Legal

data privacy

In this privacy notice, we inform you about the processing of your personal data in connection with the use of the Prematch app (hereinafter referred to as the "App"). Personal data is all data relating to an identified or identifiable natural person, e.g. their name or IP address.

1. Overview

1.1 Controller and UK representative

The controller for data processing in the App pursuant to Art. 4 (7) UK GDPR is PREMATCH Sports GmbH, Brüsseler Str. 21, 50674 Cologne, Germany, email: privacy@prematchapp.de.

Our representative in the UK is xxx

1.2 Data protection officer

Our data protection officer can be contacted via heyData GmbH, Schützenstraße 5, 10117 Berlin, Germany, www.heydata.eu, email: datenschutz@heydata.eu.

1.3 Scope of data processing, processing purposes and legal bases

The scope of the processing of personal data, the purposes of processing and the legal bases are explained in detail in section 2. In principle, the following legal bases exist for processing of personal data:

  • Art. 6(1) a UK GDPR serves us as the legal basis for processing operations for which we obtain consent.
  • Art. 6(1) b UK GDPR is the legal basis insofar as the processing of personal data is necessary for the performance of a contract, e.g. to fulfill our obligations under the terms of use. This legal basis also applies to processing that is necessary for pre-contractual measures, for example in the case of inquiries about our services.
  • Art. 6(1) c UK GDPR applies if we fulfill a legal obligation with the processing of personal data, e.g. arising from tax law.
  • Art. 6(1) f UK GDPR serves as the legal basis if we can rely on legitimate interests to process personal data, e.g. for processing user inquiries.

1.4 Recipients

Where necessary, we transfer personal data to processors for one or more of the purposes specified in this privacy notice as well as to the following recipients in particular:

  • external service providers
  • public authorities
  • affiliated companies

1.5 Data processing outside the EEA

Insofar as we transfer data to service providers or other third parties outside the European Economic Area (EEA), adequacy regulations pursuant to Art. 45(3) UK GDPR guarantee the security of the data during transfer, insofar as these exist, as is the case, for example, for South Korea and Israel.

If no adequacy regulation exists, the legal basis for data transfers is usually standard data protection clauses. These form part of the contract with the respective third party. According to Art. 46 (2) b UK GDPR, they guarantee the security of data transfers. For registered service providers, we also rely on the UK Extension to the EU-U.S. Data Privacy Framework.  

1.6 Storage period

Unless explicit storage periods are specified in this privacy notice, the data stored by us will be deleted as soon as it is no longer required for its intended purpose and the deletion does not conflict with any statutory retention obligations. If the data is not deleted because it is required for other and legally permissible purposes, its processing will be restricted, i.e. the data will not be processed for other purposes. This applies, for example, to data that we must retain to comply with our obligations under commercial or tax law.

1.7 Rights of the data subjects

As a data subject, you have the following rights with regard to the personal data we process concerning you:

  • Right of access
  • Right to rectification or erasure
  • Right to restriction of processing
  • Right to object to processing if this is based on legitimate interests
  • Right to data portability
  • Right to withdraw consent once given at any time with effect for the future.

In particular, you can object to data being displayed in your profile (e.g. market value) if you do not want this. We will then delete your profile.

You can exercise the above rights by contacting us using the contact details provided in this privacy notice.  

As a data subject, you also have the right to complain to the Information Commissioner’s Office about the processing of your personal data. 

1.8 No obligation to provide data

You are neither contractually nor otherwise legally obliged to provide us with personal data. However, if you refuse to provide such data, which is absolutely necessary for the use of the App or which we are obliged to collect under applicable law, you will not be able to use the App or will only be able to use it to a limited extent.

Mandatory information is marked as such in the App.

1.9 No automated decision-making in individual cases

In principle, we do not use fully automated decision-making in accordance with Art. 22 UK GDPR. Should we use this technology in individual cases, we will inform you separately where required by law.

