Ski-Pic Privacy Policy
 

Ski-Pic Italy Srl (hereinafter also referred to as “we”  or “Ski-Pic”) knows that you care about how your personal data are processed. 
 

We take great pride in the relationships we have developed with the users of Ski-Pic website (https://ski-pic.com/), Ski-Pic mobile app (available on Apple Store and Android Market) and the relevant services provided therewith (Ski-Pic website, Ski-Pic app and all the relevant services provided therewith by Ski-Pic Italy Srl, including Ski-Pic account, will be collectively referred to as “Ski-Pic”), and we are committed to process users’ personal data lawfully and fairly, in accordance with the relevant applicable laws.
 

This privacy policy (“Privacy Policy”) is provided pursuant to section 13 of Italian Legislative Decree 196/2003 (the so-called “Privacy Code”) and the European union General Data Protection Regulation (GDPR) to inform you and all other Ski-Pic users about the features of the processing of the personal data collected by and through Ski-Pic, and forms part of Ski-Pic Terms of Use.
 

Please read this Privacy Policy carefully as soon as you access Ski-Pic and, in any case, before using Ski-Pic. When you access Ski-Pic and create a Ski-Pic account, you will accept Ski-Pic Terms of Use and this Privacy Policy and you will consent to the collection, storage and use of your personal data as described hereinafter. If you do not wish to consent to the processing of your personal information as described in this Privacy Policy as well as in Ski-Pic Terms of Use, you should not use Ski-Pic and the relevant services provided by Ski-Pic Italy Srl.
 

Other sites might be accessible from Ski-Pic: third party websites are not bound by this Privacy Policy and/or by Ski-Pic’s Terms of Use, therefore it is recommended that you read and understand carefully such third party’s terms of use and privacy policies before visiting and using the relevant sites and services.
 

Recognizing the global nature of the internet, you agree and accept that some minor features described in Ski-Pic Terms of Use (e.g. login in with your Facebook account, or posting Ski-Pic photos on Ski-Pic website and app) might not be available, or at least might not yet be available, in your country. This Privacy Policy and the Terms of Use shall then be deemed as concerning only Ski-Pic features available in Italy. 
 

Data Controller
 

Ski-Pic Italy Srl, with registered office in Via Vittorio Alfieri 2, 10043 - Orbassano (TO) – ITALY, is the data controller of the personal data collected by and through Ski-Pic.
 

Personal Data Collected Through Ski-Pic and Purposes of the Processing
 

The use of Ski-Pic implies the processing of the following users’ personal data (“Data”).
 

Ski-Pic Account: Email Address, Mobile Phone Number 
 

In order to use Ski-Pic, you have to create a Ski-Pic account by communicating your email address and your mobile phone number.
 

In the Ski-Pic account, the photos of you (according to our technical matching systems) are being uploaded. Such photos are being uploaded in a low resolution and with watermark in the "Preview" area. You will be able to choose the photos that you like and receive them in the app gallery and via email in high resolution.
 

Your email address is necessary to allow you to retrieve pictures you've already bought, as a second verification of your identity and as a channel of service communications with us.
 

Your mobile phone number will help us in assessing the photos that picture yourself and not someone else, acting as a phone (and, therefore, as a user) identifier.
 

The processing of the above personal data is necessary for you to use Ski-Pic: in case of your refusal, you won’t be able to access and use Ski-Pic.
 

Subject to your consent, which will be duly collected during the creation of your Ski-Pic account, we will process the above Data:
 

- to send you our newsletter regarding Ski-Pic;
 

- for the purpose of sending advertising materials, direct selling, carrying out market surveys or commercial communications regarding Ski-Pic and Ski-Pic Italy Srl via electronic communication means or via similar mechanisms (such as emails, SMS-texting, or MMS-messaging).
 

The processing of your Data for the above purposes is not necessary to let you use Ski-Pic but, in case of your refusal, you won’t be able to receive our newsletter and/or to receive marketing communications that might be of interest to you.
 

Facebook Log-In
 

Where applicable, you are able to log-in to Ski-Pic through your Facebook account: in this case, we will collect and process the personal data you agreed to publish, which are necessary for you to use Ski-Pic.
 

We will collect also other personal information that are public according to your Facebook’s settings: such information are not compulsory to use Ski-Pic and, in case of your refusal, you will still be able to use Ski-Pic. If you do not wish us to collect such information, please modify your Facebook settings or log-in without Facebook.
 

When communicated, such personal data will be processed anonymously, for statistical purposes.
 

Geographical Location
 

To let you use Ski-Pic and, in particular, to take pictures of you, we need to know your geographical position while skiing on the slopes: as soon as you are near one of our cameras, we will shoot a motion picture of you. Ski-Pic app helps in tracking your skiing on the slopes specifically near where our cameras are mounted, and we collect information regarding when and where exactly you skied on the slopes when the pictures had been taken.
 

The processing of your geographical position, collected by means of electronic communications network, is necessary: in case of your refusal, we won’t be able to provide Ski-Pic services (and, in particular, to identify the photos that picture you and submit any photo to you).
 

