1. PREAMBLE AND CONSENT
Please read carefully this Policy, which explains how information relating to an identified or identifiable individual (“Personal Data”) will be collected, used and protected, before using the Website and our dedicated pages on the social media and platforms. Your access and use of the Website and our dedicated pages on social media are conditional upon your acceptance of, and compliance with this Policy.
By browsing our Website and our dedicated pages on social media, you agree to be bound by this Policy and you agree and consent to the collection, use and processing of Personal Data in accordance with this Policy.
Please also note that you have the right to withdraw your consent at any time, it being however specified that such withdrawal:
- will not affect the lawfulness of processing of Personal Data based on your consent before its withdrawal;
- may prevent you from using some features of our Website or dedicated pages on social media.
2. DATA CONTROLLER
FWT Management SA acts as data controller for the processing of Personal Data collected via its Website and its dedicated pages on social media.
Please do not hesitate to contact us at email@example.com should you have any questions. We would be happy to answer any query.
3. GENERAL PRINCIPLES
3.1 Our Website and our dedicated pages on social media contain the following information and provides the following services:
(i) information about the services offered by our organization and its affiliates,(ii) various channels to get in touch with us (contact forms, links to social media account, etc.),
(ii) information on events (including competitions results, rankings and athletes),
(iii) links to other websites and social media platforms,
(iv) registration to newsletters,
(v) application forms.
4. PERSONAL DATA WE COLLECT, AND WHY WE COLLECT THEM
A. Sources of collection
4.1 Personal Data we collect via our website and social media are divided in three main categories:
(i) Cookies, analytics and other similar tools (below B.)
(ii) Personal Data you provide to us (below C),
(iii) Data from other sources (below D).
B. Cookies and other similar technologies
a) What are cookies and what information they collect?
4.2 Cookies are files with small amount of data which are sent to your browser from a website and stored on your device (computer or mobile device). We may also use other tracking technologies, such as scripts, to collect and track information and to improve and analyze our Website.
4.3 Through cookies and other tracking technologies, we may collect Personal Data from you when you visit our Website or dedicated pages on social media. We may log in particular usage data when you view or click on content.
4.4 The following information and Personal Data are collected through the cookies and other tracking technologies we use or through your browser:
(i) IP address of the requesting internet-enabled device,
(ii) location of the requesting internet-enabled device based on the IP address,
(iii) date and time of access,
(iv) accessed resources on the Website and actions undertaken on the Website,
(v) name and URL of the retrieved file,
(vi) website/application from which the access was made (referrer URL),
(vii) the browser you use and, if necessary, the operating system of your internet-enabled device, as well as the name of your Internet access provider.
4.5 In order to control / limit the collection of this information, you can:
(i) if available, set up your browser to refuse all cookies or other tracking technologies or to indicate when a cookie or other tracking technologies is/are being used,
(ii) when reaching our Website, select what cookie and other tracking technologies you allow and what cookie and other tracking technologies you want to block,
(iii) delete cookies and other tracking technologies and clear your browsing data directly from your browser’s settings.
However, please note that if you do not accept certain cookies or other tracking technologies, you may not be able to use some features of our Website.
4.6 List of the Cookies and other tracking technologies we use:
Designation Provider Country (destinaton) Function Expiry Type
ga Google LLC USA Provides a unique identifier in order to distinguish users 24 months Analytics cookies _ga Google LLC USA Enables to persist session state 24 months Analytics cookies
b) Why we collect information through cookies and other tracking technologies (purpose) ?
4.8 We collect Personal Data through cookies and other tracking technologies for the following purposes:
(i) to authorize access to our Website,
(ii) to make the functionalities of our Website available to you and to offer you additional functionalities,
(iii) to improve the Website or our dedicated pages on social media,
(iv) to store information about your preferences, allowing us to customize our Website according to your individual interests,
(v) to speed up your searches,
(vi) to compile behavioral and statistical information about uses of our Website or our dedicated pages on social media, in particular to estimate our audience size and usage patterns,
(vii) to produce aggregate insights that do not identify you,
(viii) to identify you and log your use, recognize you when you return to our Website, track the activity on our Website and hold certain information.
c) Legal basis for processing
4.9 In the case of cookies and other tracking technologies that are necessary for the operation, maintenance and security of our Website and dedicated pages on social media, the legal basis on which we justify the processing of your Personal Data is the necessity for the purposes of our legitimate interests (article 6(1)(f) of the GDPR, respectively article 31 para. 2 of the Swiss Data Protection Act).
