Last release: 14/09/2022

This information is drawn up according to EU Rule 2016/679 (GDPR) and are valid just for the Website (hereinafter called “Site”) owned by Giuseppe Bodrone (hereinafter called “DPO” or “Photographer”) and not for other websites possibly visited by the User through links.

  1. Data Processor Officer (DPO)

Giuseppe Bodrone, Site owner

Postal address: via Nichelino, 14 – 10135 Torino, Italia

Fiscal code: BDRGPP57S01L219B

E-mail address:

Mobile: +39 349 5865050

  1. Purpose of the Site

The Site collects photographic images taken by the Photographer to portraying subjects (mainly ice skaters) on the occasion of public events (competitions, exhibitions, etc.) both national and international, also for commercial purposes.

The Site essentially offers two Services: vision of the photographic images published on the Site and purchase of the images using the purchasing procedure that is integral part of the Site.

  1. Types of collected Data

The types of Personal Data collected in the Site are:

  1. name, surname, postal address, e-mail address, phone number of the Users (Personal Data)
  2. photographic images of the subjects portrayed by the Photographer
  3. browsing data (Usage Data)

Type a) Data can be voluntarily provided by the interested Users by filling the Site forms in order to exchange information with the Photographer and/or to purchase photographic images published on the Site. Such Data are necessary to benefit of the Services offered by the Site, therefore the User may be unable to take advantage of such Services if he refrained from providing them. In the case that the Site indicates some Data as optional, the Users are free to refrain from providing such Data, without this having any consequence on the supply of Services. The Site uses the Stripe platform for Users’ payment by credit/debit card. The Personal Data related with the payment of the Users (credit/debit card numbers) are never collected by the Site, rather directly by Stripe, that is liable of their confidentiality. For details please refer to Stripe Privacy Policy.

Type b) Data, the photographic images collected on the Site, are shots taken by the Photographer in the context of the accreditation as a photographer granted from time to time by the Organizers of the events. The accreditation indemnifies the Photographer from any liability about shooting the subjects, for which please refer to the Regulations of each event. The images taken from the Photographer are processed in the manner described in Par. 6 in order to protect the subjects’ privacy.

Type c) Data are automatically collected while browsing the Site. The computer systems and software procedures used to operate the Site acquire some Personal Data, whose transmission is implicit in the use of the Internet communication. This information could allow Users to be identified through processing and association with other data held by third parties. This category of data includes the IP addresses or domain names of the computers used by the Users who connect to the Site, the URI (Uniform Resource Identifier) ​​addresses 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 (successful, error, etc.) and other parameters relating to the operating system and the User’s IT environment. These data are used for the sole purpose of checking the correct functioning of the Site and are deleted immediately after processing, except in case of any computer crimes against the Site in order to ascertain responsibility.

  1. Methods and purpose of processing the Data provided by the User

Depending on what is required by the specific activity, the Data processing can be carried out manually or through IT or telematic tools, with organizational methods or logics strictly connected with the following purposes:

  • Usability of the Site while browsing
  • Purchasing of photographic images from the Site
  • Payment management from the Site
  • Sending communications to the Users through e-mail or other IT communication tools
  • Management and archiving of the Users’ contacts
  • Statistical processing of the Users’ contacts
  • Interaction with Users’ social profiles.

For further information about the Data processing purpose, the User can directly contact the DPO.

In addition to the DPO, in some cases other parties involved in the Site organization may have access to the Data (i.e. Administrators of System), or external parties providing technical service (hosting provider, IT companies, communication agencies) nominated Processing Responsible by the Controller. The Controller adopts the appropriate security measures in order to prevent the access, if not authorized, the disclosure, the modification or the \destruction of the Data collected by the Site. The Data are in no case transferred/disclosed/disseminated/sold to third parties.

  1. Details about the processing of Personal Data provided by Users

This paragraph provides further details about the processing of personal Data provided by the Users and used for the following specific purposes:

  • To contact the User

By filling the contact form (contained in the section CONTACTS of the Site) with his Personal Data, the User agrees to their use in order to reply to the information or quotation requests or any other request connected to the Site purpose.

Personal Data collected: name, surname, e-mail address.

  • Mailing or Newsletter

The e-mail addresses provided by the Users are included in a contact list.  E-mail messages relating to the Photographer’s activity, included promotional information, may be transmitted to the e-mail addresses of this list. The Users’ e-mail addresses collected through the purchasing procedure may be added to this list. In case of disagreement, the User has the right to ask for the cancellation of his contact from the aforementioned list.

Personal Data collected: name, surname, postal address, e-mail address.

  • Phone contacts

The phone numbers provided by the Users can be used by the Photographer to contact the Users  for purposes connected with the Site, or to reply to support requests.

Personal Data collected:  telephone number.

  • Payment management (PayPal)

Stripe is a payment service supplied by Stripe Inc., that allows the User to make online payments by credit/debit cards. The Site uses the Stripe platform to process Users’ payments through their credit/debit cards. Payment Data (credit/debit card numbers) are acquired solely by the payment service provider (Stripe) and they are not processed in any way by the Site. For the details about Stripe Data processing please refer to Stripe privacy policy ( The online purchasing service of the Site provides for the automatic sending of e-mail messages to the Users, such as purchase and payment notifications.

Personal Data collected: name, surname, postal address, e-mail address, phone number of the Users.

