PRIVACY POLICY

pursuant to art.13 of Regulation (EU) 2016/679 of the European Parliament and of the Council

WHEREAS

The ATP Tour Inc. (" ATP") is the international body that manages the professional men's tennis circuit known as the "ATP Tour". The ATP is the exclusive owner of the intellectual property rights and commercial exploitation rights related to the professional men's tennis tournament currently known as the "Nitto ATP Finals", reserved for the best players of the ATP Tour (" Event").

The Federazione Italiana Tennis (" FIT") collaborates with the ATP in order to host, organize and promote the 2021, 2022, 2023, 2024 and 2025 editions of the Event.

****

FIT wishes to inform you that pursuant to article 13 of the Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data (" European Regulation"), may process your personal data collected automatically or provided by you through the surfing or use of the www.tickets.nittoatpfinals.com (" Ticket Website ).

This Privacy Policy, therefore, refers exclusively to the Ticket Website and does not apply to the rest of the nittoatpfinals.com site or to other websites or online services that can be reached through hypertext links that may be published within the Ticket Website or the rest of the www.nittoatpfinals.com site.

FIT reserves the right to amend this privacy policy, taking care to notify such amendments by means of a specific notice. The amendments shall be effective to commence on said notice, or on a different date specified in the same notice. The amendments consequential to statutory or provision amendments of the public authority shall be effective regardless of the notice.

1. JOINT CONTROLLERS

The Joint Controllers are:

  • FIT, in the person of the legal representative, domiciled at the registered office of Stadio Olimpico – Curva Nord – Ingresso 44 Scala G - 00135 Roma (RM);
  • ATP, No-profit organization in Delaware, domiciled at the registered office in 201 ATP Tour Boulevard, Ponte Vedra Beach, Florida 32082, United States;

separately, " Data Controller" and, jointly, " Joint Controllers".

An excerpt of the transparent arrangement is available at the registered office of both Joint Controllers or you can ask for a copy by writing to privacy@federtennis.itor privacy@atptour.com.

2. DATA PROTECTION OFFICER

Due to the processing activities carried out, FIT has deemed it necessary to designate a Data Protection Officer in accordance with article 37 of the European Regulation. In order to contact him, please write to Stadio Olimpico – Curva Nord – Ingresso 44 – Scala G - 00135 Roma (RM) or send an e-mail to dpo@pec.federtennis.it.

Same way, also ATP has deemed it necessary to designate a Data Protection Officer , Mr. Murray Swartzberg, who can be reached sending an email to privacy@atptour.com.

3. TYPES OF PROCESSED DATA

In order to allow you to use the Ticket Website and its services – including the possibility to access to your reserved area and purchase a Gift Card (i.e. a voucher of predetermined value associated with a code, which allows to purchase tickets through the Ticket Website), a valid tickets to attend the Event or, where possible, ask for a refund of the price (even through the issuance of a voucher) – the Joint Processors need to know and process some of your personal data, such as your name, your surname, your date of birth and your email address. In addition, in order to ascertain the existence of the indispensable requirements for you to be able to use certain services (such as access services to the Event provided for disabled persons), special categories of data, such as that related to your state of health, may be requested. For the purposes of the following paragraph 4, letter A), your citizenship and, if Italian, your address will also be requested. Finally, if, once you have purchased a Gift Card, a ticket, you would like to request the issue of an invoice or, where possible, the refund of the price (even through the issuance of a voucher), in addition to the personal data already entered for registration and purchase, we will also ask you to provide the following data: your tax code, your address, your telephone number and the data of your bank account and/or postal account.

Navigation Data

The computer systems and software implemented on the Ticket Website acquire, during their normal operation, some personal data whose transmission is implicit in the use of communication protocols of the Internet.

This category of data includes IP addresses or domain names of the computers used by users connecting to the Ticket Website, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and the user's computer environment.

This data, necessary for the use of the Ticket Website, are processed only for the purpose of obtaining statistical information on the use of the services (most frequently visited pages, number of visitors per time slot or daily, geographical area of origin etc.) and to verify the correct functioning of the offered services.

The navigation data are not stored for more than seven days and are deleted immediately after their aggregation, without prejudice to the possible requests of judicial authorities to ascertain criminal offenses.

Data provided by the user

The creation of your personal area, the subscription to the newsletter and the purchase a Gift Card or tickets through the Ticket Website entail the acquisition of your name, your surname, your date of birth, your email address and in the case of ticket purchase, the data listed at paragraph 2. Furthermore, the Joint Controllers may acquire knowledge of other possible personal data inserted in the message or in forms to be completed in case of purchase.

