Introductory information
Livesport s.r.o. ("we", "our" or "us") respects the privacy of its users ("you" or "your"). This information about the processing of personal data ("Information") explains how we collect, use, disclose and protect your personal data in connection with our Mobile Application in any language version or location ("Mobile Application"). We process your personal data in connection with your registration, use of the Mobile Application (Art. 2) and in connection with direct marketing (Art. 3). If you have given your consent in the context of the Mobile Application, the information concerning the processing of data for the purpose of direct marketing with your consent (Art. 4) and the processing of data in connection with the analytics of the use of the Mobile Application (Art. 5) also applies to you.
Our identity and contact details
We, as the controller of your personal data, are Livesport s.r.o., with its registered office at Bucharova 2928/14a, Stodůlky, 158 00 Prague 5, Aspira Business Centre, ID 274 33 722, registered in the Commercial Register maintained by the Municipal Court in Prague, file no. C113331, Czech Republic.
Our contact details are as follows: postal address Livesport s.r.o., Bucharova 2928/14a, Stodůlky, 158 00 Prague 5, Aspira Business Centre, Czech Republic, email address privacy@livesport.eu.
We have appointed a data protection officer who can be contacted on all matters relating to the processing of your personal data and the exercise of your rights via the email dpo@livesport.eu.
PROCESSING IN CONNECTION WITH THE USE OF THE MOBILE APPLICATION AND YOUR REGISTRATION
Specification of processing when using the Mobile Application. If you use the Mobile Application, we process for the B and C purposes set out below records related to your use of the Mobile Application (IP address, Geo IP, data about the operating system and hardware of your device, user settings of the Mobile Application) which are obtained automatically when you use the Mobile Application and information about your age if you have provided us with such information.
Registration and login processing specifications. If you create an account when using the Mobile Application or log into the Mobile Application using a previously created account from our other platforms or products, we will further process your personal data when you use the Mobile Application for the purposes A, B and C below, such as:
the contact details, including email, that you provided to us when you created your account;
your age information, if required for registration or upon login;
data related to the use of the Mobile Application features (e.g. votes in polls or favorite teams);
a pseudonymized identifier for monitoring the operation of Mobile Application and reporting technical faults (Crashlytics ID), other pseudonymized identifiers that we have put in place to protect you, and if you have chosen to register or log in to the Mobile Application through your existing account with a third party (e.g. Facebook, Gmail, Apple), we also process your name, photograph and a third party generated pseudonymized identifier provided by such authorized third party for logging in;
data about your purchases, if any, on the Mobile Application.
Purposes of processing. We process your personal data to the extent necessary for the following purposes:
Purpose A: The purpose of processing your personal data is to perform under a contract between you and us or to enable us to take steps prior to entering into such a contract in connection with your registration or login in the Mobile Application.
Purpose B: The purpose of the processing of the aforementioned personal data is to ensure the technical operation of the Mobile Application, i.e. the proper and smooth functioning of the Mobile Application and the related troubleshooting of reported technical errors and the subsequent optimization (prevention of errors in the future) of the Mobile Application.
We have carried out an assessment of whether it is possible to process your personal data for this purpose and we have also carried out the necessary proportionality test, which balances the interests in protecting your rights against our interests. We have concluded that, in view of the fact that most of the personal data we process is available for other purposes, that we use pseudonymized identifiers, that debugging is also in the interest of the user of the Mobile Application, and that the subsequent optimization of the Mobile Application is in the interest of all users of the Mobile Application, it does not appear to us that your interests or fundamental rights and freedoms to protect your personal data outweigh our legitimate interests as set out above.
Purpose C: The purpose of processing your personal data is to comply with our legal obligations, in particular in the areas of tax, accounting, and advertising regulation.
