CAMERA POLICY

In order to guarantee the right to the protection of personal data and to provide data subjects with complete information about the FISG TV service, in compliance with Regulation (EU) 2016/679 (hereinafter the “Regulation”) and Italian Legislative Decree no. 196/2003, the Italian Ice Sports Federation has adopted this Privacy Policy.

1. Data Controller

The Data Controller pursuant to Articles 4 and 24 of the Regulation is the Federazione Italiana Sport del Ghiaccio (Italian Ice Sports Federation), registered office in Milan, Via Piranesi 46, Postcode 20137, Milan, Tax Code 97016560159, VAT no. 05235981007, email address: info@fisg.it
You may contact the Data Controller by writing to the above address or by sending an email to the following address: info@fisg.it.

2. Purposes and legal basis for the processing

The processing of personal data through FISG TV involves registered members (athletes, coaches, referees) and individuals attending matches or training sessions as spectators.

The data are used for the following purposes:

a) Recording matches for distribution via the game website, Team Accounts, and Player Accounts.
b) Recording training sessions for distribution via Team Accounts.
c) Distributing live and on-demand recordings of matches and training sessions through the Platform.

The legal basis for processing with regard to registered members consists of:
1) The necessity to fulfil obligations arising from membership registration pursuant to Art. 6(1)(b) of the GDPR.
2) The data subject’s consent, as provided at the time of membership registration, pursuant to Art. 6(1)(a) of the GDPR.

The legal basis for processing with regard to spectators consists of:

1) the legitimate interest of the Data Controller pursuant to Art. 6(f) of the GDPR.

The interest of the Data Controller and the legal position of the spectator have been subject to a careful and thorough balancing test, following which the interest of the former was deemed harmless to the spectator and, therefore, overriding. In fact, the camera is positioned so as to capture only the playing field in the foreground, while the spectator stands are filmed only in the background. Furthermore, the FISG TV cameras: a) frame exclusively the front rows of the stands, thereby reducing the number of spectators involved in the recordings and live streams; b) are positioned at such a distance as to make the identification of any spectator highly unlikely.

3. Subject Matter of Data Processing

The following personal data may be processed during the activities described above.

1) registered members (athletes, coaches, support staff, referees): name, surname, jersey number, image, game statistics.
2) spectators at matches or training sessions and venue staff: background image that makes the identification of the person filmed highly unlikely.

4. Data Retention and Archive

The data of athletes, referees, coaches and spectators, recorded through FISG TV cameras, are stored in FISG archives indefinitely (without time limits) for the purpose of maintaining a record of sporting events.
The data are stored on the FISG TV platform for the time necessary for the distribution of the sporting event to the users.

5. Data Transfer
The personal data provided during reporting will be processed by the Data Controller and by those specifically appointed as Data Processors pursuant to Art. 28 of the GDPR.
Data may be processed by the Data Controller’s employees, who have been appropriately trained and appointed as persons authorised to process data pursuant to Art. 29 GDPR and Art. 2-quaterdecies of Legislative Decree no. 196/2003.
In particular, Sportway Italy S.r.l. has been appointed as Data Processor with regard to the FISG TV streaming platform and the provision of the service. Conversely, the same Sportway Italy S.r.l. acts as Joint Data Controller for other processing operations determined in agreement with FISG, with which it jointly determines the purposes and means of processing personal data. (https://hockey.fisg.tv/it/privacy-policy, https://figura.fisg.tv/it/privacy-policy ).
Sportway Italy S.r.l. may share the data with its commercial partners or with companies within the Sportway group.
The data provided may also be processed by the Data Controller directly and disclosed to third parties should such processing be necessary for the fulfilment of legal obligations. For this purpose, data may be disclosed to external companies or professionals (accountants, auditors, labour consultants) whose services the Data Controller may use for the purposes set out in this privacy notice.
In order to allow the fulfilment of contractual and legal obligations, data may be disclosed to postal offices, shippers, couriers, and freight forwarders for sending documentation, as well as to banking institutions for accounting management resulting from the execution of the contract, as well as to Public Authorities as required by law, and to third parties for the provision of IT services or archiving services.
The data subject’s personal data will not be disclosed to the public, i.e. the Data Controller will not disclose or make them available in any way to unspecified parties.