Cookie Policy

The Ticket Website use the following categories of cookie.

Technical Cookie

Technical cookies and session cookies are used, i.e. small text files containing a certain amount of information exchanged between your terminal or browser and the Ticket Website, which allow the correct operation and use of the latter. On the opposite, cookies are neither used to transmit information of a personal nature nor the so-called persistent cookies have been implemented.

Analytical Cookies

Analytical cookies are used and made available by third parties, such as Google Analytics. This is done by mere internal statistical analysis of access, to improve and simplify the Ticket Website and their usage as well as to monitor their correct functioning. The Data Controller has utilized the most suitable instruments to reduce to the maximum the identification power of this type of cookie. We highlight – for example – that for this Ticket Website the anonymization function of the IP address is activated. Google Analytical publishes its cookie policy in the following page.

Profiling Cookie

The Ticket Website only uses profiling cookies installed by third parties.

Third Parties Cookies

This website uses the analytical cookies created and made available by Google Analytics, as mentioned above.

In addition, this Ticket Website uses profiling cookies installed by third parties, in particular from Facebook. We provide here the link to Facebook's privacy policy, where you can express your consent to install these cookies. These cookies are not essential, but they help us to personalize and improve your experience on the Ticket Website by tracking your browsing, as well as to allow us to perform internal statistical access analysis and measure the effectiveness of our advertising campaigns. Therefore, while the deletion of these cookies does not affect the general usability of the Ticket Website, it may result in some functionality being limited.

Options regarding the use of cookie on the Ticket Website through browser settings

The installation of all types of cookies may, nevertheless, be disabled in settings of your browser. It should be noted, however, that any changes on these settings could make the Ticket Website unusable where the cookies that are essential for the provision of our services were to be blocked. However, each browser has different settings for deactivating cookies. Below are the links to the instructions for the most common browsers: Apple Safari, Google Chrome, Microsoft Internet Explorer, Mozilla Firefox, Opera.

4. PURPOSE OF THE DATA PROCESSING AND LEGAL BASIS

The Joint Controllers exclusively holds that personal data provided by you during surfing of the Ticket Website and the use of their services. Such data will exclusively be used for:

  1. allow you to use our Ticket Website and its services, including the possibility to access your personal area and purchase a Gift Card, your desired tickets or, where possible, obtain the required refund and facilitate your request for a refund (even through the issuance of a voucher) in case of difficulties. Some special data (such as data relating to your state of health) may be processed in order to allow us to ascertain the existence of the essential requirements for you to be able to take advantage of the access services to the Event provided for the disabled persons.

The legal basis on which this processing is based are (i) the execution of a contract of which you are part of, and (ii) FIT's fulfilment of legal obligations. In case of processing of special data, the legal basis is your express consent.

Furthermore, FIT and ATP may process your personal data as autonomous Data Controllers for the following purposes:

  1. allow FIT to keep you always updated on its activities and promotions, sending – both through traditional and fully automated contact systems, such as, for example, through the use of your e-mail address – advertising material and/or communications and information of a commercial and direct marketing nature on its services and products, related offers, discounts and any other promotional and loyalty initiatives adopted, as well as to allow FIT to send you newsletter aimed at allowing you to benefit from the possibility to purchase tickets in priority over other users, if provided.

The legal basis for this processing is your express consent.

  1. allow FIT to keep you always updated on promotions you may be interested in, sending – both through traditional fully automated contact systems, such as, for example, through the use of your e-mail address – advertising material and/or communications and information of a commercial and indirect marketing nature on services and products, related offers, discounts and any other promotional and loyalty initiatives adopted by its commercial partners.

FIT's partners belong to the following product categories: consumer electronics, diversified materials (including tapes, vinyls, LCDs, insulators and many other plastic products); banking, financial trading and insurance; airline and train transport, packaging, shipping and logistics; coffee and machines for its preparation; sportwear, formal and casual apparel; glasses and sun glasses; two and four-wheel vehicles; timepieces, watches, smartwatches and clocks; telecommunications; waters; beers and wines; alcoholics and spirits; soft and energy drinks; tennis and padel balls, rackets and related accessories; energy and utilities (including electricity and gas); travel and accommodation; IT, digital transformation, computing and cloud computing; confectionary, dried fruit and other snacks; sanitizers; gaming; betting; educational; entertainment (including linear and on-demand broadcasting).

