Privacy Policy

Dear User,
This page describes how the website of the San Marino Football Federation (hereinafter “FSGC” or simply “the Federation”) is managed with regard to the processing of your personal data.
Pursuant to Articles 13 and 14 of European Regulation No. 679/2016 (hereinafter referred to simply as the GDPR) and Articles 13 and 14 of San Marino Law No. 171/2018 (hereinafter referred to simply as the RSM Law) on the protection of personal data, we hereby provide the information set out below in order to supply accurate and transparent details regarding the data collected by our website and the manner in which it is used.
This policy is also based on Recommendation No. 2/2001, which the European data protection authorities, meeting within the Working Party established by Article 29 of Directive No. 95/46/EC, adopted on 17 May 2001 to identify certain minimum requirements for the online collection of personal data and, in particular, the methods, timing and nature of the information that data controllers must provide to users when they connect to web pages, regardless of the purpose of the connection.

1. Data collection

The personal data being processed is freely provided by you and collected by us whilst you browse our website: www.fsgc.sm as well as through interaction with our web services, namely:

  • By completing our contact form;
  • By registering in the “Cheer for Titan” section, through which you can join our community;
  • By subscribing to the free newsletter service we provide;
  • By completing the “Accreditation Procedures” section dedicated to media professionals;
  • By applying for a job with us via the “Work with us” section of the website;
  • By completing the reporting form in the “Safeguarding” section;
  • Finally, by taking part in the “Rate goal and save” initiative.

2. Data subject to processing

The processing will concern the following information:
a) Browsing data:
When you visit our website, we send cookies, or technologies with similar functionality, to your devices, which enable us to track your behaviour. These cookies transmit data to our analytics tools. We are therefore able to track which marketing channel generated your visit (e.g. Google AdWords, email, newsletter) and which pages you have visited, as well as other similar information. We also receive information on how you use the website and interact with it, as well as the time spent on the site. Our website server also collects basic information regarding the search carried out on your browser when you visit the site. This data may include information on the date and time of your last visit, the date and time of the browser search, your IP address, basic HTTP header information (such as URL references and user agent), and the previous URLs searched by your browser.
On this website, you can also select certain features that process your personal data by sharing it with other entities or websites (such as Facebook, X, Instagram, YouTube and Flickr). These features transmit data to third parties, who may use your personal information in accordance with their own privacy policies. These features are operated by third parties with whom we have no affiliation; we strongly recommend that you review their privacy policies.
The use of cookies and other digital tools with similar functionality is described in more detail in our cookie policy, which can be viewed online in the relevant section.
b) General data (personal details, contact details, etc.) and specific data:

  • When you freely choose to join the “Cheer for Titan” community and/or subscribe to the free newsletter service we provide, we will collect your personal details, contact information, etc., and we will keep a record of the communications we have sent you.
  • When you wish to request any information via the “Contact Us” section of the website, we will collect your personal details, your email address, your telephone number or any other information you provide, in order to process your requests.
  • When you wish to register, using the section dedicated to media representatives, “Accreditation Procedure”, UEFA or FIFA, we will collect a range of data (such as: your personal details, your email address, a photo and an identity document) necessary for proper identification.
  • When you wish to submit a report via the “Safeguarding” section of the website, we will collect your contact details (email address, telephone number) where you freely choose to provide them, thereby waiving your right to anonymity, as these are optional details in addition to any specific information contained in the report.
  • When you voluntarily choose to take part in the “Rate goal and save” initiative via the dedicated form, we will collect your email address.
  • When you eventually apply for a position with us via the “Work with us” section, we will collect your personal details, contact information and any other data (general and specific) provided in your CV in order to process your application.

When you enter third-party data, you assume responsibility for any personal data (belonging to third parties) obtained, published or shared via this website, and you warrant that you have the right to communicate or disseminate such data, thereby releasing the Data Controller from any liability towards third parties.

3. Methods of processing

Processing will be carried out, including but not limited to the use of IT and/or automated means, in a manner suitable to ensure the security, protection and confidentiality of the data, to prevent and limit the risk of loss, deterioration or theft of the data, and to ensure its restoration within a reasonable timeframe in the event of a ‘data breach’.
The processing will involve the following operations: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, alignment or combination, restriction, erasure and destruction of data.

4. Purposes of processing

Your personal data will be processed for the following purposes:

  • a) To enable the technical and operational management of our website (including the maintenance of IT security), for example, by identifying parts of the website that have low latency;
  • b) For purposes related to our services, namely, to process requests submitted via the “Contact Us” section, to grant you the accreditation requested via the “Accreditation Procedures” section, to allow you to take part in the “Rate goal and save”, to join our community, and to contact you to arrange an interview if you apply via the “Work with us” section;
  • c) To manage reports made in accordance with Safeguarding regulations;
  • d) To send you newsletters and communications containing promotional and informational/advertising content regarding our products and services (official merchandise, tickets, etc.) as well as events and initiatives organised by us, provided you have given your consent;
  • e) For profiling purposes, i.e. to create profiles (individual and/or aggregated) based on your profile, preferences and consumption choices, to carry out market analysis and statistics, and to send personalised communications, provided you have given your consent;
  • f) For so-called soft-spamming purposes: if you have already purchased a product and/or used one of our services, FSGC may use the email address provided to send you communications relating to the direct sale of products or services similar to those already purchased, without the need for your consent, provided that you do not exercise your right to object.

