Privacy Policy of We Play Sport

Full policy

Owner and Data Controller

We Play Sport SA
Chemin de Monribeau 4,
Lausanne, Vaud 1005,
Switzerland

Owner contact email: Data.Controller@weplay.sport

Types of Data collected

Among the types of Personal Data that We Play Sport collects, by itself or through third parties, there are: Tracker; Usage Data; Data communicated while using the service; first name; last name; country; email address; various types of Data; username; gender; date of birth; phone number; password; state; county; profile picture; User ID; billing address; language; Twitter handle; ZIP/Postal code; city; device logs; device information; app information; Calendar permission; Camera permission; Precise location permission (non-continuous); Approximate location permission (non-continuous); Microphone permission; Social media accounts permission; Photo Library permission; geographic position.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using We Play Sport.
Unless specified otherwise, all Data requested by We Play Sport is mandatory and failure to provide this Data may make it impossible for We Play Sport to provide its services. In cases where We Play Sport specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by We Play Sport or by the owners of third-party services used by We Play Sport serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through We Play Sport and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of We Play Sport (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Access to third-party accounts, Analytics, Collection of privacy-related preferences, Contacting the User, Data transfer outside of the UK, Data transfer outside the EU, Hosting and backend infrastructure, Infrastructure monitoring, Interaction with data collection platforms and other third parties, Managing contacts and sending messages, Platform services and hosting, Registration and authentication, Registration and authentication provided directly by We Play Sport, Social features, Backup saving and management, Beta Testing, Content commenting, Device permissions for Personal Data access, Interaction with external social networks and platforms and Location-based interactions.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Facebook permissions asked by We Play Sport

We Play Sport may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows We Play Sport to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.

The permissions asked are the following:

Basic information

By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.

Contact email

Access the User's contact email address.

Device permissions for Personal Data access

Depending on the User's specific device, We Play Sport may request certain permissions that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.

Please note that the revoking of such permissions might impact the proper functioning of We Play Sport.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by We Play Sport.

Approximate location permission (non-continuous)

Used for accessing the User's approximate device location. We Play Sport may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for We Play Sport to derive the approximate position of the User on a continuous basis.

Calendar permission

Used for accessing the calendar on the User's device, including the reading, adding and removing of entries.

Camera permission

Used for accessing the camera or capturing images and video from the device.

Microphone permission

Allows accessing and recording microphone audio from the User's device.

Photo Library permission

Allows access to the User's Photo Library.

Precise location permission (non-continuous)

Used for accessing the User's precise device location. We Play Sport may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for We Play Sport to derive the exact position of the User on a continuous basis.

Social media accounts permission

Used for accessing the User's social media account profiles, such as Facebook and Twitter.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• Access to third-party accounts

  This type of service allows We Play Sport to access Data from your account on a third-party service and perform actions with it.
  These services are not activated automatically, but require explicit authorization by the User.

  Facebook account access (Meta Platforms, Inc.)

  This service allows We Play Sport to connect with the User's account on the Facebook social network, provided by Facebook, Inc.

  Permissions asked: Contact email.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers.

  Twitter account access (Twitter, Inc.)

  This service allows We Play Sport to connect with the User's account on the Twitter social network, provided by Twitter, Inc.

  Personal Data processed: email address.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Linkedin account access (LinkedIn Corporation)

  This service allows We Play Sport to connect with the User's account on Linkedin, provided by LinkedIn Corporation.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Analytics

  The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

  Google Analytics

  Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of We Play Sport, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  MixPanel (MixPanel)

  MixPanel is an analytics service provided by Mixpanel Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Backup saving and management

  This type of service allows the Owner to save and manage backups of We Play Sport on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to We Play Sport.

  Amazon Glacier

  Amazon Glacier is a service to save and manage backups provided by Amazon Web Services Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy; Luxembourg – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

• Beta Testing

  This type of service makes it possible to manage User access to We Play Sport, or parts of it, for the purpose of testing a certain feature or the entire Application.
  The service provider may automatically collect data related to crashes and statistics related to the User's use of We Play Sport in a personally identifiable form.

  Google Play Beta Testing (Google Ireland Limited)

  Google Play Beta Testing is a beta testing service provided by Google Ireland Limited.

  Personal Data processed: country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; Usage Data; username.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; biometric information; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  TestFlight (Apple Inc.)

  TestFlight is a beta testing service provided by Apple Inc.

