Privacy Policy for User Registration on the XMS Portal

English version

1. Introduction

This Privacy Policy describes how personal data of users registering on the XMS portal is collected and processed in order to provide the services available or enabled through the portal.

Personal data is processed in accordance with applicable data protection laws, including Regulation EU 2016/679, where applicable.

2. Data Controller and Data Owner

The Data Controller is:

The data collected through the XMS portal is owned by Tennium Megatennis UTE, which determines the purposes and means of processing, unless otherwise provided by contractual arrangements or applicable law.

3. Data Processor and sub-processors

Crionet SRL acts as Data Processor for the technical and operational management of the XMS platform, processing personal data exclusively on behalf of the Data Controller, according to documented instructions received from the Data Controller and for purposes connected to the provision of the services enabled on the portal.

4. Personal Data Collected

During registration and use of the XMS portal, the following personal data may be collected:

• first name;
• last name;
• date of birth;
• photograph;
• country;
• city;
• address.

Additional data may be requested where necessary for the activation or provision of specific services available on the portal.

5. Purposes of Processing

The personal data collected is processed for the following purposes:

1. to allow user registration on the XMS portal;
2. to correctly identify the user;
3. to provide the services requested or enabled through the portal;
4. to manage requests for credentials, badges, authorizations, accreditations or other services connected to user identification, depending on the features enabled on the portal;
5. to verify, where necessary, the user’s eligibility to access specific services;
6. to manage operational and administrative communications related to the enabled services;
7. to comply with legal, regulatory or contractual obligations, where applicable;
8. to ensure the security, technical management and proper functioning of the portal.

The specific features available may vary depending on the configuration of the portal and the services enabled by Tennium Megatennis UTE.

6. Legal Basis for Processing

Depending on the circumstances, the processing of personal data may be based on one or more of the following legal bases:

• performance of a contract or pre-contractual measures requested by the user;
• necessity to provide the services requested by the user through the portal;
• compliance with legal obligations;
• legitimate interest of the Data Controller, for example to ensure portal security, proper access management and prevention of misuse;
• user consent, where required by applicable law or for specific features.

7. Provision of Data

The provision of the data requested during registration is necessary to create the user account and provide the services available on the portal.

Failure to provide the required data may prevent, in whole or in part, registration, user identification, issuance of credentials or access to the enabled services.

8. Processing Methods

Personal data will be processed using IT, electronic and, where necessary, manual tools, in accordance with the principles of lawfulness, fairness, transparency, minimization, accuracy, integrity and confidentiality.

Appropriate technical and organizational measures will be adopted to protect personal data against unauthorized access, loss, destruction, alteration or unlawful disclosure.

9. Recipients of Personal Data

Personal data may be processed by authorized personnel of the Data Controller and by third parties providing technical, organizational or administrative services connected to the operation of the XMS portal.

Such parties may include, by way of example:

• platform providers and related technical service providers;
• parties involved in the management of accreditations, credentials or authorizations;
• operational partners involved in the provision of the enabled services;
• sub-processors, where authorized and necessary for the provision of the services;
• public authorities or entitled parties, where required by law.

Where necessary, such parties will be appointed as Data Processors, sub-processors or authorized to process personal data in accordance with applicable law.

10. Data Transfers

Personal data will mainly be processed within the European Economic Area. Any transfers to countries outside the European Economic Area will be carried out only where necessary and in compliance with the safeguards provided by applicable data protection laws.

11. Data Retention Period

Personal data will be retained for as long as necessary to achieve the purposes for which it was collected and, in particular, for the duration of the user account and/or the services enabled through the XMS portal.

At the end of the relationship or when the processing is no longer necessary, the data will be deleted, anonymized or retained for a further period only where necessary to comply with legal obligations, protect rights or manage potential disputes.

The specific retention period may be determined by Tennium Megatennis UTE based on the nature of the enabled services.

12. Data Subject Rights

The user, as data subject, may exercise the rights provided by applicable data protection laws, including:

• right of access to personal data;
• right to rectification of inaccurate or incomplete data;
• right to erasure, where applicable;
• right to restriction of processing;
• right to object to processing;
• right to data portability, where applicable;
• right to withdraw consent, where processing is based on consent, without affecting the lawfulness of processing carried out before withdrawal.

Requests may be sent to: le@tennium.com / Lily End.

The user also has the right to lodge a complaint with the competent data protection supervisory authority.

13. Updates to this Privacy Policy

This Privacy Policy may be updated from time to time to reflect legal, technical, organizational or service-related changes concerning the XMS portal.

The updated version will be made available within the portal or through other appropriate channels.