Privacy Policy
Track4fun.com srl pays particular attention to the processing and protection of the personal data of its customers and of everyone it deals with. This notice is provided under Articles 13 and 14 of Regulation (EU) 2016/679 ("GDPR") and Legislative Decree 196/2003 ("Italian Privacy Code"), as amended by Legislative Decree 101/2018, to anyone who visits www.track4fun.com, registers, buys a Trackday, a T4F Experience, a gift voucher, a annual membership or a shop product, or contacts us.
1. Data controller
Track4fun.com srl
Registered office: Via Dalmine 10/a – 24035 Curno (BG)
R.E.A. (Business Register) of Bergamo no. 385054 – Tax Code/VAT no. 03514230162
Email: info@track4fun.com – Tel. +39 392 3667406
Track4fun.com srl has not appointed a Data Protection Officer (DPO), because the appointment is not mandatory for its activity. For any privacy question, the point of contact is the Data Controller, Track4fun.com srl, in the person of Luca Adami: info@track4fun.com.
2. What data we process
- Browsing data: IP address, date and time of the request, pages visited, type of browser and device. They are collected automatically by the systems that run the site.
- Account and order data: first name, last name, email, phone, billing address and, if necessary, shipping address, tax code and/or VAT number, SDI code or PEC for the electronic invoice, order history.
- Driver and car data (Trackday and T4F Experience): driver's first and last name, driving licence number, car model and year, any passengers and additional drivers indicated by you.
- Liability Waiver: the acceptance of the Liability Waiver with date and time, and the documents accompanying it. [TO BE VERIFIED: if health information is collected in the Liability Waiver or at the briefing, the paragraph on special categories of data under Art. 9 GDPR must be added, with the relevant legal basis.]
- Payment data: online payments are made through PayPal or Revolut (also when paying by card). Card or account details are entered directly into PayPal's or Revolut's systems: Track4fun does not see or store them; we receive only the outcome and the transaction references. For bank transfers we receive the data contained in the bank transfer order.
- Communications: the data contained in the emails, WhatsApp messages and phone calls through which you contact us.
- Photos and videos: during Trackdays and events, photos and footage may be taken on the track and in the paddock. Photos and videos are made by professional photographers and videomakers engaged from time to time for the individual event, not always the same ones. [TO BE VERIFIED with consultant: role of the photographers (independent controllers or data processors), where the images are published and whether specific consent is requested or the event notice is used.]
We do not process judicial data. We do not use your data for automated decision-making. Only with your consent, given through the cookie banner, do we use statistics (Google Analytics) and marketing (Meta Pixel) tools: see the Cookie Policy.
3. Why we process data and on what legal basis
| Purpose | Legal basis (Art. 6 GDPR) |
|---|---|
| Creating and managing your account | Performance of the contract / pre-contractual measures (point b) |
| Managing Trackday and T4F Experience sign-ups, shop orders, gift vouchers and annual memberships, including confirmations, briefing, documents and support | Performance of the contract (point b) |
| Collecting and keeping the Liability Waiver and the driver and car data needed to access the track | Performance of the contract (point b) and legitimate interest in protecting safety and our rights (point f) |
| Managing payments, electronic invoicing and accounting and tax obligations | Legal obligation (point c) |
| Replying to your requests by email, phone or WhatsApp | Pre-contractual measures / performance of the contract (point b) |
| Sending you emails about Trackdays and services similar to those already purchased (Art. 130(4) Italian Privacy Code) | Legitimate interest (point f), with the right to object at any time |
| Newsletter and promotional communications | Consent (point a), which can be withdrawn at any time [TO BE CHECKED – Leonardo: whether and with what tool the newsletter is sent] |
| Website security, prevention of abuse and fraud, legal defence | Legitimate interest (point f) |
| Publication of event photos and videos | [TO BE CHECKED with adviser: consent or legitimate interest] |
Providing the data marked as required is necessary to complete the purchase or sign-up: without it we cannot process your request. Other data is optional.
4. How long we keep data
- Account data: for as long as the account remains active. If you request its deletion, the account is closed, except for data we are required to retain by law.
- Orders, invoices and accounting records: 10 years, as required by civil and tax law (Art. 2220 of the Italian Civil Code).
