The Data Controller informs you, as data subjcets, who will process your personal data, eventually belonging to special categories too, where requested and conferred by the same, in compliance with the regulatory provisions of the sector and, in particular, those referred to Reg. 679/16/EU, to Italian Legislative Decree n. 196/03 and its subsequent amendments, to the Guidelines and indications provided time by time by the Italian Supervisory Authority. as well as any special laws that specifically regulate the processing of data belonging to special categories in order to guarantee a reinforced guarantee to data subject.


  1. Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  1. Personal data: any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one 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 factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
  2. Special categories of personal data: personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation.


  1. The Data Controller of your personal and special categories of data is Trixman A.S.D. (C.F. 97989400581), Viale Aventino, 79 Roma, email


  1. The Data controller will process your personal data in order to achieve specific purposes and only under a specific legal base provided for by the applicable legislation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data. Specifically, the Data controller shall process the personal data only when one or more of the following legal basis recur:
  • the data subject has given consent to the processing of his or her personal data for one or more specific purposes;
  • processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the requesto of the data subject prior to entering into contract;
  • processing is necessary for the purposes of the legitimate interests pursued by the controller;
  • processing is necessary for compliance with a legal obligation to which the controller is subject;

Below are listed the purposes for which your personal data are processed by the data controller and the legal basis on which the treatment is based on:

Purposes of the Processing   Legal base
Allow the fullfilment of the contractual performance due to your participation to competition Performance of a contract
Reply to data subject’s request Performance of a contract
Control of the quality and effectiveness of the services used by data subject, as well as to adequately orientate the training actions of the persons authorized to process personal data Legitimate interest
keep the data subjects informed about this iniziative as well as their upcoming similar initiatives by including their personal data inside a mailing list Legitimate interest
Allow the Company to fulfill the obligations of law, regulation or envisaged by the Community legislation. Compliance with a legal obligation
Inclusion of data subject’s personal data into lists of names formed by the Data Controller in order to receive information and commercial communications (eg by telephone or telematic contact - newsletter) on activities, promotions and company initiatives (marketing) Consent
Inclusion of data subject’s personal data into lists of names formed by the Data Controller in order to receive information and commercial communications (eg by telephone or telematic contact - newsletter) on activities, promotions and company initiatives (marketing) to be sold or grant in use to third parties Consent
Allow the fullfilment of the contractual performance (participation to competition) Consent (about processing of special categories of personal data)
Data subject profiling Consent


  1. No automated decision-making process is provided according to article 22, paragraphs 1 and 4 of the EU reg. n. 679/16


  1. The event shall be the subject of filming and audio-video recordings. The personal data object of the treatment, inclusive of the images, the filming and the audio / video recordings, also in partial and / or modified or adapted form, realized during the event will be treated, in full compliance with the Code regarding data protection personal data (Legislative Decree 196/03 as amended by Legislative Decree 101/18) and of EU Regulation no. 679/16, as well as the provisions on the issue made by the Supervisory Authority. The collected images will be kept, also in electronic form and on any technological support for the purposes and within the limits defined above and may be diffused on the thematic websites, owned as well as through social network channels (Facebook, Twitter, Youtube by way of example but not exhaustive). The use of the images does not entitle you to any compensation to which you as data subject, by participating to the competition, declare from now on to renounce. The Data Controller has the right to access or disclose the images of the data subject without any consent, according to the art. 97 of the law n. 633/1941 and, if the data subject does not intend to allow diffusion, he is obliged not to participate to competition. Anyhow it is excluded -pursuant to the aforementioned article and pursuant to art. 10 of the Italian Civil Code-, any use of the Images that could prejudice the honor, reputation or decorum of the data subject portrayed, resumed or registered. The records will be kept by the Data Controller, in accordance with the principles set forth in art. 5 EU Regulation 679/2016, for a period of time not exceeding the achievement of the purposes and, in any case, for a maximum period of 10 years from the time the event was held, without prejudice to the possible preservation of the same for a further period where it is necessary for the management of ongoing legal actions and the fulfillment of specific legal obligations.


  1. The data subject, if envisaged by the Data Controller, may use a tracking and geolocation service -in real time and not- through mobile devices and / or GDPS-GPRS and satellite trackers carried out by an external supplier, who is identified as Data Processor.
  2. The use of such devices, where provided for, is necessary for the purpose of verifying the correct performance of sports performance (respect of pre-established tracks) as well as to allow the athletes' ready support in case of need. At the same time, the registered positions referring to the single pseudonymised athlete can be shown on public and / or private web maps during the competition, as well as providing indications regarding the only temporal performance rendered (no data collection belonging to particular categories, and in particular health and / or biometrics).
  3. The satellite device may be provided by an external provider, which is identified as the Data Processor in charge of the supply of satellite mobile devices for localization through the relevant platform.
  4. For the aforementioned protection purposes as described above, the personal data acquired may be disclosed only to Data Controller, Data Subject, insurance companies, parent companies for the performance of administrative and legal services, law firms, public bodies and judicial authorities. The data are made available, to the extent strictly necessary, for the aforementioned purposes of protection.
  5. The processing of the aforementioned data (initial and final geographical position, distance traveled, time and date of beginning and end of the journey) is carried out with precautions to prevent any tampering and thus preserving its authenticity, accuracy and 'integrity. These data are stored in compliance with all the necessary safety regulations.
  6. Your personal data will be stored, unless expressly requested by the interested party for a longer period, only for the time necessary to achieve the purposes of the aforementioned treatment, in compliance with the principles of proportionality and necessity; in any case, they will be kept no later than 6 months after the conclusion of the sporting event, without prejudice to the possible preservation of the same for a further period where necessary for the management of ongoing legal actions and the fulfillment of specific legal obligations.


