OCHRANA OSOBNÝCH ÚDAJOV
Introduction
The SLOVAK ULTRA TRAIL civic association, as the organiser of the public sporting event ‘Letecká stovka’ (hereinafter referred to as the ‘Race’), carries out activities relating to the preparation and organisation of the Race, in the course of which it processes personal data provided by Race participants, primarily for the purpose of registering participants for the Race, including the settlement and recording of participants’ payments, necessary communication with participants, ensuring the smooth running of the Race, and recording the Race results or storing data on the Race results, for the period specified in these terms and conditions. Personal data will be processed, used and disclosed only to the extent expressly set out in these terms and conditions.
I. Legal framework for the protection of personal data
Act No. 18/2018 Coll. on the Protection of Personal Data (hereinafter referred to as the ‘Act’) and related legislation of the Slovak Republic (e.g. decrees of the Office for the Protection of Personal Data of the Slovak Republic)
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation – ‘GDPR’)
II. Controller’s identification details
The controller is o.z. SLOVAK ULTRA TRAIL (registered office: Nejedlého 41, 841 02, Bratislava, Company Registration Number: 42364582) (hereinafter referred to as the ‘controller’).
Contact details of the data controller:
name: SLOVAK ULTRA TRAIL o.z.
address at which the data subject may exercise their rights regarding the processing of personal data: Nejedlého 41, 841 02, Bratislava
email: letecka100k@gmail.com
Data controller’s representative: none appointed
Data protection officer: none designated
Data protection supervisory authority:
Office for Personal Data Protection of the Slovak Republic, Hraničná 12, 820 07 Bratislava 27; telephone number: +421 2 3231 3214; email: statny.dozor@pdp.gov.sk, www.dataprotection.gov.sk.
III. Scope of personal data processing
1. First name, surname, country, date of birth, telephone number, email address, account number (for recording payments received and any refunds).
2. Any audiovisual or visual recordings made of the Races, where the data subject is identified or identifiable.
IV. Purpose of personal data processing
1. Registration via the registration system on the website www.letecka100.sk; recording data on the data subject, their orders and the status of order fulfilment, for the purposes of registering for the Races.
2. Registration of a participant – the data subject – for the Races: receipt, processing and handling of the electronic application form (participant registration), recording of payments received and any refunds to the participant, and fulfilment of related legal obligations (accounting, tax and similar).
3. Ensuring the smooth running of the Race, in accordance with all rules set out in the Race regulations and other conditions applicable to the Race, and with the provisions of the relevant legislation governing the obligations involved in organising the Race (in particular Act No. 1/2014 Z. z. on the organisation of public sporting events); fulfilment of the relevant statutory and contractual obligations of the Race operator or organiser towards the participant – the data subject.
4. Recording of provisional and final Race results, including the long-term storage of data on Race results, the compilation of statistics on the results of the Slovak Ultratrail League and, where applicable, other statistics, whereby the following applies:
- personal data comprising: first name, surname, country – are published in the start list, in the provisional results and in the results list (together with provisional or final finishing times) on the Race website and/or the SLOVAK ULTRA TRAIL website as the Race organiser and/or the hiking. dennikn.sk, or on the relevant social media pages, or on the website of the GPS tracking service provider;
- if the Race is registered with the ITRA (International Trail Running Association) for the allocation of ITRA points, personal data comprising: first name, surname, date of birth and country are provided to ITRA (either directly by the organiser or via SLOVAK ULTRA TRAIL), together with the participant’s result, for the purpose of awarding ITRA points to the participant, compiling statistics on the participant’s results and determining the participant’s ITRA Performance Index.
- if the race is registered for the UTMB Index, personal data comprising: first name, surname, date of birth and country, together with the participant’s result, are provided to the UTMB World Series (either directly by the organiser or via SLOVAK ULTRA TRAIL) for the purpose of awarding points towards the participant’s UTMB Index, maintaining statistics on the participant’s results and determining the participant’s UTMB Index.
5. The collection of information about the Race and the documentation of the Race through audiovisual or visual recordings, where the data subject is identified or identifiable – the organiser and/or SLOVAK ULTRA TRAIL may, for the purpose of providing information about the Race, its progress and results, use and publish personal data to the extent of: first name, surname, together with the participant’s result, as well as any audiovisual or visual recordings made in which the participant is identified or identifiable, on the Race website and/or the SLOVAK ULTRA TRAIL website as the Race organiser and/or the hiking.dennikn.sk website, or on the relevant social media pages, or on the website of the GPS tracking service provider.
V. Legal basis for the processing of personal data
1. For the purpose specified in paragraph IV, point 1 above: pursuant to Section 13(1)(a) of the Act – the data subject has given their explicit consent to the processing of their personal data, namely upon the data subject’s registration via the registration system on the website www.letecka100.sk.