  Personal Data processed: app information; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; Tracker; Usage Data; username.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; biometric information; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Collection of privacy-related preferences

  This type of service allows We Play Sport to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.

  iubenda Consent Solution (iubenda srl)

  The iubenda Consent Solution allows to store and retrieve records of Users’ consent to the processing of Personal Data, and information and preferences expressed in relation to the provided consent.
  In order to do so, it makes use of a Tracker that temporarily stores pending information on the User’s device until it is processed by the API. The Tracker (a browser feature called localStorage) is at that point deleted.

  Personal Data processed: Data communicated while using the service; Tracker.

  Place of processing: Italy – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  iubenda Cookie Solution (iubenda srl)

  The iubenda Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information, and in particular to the use of Cookies and other Trackers on We Play Sport.

  Personal Data processed: Tracker.

  Place of processing: Italy – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

• Contacting the User

  Contact form (We Play Sport)

  By filling in the contact form with their Data, the User authorizes We Play Sport to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

  Personal Data processed: country; email address; first name; last name.

  Category of personal information collected according to CCPA: identifiers.

  Mailing list or newsletter (We Play Sport)

  By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning We Play Sport. Your email address might also be added to this list as a result of signing up to We Play Sport or after making a purchase.

  Personal Data processed: country; email address; first name; last name.

  Category of personal information collected according to CCPA: identifiers.

• Content commenting

  Content commenting services allow Users to make and publish their comments on the contents of We Play Sport.
  Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
  If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.

  Comment system managed directly (We Play Sport)

  We Play Sport has its own internal content comment system.

  Personal Data processed: email address; first name; last name; Usage Data; username.

  Category of personal information collected according to CCPA: identifiers; internet information.

• Data transfer outside of the UK

  The Owner is allowed to transfer Personal Data collected within the UK to third countries only subject to specific legal requirements (so-called "restricted transfers"). Restricted transfers may take place according to the conditions specified below.

  Users can enquire with the Owner to learn which legal basis applies to which specific service.

  Data transfers according to a UK adequacy regulation (We Play Sport)

  If this is the legal basis, the transfer of Personal Data from the UK to third countries may take place according to a so called “adequacy regulation” of the UK Government.

  The UK Government adopts adequacy regulations for specific countries or territories whenever such countries or territories guarantee Personal Data protection standards comparable to those set forth by UK data protection legislation. Users can find an updated list of all adequacy regulations on the website of the Information Commissioner’s Office (ICO).

  Personal Data processed: various types of Data.

  Category of personal information collected according to CCPA: internet information.

• Data transfer outside the EU

  The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
  Users can inquire with the Owner to learn which legal basis applies to which specific service.

  Data transfer to countries that guarantee European standards (We Play Sport)

  If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
  The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.

  Personal Data processed: various types of Data.

  Category of personal information collected according to CCPA: internet information.

• Device permissions for Personal Data access

  We Play Sport requests certain permissions from Users that allow it to access the User's device Data as described below.

  Device permissions for Personal Data access (We Play Sport)

  We Play Sport requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.

  Personal Data processed: Approximate location permission (non-continuous); Calendar permission; Camera permission; Microphone permission; Photo Library permission; Precise location permission (non-continuous); Social media accounts permission.

  Category of personal information collected according to CCPA: internet information; geolocation data.

• Hosting and backend infrastructure

  This type of service has the purpose of hosting Data and files that enable We Play Sport to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of We Play Sport.

  Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  Amazon Web Services (AWS) (Amazon Web Services, Inc.)

  Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy; United Kingdom – Privacy Policy; Germany – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  Microsoft Azure (Microsoft Corporation)

  Microsoft Azure is a hosting service provided by Microsoft Corporation.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Switzerland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

• Infrastructure monitoring

  This type of service allows We Play Sport to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
  Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of We Play Sport.

  Firebase Performance Monitoring (Google Ireland Limited)

  Firebase Performance Monitoring is a monitoring service provided by Google Ireland Limited.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

• Interaction with data collection platforms and other third parties

  This type of service allows Users to interact with data collection platforms or other services directly from the pages of We Play Sport for the purpose of saving and reusing data.
  If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

  Mailchimp widget (Intuit Inc.)

  The Mailchimp widget is a service for interacting with the Mailchimp email address management and message sending service provided by Intuit Inc.

