PRIVACY NOTICE

We, at Azerion Sports B.V. (“Azerion”, “we”, “us” or “our”) respect your privacy and recognise the importance of providing a secure environment for your personal data. Therefore, we are committed to being transparent about how we collect and process your personal data.

This privacy notice (“Privacy Notice”) gives information to you regarding the processing of your personal data by us as a data controller within the Fanzone applications offered by sports clubs (“Services''), as detailed below, and it applies whenever you use our Services. The purpose of this Privacy Notice is to inform you as a user about why and how we process your personal data (that is any information that can be linked or attributed to you, (“Personal Data”) when you access and use our Services. This includes information regarding with whom we will share your Personal Data, how long we will retain it, and which rights you have in relation to the processing.

As Azerion Sports, we assist the sports clubs (“Clubs”) by developing/providing Fanzone applications to foster their interactions and communication with their fans. For such activities within Services, we act under the instructions of Clubs as a processor; including assisting Clubs to connect the integrated ticket or other merchandise products as well as other features (such as newsletters), to provide application governance (such as hosting, content delivery networks, account creation features), to identify and correct any bugs/errors. Please refer to the club’s Privacy Notice for more information on the processing of your personal data by Clubs as data controller.

GENERAL INFORMATION

In this part of our Privacy Notice, you will find general information about how we process your Personal Data when you use our Services. For specific information with more details about our processing activities, please see the specific information below.

1. Who is Responsible for the processing of your Personal Data?

Azerion Sports B.V., Boeing Avenue 30, 1119 PE, SCHIPHOL-RIJK, the Netherlands is responsible (“the data controller”) for the processing of your Personal Data.

2. What types of Personal Data do we process and how do we collect it?

When you use our Services, we collect, use, store and transfer different kinds of Personal Data. As a general principle, we do not collect and do not ask you to provide any “special categories of Personal Data”, which is any particularly protected information such as data concerning health, religion, political opinions or philosophical beliefs, sexual preferences or orientation.

2.1 Personal Data we receive or generate from your use of our Services

When you use our Services, we also process device-related information and information about how you interact with our Services, including:

Technical information: We collect information about your device/device settings you use for the purposes described below. The information we obtain from your device(s) includes the type of your device, OS, user-agent, screen resolution, device ID(s), user ID, IDFA or Google Advertising ID, online identifiers (your IP address), timestamp, geolocation data (based on your IP address and limited to the country), app screens visited and other technical information.
Your usage: We collect information about how you use our Services. This information includes the actions you take within the app (e.g. your achievements, purchase events, the amount you spent in), the time and duration of your activity, and your interaction with advertisements (clicks, installs and creative views).

2.2. Personal Data we collect from third parties

In certain scenarios, we will also obtain your Personal Data from third parties, in strict compliance with applicable data protection laws and regulations.

We may receive information about your approximate geolocation (the country you are located in) from third parties (e.g. Google). We use this information to comply with our legal obligations applying to the processing of your Personal Data, customize certain services to your location, and for fraud or abuse prevention purposes.

We may also receive information from sports clubs about your customer service requests and this information will be processed together with your IP address, device information (device ID, model, OS, game language, carrier), the user ID, user segment, and the last steps taken within our Services. We process this data on the basis of the performance of a contract as far as the information is required to answer your request. The continued storage of your request history is based on our legitimate interest, in order to improve our services and for potential legal disputes.

To learn more about which data is processed when you use our Services, please see the section with service specific information below.

3. Do we collect data from minors?

The Services are not targeted towards minors. Our services can only be used if the user is of legal age. If you believe that a user might be under the legal age, please contact our support team at dpo@azerion.com.

