Privacy Policy – Nice Ironman

PRIVACY POLICY

Information on the processing of personal data by TWO CIRCLES

WHO ARE WE?

Two Circles is a sports marketing agency registered in the UK as Two Circles Limited (registered number 07753583, of C/O Corporation Service Company (UK) Limited, 5 Churchill Place, 10^th Floor, London, United Kingdom, E14 5HU).

In accordance with the regulation applicable to the protection of personal data, in particular the provisions of the French Data Protection Act of 6 January 1978 as amended and the Regulation on the protection of individuals with regard to the processing of personal data and on the free movement of such data (EU Regulation 2016/679 known as the “GDPR“), Two Circles, acting as data controller, informs you that the information collected in the context of the survey concerning attendees of the Ironman Race is subject to the processing of personal data.

PURPOSES OF PROCESSING, DATA COLLECTED, LEGAL BASIS AND RETENTION PERIOD

Two Circles processes the following categories of personal data for the purposes defined in the table:

THE LEGITIMATE INTEREST FOR PROCESSING

We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or those of a third party, for the following purposes:

1. To carry out analytics for the purpose of informing our marketing and consultancy strategy
2. To share personal data with other Two Circles’ companies to support our legitimate interests (strictly not for resale or marketing purposes)

RECIPIENTS OF THE PERSONAL DATA

THIRD COUNTRY TRANSFERS

We may share your personal data within the Two Circles group of companies and with our processors. This will involve transferring your data outside of the European Union. Where third country transfers take place, we ensure an appropriate transfer mechanism is used to legitimise those transfers in accordance with the GDPR.

DATA PROTECTION RIGHTS

In accordance with the applicable regulations on the protection of personal data, you have a right to (a) access, (b) rectification, (c) erasure, (d) limitation of data processing as well as (e) a right to data portability and (f) opposition.

In addition, you have the right to define directives relating to the conservation, erasure and communication of your personal data post mortem (g).

a) Right of access

You have the right to request confirmation that Two Circles is processing your personal data and, if so, to receive a copy of it.

b) Right of rectification

You have the right to request rectification of your personal data if you find that it is inaccurate.

c) Right to erasure

You have the right to request the deletion of your personal data. This right can only be exercised in certain cases, where one of the grounds set out in Article 17 of the GDPR applies. For example, your personal data may no longer be necessary for the purposes for which it was collected or it may have been processed unlawfully. If you exercise this right and if one of the reasons is applicable to your request, Two Circles will proceed to erase your personal data as soon as possible.

d) Right to limit data processing

You have the right to have the processing of your personal data restricted. This means that we mark these data, if we do indeed keep them, with a view to temporarily suspending their processing. This right may be exercised on the grounds set out in Article 18 of the GDPR. This right does not give rise to erasure and we are obliged to inform you before the corresponding processing restriction is lifted.

e) Right to data portability

You have the right to request the supply of personal data that you have directly communicated to us in a structured, commonly used and machine-readable format, if its processing is automated and based on the collection of your consent. This right does not apply to other legal bases for processing. Where applicable and where technically possible, you also have the option of requesting the transfer of this data directly to another data controller.

f) Right to object

You have the right to object to the processing of your personal data where the processing is legally based on the legitimate interests of Two Circles.

However, this right of objection may not be exercised in respect of processing necessary for Two Circles to comply with its legal obligations.

g) Right to decide what happens to your personal data after your death

You have the right to organize what happens to your personal data after your death by adopting general or specific directives. Two Circles undertakes to respect these directives.

How to exercise your rights:

If you wish to exercise your rights, simply send a request to Two Circles’ Data Protection Department:

Data Protection Officer, Two Circles Limited, C/O Corporation Service Company (UK) Limited, 5 Churchill Place, 10^th Floor, London, United Kingdom, E14 5HU

or by email at dpo@twocircles.com.

In order to process your request as efficiently as possible, we would ask you to include with your request the information required to identify yourself (surname, first name, e-mail address) as well as any other information required to confirm your identity. If there is any doubt about the applicant’s identity, you may be asked to provide proof of identity.

Requests are processed as quickly as possible and in any event within one month of receipt of your request. If necessary, this period may be extended by two months, depending on the complexity and number of requests we receive. In this case, you will be informed of the extension and the reasons for the postponement.

If, after contacting Two Circles and despite its efforts, you believe that your rights have not been respected, you may also lodge a complaint with a supervisory authority. In France, this is the Commission Nationale de l’Informatique et des Libertés (CNIL): 3 Place de Fontenoy – TSA 80715 – 75334 Paris Cedex 07 or directly on its website at https://www.cnil.fr.

DATA SECURITY

As the confidentiality and security of personal data are central concerns of Two Circles, technical and organisational security measures are put in place to preserve their security and, in particular, to prevent any accidental or unlawful destruction, loss, alteration, disclosure, intrusion or unauthorised access to such data.

Two Circles implements such technical and organisational measures in order to ensure that personal data is kept securely for the time necessary to fulfil the purposes pursued, in accordance with applicable law.

In accordance with the applicable regulations, in the event of a proven breach of personal data likely to give rise to a risk to the rights and freedoms of the persons concerned, Two Circles undertakes to communicate this breach to the competent supervisory authority and, where required by the said regulations, to the persons concerned.

UPDATING OF THE POLICY

Two Circles reserves the right to modify or update this confidentiality policy.

Any changes or updates will be effective immediately upon notification to you.

APPLICABLE LAW

This privacy policy is governed by French law, unless mandatory provisions are provided by the law of any other country in which the person concerned by the processing of personal data resides.