Legal basis. The legal basis for the processing of personal data for each purpose is as follows:
For purpose A, the fact that such processing is necessary for the performance of a contract between you and us or to enable us to take steps prior to entering into such a contract within the meaning of Art. 6(1)(b) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (the "Regulation").
for purpose B, our legitimate interest under Art. 6(1)(f) of the Regulation is to ensure the technical operation of the Mobile Application.
for purpose C is to comply with our legal obligations under Art. 6(1)(c) of the Regulation.
Retention period. Your personal data will be processed:
for purpose A for a period of three (3) years from the end of your contract;
for purpose B for the duration of the contract if you have an account with us, or for 1 month after using the Mobile Application if you do not have an account; and
for purpose C for duration as long as necessary to comply with legal obligations under applicable generally binding legislation.
Other beneficiaries. Persons who provide technical activities for us, including persons providing us with hosting and software development services, and other companies in our group ("our group") may be other recipients of your personal data. In cases where we are required to do so by generally binding legislation, the relevant public authorities may also be additional recipients of your personal data for the purpose of fulfilling their obligations under generally binding legislation.
Your rights. Subject to the conditions set out in the Regulation and depending on the purposes stated, you have the right to request that we provide you with access to your personal data, the right to rectification or erasure of your personal data or restriction of its processing and the right to portability of your personal data. Please note that we may ask you to verify your identity before complying with such a request.
If you suspect that the processing of your personal data has infringed or is infringing the Regulation, you have the right, inter alia, to lodge a complaint with a supervisory authority, in particular with a supervisory authority in the EU Member State where you are habitually resident, have your place of work or where the place of the alleged infringement of the Regulation is located.
You have the right to object at any time to the processing of your personal data for the purpose B. In the event that you object to the processing of your personal data for the purpose B, we will not further process your personal data unless we demonstrate compelling legitimate grounds for the processing which override the interests or your rights and freedoms or where such data is necessary for the establishment, exercise or defense of our legal claims.
You are not obliged to provide us with your personal data. However, the provision of your personal data is a necessary requirement for purpose A, i.e. for the conclusion and performance of the contract, and without providing your personal data, the contract cannot be concluded or performed, and this may prevent you from using certain features and purchases within the Mobile Application that are only available to registered users. The processing of your personal data for purpose C is a legal requirement in connection with your eventual purchase on the Mobile Application.
PROCESSING RELATED TO DIRECT MARKETING TO REGISTERED USERS
Processing specifications. If you create an account within the Mobile Application, or log into the Mobile Application using a previously created account from our other platforms or products, we may send you commercial communications (marketing offers) regarding our own similar services in accordance with generally applicable law, and for this purpose we process:
the contact details, including email, that you provided to us when you created your account;
pseudonymized identifiers that we have put in place to protect you, and where you have chosen to register or log into the Mobile Application through your existing account with a third party (e.g. Facebook, Gmail, Apple), we also process the pseudonymized identifier generated and provided by such authorized third party for logging in;
This processing of personal data is not based on your consent, however, you have the right to object to this processing at any time.
Purpose of processing. The purpose of processing your personal data is to send you, as our customer, commercial communications in accordance with generally binding legal regulations.
Legal basis. The legal basis for processing your personal data is that this processing is necessary for the purposes of our legitimate interests within the meaning of Art. 6(1)(f) of the Regulation.
Our legitimate interests. Our legitimate interest is based on the fact that you are our customer (user) and that we have provided you with a clear, distinct, free and simple opportunity to opt-out of the use of your electronic contact details for sending commercial communications when collecting your personal data.
When sending commercial communications, we act in accordance with generally binding legal legislation.
The preamble to point 47 of the Regulation states, among other things, that "processing of personal data for direct marketing purposes may be regarded as processing carried out for legitimate interest".
We have carried out an assessment of whether it is lawful to process your personal data for the purpose of sending you commercial communications and we have also carried out the necessary proportionality test which assesses the interests in protecting your rights and our interests. We have concluded that, in view of the previous fulfilment of the prerequisites set out in the generally binding legislation for sending commercial communications and also in view of the fact that you can refuse further commercial communications at any time, it does not appear to us that your interests or fundamental rights and freedoms to protect the personal data you have voluntarily provided outweigh our legitimate interests in sending commercial communications.