2. Specific data processing

2.1 Downloading the App

Our App is available for download from Google's Play Store and Apple's App Store (hereinafter "Stores"). When you download the App, the required information is transmitted to the stores, in particular your user name, email address and account customer number, time of download, payment information and individual device identification number. We have no influence on this data collection and are not responsible for it. We process the data only to the extent necessary for downloading the App to the mobile device.

2.2 Information security

When you use our App, we collect data that is necessary to ensure the stability and security of the App. This is our legitimate interest, so the legal basis is Art. 6 (1) f UK GDPR.

2.3 Collection of data from public sources & calculation of market values

We collect data on amateur footballers from public sources, such as online platforms, websites and club press releases. From this data, the App calculates a fictitious market value, which includes the following parameters in particular:

  • Current & previous league level of the player
  • Age of the player
  • Position of the player
  • Performance data of the team
  • Performance data of the player

Prematch calculates a fictitious market value for all players in the adult sector (unless they have expressly objected to this). The market values are determined using various publicly available parameters (if known):

  • In a first step, a base value is calculated based on the player's current league level. The higher the league, the higher the respective base value. This base value is then adjusted based on the historical leagues in which the players were active in recent seasons.
  • In a second step, the team's performance data (goals scored, goals conceded, fair play rating) as well as the position and age of the players are taken into account. This is based on the consideration that, for example, a younger player has greater development potential than an older player and his market value should therefore be higher if the other parameters are the same.    
  • In a third step, individual performance data from the player's last ten matches is then included in the evaluation. For all players, it is taken into account whether they were in the squad, were in the starting eleven, how long they played and whether they led the team onto the pitch as captain. In addition, the performance data included differs according to position: for goalkeepers, the goals conceded by the team are included, whereas for strikers, the goals scored are included in the market value.
  • Our market value has no claim to accuracy or realism, but serves - just like the presentation of the data in our App - solely to entertain our users.

The data is stored on our servers for as long as the player is active and deleted as soon as the player requests the deletion of their data.

The legal basis for data processing is Art. 6 (1) f UK GDPR. Our interest is to offer our users an app that is as attractive as possible, including market values for comparing the performance of players.

If you do not agree to your data (e.g. market value) being displayed in our App, you can object to it at any time. We will then remove your profile from the App.

2.4 User account

You can open a user account in the App. We process the data requested in this context to perform the contract concluded via the account, so that the legal basis for the processing is Art. 6 (1) b UK GDPR.

As a verified user, you can add further data to your user account on a voluntary basis. You can find further information on this in your user account.

2.5 Single sign-on

You can log in to our App using one or more single sign-on solutions. You use the login data you have already created for another provider. The prerequisite is that you are already registered with the respective provider. If you log in using the single sign-on solution, we will receive information from the provider that you are logged in with the provider and the provider will receive information that you are using the single sign-on solution in our App. Depending on the settings in your account on the provider's website, the provider may provide us with additional information. The legal basis for this processing lies in the user contract between the provider and you.

The provider(s) of the offered solution(s) are

  • Apple Inc, Infinite Loop, Cupertino, CA 95014, USA (privacy notice: https://www.apple.com/legal/privacy/de-ww/).
  • Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (privacy notice: https://policies.google.com/privacy).
  • Meta Platforms Ireland Ltd, 4 Grand Canal Square, Dublin 2, Ireland ("Facebook"). Which data we receive from Facebook is communicated to users by Facebook as part of the registration process. Information on Facebook and the contact details of the data protection officer as well as further information on how Facebook processes personal data, including the legal basis and the options for exercising rights as a data subject vis-à-vis Facebook, can be found at https://www.facebook.com/about/privacy. We are jointly responsible with Facebook for the data processing carried out by Facebook in the context of the use of the solutionand have concluded a joint controllership agreement with Facebook (Art. 26 UK GDPR). Therein we have defined the respective responsibilities for fulfilling the obligations under the UK GDPR with regard to joint processing. We are obliged to provide the above information and Facebook has assumed responsibility for the further rights of data subjects in accordance with Art. 15-20 UK GDPR.

2.6 Verification of a player profile

As a user, you can request to verify your player profile in our App. In order to verify the identity of the user, we process the personal data that is requested in the verification flow.

