Privacy Policy of the Prematch App

Status: 27.07.2022

1. we protect your data and your informational self-determination

Thank you for your interest in our app. In the following, we will inform you about how we handle your data and what rights you have with regard to data processing with us. We would like to emphasise that we take your interest in the protection of your data seriously and therefore limit our data collection to the necessary extent and take suitable security measures to protect your data. We do not use automated decision-making.  

Please note that our app may display links to websites of other providers. Such links are either clearly marked as links or they can be recognised by a change in the address bar of your browser. We cannot assume any responsibility for compliance with data protection regulations on third-party websites. Information on data protection there should be contained in the data protection statement available there.

Insofar as we use legal terms in this privacy statement, they correspond to the legal definitions in Art. 4 DSGVO (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data, on the free movement of such data and repealing Directive 95/46/EC). This regulation can be found, for example, at

eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32016R0679

viewable.

2. name and contact details of the data controller

Responsible for the collection, processing and use of your personal data within the meaning of the EU General Data Protection Regulation (DS-GVO) and the Federal Data Protection Act (BDSG-2018) is    

PREMATCH Sports GmbH
Rathenauplatz 9
50674 Cologne
privacy@prematchapp.de
+49 1590 6334521

3. obtaining data from public sources

Our app collects data on amateur footballers from public sources, such as online platforms, websites and press releases from clubs. From this data, the Prematch app calculates a fictitious market value, which includes the following parameters in particular:

  1. League level
  2. Age
  3. Position
  4. Current table position
  5. Minutes played
  6. Goals scored (Individual)
  7. Goals conceded (team)

Parameter 1. represents a base value, which is the starting point for the market value calculation. The parameters 2.-4. are used as multipliers by means of a weighting determined by Prematch in order to correct the base value. This results in the "intermediate value". Parameters 5-7 are then used to supplement the intermediate value with performance-related data. Thus, a key was defined for "minutes played", "goals scored" and "goals conceded", which is added to the intermediate value according to the performance data. Finally, the market value is converted into a market value interval by defining a lower limit as well as an upper limit through correction by a certain percentage. This market value interval is intended to represent the inclusion of further, non-measurable factors. This market value has no claim to accuracy or realism, but serves - just like the presentation of the data in our app - to entertain our users.

The data is stored on our servers for as long as an amateur footballer is active and is overwritten as soon as the footballer is no longer listed as a player by any amateur club.

The legal basis for data processing is Art. 6 (1) sentence 1 lit. f DSGVO, according to which processing is lawful if the processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, override these interests.

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4. installing the app from an app store

In order to use our app, you must download it from an app store. For this purpose, it may be necessary for you to create a user account in the app store. We have no influence on the data collection that takes place in this process. More detailed information about the data processing by the app store provider should be made available to you by the provider itself.

You can find the privacy policy of the Apple App Store at:

https://support.apple.com/de-de/HT211970

You can find the privacy policy of the Google App Store at:

https://policies.google.com/privacy?hl=de

If you use an app store, the app store may provide us with data about you. We process the data provided by the app store only to the extent necessary to download and install the app on your mobile device (e.g. smartphone, tablet). If the app is a paid prematch app, we also process billing and payment data to process the purchase.

The legal basis for this data processing is Art. 6 para. 1 lit. b.) of the General Data Protection Regulation, according to which data processing may be carried out for the performance of a contract or for the implementation of pre-contractual measures, insofar as this is necessary for the aforementioned purposes and in response to a request from the data subject.

5. use of our app

To ensure that our content is displayed correctly, we collect data on the operating system used (e.g. Android or iOS), the host name of the accessing end device (IP address) and the time of the server request when you use our app. The IP address is deleted or anonymised within 14 days. In the case of anonymisation, the IP addresses are changed in such a way that the person concerned cannot be identified or can no longer be identified. A location determination is carried out on the basis of the anonymised IP address. For data protection reasons, this is only carried out up to the geographical level of the country from which the call originates. It is therefore not possible to draw any conclusions about the specific location or place of residence of a user.