The legal basis for this processing is your express consent.

  1. allow ATP to keep you always updated on its activities and promotions, sending - both through traditional and fully automated contact systems, such as, for example, through the use of your e-mail address - advertising material and/or communications and information of a commercial and direct marketing nature about - advertising material and/or communications and information of a commercial and direct marketing nature on our services and products, related offers, discounts and any other promotional and loyalty initiatives adopted, as well as to allow ATP to send you newsletter aimed at allowing you to benefit from the possibility to purchase tickets in priority over other users, if provided.

The legal basis for this processing is your express consent.

  1. allow ATP to keep you always updated on promotions you may be interested in, sending – both through traditional fully automated contact systems, such as, for example, through the use of your e-mail address – advertising material and/or communications and information of a commercial and indirect marketing nature on services and products, related offers, discounts and any other promotional and loyalty initiatives adopted by its commercial partners.

ATP's partners belong to the following product categories: consumer electronics, diversified materials (including tapes, vinyls, LCDs, insulators and many other plastic products); banking, financial trading and insurance; airline and train transport, packaging, shipping and logistics; coffee and machines for its preparation; sportwear, formal and casual apparel; glasses and sun glasses; two and four-wheel vehicles; timepieces, watches, smartwatches and clocks; telecommunications; waters; beers and wines; alcoholics and spirits; soft and energy drinks; tennis and padel balls, rackets and related accessories; energy and utilities (including electricity and gas); travel and accommodation; IT, digital transformation, computing and cloud computing; confectionary, dried fruit and other snacks; sanitizers; gaming; betting; educational; entertainment (including linear and on-demand broadcasting).

The legal basis for this processing is your express consent.

Your personal data may be processed either through IT tools or paper-based means.

5. DATA RETENTION PERIOD

The Joint Controllers plan to keep your personal data for a period of time no longer than it is necessary to achieve the purposes for which they were collected and processed. Therefore, personal navigation data and those acquired through the use of the Ticket Website will not be stored for longer than seven days.

Regarding the activity of personal data processing for the purpose of Gift Card, ticket purchasing, or, where possible to obtain the requested refund (even through the issuance of a voucher), in compliance with the applicable legislation, including the accounting legislation, the Joint Controllers store your personal data for no longer than 10 years. Successively, they will erase your personal data, or transforms it in an anonymous form, permanently and not reversibly.

With regard to the special data processed in order to allow you to take advantage of the services to access to the Event provided in favor of disabled persons, in compliance with the applicable legislation, including the accounting legislation, the Joint Controllers will keep your personal data for no longer than 10 years. Successively, they will provide for their erasure, or their transformation into anonymous form in a permanent and non-reversible way.

Regarding the data processing for direct marketing purposes, in compliance with the applicable legislation and if it has been explicitly authorized by you, FIT and ATP, as autonomous Data Controllers, provide the automatic erasure of your personal data, or ensure they are permanently transformed in an anonymous form, permanently and not reversibly, within 24 months from the collection.

With regard to other personal data, since the Data Controller cannot accurately determine the period of storage, the Data Controller commits to inspire the data processing to the principles of adequacy, relevance and data minimization, so as required by the European Regulation, annually assessing the need of continued storage. Therefore, once the purposes for which they were collected and processed are achieved, we will remove them from our systems and records and/or take any appropriate measures to render them anonymous, preventing your identification.

The abovementioned paragraphs are without prejudice to the case in which such data will be stored to comply with regulatory obligations, or to ascertain, exercise or defend our right in court.

6. CATEGORIES OF RECIPIENTS OF PERSONAL DATA

The processed data are not disclosed to third parties. The following may, however, come to know your personal data, in relation to the abovementioned processing purposes:

  • organizations who may access the data pursuant to European Union law or Member State legislation to which the Data Controller is subject;
  • subjects performing, within the borders of the European Union, in complete autonomy, as separate data controllers, or as data processors appointed for this purpose by the Data Controllers, purposes auxiliary to those activities and services under paragraph 4, i.e. companies that provide ticket purchasing services, postal services and shipping and delivery agencies, companies offering advertising, marketing and communication services, companies offering IT support and consultation in charge of planning and implementing software and websites, law firms, companies offering services useful to analyze and develop personal data, (including those relative to interactions between users and our services) and elaborate and conduct market researches, service centers, companies or consultants in charge of provide further services to the Joint Controllers within the limits of the purpose for which data has been collected.