4.10 With regard to cookies and other tracking technologies used for statistical purposes in connection with our Website and dedicated pages on social media, the legal basis on which we justify the processing of your Personal Data is your consent obtained by means of the cookie banner displayed on the Website (article 6(1)(a) of the GDPR and article 6 para. 6 of the Swiss Data Protection Act).
C. Personal Data you provide us
a) What Personal Data you provide us?
4.11 We collect Personal Data offered by you voluntarily when, on our Website, you:
(i) fill out a form, including a contact form, a questionnaire or an online game/quiz,
(ii) subscribe to our newsletter,
(iii) apply for a position,
(iv) apply for a media accreditation.
4.12 These Personal Data may include your name, postal and e-mail address, phone number, professional information and other information mentioned on your resume, as well as any other Personal Data that can be mentioned in the content of your message or of the form/questionnaire.
b) Why we collect such Personal Data (purpose)?
4.13 We use the Personal Data you provide us with for the following purposes:
(i) to provide customer support,
(ii) to deliver manage our newsletter services,
(iii) to process your request through a form, including to process your application for a position or a media accreditation,
(iv) to fulfill the purposes for which you provide the data.
c) Legal basis for processing
4.14 The legal basis we rely on to process the Personal Data you provide us is the data subject’s consent to the processing of his or her personal data (article 6(1)(a) of the GDPR and article 6 para. 6 of the Swiss Data Protection Act).
d) Unsubscribing from our newsletter
4.15 If you have agreed to receive our newsletter or other communications from us, you can revise your preferences by clicking on the “unsubscribe” link within the e-mail you receive or you can email us at firstname.lastname@example.org.
D. Personal Data collected about you from other sources
a) What information we collect from other sources?
4.16 We may process Personal Data about FWT’s athletes which are publicly available or that the data subject has agreed to be made publicly available in the context of its participation to FTW’s events.
4.17 We may collect Personal Data about you available on your social media account(s), such as Facebook, if you are logged onto your account while you are browsing our Website, or from third party providers listed in Section 5.3 in compliance with their policies.
b) Why we collect information through these other sources?
4.18 We collect and use Personal Data about you which are publicly available or that the data subject has agreed to be made publicly available for public information on FWT’s events purposes.
c) Legal basis for processing
4.20 The legal basis for collecting and processing Personal Data about FWT’s athletes which are publicly available or that the data subject has agreed to be made publicly available is the athlete’s acceptance with such processing, respectively an overriding private or public interest (article 6(1)(a) and (f) of the GDPR and articles 6 para. 6 and 31 para. 2 of the Swiss Data Protection Act).
4.21 The legal basis for collecting your Personal Data your social media account(s) if you are logged onto your account while browsing our Website is your acceptance through the means of our cookie banner, in particular the Facebook pixel cookie (article 6(1)(a) of the GDPR and article 6 para. 6 of the Swiss Data Protection Act).
5. PERSONAL DATA COLLECTED BY THIRD PARTIES
5.1 Our Website and our dedicated pages on social media contain links that direct you to social networks or to other websites, in order to connect you with the content displayed in these platforms. This Policy does not cover how that social network or that other website processes your Personal Data.
5.3 Among other links available on our Website, when you:
(i) subscribe to our newsletter or apply for a media accreditation, our Website redirects you to ‹https://mailchi.mp› operated by Mailchimp (The Rocket Science Group LLC which is part of the Intuit Inc. group);
(ii) subscribe to a campaign, fill up a questionnaire or take part to an online game/quiz, our Website and/or our dedicated pages on the social media redirect to ‹qualifio.com› operated by Qualifio SA, Belgium;
(iii) apply for a position, our Website redirects you to ‹https://tally.so› operated by Tally (Belgium);
(iv) ask for a license, our Website redirects you to ‹https://liveheats.com› operated by LiveHeats (LiveHeats Pty Ltd);
(v) click on Fun Bet, our Website redirects you to ‹https://peakperformance.pronosticgames.fr› operated by PEAK PERFORMANCE PRODUCTION AB;
(vi) visit our shop, our Website redirects you to ‹https://freerideworldtour-shop.com›, another website operated by us.