The legal basis for data processing is Art. 6 (1) sentence 1 lit. f DSGVO, according to which processing is lawful if the processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, override these interests.

6. registration in our app

Our app offers you the opportunity to register personally. When you register in our app, we may collect further personal data. This is the data you entered during registration (name, address and email address). In addition, you can enter further personal data, such as your date of birth and height, into the app. The legal basis for this data processing is your consent in accordance with Art. 6 Para. 1 S. 1 lit. a DSGVO. You can revoke your consent at any time by deleting your user profile or by sending an email to privacy@prematchapp.de (for more information on the legal consequences of revoking your consent, see section 12).

You can also log in to our app using the account of a third-party provider. This leads to a link between your account with the third-party provider and our app. The third-party provider receives our app ID. After the link, our app provides further functions, such as updating your settings on different devices. We use the "Facebook Sign In", "Google+ Sign In" and "Sign in with Apple" systems for this purpose.

When using "Facebook Sign In", we store and process

- Your email address,

- the URL of the profile picture,

- the name,

- the public profile and

- the token.

"Facebook Sign In" is a service provided by Facebook Inc., 1601 Willow Road, Menlo Park, California, 94025, USA. You can find more information about how this company handles your personal data at:

https://www.facebook.com/business/m/one-sheeters/gdpr-developer-faqs and https://www.facebook.com/policy.php

When using "Google+ Sign In", we store and process the permissions set by Google by default, these are

  • Your profile,
  • The JWT (token) and
  • Your Google ID.  

"Google+ Sign In" is a service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. You can find more information about how these companies handle your personal data at:

https://policies.google.com/?hl=de

When you use "Log in with Apple", your Apple ID is linked to our app. In addition, your IP address is transmitted to Apple. You then have the option of sharing your email address or hiding your email address in the settings of your iPhone. If you choose "Share email address", we also receive your email address and name. With "Hide email address", an email relay service from Apple, you can create a new email address that forwards emails to your private email address. This allows you to receive messages from the app without sharing your private email address with us.

Sign in with Apple" is a service provided by Apple Inc. One Apple Park Way, Cupertino, California, USA, 95014. For more information about how this company handles your personal data, please visit:

https://support.apple.com/de-de/HT210699

The data transfer is based on your consent in accordance with Art. 6 para. 1 p. 1 lit. A DSGVO. You can revoke your consent at any time by deleting the link or by sending an email to privacy@prematchapp.de (for more information on the legal consequences of this revocation, see section 12).

7. contacting

You can contact us via

  • the feedback option of our app,
  • the "Report content" option
  • the "I can't find myself" onboarding option
  • by e-mail or
  • by telephone

possible. If you contact us via an option in our app or on our website, this is done via TypeForm. TypeForm is a service of TYPEFORM SL, Carrer Bac de Roda, 163, local, 08018 - Barcelona, Spain). TypeForm processes the following data

  • Your email address,
  • Your country of residence,
  • Language of the unit,
  • App version,
  • OS version,
  • Device ID,
  • Device name,
  • IP address.

This data is transmitted to a closed Slack channel via Typeform. You can find more information about how this company handles your personal data at:

https://help.typeform.com/hc/en-us/articles/360029581691-What-happens-to-my-data

Slack is a service provided by Slack Technologies Limited, 4th Floor, One Park Place, Hatch Street Upper, Dublin 2, Ireland. You can find more information about how this company handles your personal data at:

https://slack.com/intl/de-de/trust/privacy/privacy-faq

Whenever you contact us (i.e. also by e-mail or telephone), we may collect and store the data you provide. This is done for the purpose of answering your enquiry. The legal basis for this data processing is your consent in accordance with Art. 6 Para. 1 S. 1 lit. a DSGVO. You can revoke your consent at any time by sending an email to privacy@prematchapp.de (for more information about the legal consequences of this revocation, see section 12).

The personal data collected will be deleted within a maximum of 3 months after the request has been dealt with, unless there is a legal obligation to retain the data or the retention is necessary to protect the legitimate interest of the person responsible or a third party.

8. participation in a raffle

When we run a competition, we collect contact details and a shipping address for this purpose. This data is deleted after the competition has been completed, unless there is a legal obligation to retain it.

