Protection of personal data

1. The commitment of European Sport Communication (ESC) S.A. for the protection of personal data
The trust shown by its customers is essential for ESC.

This is why, in accordance with European Directive 2016/679 which entered into force on May 25, 2018, ESC has clarified its personal data protection policy.

2. Personal data
“Personal data is information relating to an identified natural person or who can be identified, directly or indirectly, by reference to an identification number or to several elements of his own.”

3. Principles of European Sport Communication S.A. in order to protect the personal data received
ESC applies the following 7 principles:

  1. Privatization: ESC does not sell or distribute the personal data collected for purposes other than those for which it is received. If ESC has received the express consent of the data subject, this data may be used by ESC for marketing purposes for the sole benefit of ESC.
  2. Legitimacy: ESC only collects and processes personal data for the provision of the service requested of it. After the express consent of the person concerned, this data may be used by ESC to offer its future activities.
  3. Relevance and precision: ESC only collects the personal data it needs to process them and takes all reasonable steps to keep the personal data held up to date.
  4. Storage: ESC keeps personal data for the time necessary to perform the requested service but also, where applicable, for the time prescribed by all the laws in force.
  5. Access, rectification, opposition: any natural person whose personal data ESC holds has the right to access, modify, correct and request their deletion. This person may also object to the use of their personal data, in particular for commercial or marketing reasons. The contact details of the service to be contacted for this purpose can be found below, under point 12 “Access and modifications”.
  6. Confidentiality and security: ESC takes all reasonable and necessary measures, both technically and organizationally, to ensure that personal data held is protected against any access, modification, loss, malicious intent, dissemination or unlawful use.
  7. Sharing and transfer: as an event and travel organizer, ESC transmits certain personal data to subcontractors for the sole purpose of providing the required service. ESC strives to verify that its subcontractors subject to the European Directive are committed to respecting it.

For any questions relating to the 7 rules of personal data protection above, please contact the service concerned, the contact details of which can be found below, in point 12 “Access and modifications”.

4. What personal data do we collect?
In order to perform the service requested of it, ESC collects information about the people participating in the event or the service to be provided. This information may relate to:

  • contact data (last name, first name, phone number, email address, etc.)
  • personal information (gender, date of birth, nationality, clothing size, etc.)
  • information relating to the children (surname, first name, date of birth, age, etc.)
  • copy of identity documents or driving license
  • travel dates
  • preferences or interests (diet, allergies, desired type of bedding, etc.)

ESC does not knowingly collect sensitive information within the meaning of the European Data Protection Directive.

5. When do we collect this personal data?
They can be collected in several cases including, but not limited to:

  1. Hotel activities:
    • room booking
    • check-in on arrival
    • catering during the stay
    • requests or complaints
  2. Participation in events:
    • when purchasing or registering for programs
    • when subscribing to a newsletter or to receive promotional offers by e-mail
  3. Communication of information by third parties:
    • by companies providing us with guest lists, by reservation systems…
  4. Internet activities:
    • online forms, ESC pages on social networks…

6. For what purposes?
ESC collects personal data:

  1. to fulfill our mission as a service provider and / or event organizer
  2. to manage reservations relating to accommodation, catering, passenger transport (plane, train, car, ferry, etc.)
  3. as part of participation in an event or activity
  4. to manage complaints or complaints
  5. in order to comply with the legislation in force (particularly in tax, accounting and administrative matters).

7. Conditions of access to personal data of a third party
In order to guarantee the right of access and modification (point 12 “Access and modifications”), we may have to share the personal data received both internally and externally. This is done under the following conditions:

  1. within ESC, in order to provide the best service, we may share personal data with employees of our company, who are bound by our privacy policy;
  2. with partners and subcontractors: personal data may be sent to them in order to meet our obligations towards our customers. These external recipients are either bound by our confidentiality rules, or scrupulously observe the European Directive;
  3. local authorities: we may also be required to disclose personal data to the supervisory authorities to which ESC is subject if this is required by law or if it is as part of an investigation, in strict compliance with the laws in force.

8. Protection of personal data during transfers
As part of point 6 above, ESC may need to transfer personal data both internally and externally to recipients in countries offering different levels of personal data protection.
ESC, in addition to implementing this policy, takes the necessary measures to secure this data during these transfers so that it maintains the same level of confidentiality as in the country where it was collected.
Other than those necessary for the successful delivery of the requested service or the organization of events, no data flow is provided by ESC to third parties.

9. Data security
ESC takes all technical and organizational measures, in accordance with legal provisions, to protect the personal data collected against any unlawful or accidental destruction, accidental loss or modification, as well as to protect access to this data and prevent its dissemination. To this end, ESC takes technical (such as the implementation of firewalls) and organizational measures (implementation of an identification and password system, physical means of protection, etc.).
In addition, any online payment made by our customers using a credit card is hosted on secure servers belonging to one of the major players in the segment. At no time can ESC read or have access to all of the data on the card.

10. Cookies
ESC does not use cookies or any other tracker on its website. Likewise, ESC does not install any in your hardware during your visit to its site.

The cookies installed by social networks allow you to share your opinion and the content of our site on these networks (for example the “like” or “share” buttons).

Social network applications installed on our site such as those indicated above may, in some cases, allow the social network to identify the visitor even if the visitor does not click on the application button. Please note that this type of button may allow the social network to track your browsing on the ESC site simply because your account on this network is active (session open) while you are surfing.

We urge you to read the networks’ privacy policies so that you know how they use the information they collect, especially with regard to advertisements. These policies must in particular allow you to make choices on these networks, in particular by configuring your user account for each of them.

11. Data storage
We keep personal data for the time necessary to achieve the objective pursued, namely the provision of a clearly identified service or participation in an event, but also for the time prescribed by the applicable legal provisions.

12. Access and modifications
Individuals have the right to access their personal data collected by ESC and to modify it in accordance with the legal requirements in force.
Individuals also have the right to submit complaints to the address below.
In case of difficulty in asserting your rights, we would be grateful if you would contact our personal data protection department directly, by sending an e-mail to personaldata@european-sport.net or by writing to the address:

European Sport Communication S.A.
Personal Data Department
53, Gruuss-Strooss
L-9991 WEISWAMPACH
Grand-Duché de Luxembourg

For confidentiality and privacy issues, we will need to be able to identify the person concerned in order to be able to respond to their request. To do this, a copy of an identity document (identity card, passport, etc.) should be attached to any request.
If it appears that the person’s personal data are inaccurate, incomplete or obsolete, the person must communicate the corrected data to the personal data protection department, at the contact details indicated above.
All inquiries will be answered as quickly as possible and, in any case, within the time limits prescribed by law.

13. Updates
We reserve the right to update our personal data protection policy, in particular so that it can always meet the requirements of applicable law. Accordingly, we recommend that you consult them regularly.

14. Questions and contacts
For any questions regarding ESC’s personal data protection policy, please contact the Personal Data Department (see point 12).

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