4. For what purpose do we process your Personal Data?

Depending on which Service you are using and which privacy settings you have selected, we process your Personal Data for the following purposes:

Provision and improvement of our Services

to identify and correct any bugs/errors
to indicate the popularity of our Services
to assess the quality of our Services
to understand and improve your online experience
to understand usage of our Services across all our group companies to support strategy and growth

Marketing and analytics

to deliver (targeted and non-targeted) advertising in our Services
to show you advertisements for our Services on other websites or apps
to measure the effectiveness of advertising
to personalize advertising for you
to pay our business partners for the promotion of our Services
to understand usage of our Services across all our group companies to support strategy and growth

Prevention of fraud and illegal activity

to investigate fraud and illegal behavior in our Services and reporting it to relevant authorities
to enforce our policies and terms of use

Compliance with our legal or regulatory obligations

to determine the legal requirements for processing of your Personal Data (based on your location and your age)
to respond to your requests related to your data subject rights
to comply with our legal obligations (e.g. tax and accounting obligations and any request from a legal authority)
to inform you about any changes to this Privacy Notice

Please see the section with service specific information below for a more detailed description of the purposes for which we process your Personal Data within our Services.

5. On which legal basis do we process your Personal Data?

We process your Personal Data for the purposes described in this Privacy Policy, based on the following legal grounds:

Your consent: We process your Personal Data if you have provided your consent for a specific purpose. For example, when you use our Services for the first time, we ask for your consent for the data processing in the context of showing you personalized content, offers and recommendations and for showing you interest based ads and analytics. We also show you just-in-time contextual notifications and consent pop-ups to obtain your consent for further processing activities. You have the right to withdraw your consent at any time, for example by changing your in-app settings. Please note that this will not affect any processing carried out before you withdraw your consent.
Performance of a contract: We process your Personal Data for the performance of a contract or to take steps prior to entering into a contract to which you are party, for example, where it is necessary for the support the operation of the appor facilitate the delivery of requested services.
Compliance with legal obligations to which we are subject: We process your Personal Data to comply with legal obligations, for example, in order to verify your age, for tax and accounting purposes or legal disputes as well as any requests or claims from legal authorities.
Legitimate interests: We also process your Personal Data to the extent that the processing is necessary for our legitimate interests or those of third parties while applying appropriate safeguards that protect your privacy. For example, we process your Personal Data for improvement of the Service provided to you or to provide you with a better user experience or we transfer your personal data across all our group companies for administrative transfers as well as to determine the size of the user base of our Services. We may also disclose your Personal Data to legal authorities for prevention of a crime, facilitation of an investigation related to public safety, protect the security or integrity of our Service.

Please see for additional information the section with service specific information below.

6. With whom do we share your Personal Data?

We will not disclose your Personal Data to any party who is not authorized to process them. To manage our Services, we will share your Personal Data internally with members of our responsible departments, technical support or customer support and in each case only if access to your Personal Data is necessary for the performance of their roles.

Moreover, and only when necessary to fulfill the purposes mentioned above, we disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services:

Group companies: We share your personal data with our group companies which are responsible for internal analytics for the purposes of cross-product audience measurement. Where we share your personal data with our group company, we have appropriate agreements (an intra-company data sharing agreement) in place to ensure that your personal data is processed in compliance.
Backend as a service provider: In order to improve our development productivity while delivering high-quality service to you, we use backend as a service platform in our Services. These platforms automate backend side development for us so that we only have to write and maintain the frontend. In other words, our Services do not need to contain all the code in themselves and instead they fetch information from the backend as a service solution. All features in our Services that you interact with such as advertisements, analytics and consent management platform services are provided via a backend as a service tool. We share your Personal Data with the backend as a service provider to deliver our such services to you. Backend as a service provider also offers analytics services and we share your personal data in this respect to be able to understand how well our services perform.
External service providers: We share your Personal Data with external service providers who perform services on our behalf, like hosting and analytics services. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
External advertising companies: With your consent, we share your Personal Data with third-party advertising companies or allow third-party advertising companies to collect your Personal Data when you use our Services. If you choose not to receive personalized ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific. Please note that by clicking on a third-party advertisement, you may be redirected to the third-party advertiser’s environment over which the third party is in control.
Law enforcement, government authorities or courts: We disclose your Personal Data in response to lawful requests from public authorities, including law enforcement, government authorities, supervisory authorities or courts. We may also disclose your Personal Data to legal authorities where we believe such disclosure is necessary for prevention of a crime, facilitation of an investigation related to public safety, protect the security or integrity of our Service, or enable us to take precautions against liability or to protect our rights.
Other third parties: We also disclose your Personal Data in the event of any contemplated or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in any insolvency or similar proceedings).