2. For the purpose set out in paragraph IV, points 2 and 3 above: pursuant to Section 13(1)(b) and Section 13(1)(f) of the Act respectively – the processing of personal data is necessary for the proper performance of the contract between the controller or the organiser of the Race and the data subject, and in connection with the existence of mutual claims arising from such a contract, whereby the controller, subject to the data subject meeting the conditions for participation in the Race – including payment of the entry fee – provides the data subject with the relevant activities and services associated with the organisation of the Race and the data subject’s participation therein; at the same time, the processing of personal data is necessary for the purposes of the legitimate interests of the controller or a third party (paragraph VI below).
3. For the purpose set out in paragraph IV(4) above: pursuant to Section 13(1)(f) of the Act – the processing of personal data is necessary for the purposes of the legitimate interests of the controller or a third party (paragraph VI below).
4. For the purpose set out in paragraph IV(5) above: pursuant to Section 13(1)(a) of the Act – the data subject has given their explicit consent to the processing of their personal data upon registration (sign-up) of the participant – the data subject – for the Race, via the registration system on the website www.letecka100.sk.
VI. Legitimate interests of the controller or a third party, where personal data are processed in accordance with Section 13(1)(f) of the Act
1. In relation to the purpose set out in paragraph IV, point 2 above: the controller’s legitimate interest is the identification of the data subject – a participant in the Race – in connection with the proper registration of participants and the organisation of the Race.
2. In relation to the purpose set out in paragraph IV, point 3 above: the controller’s legitimate interest is the identification of the data subject – a participant in the Race – in connection with the proper organisation of the Race and the fulfilment of all relevant obligations of the controller or the Race organiser, and to assert any claims against the data subject or to mount a legitimate defence against any claims made by the data subject through the appropriate legal means.
3. In relation to the purpose set out in paragraph IV, point 4 above: the data controller’s legitimate interest lies in the necessity of recording and publishing the complete interim and final results of the Race, as well as the long-term storage of data and the compilation of statistics on the results of the Race and other similar events, such activities arising from the nature of the Race as a public sporting event; if the Race is registered with ITRA, the provision of personal data to ITRA for the aforementioned purposes is an obligation of the Race organiser; if the Race is registered for the UTMB Index, the provision of personal data to the UTMB World Series for the aforementioned purposes is an obligation of the Race organiser.
VII. Recipients of personal data
Certain personal data of the data subject – the Race participant – will be provided to third parties in accordance with the specified purpose of personal data processing set out in Section IV above, and such provision of personal data is necessary for the proper fulfilment of the specified purpose of personal data processing.
Such recipients of personal data are:
1. The SLOVAK ULTRA TRAIL civic association, Company Registration Number: 42364582 – recipient of the following data: first name, surname, date of birth, country, exclusively for the purpose specified in paragraph IV, point 4 above; recipient of the following data: audiovisual or visual recordings from the Races, where the data subject is identified or identifiable, solely for the purpose specified in paragraph IV, point 5 above;
2. Ľubomír Mäkký, Company Registration Number: 41638484 (publisher of hiking.sk) – recipient of the following data: first name, surname, country, date of birth, solely for the purpose specified in paragraph IV, point 4 above; recipient to the extent of: audiovisual or visual recordings from the Races, provided that the data subject is identified or identifiable, exclusively for the purpose specified in paragraph IV, point 5 above;
3. International Trail Running Association (ITRA) – recipient: first name, surname, date of birth, country, solely for the purpose specified in paragraph IV, point 4 above; UTMB World Series – recipient of the following data: first name, surname, date of birth, country, exclusively for the purpose specified in paragraph IV, point 4 above;
4. individuals authorised by the controller to carry out specific tasks in the organisation of the Races (volunteers): recipients to the extent of first name, surname, country, telephone number, exclusively for the purpose specified in paragraph IV, point 3 above, in the event of a necessary need to communicate with the data subject during the Races;
5. external provider of timing/GPS tracking services – recipient of the following data: first name, surname, country, date of birth, solely for the purpose specified in paragraph IV, point 4 above;
Recipients of personal data are obliged to comply with all necessary security, technical and organisational measures to ensure the required protection of personal data, which will be used exclusively for the purposes set out in these terms and conditions.
Apart from ITRA and the UTMB World Series (point 3 above), no personal data will be provided to any other recipient in a third country or to an international organisation.
VIII. Transfer of personal data to a third country or an international organisation
No transfer of personal data to a third country or an international organisation takes place or is intended; this does not affect the provision of personal data to ITRA or the UTMB World Series as recipients within the meaning of paragraph VII above.
IX. Retention period for personal data
1. Personal data processed for the purpose specified in paragraph IV, point 1 above: For the duration of the data subject’s registration within the registration system on the website www.letecka100.sk; the data subject is entitled to cancel their registration at any time, in which case the relevant purpose of processing ceases to apply and the retention period for personal data on this basis ends.
2. Personal data processed for the purpose set out in paragraph IV(2) above: For the duration of the preparation and organisation of the Race; in the event of early cancellation of registration (entry) for the Race, for the period ending with such cancellation of registration or, where applicable, the refund of payments made to the participant.
3. Personal data processed for the purpose specified in paragraph IV, point 3 above: For the duration of the preparation and organisation of the Race, and, where applicable, during the enforcement of claims arising from the contractual relationship with the data subject or by the data subject (at least for the duration of the relevant limitation period applicable to such claims).