  Personal Data processed: email address; first name; last name; Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Interaction with external social networks and platforms

  This type of service allows interaction with social networks or other external platforms directly from the pages of We Play Sport.
  The interaction and information obtained through We Play Sport are always subject to the User’s privacy settings for each social network.
  This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
  It is recommended to log out from the respective services in order to make sure that the processed data on We Play Sport isn’t being connected back to the User’s profile.

  Twitter Tweet button and social widgets (Twitter, Inc.)

  The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

  Personal Data processed: Tracker; Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Facebook Like button and social widgets (Facebook Ireland Ltd)

  The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook Ireland Ltd

  Personal Data processed: Tracker; Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Location-based interactions

  Non-continuous geolocation (We Play Sport)

  We Play Sport may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by We Play Sport.
  The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.

  Personal Data processed: geographic position.

  Category of personal information collected according to CCPA: geolocation data.

• Managing contacts and sending messages

  This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  Mailchimp (Intuit Inc.)

  Mailchimp is an email address management and message sending service provided by Intuit Inc.

  Personal Data processed: country; email address; first name; last name; Tracker; username.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Sendgrid (Sendgrid)

  Sendgrid is an email address management and message sending service provided by Sendgrid Inc.

  Personal Data processed: country; email address; first name; gender; last name; username.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: identifiers; biometric information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Platform services and hosting

  These services have the purpose of hosting and running key components of We Play Sport, therefore allowing the provision of We Play Sport from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
  Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  Apple App Store (Apple Inc.)

  We Play Sport is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.

  By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of We Play Sport. Much of this information is processed on an opt-in basis.

  Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

  Personal Data processed: Usage Data.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  Google Play Store (Google Ireland Limited)

  We Play Sport is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google Ireland Limited.

  By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.

  Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

  Personal Data processed: Usage Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

• Registration and authentication

  By registering or authenticating, Users allow We Play Sport to identify them and give them access to dedicated services.
  Depending on what is described below, third parties may provide registration and authentication services. In this case, We Play Sport will be able to access some Data, stored by these third-party services, for registration or identification purposes.
  Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

  Direct registration and profiling (We Play Sport)

  By registering or authenticating directly through We Play Sport, Users allow We Play Sport to identify them and give them access to dedicated services. The Owner may process Data collected when Users register or authenticate also for targeting and profiling purposes; to find out more, Users can contact the Owner using the contact details provided in this document.

  Personal Data processed: billing address; country; county; date of birth; email address; first name; gender; language; last name; password; phone number; profile picture; state; Twitter handle; User ID; username.

  Category of personal information collected according to CCPA: identifiers; biometric information; sensorial information; inferred information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Facebook Authentication (Facebook Ireland Ltd)

  Facebook Authentication is a registration and authentication service provided by Facebook Ireland Ltd and is connected to the Facebook social network.

  Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Facebook Oauth (Facebook Ireland Ltd)

  Facebook Oauth is a registration and authentication service provided by Facebook Ireland Ltd and is connected to the Facebook social network.

  Personal Data processed: Tracker; various types of Data.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Google OAuth (Google Ireland Limited)

  Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Instagram Authentication (Facebook Ireland Ltd)

  Instagram Authentication is a registration and authentication service provided by Facebook Ireland Ltd and is connected to the Instagram social network.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: Ireland – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

  Twitter OAuth (Twitter, Inc.)

  Twitter Oauth is a registration and authentication service provided by Twitter, Inc. and is connected to the Twitter social network.

  Personal Data processed: various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

  Category of personal information collected according to CCPA: internet information.

  This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

• Registration and authentication provided directly by We Play Sport

  By registering or authenticating, Users allow We Play Sport to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

  Direct registration (We Play Sport)

  The User registers by filling out the registration form and providing the Personal Data directly to We Play Sport.

  Personal Data processed: billing address; city; country; county; date of birth; email address; first name; gender; language; last name; password; phone number; profile picture; state; Twitter handle; User ID; username; ZIP/Postal code.

  Category of personal information collected according to CCPA: identifiers; biometric information; sensorial information; inferred information.

• Social features

  Public profile (We Play Sport)

  Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with We Play Sport.

  Personal Data processed: country; first name; last name.

  Category of personal information collected according to CCPA: identifiers.

  Inviting and suggesting friends (We Play Sport)

  We Play Sport may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.

  Personal Data processed: various types of Data.

  Category of personal information collected according to CCPA: internet information.

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US) and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.