Should Prematch conduct a competition together with a third party provider, the participants will be expressly informed of this. In this case, contact and/or shipping data may be passed on to the third-party provider.  

The legal basis for this data processing is your consent in accordance with Art. 6 para. 1 p. 1 lit. a DSGVO. You can revoke your consent at any time by sending an email to privacy@prematchapp.de (for more information about the legal consequences of this revocation, see section 12).

 

9. conclusion of a contract for consideration

When concluding a contract, we generally collect the following personal data for the purpose of executing the contract:

  • Salutation
  • First and last name
  • Address
  • Telephone number
  • E-mail address

If you provide us with further data and it is necessary for the execution of the contract, this data will also be stored and processed.

The legal basis for the collection of this data is Art. 6 para. 1 p. 1 lit. b DSGVO (collection of data required for the performance of a contract). Without transmission of this data, the contract cannot be concluded.

The personal data is stored until the expiry of the statutory retention obligation and then deleted. As a rule, the retention and documentation obligations under tax and commercial law are decisive for the storage period.    

10. videos

We have embedded videos in our app that are stored on YouTube. YouTube is a company of YouTube LLC, 901 Cherry Ave, San Bruno, CA 94066, USA. When you use our app, a connection is established to YouTube's servers. In doing so, YouTube receives information that you have accessed the corresponding subpage. If you are logged into your YouTube account, YouTube has the option of creating a link between your user behaviour and your YouTube profile. This can be avoided by logging out of your YouTube account. Even if you are not logged in to YouTube, YouTube collects and stores data about your user behaviour for advertising purposes. You can prevent this by deactivating the "Personalised advertising on the web" button in your Google settings. Further information on the processing of personal data by YouTube can be found at the following URL:
www.google.de/intl/de/policies/privacy

The legal basis for data processing is Art. 6 (1) sentence 1 lit. f DSGVO, according to which processing is lawful if the processing is necessary to protect the legitimate interests of the controller or a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, override these interests.

11. third-party advertising and push notifications

The first time you use our app, you will be presented with a privacy pop-up where you can choose whether or not to consent to advertising and analytics technologies. This consent is not required to use the app. You will also be asked for permission to receive push notifications. This permission is also not required to use the app.

If you have agreed to the use of analysis technologies, your usage behaviour will be evaluated anonymously using pseudonyms. If you have activated push notifications, you will receive information about events that may be of interest to you (e.g. goals from your favourite club). We use various Firebase services for this purpose, including Remote Config, A/B Testing, Performance Monitoring, Crashlytics, Predictions and App Distribution. These are services provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. You can find more information about how this company handles your personal data at:

https://policies.google.com/?hl=de

In addition, we use Segment, a service provided by Segment Technologies Ireland, Limited c/o Segment.io, Inc. 101 Spear Street, Fl 1 San Francisco, CA 94105 USA. This service allows us to collect and organise user data in order to forward relevant data to our service provider Amplitude. You can find more information about how this company handles your personal data at:

https://segment.com/legal/privacy/

Amplitude is a service of Amplitude, Inc., 631 Howard Street, Floor 5, San Francisco, CA 94105, USA). You can find more information about how this company handles your personal data at:

https://amplitude.com/privacy

We also use Appsflyer, a service provided by Appsflyer, Ltd. , 100 1st St 25th floor, San Francisco, CA 94105, United States. For more information about how this company handles your personal data, please visit:

https://www.appsflyer.com/legal/privacy-policy/

In addition, we use Smartlook, a service of Smartlook.com, s.r.o., Šumavská 524/31, Veveří, 602 00 Brno, Czech Republic, EU  

The tool is a technical solution for heat mapping and session recording of mobile apps and helps us to further optimise our app based on observable user behaviour to meet emerging user needs.