5.4 If you establish a connection with a social network or another website, your browser connects directly to the provider’s servers. Through this integration, the social network or the other website may receive the information that your browser previously accessed the corresponding page of our Website or our dedicated page on a social media, even if you do not have a profile or are currently not logged in to your account. This information (including your IP address) will be transmitted from your browser directly to a provider’s server and stored there. If you are logged in to your account, the provider can immediately assign the visit to our Website or our dedicated page on a social media to your profile. If you interact with the Website or our dedicated page on a social media, for example by clicking a "Like" or “Share” button, this information will also be transmitted directly to the provider’s server and stored there.
6. SHARING YOUR PERSONAL DATA WITH THIRD PARTIES
6.1 Your Personal Data may be transferred to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of FWT’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by FWT about our Website users is among the assets transferred.
6.2 We may give certain independent contractors and affiliates access to the Personal Data you made available to us through our Website or our dedicated pages on social media in order to assist us with the operation of our Website or our dedicated pages on social media, as well as data management and marketing activities. To date, those contractors are the following:
(i) Hosting company: Cloudways Ltd., Junction Business Centre, 1st Floor Sqaq Lourdes, St Julians STJ3334, Malta, hosting data in Frankfurt (Germany).
(ii) Frontend hosting company: Vercel Inc., 440 N Barranca Ave #4133
Covina, CA 91723, United States of America, hosting data through clouds located worldwide.
(iii) Analytics cookies: Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.
(iv) Meta-Video media player hosting company: OVS SAS, rue Kellermann 2, 59100 Roubaix, France, hosting data in France.
(v) Hosting of Personal Data collected through some questionnaires or online games/quizzes: Qualifio SA, 25, place de l’Université, 1348 Louvain-la-Neuve, Belgium, hosting data in [location].
6.4 The purpose for sharing your Personal Data to the above-mentioned third-party is to support our business and to maintain and to constantly look to improve our Website and the services it offers to our users. The legal basis we rely on to process your personal data is the necessity for the purposes of our legitimate interests (article 6(1)(f) of the GDPR, respectively article 31 para. 2 of the Swiss Data Protection Act). When the sharing of your Personal Data cannot be justified on our legitimate interests, we will justify the sharing of your Personal Data by your acceptance through the means of our cookie banner.
7. TRANSFER OF YOUR PERSONAL DATA WITH AUTHORITIES
7.1 We may also transfer your Personal Data (including your communications) if we think it’s necessary for security purposes, to investigate possible fraud or other violations of this Policy and/or attempts to harm other users of our Website or our dedicated pages on social media. Hence, we may share or transfer your Personal Data to investigate, respond to and resolve complaints and issues relating to our Website or our dedicated pages on social media.
7.2 It is possible that we will need to disclose your Personal Data when required by law or if we have a good faith belief that disclosure is necessary to:
(i) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies,
(ii) enforce our agreements with you,
(iii) investigate and defend ourselves against any third-party claims or allegations,
(iv) protect the security or integrity of our Website or our dedicated pages on social media, or
(v) exercise or protect the rights and safety of our users, personnel, or others.
7.3 We attempt to notify users about legal demands for their Personal Data when appropriate in our judgment and technically feasible, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
7.4 The purpose for sharing your Personal Data to the above-mentioned authorities is to comply with our legal obligations (article 6(1)(c) of the GDPR, respectively article 31 para. 1 of the Swiss Data Protection Act).
8. NO COMMERCIAL DISCLOSURE OF YOUR PERSONAL DATA
8.1 We will not sell your Personal Data to third parties. We will not share or otherwise make available your Personal Data to third parties except as provided in this Policy.
9. CROSS-BORDER DATA TRANSFER
9.1 For some of the third-party service providers, we may transfer your Personal Data to one of their databases outside Switzerland or the European Economic Area, potentially including countries which may not have an adequate level of protection for your Personal Data compared with that provided in Switzerland or the European Economic Area. In such event and unless provided otherwise in this Policy, we enter into agreements with such third-parties ensuring an adequate level of protection for your Personal Data.