The legal basis for the processing is Art. 6 (1) f UK GDPR in conjunction with our legitimate interest in preventing the takeover of third-party player profiles.

2.7 Making contact

When you contact us, e.g. by email or telephone, the data you provide us with (e.g. names and email addresses) will be stored by us in order to answer your questions. The legal basis for the processing is our legitimate interest (Art. 6 (1) f UK GDPR) in answering inquiries addressed to us.

2.8 Competitions

We occasionally offer competitions. We process the data requested to determine and notify the winners. We then delete the data. It is in our legitimate interest to offer competitions to attract new users or to interact with our existing users. The legal basis for data processing is Art. 6 (1) f UK GDPR.

2.9 Surveys

From time to time, we conduct surveys to get to know our users and their wishes better. In doing so, we collect the data requested in each case. It is our legitimate interest to get to know our users and their wishes better, so that the legal basis for the associated data processing is Art. 6 (1) f UK GDPR. We delete the data once the results of the surveys have been evaluated.

2.10. Newsletter

We reserve the right to inform users who have already used our services and from whom we have received an email address or other address for electronic contact (e.g. via SMS and/or WhatsApp or other messenger services) from time to time via this email or other electronic contact address about our similar offers, unless they have objected to this. The legal basis for this data processing is Art. 6 (1) f UK GDPR. Our legitimate interest lies in the use of direct marketing (Recital 47 UK GDPR). You can object to the use of your email or other electronic contact address for advertising purposes at any time and without stating reasons and at no additional cost, for example via the link at the end of any electronic contact in this context or by email to our email address stated above.

Based on the consent of the recipients (Art. 6 (1) a UK GDPR), we also measure the opening and click rate of our newsletters in order to understand which content is relevant to them.

We send newsletters using the tools

  • SendGrid from the provider Twilio, Inc., 375 Beale Street, Suite 300, San Francisco, CA 94105, USA (privacy notice: https://www.twilio.com/legal/privacy). The provider processes content, usage, meta/communication data and contact data in the USA.
  • Mailchimp of the provider Rocket Science Group LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA (privacy notice: https://mailchimp.com/legal/privacy/). The provider processes content, usage, meta/communication data and contact data in the USA.
  • Sendinblue of the provider Sendinblue GmbH, Köpenicker Str. 126, 10179 Berlin (privacy notice: https://de.sendinblue.com/legal/privacypolicy/). The provider processes content, usage, meta/communication data and contact data in the EU.

We also regularly send information, vouchers and other marketing communications to users who have registered for our newsletter (by email or telephone number). In these cases, the processing is based on the consent of the recipients in accordance with Art. 6 (1)  a UK GDPR. You can revoke your consent to receive the newsletter at any time, e.g. by contacting us using the contact details provided in this privacy notice.

If you have registered to receive communications via WhatsApp, we will process the contact details using WhatsApp. The provider is WhatsApp Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. Further information about the processing of personal data by WhatsApp can be found at https://www.whatsapp.com/legal/privacy-policy.

2.11. Tools from third-party providers

2.11.1 Firebase Cloud Messaging

We use Firebase Cloud Messaging to communicate with our users. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. interest in content, access times) and meta/communication data (e.g. device information, IP addresses).

The legal basis for processing is Art. 6 (1) a UK GDPR. Processing takes place on the basis of consent. You can withdraw your consent at any time with effect for the future, e.g. by contacting us using the contact details provided in this privacy notice.

Further information can be found in the provider's privacy notice at https://firebase.google.com/support/privacy

2.11.2 Amazon AWS

We use Amazon AWS for hosting. The provider is Amazon Web Services EMEA Sarl, 38 avenue John F. Kennedy, L-1855, Luxembourg. The provider processes usage data (e.g. interest in content, access times) and meta/communication data (e.g. device information, IP addresses).

It is our legitimate interest to provide an app, so the legal basis for data processing is Art. 6 (1) f UK GDPR. Insofar as the hosting of the data is necessary to fulfill our obligations under the terms of use, the legal basis is Art. 6 (1) b UK GDPR.  

