Information on Users and Subscribers

SPORTWIG.COM USER AND SUBSCRIBER POLICY

pursuant to art. 13 Regulation (EU) 2016/679 (GDPR) on the processing of personal data

With this information, we would like to explain to you what information we collect through the Sportwig platform, once you decide to become our registered user and if you also subscribe to our e-learning service.

DATA CONTROLLER.

The Sportwig e-learning platform is managed, as Data Controller, by SW Holding S.r.l., with registered office in Via Sansovino 6 — 20045 Lainate (MI). You can contact us for any questions or requests for information, by filling out the appropriate form on our site

In our capacity as Data Controller, we decide which personal data to process, with what means and purposes. We have also appointed a Data Protection Officer, Attorney Andrea Baldrati, who will answer any specific questions or clarifications on the way in which we process our customers' data. You can contact him at the following email: privacy@sportwig.com.

LEGAL BASES AND PURPOSES.

Every treatment must be based on an appropriate legal basis, taking into account the purposes for which the personal data are processed. The following table is intended to represent in a clear and concise manner the purposes and legal bases of the treatments carried out in our capacity as Data Controller, if you have decided to register on the platform and subscribe to the service on a monthly or annual basis

N.B. This information does not include the processing of personal data relating to simple visitors to the app.sportwig.com website, who are not, however, registered or subscribed to the Sportwig platform. This specific hypothesis is in fact the subject of another information, which you can find HERE.

Purposes of processing activities	Description of treatment activities	Legal basis for processing activities
Sportwig registration procedure//On Boarding user	SPORTWIG REGISTRATION PROCEDURE. By connecting to the official website www.sportwig.com it is possible to register for the service. The first step is to indicate email, password and confirm password. You can also proceed with the Social Login (Google and Facebook), installed through their respective APIs. In this case, Sportwig obtains certain data from third-party companies (e.g. name, email, profile picture) depending on the Social Login chosen. At this stage, we also process your IP and the technical cookies that are necessary for the registration phase, as well as data relating to the payment methods that are necessary if you have activated a subscription or want to purchase one of the training courses.	SPORTWIG REGISTRATION PROCEDURE. Pre-contractual measures at the request of the interested party to fill out the registration form and to send an email to the non-subscribed user in order to proceed with the creation of a random password. Sportwig's legitimate interest in storing the registration cookie, IP, user device. User consent in case of Social Login (consent collected from the third-party provider). Execution of the contract for the entry of data relating to payment methods and the conclusion of the registration phase, as well as for the activation of the course within the platform. Legal obligation in relation to tax or accounting obligations.
Purchase process with registration	PURCHASE PROCEDURE WITH SPORTWIG REGISTRATION. By connecting to the official website www.sportwig.com it is possible purchase the products for sale on the site (e.g. subscription), in this case, during the purchase phase, the user can register on the site by entering name, surname and e-mail and accepting the general conditions of use of the site and the privacy policy; after which the user can proceed with the payment through Stripe. At the end of the procedure, two emails are sent to the user: one confirming the purchase made; the other, on the other hand, is used by the user to choose their password (changing it from the one created by Sportwig in an automated way ).	PURCHASE PROCEDURE WITH SPORTWIG REGISTRATION. Pre-contractual measures at the request of the interested party to fill out the registration form. Legitimate interest of the Data Controller for the storage of the registration cookie, IP, device. Execution of the contract for entering data relating to payment methods, the conclusion of the registration phase and the sending of the order confirmation email and the email that allows the user to choose their password (changing it from the one created by Sportwig in an automated way). Legal obligation to which the Data Controller is subject, in relation to tax or accounting obligations
User Onboarding	ON USER BOARDING. When first accessing the site, the user is asked to select up to 3 preferences from the list of sports categories indicated by Sportwig. This allows Sportwig to send the user emails that may be more relevant to the preferences expressed.	-ON USER BOARDING. Legitimate interest of the Data Controller in the selection by the subscribed user of 3 preferences from the list of sports categories indicated by Sportwig on the first access to the site and for sending more relevant marketing emails in relation to the preferences expressed by the user.
Registered User and Subscribed User Dashboard - Certificate Issuance	As a user, you can enter the following data in the dashboard: your profile picture; an indication of the preferred sport; main email; the type of active subscription; the list of certificates obtained. You can also monitor your active courses and redeem the Gift code.	Execution of the contract, for all personal data relating to the provision of the subscription service and therefore also to the management of your profile, in addition to the issuance of certificates once the course tests have been successfully completed. Sportwig's legitimate interest, with regard to the indication of the user's favorite sport. In fact, it is reasonable to expect such a request from an e-learning platform that wishes to provide courses of interest to its subscribers . Sportwig's legitimate interest, for the collection of user performance data during the course (e.g. how many times the user repeated a test before passing it) for protection purposes in case of disputes about the final outcome of the course itself.
Use of the Sportwig user profile and platform	If you are a registered user of ours or also a subscriber, we may process the following data: -browsing, IP and device data for platform security reasons, but also to extract aggregated data on the use of the platform through the Vimeo software, in particular in relation to some statistical data regarding the use of videos. - your email for sending service communications or for reminder purposes if you remain inactive after purchasing one of our courses (through Sendinblue), as well as to remind the user to log in for the first time after registration, or to invite the user to make the first purchase or further purchases on the site and also for the purpose of activating the newsletter service (through Active Campaign).	Sportwig's legitimate interest in collecting statistical data related to the use of the platform, also in order to improve the user experience Execution of the contract, for everything related to the use of subscription courses, including the sending of service communications via email; Legitimate interest of the Data Controller, for sending newsletters to those who have already registered with the possibility of opting out at the bottom of the email , for communication following unsubscription, for sending emails reminding the user to log in for the first time after registration, for sending emails inviting the user to make the first purchase or further purchases on site.
Manage subscriptions with Stripe	For the management of user subscriptions, we use special Stripe applications. We would like to tell you that we only see the data connected to payment receipts or invoices, but we have no control or access to the data necessary to process the related transactions, relying on Stripe's security measures. In fact, the terms and conditions of the supplier apply to that data .	Sportwig's legitimate interest for reasons of security and service stability. Execution of the subscription contract. Legal obligation to which we are subject for tax and accounting reasons.
Give the gift of Sportwig	We offer you the possibility to give the subscription to your friend or relative by entering your name and your email in addition to the email of the recipient of the gift. You can also participate in a survey that rewards those who fill it out with a free subscription. At that location, you are only asked for the email to receive the code that allows you to 'redeem' the prize.	Pre-contractual measure at the request of those who intend to give away the Sportwig subscription. Pre-contractual measure at the request of the interested party who participates in the survey by leaving their email. Sportwig's legal obligation, also to comply with tax obligations.

