1. European Sport Communication (ESC) S.A. commitment for privacy protection
Because we highly consider our clients, their complete confidence in ESC is essential to us.

This is why, to comply with European Directive 2016/679 entered in force this May 25th 2018, ESC set up a customer privacy protection policy.

2. Personal data
Personal data means any information collected and logged in a format that allows you to be identified personally, either directly (e.g. name) or indirectly (e.g. telephone number) as a natural person.”

3. European Sport Communication S.A. principles to protect personal data received
The seven principles below are applicable within ESC.

1. Privatization: ESC neither sells nor shares personal data collected and never uses them for any purpose other than the one for which they have been received. If ESC has an explicit and informed consent, ESC might use such personal data only for ESC marketing benefit.
2. Legitimacy: ESC collects and processes personal data only for the provision of services it has been asked for. If ESC has an explicit consent, ESC might use said personal data to promote its own future events.
3. Relevance and accuracy: ESC only collects personal data that is necessary for data processing. ESC takes all reasonable steps to ensure that the personal data hold is accurate and up to date.
4. Storage: ESC holds personal data for the period necessary to provide the requested service and in compliance with the provisions of the law.
5. Access, rectification, opposition: any natural person for which ESC detains personal data can ask to access, modify, correct or delete them. He may also oppose the use of his personal data, particularly to avoid receiving sales and marketing information. The details of the department to contact in this respect are shown below (§12) in the clause "Access and modification".
6. Confidentiality and security: ESC ensures reasonable technical and organizational measures are taken to protect personal data against alteration or accidental or unlawful loss, or unauthorized use, disclosure or access.
7. Sharing and transfer: as event and travel organizer, ESC might share personal data with reliable subcontractors for the one and lonely scope to achieve the service required. ESC makes its best efforts to ensure that subcontractors subject to European regulation on data protection demonstrate a commitment to respect Directive rules.

For any questions concerning the seven principles of ESC Data Protection, please contact the Personal Data controller whose details appear in the clause "Access and modification".

 

4. What Personal Data is collected?
To perform the provision of service, ESC has to ask for information about people attending our events or involved in the service provided. This information might be:

• contact details (first name, last name, telephone number, email)
• personal information (date of birth, nationality, clothes size…)
• information relating to children (first name, date of birth, age)
• copy of passports or driving licences
• travel dates
• preferences and interests (specific diet, type of bedding…)

ESC does not deliberately collect sensitive information within the meaning of European regulation on data protection.

5. When are personal data collected?
Personal data may be collected on a variety of occasions, including but not limited to:

1. Hotel activities:
   • booking a room
   • checking-in
   • eating/drinking during a stay
   • requests, complaints and/or disputes.
2. Participation in events:
   • signing up for programs
   • subscription to newsletters, in order to receive offers and promotions via email.
3. Transmission of information from third parties:
   • companies providing us guests’ lists, reservation systems and others.
4. Internet activities:
   • online forms (online bookings, ESC pages on social networks etc.).

6. For which purposes?
ESC collects personal data for the purposes of:

1. Meeting our obligations with respect to the service provision/event organization.
2. Managing the reservation of requests relating to accommodation, catering, personal transport means (plane, train, car, ferry…).
3. Participating to events/activities.
4. Managing claims/complaints.
5. Conforming to local legislation (for example, storing of accounting documents).

7. Conditions of third-party access to personal data
To guarantee the right of access and amendment (§12 "Access and modification" clause), ESC might have to share personal data with internal and external recipients subject to the following conditions:

1. Within ESC in order to offer you the best service, we can share personal data and give access to authorized personnel of the company, who is bound to our personal data policy.
2. With subcontractors and partners: personal data may be sent to a third party for the purposes of fulfilment of our obligations with respect of our client. These external recipients are bound by our private policy or they committed themselves to comply with Directive rules.
3. Local authorities: we might also be obliged to send personal data to local authorities if this is required by law or as part of an inquiry and strictly in accordance with local regulations.

8. Protection of personal data during transfers
For the purposes set out in Clause 6 of this policy, ESC may transfer personal data to internal or external recipients who may be in countries offering different levels of personal data protection.
Consequently, in addition to implementation of this policy, ESC employs appropriate measures to ensure secure transfer of personal data to its staff or to an external recipient located in a country offering a different level of privacy from that proposed in the country where the personal data is collected.
Other than those that are required to carry out the requested service provision/event organization, no dataflows are delivered by ESC to any third-party.

9. Data security
ESC takes appropriate technical and organizational measures, in accordance with applicable legal provisions, to protect personal data against illicit or accidental destruction, accidental alteration or loss and unauthorized access or disclosure. To this end, we have taken technical measures (such as firewalls) and organizational measures (such as a user ID/password system, means of physical protection etc.).
Moreover, any payment made through credit card is hosted on a secured server belonging to one of the major actors of this business. At no time ESC can read or have any access to credit card details.

10. Cookies
Please be advised that ESC doesn’t use any cookie or other tracer on its website and doesn’t install any on your device.

Social network cookies, set by third parties, allow you to share your opinion and content of ESC website on social networks (for example, the "Share" or "Like" application buttons for social networks).

The social network applications on ESC website as mentioned above can in some cases allow the social network concerned to identify visitor even if he did not click on the application button. This type of button can allow a social network to track the browsing on ESC website, simply because your account in the social network is enabled on your device (open session) while you are browsing.

We recommend that you read the policies of these social networks to familiarize yourself with how they use the browsing information they may collect, especially with regard to advertising. These policies must specifically allow you to make choices on these social networks, particularly by configuring your user account for each of them.

11. Storage of data
We retain your personal data only for the period necessary for the purposes set out in this policy or in accordance with the provisions of applicable law.

 

12. Access and modification
Natural persons have the right to access their personal data collected by ESC and to modify it subject to applicable legal provisions.
People may also exercise his right to object by writing to the address below.
In the event of difficulty in exercising your rights, please contact the Personal Data department of ESC directly by sending an email to personaldata@european-sport.net or by writing to the address below:

European Sport Communication S.A.
Data Privacy Department
53, Gruuss-Strooss
L-9991 WEISWAMPACH
Grand Duchy of Luxembourg

For the purposes of confidentiality and personal data protection, we will need to identify the individual concerned in order to respond to his request. He will be asked to include a copy of an official piece of identification, such as a driver's license or passport, along with his request.
If his personal data is inaccurate, incomplete or not up to date, he will be requested to send the appropriate amendments to the Personal Data department as indicated above.
All requests will receive a response as swiftly as possible and in accordance with applicable law.

13. Updates
We may modify this policy from time to time and to always comply with existing regulation. Consequently, we recommend that you consult it regularly.

14. Questions and contacts
For any question concerning the European Sport Communication S.A. personal data protection policy, please contact the Personal Data department (§12 "Access and modification"clause).