PRIVACY POLICY
Last updated: 13 July 2026
1. DATA CONTROLLER
Data Controller: KLASSMARK NO NATURE NO FUTURE, S.L.
Project and brand: GRAVEL EARTH SERIES
Spanish Tax Identification Number (NIF): B75391060
Registered office: C. Can Pau Birol, 35, 17005 Girona, Spain
General and privacy contact: info@gravelearthseries.com
Alternative corporate contact: info@klassmark.com
Commercial Registry: Girona Commercial Registry, Sheet GI-75679, Entry 1
Website: gravelearthseries.com
KLASSMARK NO NATURE NO FUTURE, S.L. may hereinafter be referred to as “Klassmark”, “Gravel Earth Series”, “GES”, “the Data Controller” or “the Entity”.
2. SCOPE AND ROLE OF EVENT ORGANISERS
This Privacy Policy applies to personal data processed by GES through:
a) The Gravel Earth Series website.
b) Contact and newsletter forms.
c) Official series rankings and historical results.
d) Sporting administration, enquiries, complaints and ranking corrections.
e) Prize administration, where applicable.
f) Press, media, audiovisual and accreditation activities.
g) Social media and series-related communications.
h) Relationships with event organisers, sponsors, partners and professional contacts.
Individual events may have their own organiser, registration platform and privacy policy.
Where an independent event organiser manages registration, payment, safety, timing, medical assistance or other event operations, that organiser will normally act as an independent data controller.
GES will act as data controller for the processing activities whose purposes and means it determines, including the management and publication of the Gravel Earth Series rankings.
Where GES and another organisation jointly determine a processing activity, the relevant individuals will be informed of the respective responsibilities.
3. PERSONAL DATA WE MAY PROCESS
Depending on the user’s relationship with GES, we may process:
3.1 Identification and contact data
Name, surname, email address, telephone number, nationality, country of residence and preferred language.
3.2 Sporting and ranking data
Event, race distance, category, age group, gender classification, team or club, race number, official time, split times, finishing status, position, points, penalties and ranking history.
3.3 Eligibility and verification data
Information necessary to resolve duplicate identities, verify a category, confirm eligibility for a ranking or prize, or deal with a sporting complaint.
As a general rule, GES will not retain copies of identity documents unless this is necessary, proportionate and legally justified.
3.4 Prize and financial data
Bank details, tax information, payment records and supporting documentation where a rider is entitled to prize money or another financial benefit.
GES does not receive complete payment-card details when payments are processed by an independent payment provider.
3.5 Image and voice data
Photographs, videos, interviews, recordings, live broadcasts and appearances in editorial, documentary, press or promotional content.
3.6 Press and professional data
Media outlet, professional role, accreditation information, contact details and content requests.
3.7 Technical data
IP address, device and browser information, access logs, online identifiers, security records and information generated through cookies or similar technologies.
3.8 Marketing data
Newsletter subscription, consent record, language preference, communication history, email interactions and unsubscribe requests.
3.9 Voluntarily submitted information
Information included in messages, applications, stories, comments, complaints or free-text fields.
GES applies the principle of data minimisation and will only process information that is adequate, relevant and necessary.
4. PURPOSES AND LEGAL BASES
4.1 Website operation and security
GES processes technical data to operate the website, prevent fraud and unauthorised access, detect errors, manage logs and respond to security incidents.
The legal basis is GES’s legitimate interest in maintaining a secure and operational website under Article 6(1)(f) GDPR.
Non-essential cookies are used only with consent.
4.2 Enquiries and communications
Data is processed to respond to questions, complaints, media requests and requests for information about the series.
The legal basis is the implementation of pre-contractual measures requested by the individual under Article 6(1)(b) GDPR or GES’s legitimate interest in managing communications under Article 6(1)(f).
4.3 Newsletter and marketing communications
GES may send information about the series, future seasons, rankings, news, media content and related activities.
The legal basis is consent under Article 6(1)(a) GDPR and applicable electronic communications legislation.
Consent may be withdrawn at any time through the unsubscribe link in each message or by contacting GES.
Unsubscribing from marketing does not prevent GES from sending a necessary response to an enquiry or a communication connected with an existing sporting or contractual matter.
4.4 Rankings, results and sporting history
GES may receive official results from event organisers, timing companies or results platforms in order to:
a) Identify riders across different events.
b) Calculate points under the published sporting regulations.
c) Create and publish provisional and final rankings.
d) Manage categories and age groups.
e) Correct errors and resolve ranking complaints.
f) Maintain a historical sporting record.
The legal basis is the application of the sporting rules and, where applicable, the performance of a contractual relationship under Article 6(1)(b) GDPR, together with GES’s legitimate interest and the legitimate interest of riders and the sporting community in maintaining transparent and verifiable competition records under Article 6(1)(f).