Furthermore, FIT's and ATP's employees may also become aware of your personal data, provided that they are previously designated as an individual acting under the authority of the Data Controller pursuant to art. 29 of the European Regulation or as System Administrators.

Any communication of your personal data will take place in full compliance with the provisions of the law set by the European Regulation as well as technical and organizational measures put forth by the Data Controller to ensure an adequate level of security.

7. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

FIT intends to transfer your personal data to the United States for the provision of services on the Ticket Website.

Such transfer is always subject to adequate guarantees as the Data Controllers have signed the Standard Contractual Clauses.

For more information on data transfer regulations to countries outside the European Union, including the mechanisms on which we rely, please see the European Commission website here.

8. AUTOMATED DECISION-MAKING PROCESSING

The Joint Controllers do not intend to use automated decision-making processes, including the profiling referred to in article 22, paragraphs 1 and 4, of the European Regulation.

9. NATURE OF DATA PROVISION

The provision of your personal data for the purposes referred to in paragraph 4.A is mandatory, as your refusal to provide the personal data requested would make it impossible for FIT to allow you to use the Ticket Website, including the possibility of purchasing a Gift Card, tickets valid to attend the Event, or where possible, obtain the required refund (even through the issuance of a voucher). The provision of your particular data is in any case optional, but failure to provide it, while not preventing in any way the use of the Ticket Website, would not allow us to give you the possibility to use the services of access to the Event provided for disabled persons, if so requested.

The provision of your personal data for the purposes referred to in paragraphs 4.B, 4.C, 4.D and 4.E is optional, but failure to provide such data, while not preventing in any way the use of the Ticket Website, may not allow FIT and ATP to make you fully enjoy the benefits they offer their community through advertising, commercial and direct marketing information, to receive newsletters and to inform you about additional services, events and promotions that FIT and ATP aim to offer you.

10. RIGHTS OF THE DATA SUBJECTS

Regarding the processing of your personal data pursuant to the European Regulation, as data subjects you are entitled to the following rights:

  • revoke your consent to data processing at any time. However, it should be noted that revoking the consent will not undermine the legitimacy of any previous processing activity, as provided by article 7, para 3, of the European Regulation;
  • request to the Data Controller access to your personal data, as provided by article 15 of European Regulation;
  • require the Data Controller to rectify or complete your personal data, by means of a declaration, as provided by article 16 of European Regulation;
  • require the Data Controller to erase your personal data, in the cases provided in article 17 of the European Regulation;
  • obtain from the Data Controller restriction of processing whenever the cases provided in article 18 of the European Regulation occur;
  • receive from the Data Controller your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance as provided by article 20 of the European Regulation;
  • object at any time, on grounds relating to your particular situation, to processing of personal data concerning you pursuant to point (e) or (f) of article 6, paragraph 1, of the European Regulation, including profiling based on those provisions, as provided by article 21 of the European Regulation;
  • not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, unless the processing is based on your prior consent pursuant article 22 of the European Regulation. By way of example, any form of automatic personal data processing aimed at analyzing or profiling consumer and purchasing preferences, economic capabilities, interests, reliability, and behavior;
  • lodge a complaint with a supervisory authority (article 77 of the European Regulation), or relevant Judicial bodies (article 79 of the European Regulation) if you deem that the processing of your personal data relating infringes the European Regulation. The complaint may be filed in the Member State of your habitual residence, place of work, or place of alleged infringement.

In order to exercise your rights, you shall contact:

  • FIT, in the person of its legal representative, sending a communication to the registered office in (00135) Roma, Stadio Olimpico – Curva Nord, Ingresso 44, Scala G, or sending an email to privacy@federtennis.it or a p.e.c. to dpo@pec.federtennis.it;
  • ATP, in the person of its Data Protection Officer, Mr. Murray Swartzberg, sending an email to privacy@atptour.com;

The communication sent will have to provide the following data:

  • name, surname and postal code;

  • details of the request;

  • type of the access title held (with the indication of the date, the session and the eventual place indicated on the access title itself);

  • copy of your valid ID.

11. MINORS' CONSENT RELATED TO THE SERVICES OF THE INFORMATION SOCIETY

Children under fourteen (14) years of age are expressly prohibited from using the services provided through the Ticket Website and those under the age of eighteen (18) are expressly prohibited from using the Gift Card and ticket purchase service or the refund request service (even through the issuance of a voucher). By subscribing to the newsletter, you confirm that you are at least 14 years of age. By purchasing Gift Card, tickets or making a refund request where possible, you confirm that you are at least 18 years of age.