In light of the above and the fact that you can reasonably expect your personal data to be processed for the purpose of sending commercial communications, we consider our legitimate interest to be the legal basis for processing your personal data for the purpose of sending commercial communications.
Retention period. Your personal data will be processed by us for a period of three (3) years from the end of your contract, but no longer than until you object or make any other similar request to the processing of personal data for the purpose of sending commercial communications by us, including exercising your right to erasure of personal data.
Other recipients. Persons providing marketing services for us in accordance with our instructions, persons operating our website or Mobile Application (data processors) and other companies in our group are other recipients of your personal data.
Your rights. Subject to the terms of the Regulation, you have the right to request that we provide you with access to your personal data, the right to rectification or erasure of your personal data, or the right to restrict the processing of your personal data.
If you suspect that the processing of your personal data has infringed or is infringing the Regulation, you have the right, inter alia, to lodge a complaint with a supervisory authority, in particular with a supervisory authority in the EU Member State where you are habitually resident, have your place of work or where the place of the alleged infringement of the Regulation is located.
You have the right to object at any time to the processing of your personal data for marketing purposes, including profiling, where the profiling relates to such direct marketing. If you object to the processing of your personal data for direct marketing purposes, your personal data will no longer be processed for such purposes.
PROCESSING RELATED TO DIRECT MARKETING (WITH YOUR CONSENT)
Processing specifications. With your consent, we process your
contact details, including email, that you provided to us when you created your account;
age information, if you have provided it to us;
the pseudonymized identifiers we have put in place to protect you and, where you have chosen to register or log into the Mobile Application through your existing account with a third party (e.g. Facebook, Gmail, Apple), we also process the pseudonymized identifier generated and provided by such authorized third party for logging in;
data about your use of the Mobile Application (e.g. IP address and Geo IP) and identification data about your device (e.g. UUID/UDID), which is automatically collected by your use of the Mobile Application;
for the purpose of sending commercial communications (marketing offers) promoting us, our group or third parties or for the purpose of carrying out other marketing activities towards you, including marketing profiling and subsequent personalization of the advertising displayed. This processing of personal data is based on your explicit consent, which you have the right to withdraw at any time.
Purpose of processing. The purpose of processing your personal data is to send you commercial communications and to carry out other marketing activities towards you, including marketing profiling and subsequent personalization of the advertising displayed.
Legal Basis. The legal basis for the processing of your personal data is your consent given to us in the sense of Art. 6(1)(a) of the Regulation.
Retention Period. We will process (retain) your personal data for a period of four (4) years from the receipt of your consent to processing, and processing will cease if you withdraw your consent to the processing of your personal data for this purpose.
Other Recipients. Persons who provide marketing and advertising services for us, in particular the entities listed here, as well as persons who operate our website or Mobile Application and other companies in our group (data processors), and the most widely used social networks such as Facebook, Twitter, LinkedIn (as controller or joint controllers as the case may be) are additional recipients of your personal data.
Your rights. Subject to the conditions set out in the Regulation, you have the right to request that we provide you with access to your personal data, the right to rectification or erasure of your personal data or restriction of its processing, and the right to the portability of your personal data.
You have the right to withdraw your consent to the processing of your personal data that you have provided to us at any time. This does not affect the lawfulness of the processing of your personal data prior to such withdrawal of consent. You may withdraw your consent to the processing of your personal data by clicking on the hyperlink provided in any commercial communication we send you, by using the relevant button in the Mobile Application or by sending an e-mail message to our contact e-mail address (see Art. 1.2 of this Information).
If you suspect that the processing of your personal data has infringed or is infringing the Regulation, you have the right, among other things, to lodge a complaint with a supervisory authority, in particular with a supervisory authority in the EU Member State where you are habitually resident, work or where the place of the alleged infringement is located.