Purchases

In case you decide to buy any Ski-Pic photo, Ski-Pic will have to collect the due data to process the payment of the relevant amount. These data will be processed only for this aim and will not be store at all.
 

The collection and transfer of said data to the financial payment provider is necessary to let you buy Ski-Pic photos: in case of your refusal, you won’t be able to purchase any Ski-Pic photo.
 

Third Parties’ Personal Data that You Communicated

Ski-Pic is not interested in processing, and does not need to process, any third parties’ personal data: kindly refrain from communicating data which do not belong to you.
 

In case you communicate third parties’ personal data despite the above provision, you shall be aware that you do so under your own responsibility and that you are solely responsible to follow the relevant personal data protection rules and, inter alia, to collect such third parties’ consent.
 

Third Parties’ Personal Data Collected Accidentally
 

We do not collect and process voluntarily any third parties’ personal data and we take all possible measures to avoid third parties to be pictured in your Ski-Pic photos, but we cannot grant that this won’t happen because you are skiing in public slopes and we all cannot prevent anyone else to ski in the same place and time as you do.
 

We hereby remind you that, according to Ski-Pic Terms of Use, you commit yourself, under your own responsibility and expressly relieving Ski-Pic Italy Srl of any liability, including any third parties’ claims:
 

- to use Ski-Pic photos only in a fair and lawful way;
 

- to use Ski-Pic photos only for private purposes with the exception of commercial and profit aims;
 

- to not share, modify, spread, public, communicate and/or broadcast, also on any of your social networks accounts (irrespective of the private or public nature of said accounts) and/or on Ski-Pic and/or on Ski-Pic Facebook page, any Ski-Pic photo that pictures also third parties, at least without such third parties’ prior written consent.
 

Ski-Pic Photos
 

We do not store the photos shot by our cameras, we do not keep back-up copies of the photos that you choose and we do not process Ski-Pic photos and the personal data included in Ski-Pic photos. All photos are being deleted within 24 hours from upload in your Ski-Pic account according to the Terms of Use.
 

The only exception to the above concerns Ski-Pic photos which have been purchased by Ski-Pic users: of these photos only, we keep a back-up copy to be forwarded to users in case of reissuance requests. Such photos will be stored for 1 year.
 

We do not collect any biometric data to match the photos with Ski-Pic users: the matching process, as described above, is based only on the collection of the geographical position of Ski-Pic users.
 

Information Sent to Us by Your Web Browser
 

We collect information that is automatically sent to us by your web browser. This information typically includes: your IP address; the name and version of your operating system; the name and version of your browser; the page you were visiting before you accessed our Site; the date and time of your visit. The information we receive depends on the settings of your browser. Please check your browser if you want to learn what information your browser sends or how to change your settings. We will use this information to create anonymous statistics that help us improve Ski-Pic and make them more compatible with the technology used by our users.
 

Cookie
 

No personal data concerning Ski-Pic users is collected through cookies: no cookies are used to transmit personal information, nor are so-called persistent cookies or user tracking systems implemented.
 

Use of the so-called session cookies – which are not stored permanently on personal computers and disappear upon closing the browser – is exclusively limited to the transmission of session ID's – consisting of server-generated casual numbers – as necessary to allow secure, effective navigation. Such session cookies do not acquire any user’s personal identification data.
 

Communication of Your Data
 

Ski-Pic does not sell your Data to outside marketers or advertisers. Under limited circumstances we may disclose the personal information we collect with outside parties for specific purposes. Those circumstances are described here below.
 

To The Controlling Company
 

The Data might be communicated to Global Ski-Pic Ltd., with registered office in Galgalei Haplada St, Herzliya, 3672220 – Israel, for both administrative and accounting purposes, including the activities aimed at fulfilling contractual and pre-contractual obligations, and for the provision of supporting services to us. Global Ski-Pic Ltd. has been therefore appointed as external data processor of the Data.
 

To Our Service Providers
 

We may communicate your Data to companies that provide support services to us. These companies may need information about you in order to perform their functions and let you benefit from Ski-Pic services (including the purchase of Ski-Pic photos). When needed, these companies will be duly appointed as data processors and will process your Data only for the purpose of delivering the service we hire them to provide. In addition, we only disclose the information they need to provide the specific service or function on our behalf and according to our instructions.
 

The full list of data processors is kept at our offices and might be consulted upon written request to be forwarded to the contacts stated here below.
 

To Our Hosting Resorts

Subject to your consent, which will be duly collected during the creation of your Ski-Pic account, we will communicate your email address and phone number to our hosting resorts  
(https://www.chamonix.com/ , http://www.pila.it/ , http://www.visitmonterosa.com/ , http://www.lathuile.it/ )  for marketing purposes. Kindly note that your consent thereto is not necessary for you to use Ski-Pic: therefore, in case of your refusal, you will still be able to use Ski-Pic but you will not receive marketing communications from our hosting resorts that might be interesting for you.

 

Hosting resorts shall process your Data as independent data controllers.
 