Further information can be found in the provider's privacy notice at https://aws.amazon.com/de/privacy/?nc1=f_pr.

2.11.3 AppsFlyer

We use AppsFlyer for analysis. The provider is AppsFlyer Ltd, 14 Maskit St., Herzlia, Israel. The provider processes usage data (e.g. interest in content, access times) and meta/communication data (e.g. device information, IP addresses).

The legal basis for the processing is Art. 6 (1) a UK GDPR. Processing takes place on the basis of consent. You can withdraw your consent at any time, e.g. by contacting us using the contact details provided in this privacy notice.

Further information can be found in the provider's privacy notice at https://www.appsflyer.com/legal/privacy-policy/.

2.11.4 Firebase

We use Firebase for application development. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, D04e5w5, Ireland. The provider processes usage data (e.g. interest in content, access times), contact data (e.g. email addresses, telephone numbers) and meta/communication data (e.g. device information, IP addresses).

The legal basis for processing is Art. 6 (1) f UK GDPR. We have a legitimate interest in developing new applications in a simple manner.

Further information can be found in the provider's privacy notice at https://firebase.google.com/terms/data-processing-terms/.

2.11.5 Firebase App Check

We use Firebase App Check to track errors in applications and for repair management. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, D04e5w5, Ireland. The provider processes usage data (e.g. interest in content, access times) and meta/communication data (e.g. device information, IP addresses).

The legal basis for processing is Art. 6 (1) f UK GDPR. We have a legitimate interest in appropriately monitoring the functionality of our App.

Further information can be found in the provider's privacy notice at https://policies.google.com/privacy.

2.11.6 Firebase Crashlytics

We use Firebase Crashlytics to track errors in applications and for repair management. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, D04e5w5, Ireland. The provider processes usage data (e.g. interest in content, access times) and meta/communication data (e.g. device information, IP addresses).

The legal basis for the processing is Art. 6 (1) f UK GDPR. Our legitimate interest is to be able to offer a functioning app.

Further information can be found in the provider's privacy notice at https://policies.google.com/privacy.

2.11.7 CleverTap

We use CleverTap to analyze and communicate with our users. The provider is WizRocket Inc, 19th Floor, DLH Park, SV Road, Goregaon West, Mumbai 400062, India. The provider processes usage data (e.g. interest in content, access times) and meta/communication data (e.g. device information, IP addresses).

The legal basis for processing is Art. 6 (1) f UK GDPR, insofar as we send you messages with content that is a core component of our App (e.g. messages that inform you about the progress of a game) or do not require consent for other reasons. Insofar as we send you messages that contain advertising content and require prior consent, the legal basis is Art. 6 (1) a UK GDPR in conjunction with your consent. You can withdraw your consent at any time with effect for the future, e.g. by contacting us using the contact details provided in this privacy notice.

Further information can be found in the provider's privacy notice at https://clevertap.com/privacy-policy/.

2.11.8 Intercom

We use Intercom to communicate with our users. The provider is Intercom R&D Unlimited Company, 2nd Floor Stephen Court, 18-21 St. Stephen's Green, Dublin, 2, Ireland. The provider processes content data (e.g. entries in online forms), contact data (e.g. email addresses, telephone numbers), meta/communication data (e.g. device information, IP addresses) and master data (e.g. names, addresses).

The legal basis for processing is Art. 6 (1) 1 f UK GDPR. Our legitimate interest lies in responding to requests from our users.

Further information can be found in the provider's privacy notice at https://www.intercom.com/de/legal/privacy.

2.11.9 Segment

We use Segment for analysis. The provider is Segment.io, Inc, 100 California Street Suite 700 San Francisco, CA 94111, USA. The provider processes meta/communication data (e.g. device information, IP addresses).

The legal basis for the processing is Art. 6 (1) a UK GDPR. Processing takes place on the basis of consent. You can withdraw your consent at any time with effect for the future, e.g. by contacting us using the contact details provided in this privacy notice.