Public rankings may include:
- Name and surname.
- Nationality.
- Team or club.
- Race category or age group.
- Participating events.
- Official results and times.
- Points and ranking position.
- Finishing, withdrawal or disqualification status.
GES will not publish contact information, bank details, complete identity-document numbers, complete dates of birth or medical information.
Individuals may request the correction of inaccurate information and may object to processing based on legitimate interest for reasons related to their particular situation. GES will assess each request against the integrity and legitimate historical value of the sporting record.
4.5 Para-cyclist classification and sensitive information
Where a rider voluntarily requests inclusion in a para-cyclist classification, the information may reveal disability or health-related circumstances and may therefore constitute special-category personal data.
GES will process only the minimum information necessary and will normally rely on the rider’s explicit consent under Article 9(2)(a) GDPR, unless another specific legal basis applies.
The inclusion of this classification in a public ranking must be clearly explained in advance and separately authorised where required.
4.6 Sporting eligibility, complaints and prizes
GES may process information to verify eligibility, apply the sporting regulations, manage corrections, investigate alleged breaches and determine entitlement to prizes.
The legal basis is performance of the applicable sporting or contractual relationship, compliance with legal obligations and GES’s legitimate interest in ensuring fair and consistent competition.
Where prize money is paid, data may also be processed to comply with accounting, tax and anti-fraud obligations.
4.7 Photography, video and editorial coverage
GES may process photographs, videos, audio and interviews to:
a) Report on and document the series.
b) Publish news, race reports and sporting results.
c) Produce editorial, press and documentary content.
d) Maintain the historical archive of the series.
e) Communicate the identity and values of Gravel Earth Series.
For general, panoramic, environmental or incidental images connected with the reporting of a sporting event, the legal basis may be GES’s legitimate interest, subject to an appropriate balancing assessment and applicable image-rights legislation.
Close-up portraits, individual testimonials or images primarily used for unrelated advertising, sponsor campaigns or personalised commercial promotion will require a separate legal basis, normally specific consent or an appropriate contractual authorisation.
Where content is supplied by an event organiser, photographer or production company, that party must ensure that the necessary rights and data-protection information have been provided.
4.8 Press and media management
GES may process journalist and media contact details to manage accreditation, respond to requests, provide press materials and control authorised access to media resources.
The legal basis is pre-contractual measures, performance of accreditation conditions and GES’s legitimate interest in managing press relations.
4.9 Sponsors and partners
The presence of a sponsor on the website or at an event does not mean that the sponsor receives participants’ contact information.
GES will only share personal data with a sponsor for the sponsor’s own marketing where:
a) The sponsor has been clearly identified.
b) The purpose and data involved have been explained.
c) The individual has provided separate, specific and freely given consent.
d) Refusing consent does not prevent participation in the series or an event.
4.10 Business and event-organiser relationships
GES may process the professional contact details of event organisers, suppliers, sponsors, partners and other business contacts to manage the series and its contractual relationships.
The legal basis is performance of a contract, pre-contractual measures or GES’s legitimate interest in maintaining professional relationships.
4.11 Legal compliance and claims
GES may process and retain information to comply with legal obligations, respond to authorities, prevent or investigate breaches and establish, exercise or defend legal claims.
The legal basis is compliance with legal obligations and GES’s legitimate interest in protecting its rights and responsibilities.
5. SOURCES OF PERSONAL DATA
Personal data may be obtained:
a) Directly from the individual.
b) From a legal representative.
c) From an event organiser.
d) From a timing, registration or results provider.
e) From official public results.
f) From a team, club or authorised representative.
g) Through interaction with GES social media profiles.
h) From a photographer, journalist, media outlet or audiovisual producer.
Event organisers that send official results to GES must ensure that participants have been informed of that communication.
6. RECIPIENTS
Personal data may be disclosed or made accessible, where necessary, to:
a) Website hosting, maintenance, security, email and cloud-storage providers.
b) Newsletter and communication providers.
c) Ranking, timing and results technology providers.
d) Event organisers participating in the series.
e) Banks, accounting providers and tax advisers for prize administration.
f) Photographers, audiovisual producers, press agencies and media-service providers.
g) Legal, tax, technical and professional advisers.
h) Public authorities, courts, sporting bodies or law-enforcement authorities where legally required.
i) Identified sponsors where separate consent has been obtained.
j) Internet users, search engines and media outlets in relation to legitimately published rankings, news, photographs and videos.
Providers acting on behalf of GES must process data under appropriate data-processing agreements and documented instructions.
7. EXTERNAL PLATFORMS
The website may link to or use external platforms for rankings, results, video content, social media, cloud storage, event registration, press materials and newsletters.