Please see the section with service specific information below for more information about the third parties we share your data with. Furthermore, you can find the third parties your Personal Data be shared with by clicking on the following link:

3rd party list

7. Where will my Personal Data be processed?

In general, your Personal Data is stored on servers outside the European Union (EU)/the European Economic Area (EEA). We have implemented appropriate safeguards to protect your Personal Data when it is transferred outside the EU/EEA, including the execution of the European Commission’s standard data protection clauses (also known as Model Clauses) to provide safeguards for your Personal Data.

8. How do we protect your Personal Data?

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

9. How long do we store your Personal Data?

We will not retain your Personal Data longer than necessary to fulfil the purposes for which the data was collected or to fulfil our legal obligations or necessary for the establishment, exercise or defense of legal claims or resolving disputes. Afterwards, we will delete or anonymize your Personal Data. Please see below for service specific information about how long we will retain your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third-party list available here.

10. What are your rights in respect of your Personal Data?

To the extent permitted by applicable data protection laws and regulations, you have the following rights in relation to your Personal Data:

the right to access the personal data we hold about you
the right to request the update or correction of your personal data
the right to receive your personal data in a structured, commonly used and machine-readable format
the right to request the deletion of your personal data
the right to restrict the processing of your personal data
the right to withdraw your consent

Right to object

In the event and to the extent that we process your Personal Data based on our legitimate interests, you have the right to object to the processing on specific grounds relating to your particular situation. In such cases we will no longer process your Personal Data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms, or for the establishment, exercise or defense of legal claims.

You also have the right to object where we are processing your Personal Data for direct marketing purposes (including profiling). In such a case, we will stop processing your Personal Data for marketing purposes.

You can exercise these rights by sending a request to the contact details set out below, providing your email address and other mandatory information as well as a description of your request.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority, for example the Autoriteit Persoonsgegevens in the Netherlands.

11. How can you contact us?

If you have any queries about this Privacy Notice or how we use your Personal Data, please contact our customer support at dpo@azerion.com.

12. How often do we update this Privacy Notice?

We regularly review this Privacy Notice. When there is an important change that will have a relevant impact on the processing of your Personal Data, we will inform you by email if we have your email address. If we do not have your email address, for example you did not create an account, we will inform you with a banner or message on our Website.

This Privacy Notice was last updated on:

Version: Last Updated:

2.0 01.12.2023

SERVICE SPECIFIC INFORMATION

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes that apply, please see above.

Analytics:

For the analytics, we process information about your device (device type, OS, user-agent, screen resolution), time-stamp, IP address, app screens visited. We process this information to better understand how you use our Services and to improve our websites. We also process your IP address and user id to determine the number of unique users of our Services within our group companies.

We process this information based on your consent, provided in the consent pop-up which will be shown to you when you access the app for the first time.

Advertising

On our Services, we show advertising from different advertising companies.As further explained below, such advertising is personalized or non-personalized (contextual) based on your preferences.

Personalized Advertising: In cases where you provide consent for personalized advertising, we share your Personal Data, including device type, OS, user-agent, screen resolution), your location data, your in-app activity (such as purchase events and your fan experience game play sessions), information regarding the delivery of ads and your interaction with them, through our advertising platform with third-party advertising platform
Non-personalized/Contextual Advertising: We may also show you ads that do not reflect your interests and are content specific instead of user specific. Whenever applicable, we rely on legitimate interests to serve you contextual advertising without using any tracking technology.

We also use this information to measure how effective these ads are. In our consent pop-up which will be shown to you the first time you use our Services, you can choose from which advertising company you would like to receive personalized ads or choose not to accept receiving personalized ads at all. You can adjust your preferences at any time in your privacy settings. If you choose not to receive personalised ads at all, we will still show you ads, but they may not reflect your interests as those ads will be content specific and not user specific.

Hosting

Our Services are hosted by external companies providing servers. Every time you make a request, for example by clicking on a link on our Services, the information allowing this request (e.g. device information and information on requested content) as well as online identifiers (your IP address) will be sent to the external servers. This data is used to show you the content you requested. We process this data on the basis of legitimate interest, to provide and improve our Games and ensure its functionality.