The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Further information about the processing of Personal Data

• Equal protection of User Data

  We Play Sport shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.

• Rights for registered California Users under the age of 18

  California's "Online Eraser" law, part of California's Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.

  If a registered User fits that description and posted content on We Play Sport, they may request removal of such content by contacting the Owner or its privacy policy coordinator at the contact details provided in this document.

  In response to this request, the Owner may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Owner's servers. It may also be publicly available elsewhere if a third party copied and reposted this content.

• Analysis and predictions based on the User’s Data (“profiling”)

  The Owner may use the Personal and Usage Data collected through We Play Sport to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
  User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
  The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

• Automated decision-making

  Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. We Play Sport may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. We Play Sport adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
  Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
  The rationale behind the automated decision making is:

  • to enable or otherwise improve the decision-making process;
  • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
  • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
  • to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within We Play Sport, Users can check the relevant sections in this document.

  Consequences of automated decision-making processes for Users and rights of Users subjected to it

  As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
  In particular, Users have the right to:

  • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
  • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
  • request and obtain from the Owner human intervention on such processing.

  To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

• Preference Cookies

  Preference Cookies store the User preferences detected on We Play Sport in the local domain such as, for example, their timezone and region.

• Pseudonymous use

  When registering for We Play Sport, Users have the option to indicate a nickname or pseudonym. In this case, Users' Personal Data shall not be published or made publicly available. Any activity performed by Users on We Play Sport shall appear in connection with the indicated nickname or pseudonym. However, Users acknowledge and accept that their activity on We Play Sport, including content, information or any other material possibly uploaded or shared on a voluntary and intentional basis may directly or indirectly reveal their identity.

• Push notifications

  We Play Sport may send push notifications to the User to achieve the purposes outlined in this privacy policy.

  Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for We Play Sport, some or all of the apps on the particular device.
  Users must be aware that disabling push notifications may negatively affect the utility of We Play Sport.

• Push notifications based on the User's geographic location

  We Play Sport may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.

  Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.

  Users must be aware that disabling push notifications may negatively affect the utility of We Play Sport.

• Unique device identification

  We Play Sport may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

• User identification via a universally unique identifier (UUID)

  We Play Sport may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of We Play Sport or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, We Play Sport may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, We Play Sport and any third-party services may collect files that record interaction with We Play Sport (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

We Play Sport does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within We Play Sport and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Information for Californian consumers

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running We Play Sport and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, according to "The California Consumer Privacy Act of 2018" (Users are referred to below, simply as “you”, “your”, “yours”), and, for such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term “personal information“ as it is defined in The California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

In this section we summarize the categories of personal information that we've collected, disclosed or sold and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, biometric information, internet information, geolocation data, sensorial information and inferred information.

We will not collect additional categories of personal information without notifying you.

How we collect information: what are the sources of the personal information we collect?

We collect the above mentioned categories of personal information, either directly or indirectly, from you when you use We Play Sport.

For example, you directly provide your personal information when you submit requests via any forms on We Play Sport. You also provide personal information indirectly when you navigate We Play Sport, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of We Play Sport and features thereof.

How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose

We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this document.

Sale of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer's personal information by the business to another business or a third party, for monetary or other valuable consideration”.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

Your right to opt out of the sale of personal information

You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request, simply by following the instructions below.

Instructions to opt out of the sale of personal information

If you’d like to know more, or exercise your right to opt out in regard to all the sales carried out by We Play Sport, both online and offline, you can contact us for further information using the contact details provided in this document.

What are the purposes for which we use your personal information?

We may use your personal information to allow the operational functioning of We Play Sport and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We will not use your personal information for different, unrelated, or incompatible purposes without notifying you.

Your California privacy rights and how to exercise them

The right to know and to portability

You have the right to request that we disclose to you:

• the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
• in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
  • for sales, the personal information categories purchased by each category of recipient; and
  • for disclosures for a business purpose, the personal information categories obtained by each category of recipient.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on We Play Sport, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

• provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
• describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12 month period.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

Additional information about California privacy

CCPA: Collection of personal information about consumers aged 13 to 16

We collect personal information of consumers between the age of 13 and 16 and won't sell their data unless those consumers have opted-in.

CCPA: Collection of personal information about consumers below the age of 13

We collect personal information of consumers below the age of 13 and won't sell their data unless their parents or guardians have opted-in on behalf of those minors.