IF WE DON'T COLLECT YOUR DATA.

To activate our e-learning services, we ask you for some contact or payment details, especially during the registration phase, so that you can take advantage of our courses. We remind you that you are in no way obliged to provide your data, but that in the absence of them, it will be impossible for us to activate the services you have requested from us.

DATA RETENTION PERIOD OR POLICY.

Your data will be kept for the time necessary to pursue the purposes that we have indicated above. Specifically:

5 days for cookies activated during registration;
As long as you remain a subscriber, we will keep all your contact details, payment methods, your preference regarding sport and in general any information that is necessary for the provision of our e-learning service; if you are no longer a subscriber, we will continue to keep your data up to 18 months from the date of the last view of a course accessible even to non-subscribers, except for the data that we must keep for legal obligations, for example of a fiscal nature;
As long as you remain a subscriber, we will also keep your email for service purposes and to send you our newsletter; from the moment you are no longer subscribed, we will keep it for a further 45 days before deleting the email from our newsletter list;
We will keep payment receipts and any invoices for 10 (ten) years from their issuance;
We will keep for 10 years, in accordance with the contractual requirement, even those data that could be used to protect us in the event of your disputes or complaints, including data relating to your performance in the course tests or your certificate.

RECIPIENTS AND OTHER SUBJECTS TO WHOM THE DATA ARE COMMUNICATED.

Exclusively for the purposes indicated above, your data could be:

PERSONS AUTHORIZED TO PROCESS: these are our employees or internal figures who process your data because of their respective tasks.

DATA

PROCESSORS: they are third-party collaborators who process data on our behalf, through the conclusion of a special appointment agreement as Manager, by means of which the delegated operations are defined, as well as the security measures that they must adopt in order to better protect the information they obtain from us.

In particular, they may process your data:

AWS (Amazon Web Services, Inc.), such as Website Hosting with data centers in the EU;
Sendinblue, as a SaaS solution for relationship marketing, with server location in the EU.

On this point you can learn more at this link;

Active Campaign, Saas e-mail marketing solution for the newsletter service that declares to have certified its compliance with the principles of the “Data Privacy Framework” together with the implementation of SCC (standard Contractual Clauses);
Vimeo LLC, a video hosting and sharing platform that also declares that it has certified its compliance with the principles of the “Data Privacy Framework” together with the implementation of the SCC (standard Contractual Clauses);
Google Form, hosting the survey with a prize that also declares to have certified its compliance with the principles of the “Data Privacy Framework” together with the implementation of the SCC (standard Contractual Clauses);
OVHcloud, as an email provider with a data center in the EU;
Legalmail by Infocert, our Italian PEC provider;
Stripe, Inc.

, with a data center in the EU, which assumes the role of manager if it helps Sportwig manage user subscriptions and renewals within the Platform;

Adamo, the management system used for billing and accounting purposes that guarantees the processing of data within the EU;

External professionals, such as our accountant for tax obligations;

RECIPIENTS: they are those who receive our communications of personal data, but who, following this communication, act as independent Data Controllers. Among these:

Stripe, which assumes the role of recipient when it acts as a payment intermediation service;
Banks or credit institutions;
Judicial Authority and/or Public Security Authority, in cases expressly provided for by law or in the context of judicial proceedings also to ascertain or defend our right.

YOUR RIGHTS.

In your capacity as an interested party, you have the right to obtain access to your personal data from the Data Controller, in addition to the correction or cancellation of the same; you also have the right to limit or object to the processing that concerns you (articles 15 et seq. GDPR). In addition, you have the right to lodge a complaint with the Privacy Guarantor (art. 77 GDPR), or to go to the appropriate courts (art. 79 GDPR).

LAST UPDATE OF THE PRIVACY POLICY

This Privacy Policy is subject to periodic reviews and updates to ensure compliance with current regulations and to reflect any changes in our personal data processing practices.

Last updated: May 30, 2024

In the event of substantial changes to this Privacy Policy, we will inform you through appropriate notices within our platform or through other suitable communication channels. By continuing to use our services after the changes are posted, you implicitly accept the new version of the Privacy Policy