  1. Your personal data may be processed under contract and for the purposes identified above also from external processors, appointed by the Controller, who carry out activities related to the provision of the services provided, i.e.:
  • professionals (-eg chartered accountant, occupational doctor, labor consultant, lawyer);
  • supplier of goods and/or services in outsourcing
  1. Your personal data may also be transferred to third parties in order to observe the obligations of law or contract and only for the time necessary to achieve this end; i.e.:
    • Public security authorities, judicial authorities (upon request);
    • Italian Authorities for the release of the NOS;
    • to Italian Authorities and Italian and foreign companies for access to sites (both for classified and non-classified visits) as part of business opportunities.
    • to a partner company for activities for activities consistent with the legitimate business interest, including analysis of the organizational climate as well as other bodies and / or authorities that are recipients for laws and / or regulations (eg public and / or private social security or insurance agencies, agency revenue, trade union organizations to which the mandate was given).
  2. Your data may also be processed by those authorized for that purpose by the holder for the purpose of fulfilment of the tasks and duties.
  3. If your data should take for purposes of statistics, it will be sent anonymously.


  1. Your personal data will be processed within the European Union and stored on servers located in the European Union. Any transfer of data to international organizations and/or non-EU countries, will be one of the ways permitted by the legislation by adopting Standard Clauses approved by the European Commission, the selection of persons included in international programs for the free movement of data (eg. EU-USA Privacy Shield) or operating in countries considered safe by the European Commission.


  1. Your personal data will be stored only for the time necessary to achieve the purposes of treatment above illustrated, respecting the principles of proportionality and necessity. In particular, your personal data will be stored as long as there is a contractual relationship with the data subjects and, anyway, no more than 10 years since the end of the contractual relationship, without a chance to storage it for a longer periodi if necessary for the management of judicial actions and/or to compliance with specific legal obligations.
  2. The storage takes place both in printed and electronic form.  In both modes of preservation, proper security measures, to ensure the integrity, confidentiality and availability of information, are put in place and tested periodically.


  1. Data Subject has the right to ask the data controller  for access to his personal data (to obtain confirmation as to whether or not personal data concerning him or her are being processed), rectification or erasure; he can also ask for the limitation of processing as well as to oppose their processing, in addition to the right to the portability of the data in accordance with art. 20 of EU reg. # 679/16.


  1. At any time Data Subject has the right to revoke the consent given. In that case, Data Subject is aware that the withdrawal does not affect the lawfulness of the processing based on consent given before the withdrawal, as well as is aware that any withdrawal will not allow the delivery of provision based on consent given.


  1. At any time Data Subject has the right to lodge a complaint with the Italian Supervisory Authority (Autorità Garante per la Protezione dei Dati Personali) via:
  • -registered mail to the headquarters of the Authority (actually, Piazza di Montecitorio, 121, 00186 Roma)
  • -email avaiable on the website ( or
  • -fax (actually 0039.06.69677.3785)

or to start a Judicial Claim.


  1. The provision of your Personal Data, including the photographic image of the interested party, possibly belonging to special categories, is necessary in all cases in which the processing takes place on the basis of a legal obligation, or to execute a contract of which you are a party, or from the execution of pre-contractual measures taken at your request, or in order to fulfill the obligations and exercising specific rights of the controller or of the data subject in the field of employment and social security and social protection law or of preventive or occupational medicine, for the assessment of the working capacity of the employee, medical diagnosis, the provision of health or social care or treatment or the management of health. A possible refusal could imply for the Data Controller the impossibility to proceed with the purpose for which the Personal Data are collected.
  2. The conferment of your personal data is optional for data relating to voluntary programs (eg, for welfare, insurance and social purposes, credit cards for service, car for service or for the use of Welfare Plan services "Enjoy Life Time") but, failing that, it will be impossible to keep it in the program applicable to you..

The Data Controller

By accepting the "Privacy Policy" pop up banner I declare that I have received and viewed, as the data subject, the informations provided pursuant to and for the purposes of Regulation (EU) 679/2016 (GDPR) in order to processing of my personal data, also belonging to special categories, operated on the basis of the legal bases declared and for the purposes and with the methods indicated in the aforementioned informations.