You are under no obligation to provide personal data. The provision of your personal data is not a legal or contractual requirement, nor is it a requirement that is necessary to enter into a contract.
PROCESSING RELATED TO MOBILE APPLICATION USAGE ANALYTICS
Processing specifications. With your consent, we further process your
contact details, including email, that you provided to us when you created your account; and
age information if you have provided it to us;
the pseudonymized identifiers we have put in place to protect you and, if you have chosen to register or log in to the Mobile Application through your existing account with a third party (e.g. Facebook, Gmail, Apple) we also process the pseudonymized identifier generated and provided by such authorized third party for logging in;
analytical data related to your activity on Mobile Application and pseudonymized identifiers associated with such data (e.g. USER ID, User pseudo ID) from us and from third parties providing us with the collection, analysis and evaluation of data related to your activity on Mobile Application;
for the purpose of collecting, analyzing and evaluating the use of the Mobile Application. This processing of personal data is based on your explicit consent, which you have the right to withdraw at any time.
Purpose of processing. The purpose of the processing of personal data is the collection, analysis and evaluation of data, including profiling, about the use of the Mobile Application for the purpose of subsequent optimization and improvement of the Mobile Application.
Legal basis. The legal basis for the processing of your personal data is the consent you give us within the meaning of Art. 6(1)(a) of the Regulation.
Retention Period. We will process (store) your personal data for this purpose for a maximum period of 50 months from your last login to the Mobile Application, and processing will cease if you withdraw your consent to the processing of your personal data for this purpose.
Other beneficiaries. The persons, who collect, analyze and evaluate data about the use of the Mobile Application for us, in particular the entities listed here, and companies in our group are additional recipients of your personal data.
Your rights. Subject to the conditions set out in the Regulation, you have the right to request that we provide you with access to your personal data, the right to rectification or erasure of your personal data or restriction of its processing, and the right to the portability of your personal data.
You have the right to withdraw your consent to the processing of your personal data that you have provided to us at any time. This does not affect the lawfulness of the processing of your personal data prior to such withdrawal of consent. You can withdraw your consent to the processing of your personal data by using the relevant button on the Mobile Application or by sending an e-mail message to our contact e-mail address (see Art. 1.2 of this Information).
If you suspect that the processing of your personal data has infringed or is infringing the Regulation, you have the right, among other things, to lodge a complaint with a supervisory authority, in particular with a supervisory authority in the EU Member State where you are habitually resident, work or where the place of the alleged infringement is located.
You are not obliged to provide personal data. The provision of your personal data is not a legal or contractual requirement, nor is it a requirement that is necessary to enter into a contract.
SECURITY OF YOUR INFORMATION
To protect your personal data, we use administrative, technical and factual security measures in accordance with generally binding legal legislation.
FURTHER INFORMATION
Automated decision-making. We do not carry out automated individual decision-making within the meaning of Art. 22 of the Regulation.
Third Party Activities. We are not responsible for the actions of third parties to whom you disclose personal or sensitive information, and we have no authority to direct or control the sending of third party offers. If you no longer wish to receive correspondence, emails or other communications from third parties, please contact such third party directly.
TRANSFER OF PERSONAL DATA OUTSIDE THE EU
We do not intend to purposefully transfer your personal data to a third country (non-EU country) or international organization, however some of our partners, such as the other recipients of personal data mentioned above, may be based in non-EU countries or store data on servers outside the EU. In such cases, there may be a "transfer of your data to third countries (to a country outside the EU)" within the meaning of the Regulation, including to countries for which the European Commission has not yet decided on adequate protection identical to EU law. In such cases, we will ensure that your personal data is processed and protected both in accordance with our standard privacy policy, but also through the appropriate safeguards set out in Art. 46 of the Regulation and available, for example, here.
AMENDMENTS AND ADDITIONS
We will notify you of any changes to this Information.
We encourage you to check this Information regularly so that you are aware of your rights.
In Prague on 09. 10. 2023
Livesport s.r.o.