Politique de confidentialité

1. Controller Information

SportShots BV
Registered address: Pending
Primary contact: <email>

2. Types of Personal Data Collected

Order and Account Data:

• Name
• Email address
• Billing information (excluding credit card or bank details, which are securely handled by our payment processor)

Analytics Data:

• IP address
• Browser type and version
• Device and operating system details
• General location information derived from IP
• Website interaction data (pages visited, features used, session duration)

Photographic Data:

• Digital images captured at sporting events
• Facial recognition data (facial vectors) and biometric identifiers
• Number recognition data (bib numbers, athlete identifiers)
• Metadata associated with photos (time, location, camera information)

3. Purposes of Processing

For Order Processing and Account Creation:

• To process and fulfill your orders
• To create and manage your user account, allowing access to your purchase history and downloads
• To facilitate communication regarding your orders and account

For Website and Product Analytics:

• To analyze website usage and improve our services
• To enhance the user experience and optimize our product offerings
• To identify technical issues and improve the performance and stability of our platform
• Analytics data is processed solely for these purposes and is based on our legitimate interests

For Processing Photographic Data:

• To capture and process images during sporting events
• To generate facial vectors and perform number recognition, enabling you to easily locate and purchase your pictures
• To develop and improve our facial and number recognition algorithms to enhance accuracy
• To securely manage and eventually delete unused or unpurchased images

4. Legal Basis for Processing

• Processing is necessary for the performance of a contract between you and SportShots.

• Processing is based on our legitimate interests in improving our website and services.

• Processing is required to fulfill our service obligations and is carried out in accordance with applicable data protection laws.

5. Retention Periods

• Stored for as long as you maintain an account with us and for a period of up to 7 years thereafter for tax and legal compliance purposes.

• Retained for one year from the date of collection, after which it is anonymized for statistical purposes.

• Facial vectors and related recognition data are retained for one year.
• Images that have not been purchased may be fully deleted after one year.
• Purchased images are retained indefinitely to fulfill our contractual obligations to you.

6. Data Sharing with Third Parties

• Payment Processors: Billing information is securely transmitted to our payment processors; no credit card or bank details are stored by SportShots.
• Cloud Service Providers: We use secure cloud services to store and process data, including images. All providers are bound by strict data processing agreements.
• Analytics Partners: We use PostHog to analyze website usage and product performance. This data is used solely to improve our services and user experience.
• Event Organizers: Limited data may be shared with event organizers to facilitate photo matching and delivery.
• We do not sell or rent your personal data to third parties for marketing purposes.

7. Use of Tracking Technologies

Our website uses local storage and similar tracking technologies to collect analytics data (such as IP addresses, browser data, and general location information) to improve our website and services. While these tools help us understand usage patterns, there is no mechanism for opting out at this time.

8. Security Measures

We take the security of your personal data very seriously and employ industry best practices, including:

• Disk-level and data-at-rest encryption
• Granular access control to our cloud infrastructure
• Secure data transmission using SSL/TLS encryption
• Regular security audits and vulnerability assessments
• Intrusion detection and prevention systems
• Multi-factor authentication for user accounts
• Secure backup procedures
• Staff training on data security and privacy best practices
• Data minimization and purpose limitation principles

These measures help ensure that your personal data is protected against unauthorized access, loss, or disclosure.

9. Your Rights

Under applicable data protection laws, you have the right to:

• Access your personal data
• Request correction of inaccurate personal data
• Request deletion of your personal data
• Restrict or object to the processing of your personal data
• Receive your personal data in a structured, commonly used, and machine-readable format (data portability)
• Withdraw consent at any time (where processing is based on consent)

To exercise any of these rights, please contact us at <email>. You also have the right to lodge a complaint with the relevant data protection supervisory authority.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We encourage you to review this Policy periodically. Any significant changes will be communicated via our website or by email.

11. AI and Facial Recognition Technologies

At our sporting events, we capture digital images that may include your likeness. We process these images using AI-powered facial and number recognition technology to help you locate and purchase your pictures. This section provides detailed information about how we use these technologies:

• How it works: Our AI systems analyze photos to create facial vectors (mathematical representations of facial features) and detect bib numbers to match participants with their photos. This technology is not used for surveillance or monitoring purposes.
• Data protection measures: Facial vectors and biometric data are stored separately from identifying information and protected with strong encryption. Access to this data is strictly limited to authorized personnel.
• Risk mitigation: We regularly test our AI systems for accuracy and potential biases, and implement measures to ensure fair and non-discriminatory processing.
• Human oversight: While we use automated processing, human oversight is maintained throughout the process to ensure accuracy and prevent errors.
• Retention: Facial vectors and other recognition data are retained for one year, after which they are permanently deleted.
• Opt-out: You can opt out of facial recognition processing by contacting us at <email>. This will not affect your ability to manually browse and purchase photos.
• Future Technologies: While we currently use these technologies, we may adopt alternative solutions in the future to continue providing our services.

12. Contact

If you have any questions, comments, or requests regarding this Privacy Policy or our data practices, please contact us at: <email>