Further information can be found in the provider's privacy notice at https://segment.com/legal/privacy/

2.11.10. Sentry

We use Sentry to monitor applications and to track errors in applications or on websites. The provider is Functional Software, Inc, 132 Hawthorne Street San Francisco, CA 94107, USA. The provider processes usage data (e.g. interest in content, access times), content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses).

The legal basis for processing is Art. 6 (1) f UK GDPR. Our legitimate interest is to be able to offer a functioning app.

Further information can be found in the provider's privacy notice at https://sentry.io/privacy/.

2.11.11. Amplitude

We use Amplitude for product analysis. The provider is Amplitude, Inc, 631 Howard St. Floor 5, San Francisco, CA 94105, USA. The provider processes usage data (e.g. interest in content, access times) and meta/communication data (e.g. device information, IP addresses).

The legal basis for processing is Art. 6 (1) a UK GDPR. Processing takes place on the basis of consent. You can withdraw your consent at any time, e.g. by contacting us using the contact details provided in this privacy notice.

Further information can be found in the provider's privacy notice at https://amplitude.com/privacy.

2.11.12. Typeform

We use Typeform for questionnaires and forms. The provider is Typeform S.L., 163 Carrer de Bac de Roda, Barcelona, Spain. The provider processes content data (e.g. entries in online forms) and meta/communication data (e.g. device information, IP addresses).

The legal basis for processing is Art. 6 (1) a UK GDPR. Our legitimate interest lies in particular in enabling user inquiries to our customer service.

Further information can be found in the provider's privacy notice at https://admin.typeform.com/to/dwk6gt.

2.11.13. Facebook SDK

We use Facebook SDK for analysis. The provider is Meta Platforms Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The provider processes usage data (e.g. interest in content, access times) and meta/communication data (e.g. device information, IP addresses).

The legal basis for the processing is Art. 6 (1) a UK GDPR. Processing takes place on the basis of consent. You can withdraw your consent at any time, e.g. by contacting us using the contact details provided in this privacy notice.

Further information can be found in the provider's privacy notice at https://www.facebook.com/policy.php.

2.11.14. Zapier

We use Zapier for automation between applications. The provider is Zapier, Inc, 548 Market St. #62411, San Francisco, CA 94104-5401, USA. The provider processes usage data (e.g. interest in content, access times) and meta/communication data (e.g. device information, IP addresses).

The legal basis for processing is Art. 6 (1) f UK GDPR. We have a legitimate interest in simply connecting the applications in our company and thus optimizing the way we work.

Further information can be found in the provider's privacy notice at https://zapier.com/privacy.

2.11.15. SendGrid

We use SendGrid to communicate with customers. The provider is Twilio, Inc, 375 Beale Street, Suite 300, San Francisco, CA 94105, USA. The provider processes usage data (e.g. interest in content, access times), contact data (e.g. email addresses, telephone numbers), meta/communication data (e.g. device information, IP addresses) and master data (e.g. names, addresses).

The legal basis for processing is Art. 6 (1) f UK GDPR. We have a legitimate interest in being able to send emails technically.

Further information can be found in the provider's privacy notice at https://www.twilio.com/legal/privacy.

2.11.16. Firebase Authentication

We use Firebase Authentication to authenticate our users. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Dublin, Ireland. The provider processes usage data (e.g. interest in content, access times) and meta/communication data (e.g. device information, IP addresses).

The legal basis for processing is Art. 6 (1) f UK GDPR. We have a legitimate interest in sufficiently authenticating users of our App.

Further information can be found in the provider's privacy notice at https://policies.google.com/privacy.

2.11.17. YouTube videos

We use YouTube videos for videos in the app. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. The provider processes usage data (e.g. interest in content, access times) and meta/communication data (e.g. device information, IP addresses).

The legal basis for processing is Art. 6 (1) a UK GDPR. Processing takes place on the basis of consent. You can withdraw your consent at any time, e.g. by contacting us using the contact details provided in this privacy notice.

Further information can be found in the provider's privacy notice at https://policies.google.com/privacy.