Diffusion of your Data
 

We do not make any diffusion of your Data.
 

If the relevant feature is available in your country, you will be allowed – if you want - to upload your Ski-Pic photos on Ski-Pic website and on Ski-Pic public Facebook page, according to the Terms of Use.
 

Kindly note that this implies the diffusion of the personal data included in your Ski-Pic photos: if you do not want to spread such data, do not upload and share your Ski-Pic photos.
 

How We Process the Data
 

The Data undergoing processing will be:
 

- processed lawfully and fairly;
 

- collected and recorded for specific, explicit and legitimate purposes and used in further processing operations in a way that is inconsistent with said purposes;
 

- accurate and, when necessary, kept up to date;
 

- relevant, complete and not excessive in relation to the purposes for which they are collected or subsequently processed; and
 

- kept in a form which permits identification of the data subject for no longer than is necessary for the purposes for which the data were collected or subsequently processed.
 

The Data will be processed with and without electronic means only by persons duly put in charge of the processing, and they will be kept and controlled, also in consideration of technological innovations, of their nature and the specific features of the processing, in such a way as to minimize, by means of suitable preventative security measures, the risk of their destruction or loss, whether by accident or not, of unauthorized access to the Data or of processing operations that are either unlawful or inconsistent with the purposes for which the Data have been collected.
 

We adopted all the security measures required under the Privacy Code, its Annex B and the relevant orders of the Italian Privacy Authority, in order to ensure an adequate level of personal data protection and, in particular, to protect against the loss, misuse, unauthorized access or disclosure of the Data.
 

Save for the above, you are the only owner of the log-in credentials to your Ski-Pic account and, therefore, you are the only one responsible for the protection of the same: remember to keep your log-in credentials secret and confidential, at all times.
 

Storage of Your Data

Your Data will be stored and processed on secure servers and databases in the European Union managed by high level cloud service providers such as Google, Amazon and Oracle, all of whom utilized the services of fully qualify data protection Officer (DPO).
 

The transfer of the Data from the European Union to Israel will be carried out according to the “Authorization to Transfer Personal Data from the Italian Territory to the State of Israel” issued by the Italian Privacy Authority on the 20th of January 2012.
 

Your Rights
 

As to the Data, pursuant to article 7 of the Privacy Code you are entitled: to access, control, update and/or change your Data; to acquire more information on the source of your Data and on how/why your Data are used; to have your Data cancelled or stored anonymously or to stop the use of your Data, in case your personal data are used in violation of law; to oppose to the use of your Data for one or more of the purposes to which you consented, as well as to the use of one or more of your contact information.
 

You can cancel your Ski-Pic account at any time by entering the setting button in the app side menu and choose the account deleting option; it's important to follow all stages. Please note that, should you cancel your Ski-Pic account, Ski-Pic will immediately delete all Data. The deletion will be effective after your receipt of our “account deleted successfully” notification. You will be able to re-create a Ski-Pic account at any time, but data from the deleted account will not be recoverable.
 

Please note that, should you remove the Ski-Pic app from your device without deleting your account, your Ski-Pic account will stay active in our database.
 

We will delete your account, and your Data as well, in case of no-access to your account for more than six months.
 

Contact Us
 

If you wish to exercise any of the aforementioned right, if you wish to consult the updated list of our data processors, if you have questions about this Privacy Policy or the processing of your Data, if you experienced problems in deleting your Ski-Pic account and for any other inquiry, please send your requests to our offices in Via Vittorio Alfieri 2, 10043 - Orbassano (TO) – ITALY, and/or send an email to support@ski-pic.com
 

Changes and Updates to the Privacy Policy
 

Ski-Pic may, at any time, modify or terminate Ski-Pic for any reason, as well as change, modify, add or remove portions of this Privacy Policy and/or of Ski-Pic Terms of Use by posting the amended Privacy Policy and/or Terms of Use on Ski-Pic: it is your responsibility to check periodically Ski-Pic for updates as they will be applicable to you if you continue using Ski-Pic. Changes will become effective immediately upon being posted on Ski-Pic: your continued use of Ski-Pic following the posting of changes to the Privacy Policy will be deemed as acceptance of the same changes. If you do not agree to any point of this Privacy Policy and/or of Ski-Pic Terms of Use, you should immediately stop using Ski-Pic.
 

If the variations constitute a material change to the Privacy Policy and/or to Ski-Pic Terms of Use, we will notify you by sending an e-mail and/or by placing a notice on your Ski-Pic account, and we will collect your consent when mandatory.
 

You acknowledge that Ski-Pic is an evolving service. Please note that we might publish additional policies related to specific services that may be provided in the future: your use of such services, if any, will be subject to those specific policies as well as to this Privacy Policy and Ski-Pic Terms of Use.
 

Latest update of the Privacy Policy: Do you consent to the communication of your personal data to our hosting resorts?

(https://www.chamonix.com/http://www.pila.it/,http://www.visitmonterosa.com/http://www.lathuile.it/)

 

23rd November 2018.