9.2 By your acceptance of certain cookies and other tracking technologies through the means of our cookie banner, you agree that we may transfer, store and process your Personal Data outside of Switzerland and the European Economic Area – in particular in the USA – and acknowledge that governments in certain countries such as the USA have broad powers to access data for security, crime prevention and detection and law enforcement purposes.
10. PROTECTION OF YOUR PERSONAL DATA AND DATA BREACH NOTIFICATION
10.1 We exercise commercially reasonable efforts to prevent unauthorized exposure or disclosure of your Personal Data. In particular, we implement and maintain measures (comprising administrative, physical, and technical safeguards) for managing unauthorized disclosure or exposure of your Personal Data.
10.2 In the event of a data breach, or in the event that we suspect a data breach, we will (i) do our best efforts to promptly notify you, where technically feasible, and (ii) cooperate with you to investigate and resolve the data breach, including without limitation by providing reasonable assistance to you in notifying injured third-parties. We will give you prompt access to such records related to a data breach as you may reasonably request; provided that we shall not be required to provide you with records belonging to, or compromising the security of, other users.
10.3 In the event of a data breach, or in the event that we suspect a data breach, we will in addition notify the competent authorities in accordance with applicable law.
11. MANAGEMENT OF YOUR PERSONAL DATA (YOUR RIGHTS)
11.1 Right to access, update or to delete the information we have on you: Whenever made possible, you can access, update or request deletion of your Personal Data by contacting us at the following at: email@example.com.
11.2 Right of rectification: You have the right to have your Personal Data rectified if that information is inaccurate or incomplete.
11.3 Right to object: You have the right to object to our processing of your Personal Data.
11.4 Right of restriction: You have the right to request that we restrict the processing of your Personal Data.
11.5 Right to data portability: You have the right to be provided with a copy of the Personal Data we have on you in a structured, machine-readable and commonly used format.
11.6 Right to withdraw consent: You have the right to withdraw your consent at any time where we relied on your consent to process your Personal Data.
11.7 Right to complain to an Authority: You have the right to complain to a data protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.
11.8 Please note that we may ask you to prove your identity before responding to requests based on the previous rights or somehow related to your Personal Data.
12. RETENTION OF YOUR PERSONAL DATA
12.1 We retain the Personal Data you provide to the extent necessary to provide you access to and use of our Website or our dedicated pages on social media and of their functionalities (like for instance our newsletters), as well as to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
12.2 The storage period of Personal Data hosted by Vercel is 24 hours.
12.3 The storage period of Personal Data collected through cookies and other tracking technologies depends on their purpose and is the same for everyone.
12.4 We may retain de-personalized (anonymous) information after the deletion of your Personal Data.
13. SECURITY OF YOUR PERSONAL DATA
13.1 The security of your Personal Data is important to us, but no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use technical and organizational commercially acceptable means to protect your Personal Data against manipulation, partial or complete loss and unauthorized access by third party, we cannot guarantee its absolute security.
14. PERSONAL DATA RELATING TO CHILDREN
14.1 We do not provide services directly to children or proactively collect their personal information.
14.2 In particular, we do not knowingly solicit, obtain, retain or use any Personal Data from children under the age of 13 years. Accordingly, children under the age of 13 may be restricted from participating in certain features of our Website and our dedicated pages on the following social. If FWT is made aware that we have collected Personal Data (as defined below) from a child under 13 years of age in a manner that is inconsistent with the US Children’s Online Privacy Protection Act (COPPA), FWT will delete this information as soon as possible.
15.1 We may change this Policy at any time by posting a new version on this page or on a successor page, without prior notification. If we make changes to this Policy, we will notify you through a notice on the Website home page. By continuing to access or use our Website or our dedicated pages on social media after those revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, please stop using the Website and our dedicated pages on social media.
15.2 However, we will always handle your Personal Data in accordance with the Policy that was in effect at the time of collection.
15.3 The new version will become effective on the date it is posted, which will be listed at the top of the page as the new effective date.
16.1 Our failure to enforce any right or provision of this Policy will not be considered a waiver of those rights.
16.2 If any provision of this Policy is held to be invalid or unenforceable by a court, the remaining provisions of this Policy will remain in effect.
17. ANY QUESTION OR COMPLAINT?
17.2 You can also reach us by physical mail at FWT Management SA, c/o Giovanni Locatelli, route de Verbier 115m 1936 Verbier.