4. Personal data processed for the purpose specified in paragraph IV, point 4 above: For the duration of the existence of the relevant records of the Race results or other statistics in which the results are listed together with the identification of the data subject.
5. Personal data processed for the purpose specified in paragraph IV, point 5 above: For the duration of the publication of information about the Races or Race documentation via audiovisual or visual recordings that include the data subject’s personal data.
Once the retention period for personal data has expired, the controller is obliged to erase the data subject’s personal data.
Notwithstanding the above, the controller is obliged to retain accounting records for a period of at least 10 years.
X. Information on the data subject’s rights
Under the conditions set out in the Act, the data subject has the following rights in relation to the processing of their personal data:
1. the right to request from the controller access to personal data relating to the data subject, as well as further information in accordance with Section 21 of the Act;
2. the right to have inaccurate personal data rectified or incomplete personal data completed (in accordance with Section 22 of the Act);
3. the right to erasure of personal data (in accordance with Section 23 of the Act);
4. the right to restriction of processing of personal data (in accordance with Section 24 of the Act);
5. the right to object to the processing of personal data (in accordance with Section 27 of the Act);
6. the right to data portability, i.e. the right to receive personal data concerning her which she has provided to the data controller, in a structured, commonly used and machine-readable format, and the right to transmit that personal data to another data controller (pursuant to Section 26 of the Act);
7. the right to withdraw their consent to the processing of their personal data at any time, in the same manner as in which consent was given (pursuant to Section 14(3) of the Act); the withdrawal of consent does not affect the lawfulness of the processing of personal data based on consent prior to its withdrawal;
8. the right to lodge a complaint with the Office for Personal Data Protection of the Slovak Republic pursuant to Section 100 of the Act – for the purpose of determining whether the data subject’s rights have been infringed in the processing of their personal data or whether there has been a breach of the Act or a specific regulation in the field of personal data protection, and, should any shortcomings be identified, where justified and appropriate, to impose remedial measures or, where applicable, a fine for a breach of this Act or a specific regulation in the field of personal data protection.
The data subject may exercise their rights in writing at the controller’s address or via the controller’s email address (as set out in paragraph II above), where the data subject may also be provided with any necessary further information regarding their rights.
XI. Further information for the data subject pursuant to Section 19 of the Act
The provision of personal data to the controller is voluntary; however, it is a contractual requirement, the fulfilment of which is necessary for the proper fulfilment of the individual purposes of personal data processing associated with the data subject’s participation in the Races and their organisation by the controller.
The consequences of failing to provide personal data are:
1. in relation to the purpose set out in paragraph IV, point 1 above: the inability to register the participant – the data subject – for the Race;
2. in relation to the purpose set out in paragraph IV, point 2 above: the inability to register the participant – the data subject – for the Race;
3. in relation to the purpose set out in paragraph IV, point 3 above: the inability to ensure the proper conduct of the Race with the data subject’s participation and to fulfil the relevant statutory and contractual obligations of the Race operator or organiser towards the participant – the data subject – i.e. the inability of the data subject to participate in the Race;
4. in relation to the purpose set out in paragraph IV, point 4 above: the inability to ensure the proper conduct of the Race with the data subject’s participation, in particular the recording and publication of complete interim and final Race results, as well as the long-term storage of data and the maintenance of statistics on Race results (whereas such activities arise from the nature of the Races as a public sporting event) – i.e. the impossibility of the data subject’s participation in the Races;
5. in connection with the purpose set out in paragraph IV, point 5 above: in the context of collecting and publishing information about the Race and Race documentation via audiovisual or visual recordings, the organiser and/or SLOVAK ULTRA TRAIL shall not use data through which the data subject could be identified or made identifiable.
Automated individual decision-making, including profiling, as defined in Section 28(1) and (4) of the Act, is not applied.
XII. Security of personal data
The Data Controller declares that it has taken all appropriate technical and organisational measures to ensure the security of the personal data of the
data subject.
The Controller has taken technical measures to secure data storage facilities containing personal data, in particular by securing access to computers with passwords, using anti-virus software and carrying out regular maintenance of computers.
XIII. Cookies
When logging into an account in the registration system on the website www.letecka100.sk, temporary cookies are stored to determine whether the user’s (data subject’s) browser accepts cookies. These cookies do not contain any personal data and are deleted when the browser is closed.
Upon logging in, several cookies are set to store the user’s (data subject’s) login details and display settings. Login cookies remain valid for two days and display settings for one year. If the ‘remember me’ option is selected, the login will remain valid for two weeks. When you log out of your account, the cookies are deleted.
XIV. Final provisions
By registering via the registration system on the website www.letecka100.sk or by submitting an electronic application (participant registration) for the Race, the data subject – the Race participant – confirms that they have been made aware of the terms and conditions of personal data protection and that they accept them in full, in their current and effective version (as at the date of confirmation by the data subject).
These terms and conditions regarding the protection of personal data shall come into force and effect on 1 December 2022.
