google's data protection rules can be found at www.google.com/policies/privacy

b) Data collected by Social Networks when You follow the Tour on their official pages

SC “Sofia-Europe” allows you to follow the Tour through the official pages of the Event in social networks. This is the reason why we have implemented different buttons, each corresponding to the Social Network concerned:
- Facebook
- Instagram
- YouTube

(1) Facebook and Instagram buttons

Our Site has implemented a Facebook and Instagram button to allow you to visit the Facebook and Instagram pages of the Event, in which case Facebook is considered a Joint Controller. Indeed, Facebook collects Your Data as soon as You open a site in which this Facebook Pixel is located and tracks Your navigation through all the Sites.
Facebook Ireland is a Joint Controller and You can find all the information required by Article 13(1)(a) and (b) GDPR in the data policy of Facebook Ireland https://www.facebook.com/about/privacy.
Information about your use of the applicable products as well as the purposes for collecting and communicating the personal data constituting the joint processing take place in accordance with the applicable Product Terms.
Further information on how Facebook Ireland processes personal data, including the legal basis on which Facebook Ireland relies and the means available to data subjects to exercise their rights against Facebook Ireland, can be found in the Facebook Ireland Privacy Policy available at https://www.facebook.com/about/privacy.
However, once you are redirected to the Facebook page of the Event, Facebook becomes an "Independent controller" because Facebook is the only one to decide what data to collect, the purposes of the processing of Your data and You will have to contact Facebook to exercise your rights.

 (2) YouTube Button

Our Site has implemented a YouTube button to allow you to follow the Event on videos shared on YouTube. In this case, YouTube is considered a Joint Controller. Indeed, YouTube collects Your Data each time You click on the YouTube button on Our site.
YouTube is a Joint Controller and You can find all the information required by Article 13(1) (a) and (b) GDPR in You Tube's Privacy policy
Information about your use of the applicable products as well as the purposes for collecting and communicating the personal data constituting the joint processing take place in compliance with the applicable Product Terms.
Further information on how YouTube processes personal data, including the legal basis on which YouTube is based as well as the means available to data subjects to exercise their rights against YouTube, can be found in You Tube's Privacy Policy.
However, once you are redirected to the YouTube page of the Event, YouTube becomes an "Independent controller" because YouTube is the only one to decide what data to collect, the purposes of the processing of Your data and You will have to contact YouTube to exercise Your rights.

III. USE OF YOUR DATA: PURPOSES

We only use and process data that is relevant to the following purposes:
- Allow you to register for a club of fans and enthusiasts of the Tour de France;
- Send you newsletters of other events organized by SC “Sofia-Europe” or commercial offers from Our partners, if You consent by ticking the respective boxes;
- Propose services and personalized content (videos, press articles, etc.);
- Allow you to follow the Tour or other amateur or professional cycling events on social networks;
- Allow you to know Our partners in order to acquire the products that make You happy.
- Guarantee the security of the Site;
- Fight against fraud;
- Any other purpose for which We will ask You for Your Consent, if necessary.

1. Recipients of Your Data

We share Your Data with Our Data Hosting Processor.
If You are redirected to a Third-Party Site, Your data will be processed by that Third Party Site. This can be the Social Networks or the Website of the Boutique du Tour. In this case, the publishers of the Third-Party Sites will be the Data Controllers.

As We have specified in Chapter B.1 of this Policy,from the moment You choose to log in to Your account through Your Facebook or Google accounts, You are redirected to their Sites and SC “Sofia-Europe”  is no longer the Data Controller of Your Data.

SC “Sofia-Europe” cannot control the Data Processing made by Social Networks when You are redirected to their sites and therefore cannot be held responsible for any misuse on their side. We strongly recommend that You carefully read the Privacy Policies or Statements of each of the Social Networks in order to be able to know how they use Your Data and how to exercise Your rights.

IV. CONSENT, THE LEGAL BASIS TO PROCESS YOUR DATA

We do not sell or rent Data to Third Parties. We use your data in strict compliance with applicable personal data protection law. You remain the sole master of the use of Your Personal Data by giving or withdrawing Your consent at any time:
- When You register;
- When You subscribe to the newsletters.

(1) Subscription to newsletters

When You register, You are also asked if You wish to receive newsletters from A.S.O. or from Our partners.
Each time, We ask for Your Consent.
It will always be possible for You to unsubscribe by clicking on the link at the bottom of the newsletter.

V. RETENTION OF YOUR DATA

We have implemented the principle of minimization of Your Data and We keep Your Data only for the time necessary to fulfill the Purposes here described.
We keep Your Data for a period of 3years. Once the 3-year deadline has expired, We securely delete Your Data and ask Our Data Processors to do the same.