- Liability Waiver and driver data: [TO BE VERIFIED: proposed 10 years from the event, equal to the ordinary limitation period].
- Emails and information requests: for the time needed to handle the request and then for a maximum of [TO BE VERIFIED: e.g. 24 months]. The old notice said “indefinitely”: this is no longer permitted.
- Marketing and newsletter: until consent is withdrawn or you object.
- Browsing data and technical logs: [TO BE VERIFIED with the hosting provider, usually a few days or weeks].
5. Who we share data with
Data is processed by authorised Track4fun.com srl staff and by suppliers acting as processors (Art. 28 GDPR), or as independent controllers when they process data for their own purposes:
- Website hosting: Kinsta [TO BE VERIFIED: confirmation of the provider and of the chosen data center (EU or non-EU)].
- Payments: PayPal (Europe) S.à r.l. et Cie, S.C.A. and Revolut, which also handle card payments; our bank for bank transfers [TO BE VERIFIED: name of the bank]. For payment data these parties act as independent controllers.
- Sending emails (order confirmations, briefing, documents): [TO BE VERIFIED: service used, e.g. the hosting mail server or an external SMTP service].
- Electronic invoicing: invoices are prepared by Track4fun itself (manually or with a support tool on the WordPress site) and sent to the Exchange System (SdI) of the Italian Revenue Agency; any intermediary used for sending and the accountant [TO BE VERIFIED].
- Shipping of shop products: the couriers [TO BE VERIFIED: which ones].
- Circuits: as a rule we do not share participant lists with circuits. For some circuits, such as Balocco, we share only participants' first and last names for access to the area (entry list), no other data. Legal basis: performance of the contract (Art. 6(1)(b) GDPR).
- Google Analytics (Google Ireland Ltd.) and Meta Pixel (Meta Platforms Ireland Ltd.): only if you consent to statistics or marketing cookies; details in the Cookie Policy.
- WhatsApp (Meta Platforms Ireland Ltd.): only if you choose to contact us with the WhatsApp button. In this case WhatsApp's own privacy notice also applies.
- YouTube (Google Ireland Ltd.): some pages show videos in “enhanced privacy” mode (youtube-nocookie.com); loading the player communicates the visitor's IP address to Google. The site's fonts, on the other hand, are hosted on our own server and are not requested from Google.
- Authorities and public bodies, where required by law.
Data is neither sold nor disclosed to the public.
6. Transfers outside the European Union
Some suppliers (for example Google, Meta/WhatsApp, PayPal, Kinsta) may also process data in the United States or other non-EU countries. In these cases the transfer is based on the EU-U.S. adequacy decision (EU-U.S. Data Privacy Framework) for participating companies, or on the Standard Contractual Clauses approved by the European Commission (Art. 46 GDPR). [TO BE CHECKED: final list of suppliers and safeguards.]
7. Your rights
At any time you can ask to:
- access your data and receive a copy of it (Art. 15);
- correct or complete it (Art. 16);
- delete it (Art. 17), except for data we must keep by law;
- restrict processing (Art. 18);
- receive the data in a readable format and transfer it to others (portability, Art. 20);
- object to processing based on legitimate interest and, in any case, to the sending of commercial communications (Art. 21);
- withdraw your consent, without affecting processing already carried out (Art. 7).
Simply write to info@track4fun.com. We reply within one month, a period that can be extended by a further two months in more complex cases (Art. 12).
If you believe that the processing violates the regulations, you may lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) (Italian Data Protection Authority, www.garanteprivacy.it), Piazza Venezia 11, 00187 Rome.
8. Minors
On-track services are reserved for adults with a valid driving licence (T4F Experience: over 21). Passengers must also be at least 18. We do not knowingly collect data from minors through the website.
9. Data of other people
If you buy a gift voucher or a sign-up for someone else, or tell us about passengers or additional drivers, you are giving us third-party data. Please inform them and only do so if you are entitled to. We will process this data only to provide the service purchased.
10. Security
The website uses an encrypted connection (HTTPS). Access to data is limited to authorised staff and the suppliers listed. Orders and documents are visible only to the account holder.
11. Cookies
For cookies, see the Cookie Policy.
12. Changes
This notice may be updated. The version in force is always the one published on this page, with the date of the last update.
Last updated: [TO BE CHECKED: publication date]