6. Processing Methods and Security Measures

Data processing is carried out digitally through the FISG TV platform, which utilizes AI-powered camera systems at the arenas. These systems are designed to follow competitions by emulating professional television broadcasts.
To ensure the confidentiality of data processed through FISG TV, appropriate technical security measures (personal accounts, passwords, periodic backups, antivirus, anti-malware, controlled access) and organisational measures (security protocols, data breach procedures, staff training, appointment of Data Processors) have been adopted.

7. Data Subject Rights

The rights referred to in Articles 15 to 22 of the Regulation may be exercised within the limits set out in Article 2-undecies of Legislative Decree no. 196/2003:

1) Right of Access: pursuant to Article 15(1) of the Regulation, you have the right to obtain from the Data Controller confirmation as to whether or not your Personal Data are being processed and, where that is the case, access to such Personal Data and the characteristics of the processing. This information is available within this Privacy Policy, which will always be available to you in the Privacy section of our website.

2) Right to Rectification: pursuant to Article 16 of the Regulation, you may obtain the rectification of inaccurate Personal Data concerning you. Taking into account the purposes of the processing, you may also obtain the completion of incomplete Personal Data, including by providing a supplementary statement.

3) Right to Erasure (Right to be Forgotten): pursuant to Article 17(1) of the Regulation, you may obtain the erasure of your Personal Data without undue delay, and the Data Controller shall have the obligation to erase your Personal Data where one of the following grounds applies: a) the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; b) you have withdrawn the consent on which the processing of your Personal Data is based and there is no other legal ground for the processing; c) you have objected to the processing pursuant to Article 21(1) or (2) of the Regulation and there are no longer any overriding legitimate grounds for the processing of your Personal Data; d) your Personal Data have been unlawfully processed; e) it is necessary to erase your Personal Data for compliance with a legal obligation under Union or Member State law. In certain cases, as provided for in Article 17(3) of the Regulation, the Data Controller may be entitled not to erase your Personal Data where their processing is necessary, for example, for exercising the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest, for archiving purposes in the public interest, for scientific or historical research purposes, or for the establishment, exercise, or defence of legal claims.

4) Right to Restriction of Processing: pursuant to Article 18 of the Regulation, you may obtain the restriction of processing where one of the following applies:

a) You contest the accuracy of the personal data (for a period enabling the Controller to verify such accuracy).
b) The processing is unlawful and you have opposed the erasure of your Personal Data and requested the restriction of their use instead.
c) The Data Controller no longer needs your Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise, or defence of legal claims.
d) you have objected to processing pursuant to Article 21(1) of the Regulation pending the verification whether the legitimate grounds of the Data Controller override yours.
Where processing has been restricted, your Personal Data shall, with the exception of storage, only be processed with your consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. You will be informed before the restriction of processing is lifted.

5) Right to Data Portability: pursuant to Article 20(1) of the Regulation, you may, at any time, request and receive all your Personal Data processed by the Data Controller and/or the Joint Data Controllers in a structured, commonly used, and machine-readable format, or request their transmission to another data controller without hindrance. In this case, it will be your responsibility to provide us with the exact details of the new data controller to whom you intend to transfer your Personal Data, along with written authorisation.

6) Right to Object: pursuant to Article 21(2) of the Regulation and as also reiterated in Recital 70, you may object, at any time, to the processing of your Personal Data for direct marketing purposes, which includes profiling to the extent that it is related to such direct marketing.

7) Right to Lodge a Complaint with a Supervisory Authority: without prejudice to your right to seek any other administrative or judicial remedy, if you believe that the processing of your Personal Data carried out by the Data Controller and/or the Joint Data Controllers violates the Regulation and/or applicable law, you may lodge a complaint with the competent Data Protection Authority (Garante per la Protezione dei Dati Personali).
To exercise your rights as identified above, you may contact the Data Controller and/or Joint Data Controllers at the provided email address.

8. Place of Data Processing

Personal Data will be processed by the Data Controller and/or the Joint Data Controllers within the territory of the European Union.

9. Data processing for purposes other than those for which they were collected

Should the Data Controller intend to further process personal data for a purpose other than that for which they were collected, the Data Controller shall provide the data subject, prior to such further processing, with information on that other purpose and with any relevant further information as referred to in Art. 13(2) of the Regulation.

10. Amendments

The Data Controller reserves the right to update this Privacy Policy at any time and to inform users by the most appropriate means. For any further information or queries, please contact the Data Controller at the contact details provided in section 1.