A simple external link does not mean that GES controls the provider’s processing.
Where a provider processes personal data on behalf of GES, an appropriate contractual arrangement will be put in place.
Where the provider or event organiser determines its own purposes and means, it will act as an independent data controller.
8. INTERNATIONAL DATA TRANSFERS
GES is an international series and may work with event organisers and technology providers located outside the European Economic Area.
Where GES transfers personal data to a third country, it will apply an appropriate mechanism under the GDPR, such as:
a) A European Commission adequacy decision.
b) A recognised adequacy framework.
c) Standard Contractual Clauses.
d) Binding Corporate Rules.
e) Another legally recognised safeguard or derogation.
Where necessary, GES will assess the risks of the transfer and implement supplementary measures.
Information about the safeguards applicable to a particular transfer may be requested by email.
9. RETENTION PERIODS
Personal data will be retained according to the following criteria:
Enquiries: for the time necessary to respond and generally for up to one year after the last communication, unless a contractual matter or claim arises.
Newsletter: until consent is withdrawn or the individual unsubscribes. Minimum information may be retained to demonstrate consent and respect the opt-out request.
Rankings and sporting results: while there is a legitimate sporting, informational or historical interest, subject to periodic review of necessity, proportionality and search-engine indexing.
Ranking complaints and disciplinary matters: for the period necessary to resolve the matter and subsequently during the applicable limitation periods.
Prize and accounting records: for the periods required by tax, accounting and commercial legislation.
Press and accreditation data: for the duration of the professional relationship and any subsequent period necessary to document authorisations or resolve claims.
Photographs and videos: while they retain their editorial, documentary or historical purpose, subject to applicable rights and periodic review.
Commercial content based on consent: for the period communicated or until consent is withdrawn, without affecting prior lawful use.
Technical and security records: for no longer than necessary to protect the website and investigate incidents.
After the applicable periods expire, data will be securely deleted, anonymised or blocked where required by law.
10. MINORS
Where an individual event allows participation by minors, registration and consent requirements will be governed primarily by the relevant event organiser’s conditions.
GES will apply enhanced safeguards to minors’ ranking data, images and other personal information.
GES will not publish a minor’s complete date of birth, contact details, unnecessary location information or other excessive data.
Where Spanish law applies and processing is based on consent, consent for a person under 14 must be given or authorised by the person exercising parental responsibility or guardianship.
Commercial or individually focused use of a minor’s image requires separate authorisation from the legal representative where applicable.
11. AUTOMATED RANKING CALCULATIONS
Points and rankings may be calculated automatically using the formulas established in the published sporting regulations.
Riders may request correction or human review where they believe that:
a) An official result is incorrect.
b) Results from different individuals have been combined.
c) An event or score has been omitted.
d) A category has been incorrectly applied.
e) An automated calculation has affected prize eligibility or another significant sporting outcome.
Final decisions concerning disputed results, sanctions or prize eligibility will include appropriate human review where required.
12. DATA-PROTECTION RIGHTS
Individuals may exercise the following rights:
a) Access: to know whether GES processes their personal data and obtain a copy.
b) Rectification: to correct inaccurate or incomplete information.
c) Erasure: to request deletion where the legal requirements are met.
d) Restriction: to request limited processing in legally established cases.
e) Objection: to object to processing based on legitimate interest for reasons related to their particular situation and at any time to direct marketing.
f) Portability: to receive data provided to GES in a structured, commonly used and machine-readable format where applicable.
g) Withdrawal of consent: to withdraw previously granted consent at any time, without affecting prior lawful processing.
h) Human intervention: where applicable, in relation to decisions based solely on automated processing.
Requests may be sent to:
Subject: “Data Protection – Exercise of Rights”
The request should identify the person, the right being exercised and, where relevant, the event, season or ranking concerned.
A copy of an identity document will not normally be required. Additional information will only be requested where there are reasonable doubts about identity or representation.
13. COMPLAINTS
Individuals who believe that their personal data has not been processed correctly may first contact GES.
They also have the right to lodge a complaint with the Spanish Data Protection Agency or another competent supervisory authority.
14. SECURITY AND CONFIDENTIALITY
GES implements technical and organisational measures appropriate to the nature, scope and risks of the processing.
These measures may include access controls, secure transmission, backups, confidentiality obligations, incident-management procedures, provider supervision and enhanced controls for sensitive data.
Staff, contractors and collaborators with access to personal data are subject to confidentiality obligations.
15. CHANGES TO THIS PRIVACY POLICY
GES may update this Privacy Policy to reflect legal, technical, organisational or operational changes.
The current version will remain permanently available on the website.
Where a change materially affects a processing activity or previously granted consent, GES will provide appropriate notice and request new consent where required.