You can find more information about how this company handles your personal data at:

privacy@smartlook.com

The legal basis for this data processing is your consent in accordance with Art. 6 para. 1 p. 1 lit. a DSGVO. You can revoke your consent at any time by sending an email to privacy@prematchapp.de (for more information on the legal consequences of this revocation, see section 12). In addition, the following further options are available to you for revoking your consent:

  • You can prevent the delivery of personalised advertising by selecting the appropriate setting in your operating system:
  • iOS: In the "Settings" application, the option "No ad tracking" can be activated under the menu item "Privacy" and the sub-item "Advertising".
  • Android: In the "Google Settings" application, the option "Disable interest-based advertising" can be activated under the menu item "Ads".
  • You can activate the "Opt-Out" button in our app under the menu item "Profile" and the sub-item "Privacy".

12. disclosure of data to third parties

Personal data will only be disclosed by us as described above and to third parties if:

  • the data subject has given his or her express consent in accordance with Art. 6 (1) sentence 1 lit. a DSGVO,
  • the disclosure is necessary in accordance with Art. 6 (1) sentence 1 lit. f DSGVO for the assertion, exercise or defence of legal claims and there is no reason to assume that the data subject has an overriding interest worthy of protection in not having this disclosure,
  • there is a legal obligation for the disclosure pursuant to Art. 6 para. 1 sentence 1 lit. c DSGVO, as well as
  • this is legally permissible and necessary according to Art. 6 para. 1 p. 1 lit. b DSGVO for the processing of contractual relationships with the data subject.

We cannot exclude the possibility that third-party providers (e.g. Facebook, Google or Apple) process data outside the EU. Insofar as the data processing does not take place in a third country for which the EU Commission has determined the adequacy of the level of data protection, the providers have undertaken to comply with EU data protection standards.

13. data subject rights

You have that right,

  • In accordance with Art. 7 (3) DSGVO, you may revoke your consent at any time. The revocation does not affect the lawfulness of the processing based on your previous consent. The only consequence of the revocation is that we may no longer continue the data processing based on this consent in the future.
  • to request information about your personal data processed by us pursuant to Art. 15 DSGVO. In particular, you can request information about
  • the purposes of processing,
  • the categories of personal data that are or have been processed,
  • the recipients or categories of recipients to whom your data is or has been disclosed,
  • the planned storage period,
  • the existence of a right to rectification, erasure or restriction of processing or a right to object,
  • the existence of a right of appeal to a supervisory authority,
  • the origin of your data if it has not been collected by us,
  • the existence of automated decision-making, including profiling and, where applicable, meaningful information about the logic involved and the scope and intended effects of such processing for you.
  • In accordance with Art. 16 DSGVO, you have the right to demand the immediate correction of any incorrect personal data relating to you or the completion of your personal data stored by us, insofar as this is incomplete,
  • to request the deletion of your personal data stored by us in accordance with Art. 17 DSGVO. This does not apply if the processing of your data is necessary for the exercise of the right to freedom of expression and information, for compliance with a legal obligation, for reasons of public interest in the field of public health, for archiving purposes in the public interest, scientific or historical research purposes or for statistical purposes, for the assertion, exercise or defence of legal claims.
  • You have the right to request the restriction of the processing of your personal data in accordance with Art. 18 DSGVO. This applies if you dispute the accuracy of the data, the processing is unlawful, but you refuse to delete the data and instead request the restriction of data use, we no longer need the data, but you need the data to assert, exercise or defend legal claims, you have objected to the processing pursuant to Art. 21 Para. 1 DSGVO, or if you have a legitimate interest in the processing of your personal data.
  • In accordance with Art. 20 DSGVO, you have the right to receive your personal data that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another controller,
  • complain to a supervisory authority in accordance with Art. 77 DSGVO.

As a rule, you can contact the supervisory authority of your usual place of residence or workplace or our registered office. This is the North Rhine-Westphalian State Commissioner for Data Protection and Freedom of Information, Kavalleriestr. 2-4, 40213 Düsseldorf.

14 Right of objection

If your personal data is processed on the basis of legitimate interests pursuant to Art. 6 (1) sentence 1 lit. f DSGVO, you have the right to object to the processing pursuant to Art. 21 DSGVO, provided that there are grounds for doing so that arise from your particular situation. If you wish to exercise your right to object, please send an email to privacy@prematchapp.de.