5. Legal basis for processing

The processing of your personal data will be carried out on the following legal basis:

  • a) on the pursuit of the Data Controller’s legitimate interests for the purposes referred to in points (a) and (f);
  • b) on the consent you have freely and lawfully given (in the case of marketing and profiling via newsletters) for the purposes referred to in points (d) and (e);
  • c) as necessary for pre-contractual obligations (such as the handling of requests for information) for the purposes referred to in point b);
  • d) as necessary to comply with a legal obligation for the purpose referred to in point c). In more detail:

6. Mandatory or optional nature of data processing

The provision of your data for the purposes detailed in point 4 above, “Purposes of processing”, sub-points (a) and (b), is mandatory; therefore, any refusal on your part will make it impossible for us to process the requests you intend to make. The provision of data for the purposes referred to in points c), d) and e) above is, however, optional; you may therefore choose not to provide any data without affecting your relationship with our federation.

7. Recipients of personal data

The personal data collected will be processed within the federation by our strictly authorised and appropriately trained employees/staff (pursuant to Article 29 of the GDPR and Article 30 of the RSM Law) as part of their duties.
Outside FSGC, the data may be disclosed to and processed by those natural and/or legal persons engaged, on behalf of the federation, in activities necessary and/or instrumental to ensuring its operations, in their capacity as Data Processors. The aforementioned operators will be provided exclusively with the information necessary for the provision of the commissioned services and will be required to maintain confidentiality, with the use of the data provided for any purpose other than that agreed being prohibited. The updated list of Data Processors is kept at our headquarters and is available for inspection upon request.
Your data will not be disclosed but may be communicated to supervisory bodies responsible for verifying and monitoring compliance with legal obligations, as well as to other entities acting as independent Data Controllers (for example, the first name, surname and publication of media representatives may be communicated to UEFA for the management of activities related to the accreditation procedure).

8. Transfer of data to a third country

For purposes strictly related to the fulfilment of the objectives specified above (management of the accreditation procedure), some of your personal data may be transferred to countries and organisations outside the EU (UEFA, based in Switzerland). In such cases, the Data Controller ensures that the transfer will take place in accordance with Articles 44 et seq. of the GDPR and Articles 45 et seq. of the RSM Law. In this regard, it should be noted that on 15 January 2024, the European Commission reconfirmed that the Swiss Data Protection Act (nLPD) is adequate under the GDPR.

9. Data retention period

The browsing data collected is used solely for the purpose of deriving anonymous statistical information on the use of the websites, as well as to check that they are functioning correctly, and is deleted following processing. Other personal data will be processed for the time strictly necessary to manage the requested service.
In the event of your express and specific consent, in relation to the operations referred to in Article 4(d) and (e), the data will be processed until such consent is subsequently withdrawn and, in any event, for no longer than a period deemed appropriate, namely 3 years, in light of the nature and type of service provided.

10. Diritti dell'interessato

La informiamo che, in qualsiasi momento, ai sensi degli artt. 15-22 del GDPR e della Legge RSM potrà esercitare i seguenti diritti:

  • 1) Obtain confirmation as to whether or not personal data concerning you are being processed and, where that is the case, obtain access to the data and all information relating to the processing itself (right of access pursuant to Article 15 of the GDPR and the RSM Law);
  • 2) Obtain the rectification of inaccurate personal data without undue delay and the completion of incomplete data, including by means of a supplementary declaration (right to rectification pursuant to Article 16 of the GDPR and the RSM Law);
  • 3) Obtain the erasure of your personal data without undue delay if: the data is no longer necessary in relation to the purposes for which it was collected or processed; it has been unlawfully processed; it must be erased to comply with a legal obligation; You have withdrawn your consent or object to the processing (right to be forgotten pursuant to Article 17 of the GDPR and the RSM Law);
  • 4) Obtain restriction of processing when one of the following applies: if you contest the accuracy of the personal data, for a period enabling the data controller to verify such accuracy; if the processing is unlawful and you oppose the erasure of the data and request the restriction of their use instead; although the data controller no longer needs the personal data for the purposes of the processing, you require the personal data to establish or exercise a legal claim; if you have objected to the processing, pending the verification whether the legitimate grounds of the Data Controller override yours (right to restriction of processing pursuant to Art. 18 GDPR and RSM Law);
  • 5) To receive your personal data in a structured, commonly used, and machine-readable format and to transmit those data to another Data Controller without hindrance from the Data Controller to whom the personal data were provided (right to data portability pursuant to Art. 20 GDPR and RSM Law);
  • 6) To object, in whole or in part, to the processing. If your personal data are processed for direct marketing purposes, you have the right to object at any time to the processing, including profiling to the extent that it is related to such direct marketing. If personal data is processed for scientific or historical research purposes or statistical purposes, for reasons related to your particular situation, you have the right to object to the processing, unless the processing is necessary for the performance of a task carried out in the public interest (right to object pursuant to Art. 21 GDPR and RSM Law);
  • 7) To withdraw your consent at any time;
  • 8) To lodge a complaint with the Italian Data Protection Authority.

11. Data Controller and its Representative in the European Union

To exercise the rights described above, you may contact the Data Controller, the Sammarinese Football Federation, at any time by sending an email to [email protected] or by registered mail to Strada di Montecchio, 17, 47890 San Marino (RSM). You may also contact its representative in the European Union, Dr. Nathaniel Casadei (tax code CSDNHN82S13H294O), who can be contacted at [email protected] or by registered mail to Via Pomposa n. 43/I, 47924 Rimini (RN).

12. Data Protection Officer (DPO)

Our Data Protection Officer is Valentina Rabitti, Attorney at Law, who can be contacted by email at [email protected] or by registered mail at Via Pomposa No. 43/I, 47924 Rimini (RN).

13. Changes

In compliance with applicable legislation, the Data Controller reserves the right to make changes to this policy at any time, providing appropriate notice and ensuring adequate and comparable protection of personal data. To review any changes, users are encouraged to regularly consult this policy, which always indicates the date it was last updated.

Rev. 03 of 03/11/2025

Data Controller
Sammarinese Football Federation


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