  1. Processing of photographic images

The photographic images are considered as Personal Data to be processed respecting the portrayed subjects’ privacy. For this purpose the pictures taken by the Photographer during an event are divided into two categories: “Previews Photos” and “Photos”.

At the end of each event day, the Photographer selects one image for each athlete/team among all the pictures taken during the event. These images constitute the “Previews Photos” category, that means demonstration pictures. The Previews Photos are published in specific non protected photo galleries (each event has its own gallery identifiable by means of a playbill) of the section EVENTS of the Site. The purpose of the Previews Photos is to allow the Photographer to identify the athlete/teams by means of their Preview Photo number.

All the images taken by the Photographer during an event constitute the “Photos” category. The Photos of a specific athlete/team are published on the Site only upon request of the Users interested in viewing or purchasing other images in addition to the Preview Photos already published in the EVENTS section. Through their requests these Users express their consent to the publication of the Photos on the Site. They must provide the Photographer with the Preview Photo number or its screenshot for identification purpose. The Photographer will publish all the athlete’s/team’s Photos in one specific folder of the ATHLETS / TEAMS sections protected by personal Password. The Photographer will provide Users with their Password to let them view the content of their personal folder and purchase what they want by using the purchasing procedure of the Site.

If videos have been made, also a Video Preview (10-15 s) will be included in the protected folder. The purchasing procedure of Videos is the same as per Photos.

Considering that:

  1. a) the events in which the Photographer takes photos are public events,
  2. b) it is objectively impossible to request and to obtain the prior consent for the publication of the Previews from all the portrayed subjects (or to their relatives, in the case of minors),
  3. c) only one Preview Photo per athlete/team is published just for identification purposes,

it is assumed that, in the absence of contrary communication from the interested parties, the tacit consent to the publication of the Preview Photos exists. If the consent is expressly denied by written or verbal request, the relevant Preview Photos will be immediately removed from the Site. The Photographer’s contacts are indicated in Par. 1.

If the portrayed subjects are minors, the images can be purchased only and exclusively by their parents or by persons acting as parents. Under their own responsibility, the parents must qualify as such when passing their request to the Photographer, thus freeing him from all responsibilities.

  1. User’s Rights

Users can exercise certain rights with reference to the Data processed by the Owner.

In particular, the User has the right to:

  • Withdraw consent at any time. The User can revoke the consent to the processing of his Personal Data previously expressed.
  • Oppose the processing of their data. The User can oppose the processing of their data when it occurs on a legal basis other than consent.
  • Access their data. The user has the right to obtain information on the data processed by the owner, on certain aspects of the processing and to receive a copy of the data processed.
  • Verify and ask for rectification. The User can verify whether Data are correct and request its updating or correction.
  • Obtain the treatment limitation. When certain conditions are verified, the User may request the limitation of the processing of their Data. In this case the Data Controller will not process the Data for any other purpose than their conservation.
  • Obtain the cancellation or removal of their Personal Data. When certain conditions are verified, the User can request the cancellation of their Data by the Owner.
  • Receive their data or have it transferred to another owner. The User has the right to receive his / her data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain the transfer without obstacles to another owner.
  • Propose a complaint. The User can lodge a complaint with the competent Personal Data Protection Authority or act in court.
  1. Details on the right to object

If the Users’ data are processed for direct marketing purposes, they can deny the consent to processing without giving any reasons. To exercise their rights, Users can contact the Owner using the contact details indicated Par. 1. Requests are processed by the Data Controller as soon as possible, in any case within one month of receipt of the request.

  1. Further processing information
  • Defense in court

The User’s Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this Site or related Services by the User. The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.

  • System logs and maintenance

For needs related to operation and maintenance, this Site and any third party services used by it may collect system logs, i.e. files that record the interactions and which may also contain Personal Data, such as the User IP address.

  • Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

  • Changes to this Privacy Policy

The Data processor Officer reserves the right to make changes to this Privacy Policy at any time by informing Users on this page. Please consult this page regularly, referring to the date of the last modification indicated at the top of this document. If the changes concern treatments whose legal basis is consent, the DPO will collect the User’s consent again, if necessary.

  1. Cookies Policy

This e-commerce uses cookies. To learn more and to read the detailed information, the User can consult the Cookie Policy of the Site.

  1. Legend and legal references

Personal Data (or Data)

Any information that, directly or indirectly, makes a natural person identified or identifiable, also in connection with any other information, constitutes Personal Data.

Usage Data

This is the information collected automatically through this Site (also from third-party applications integrated in this Site), including: the IP addresses or domain names of the computers used by the User who connects with this Site, the addresses in URI (Uniform Resource Identifier) ​​notation, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details of the itinerary followed within the Site, with particular reference to the sequence of the pages consulted, to the parameters relating to the operating system and the IT environment of the User.

(Interested) User

The User is the person who uses this Site. The User who provides their Personal Data to use the services offered by the Site is an Interested User.

Responsible about the Processing

The natural person appointed by the DPO who has the right to process the Data on behalf of the DPO itself.

Data processor Officer (or “DPO”)

The natural person who determines the purposes, means of data processing and the adopted tools, including the security measures relating to the Site operation and use. The DPO is the owner of the Site, unless otherwise specified.


These are the Services offered by the Site to Users, essentially the possibility of viewing and purchasing the photographic images published on the Site.


The website:, which is owned by the Photographer.


Small portion of Data stored in the User’s device. Their use is regulated by the Cookies Policy of the Site.

  1. Law references

References to European legislation or the EU Regulation no. 2016/679 (DGPR) are available here: