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PRIVACY POLICY FOR PLAYANYWHERE

This Privacy Policy (hereinafter, the "Policy") aims to regulate the processing of personal data carried out by LaLiga Group International, S.L. (hereinafter, “LALIGA”) through the PlayAnywhere website (hereinafter, the "Platform" or the "WEB").

To access the full Gamification content of the Platform, you must register with the LALIGA Ecosystem, through which you access an environment created by LALIGA, composed of various LALIGA applications and websites. Through a common registration system implemented by LALIGA across these assets (LALIGA Single Sign-On), each user receives a unique identifier so that any selection or modification of preferences or request for deletion you make on one of the applications or websites that are part of the ecosystem will affect the entire LALIGA Ecosystem environment. Follow the link to learn more about the LALIGA Ecosystem.

Who is responsible for processing your personal data?

Your personal data will be processed by LALIGA, with NIF: B05421805 and registered address at Calle Torrelaguna 60, 28043, Madrid. Contact the Data Protection Officer of LALIGA: dpo@laliga.es

Where do we obtain your personal data from?

LALIGA will process the data you provide through the registration form (email address as mandatory data) and other data inferred as a result of the use and activity you engage in on the website (registered user ID; device ID; operating system; device model and telemetry, for example, it will also be recorded when you click on specific content or how long you stay on the asset) or your interactions with communications we send you via web notifications or email, if applicable (for example, clicking on the content of a communication). Likewise, if you are a user of another asset managed by LALIGA that is part of the LALIGA Ecosystem, LALIGA may process the personal data mentioned above, declared or inferred in those assets, on the website.

Importing data from social networks

We inform you that you can use your social networks to register with the LALIGA Ecosystem. Additionally, if you consent, the social network you choose may share additional information with LALIGA to complete your profile on LALIGA's asset.

Data shared via Facebook:

  • Name and profile picture (Required for registration. However, please note that LALIGA does not process your profile picture)
  • Email address (Optional)
  • Birthday (Optional)
  • Posts on the timeline (Optional. Your public and private timeline posts, including photos and videos, information about tagged places in them, and the types of reactions they receive)
  • Gender (Optional)
  • Page likes (Optional)
  • Current city (Optional)
  • Categories of interests:
    • Food,
    • Animals and Pets,
    • Art and Culture,
    • Banking, Finance and Economics,
    • A/coho/ic Beverages,
    • Beauty,
    • Cinema, Theater and Musicals,
    • Sports,
    • Electronics and lnformation Technology,
    • Energy, Science and lndustry,
    • Social Groups,
    • Home and Housing,
    • Children,
    • Media,
    • Fashion,
    • Engine,
    • Fema/e,
    • Music,
    • Leisure and Entertainment,
    • NGOs and Causes,
    • Health, Hygiene and Wellness,
    • lnsurance,
    • Professional Services,
    • Shopping,
    • Technology and Internet,
    • Te/ecommunications,
    • TV and Radio,
    • Travel,
    • Video games,
    • Viral Media

Thanks to page likes and biography posts, LALIGA will obtain the following inferred data

  • Engagement" value: this value measures the volume of interactions that the user has with the Facebook wall of the official LALIGA page.
  • Social" value: this value measures the user's influence on social networks.
  • Promotion" value: users' walls are analyzed for references to sweepstakes, promotions and sweepstakes entries, and a value is assigned that measures the promotional ratio on the user's wall. lt also checks whether the user's profile follows Facebook pages dedicated to advertising promotions, raffles and sweepstakes.
  • Fan Value This score is a combination of the previous 3 that ranks users by the value obtained (a user with a higher score will be considered a more valuable user).

Data shared through Google:

  • Name and surname (Required for registration)
  • E-mail address (Required for registration)
  • Birthday (Optional).
  • Gender (Optional).
  • Country (Optional).
  • Youtube channels you follow (Optional).

The use (of the application) and transfer of information received from the Google APls to any other application will adhere to the Google API Services User Data Policy, including limited use requirements.

In this regard, we inform you that LALIGA uses the tool of a third-party technical provider for the structuring of the information provided by Facebook and Google.

We also remind you that LALIGA is not responsible for the legal adequacy of the social network you use to carry out the registration in LALIGA's assets. For this reason we recommend that you review the terms of use and privacy policy of the social networks that you are going to use for this purpose in order that you can verify that the treatment that is done with your personal data is in accordance with your expectations of privacy and data protection regulations that in each case is applicable.

Once the data have been imported and incorporated into your registered user account, your data will be integrated into LALIGA Ecosystem and processed by LALIGA for the purposes described in this Privacy Policy.

Far what purpose do we process your personal data?

Main Purposes

  • Access and registration to the Platform: Your personal data (identifiers of your device and, in case you register, your email) will be processed by LALIGA to allow you access and registration on the Platform Also, LALIGA will use your data to allow you access to other assets of LALIGA Ecosystem We inform you that LALIGA uses technical providers to provide these services.

 

In this regard, we inform you that LALIGA uses the services of a third party provider (RP Solutions, lnc) which involves the international transfer to the United States, a country that guarantees a level of protection equivalent to that of the European Union for personal data transferred from Europe to third party providers in the United States that are adhered to the Data Privacy Framework, among which is that provider.

 

  • Participation in Gamification: In the event that you register, we inform you that your email will be processed by LALIGA for the purpose of managing your participation in the gamification activities carried out through the website, so that you can participate fully in the gamification activities and your score will be saved lf you do not register, you will be able to participate in a limited way in the gamification activities but your score will not be saved.

The legal basis for the purposes mentioned above is that the processing is necessary for the execution of the conditions of use of the website under the provisions of art. 6.1 b) of the General Data Protection Regulation. The data necessary to carry out the access to the Platform are the identifiers of your device; and, in the event that you want to register and participate fully in the gamification offered through the website, in addition to the device identifiers, it will be necessary to treat your email. lf you do not provide this information we will not be able to offer you the required services.

  • Internal reporting: Likewise, LALIGA will process in aggregate form the personal data you have provided through the social login (where applicable, age, gender, language, city), the usage data of the website and other LALIGA Ecosystem assets you use (user ID, device ID (IDFA or where applicable, IDFV), device model, operating system and telemetry, e.g. clicking on a particular content or the time you stay on the asset) and finally, interactions with communications of any kind you receive (e.g., clicking on the content of a communication), for the development of relevant metrics and statistics that allow LALIGA to analyze the use made of the website by the different user segments generated and the impact of its campaigns, assessing the interest that the campaigns have aroused among the aforementioned segments based on the data analyzed. In particular, LALIGA will carry out aggregate segmentations based on the aforementioned data, within which are: 
    • Segmentation according to gender and age (e.g. 20 female users of X years old have viewed the page content on X date).

In this regard, we inform you that LALIGA uses technical suppliers to carry out interna! reporting.

The legal basis for the aforementioned purposes is that the processing is necessary for the satisfaction of the legitimate interest of LALIGA under the provisions of art.

6.1 f) of the General Data Protection Regulation, consisting of extracting learnings from the information provided and obtained from users that allows it to improve the website and optimize the communication campaigns it carries out based on the interest that these generate among the different groups of users. Before doing so, we inform you that LALIGA has carried out an analysis of proportionality between its legitimate interest and the rights and freedoms of its users. You can request the conclusions of this analysis through lopd@laliga.es.

You have the right to object to the aforementioned purpose at any time in accordance with the procedure described in the section "What are your rights when you provide us with your personal data?"

Additional Purposes

Below are the additional purposes for which LALIGA will process your personal data:

  • LALIGA commercial communications: So that LALIGA can send you commercial communications via email, push notifications, in-app or SMS or other instant messaging channels about its activities (the competitions it organizes, campaigns, public viewings, shows or live events), products (applications, web platforms and games developed by LALIGA), services, contests, offers, sweepstakes and/or promotions owned by LALIGA, or contests, offers, sweepstakes and/or promotions carried out by LALIGA on products and services promoted Jointly by LALIGA with its official sponsors, which you can consult here, national federations or national and international television channels.

For this purpose, LALIGA will only process the e-mail address, your user ID in the registration form.

We also inform you that, in order to send you commercial communications via email or SMS, LALIGA uses a service provided by a third party provider (salesforce.com EMEA Limited) which involves the international transfer of the email address you have provided to the United States, a country that guarantees a level of protection equivalent to that of the European Union for personal data transferred from Europe to third party providers in the United States that are adhered to the Data Privacy Framework, including this provider.

The legal basis for the processing of your data for the above-mentioned purpose is the consent you have given LIS to process your data for the specific purposes selected in accordance with the provisions of art 6.1 a) of the General Data Protection Regulation. Your personal data will be kept for this purpose until you revoke your consent.

You have the right to withdraw your consent at any time in accordance with the procedure described in the section "What are your rights when you provide us with your personal data?”, without affecting the lawfulness of the consent-based processing prior to its withdrawal.

  • Development of simple segmentations: So that LALIGA can send you segmented commercial communications via email, SMS or other instant messaging channels, about LALIGA's products and services. These communications will be made based on the information you have provided us through registration (for example, we will send you communications about products that may be of interest to you based on your age, favorite team or your province of residence).

The information used for the elaboration of segments will be only that declared by the interested party in the registration of any of the assets that make up LALIGA Ecosystem (in this case, gender, country, city, age and favorite team or sport), with a low level of detail on the user's profile without using information inferred from the interested party or from third party sources, being, in any case, segmentations not very exhaustive. In this way, commercial communications can be sent according to the simple segments created with the aforementioned information, avoiding sending content that has no relation to you. 

In this regard, we inform you that LALIGA uses consulting and technical support providers to carry out simple segmentations of users.

The legal basis for the aforementioned purpose is that the processing is necessary for the satisfaction of the legitimate interest of LALIGA under the provisions of art 6.1 f) of the General Data Protection Regulation, consisting of taking effective advantage of the personal data provided by the user to achieve greater interest and return of the communications sent Before doing so, we inform you that LALIGA has carried out an analysis of proportionality between its legitimate interest and the rights  and  freedoms  of  its  users,  the  conclusions  of  which  you  can  request  at     lopd@laliga.es.

You have the right to object to the aforementioned purpose at any time in accordance with the procedure described in the section "

What are your rights when you provide us with your personal data?"

In no case will the elaboration of segments made by LALIGA produce legal effects or significantly affect you in any similar way.

  • Elaboration of exhaustive profiles: lf you give us your permission, LALIGA will create a comprehensive profile of you so that it can offer you personalized experiences, information and products through the sending of personalized commercial communications via email, SMS, or other instant messaging channels, sending you personalized push or in-app notifications (provided that you have granted consent for the purpose "LALIGA commercial communications") or showing you banners with personalized advertising on websites, applications or social networks about LALIGA products and services (for example, if we identify that you are a fan of a particular club, we will offer you personalized incentives, such as a jersey of your favorite team).

Thus, the aforementioned information will be directed to segments (groups of users based on the information obtained from them or your use of the Website or other assets of the LALIGA Ecosystem) that we can create based on the following data sources:

  • The information you provide during registration (in this case, through information obtained from other assets of the LALIGA Ecosystem);
  • Social login (in this case, first and last name, email address, birthday, gender, city and province of residence, interest categories, as well as inferred values—engagement, social, promotion, and fan value—obtained from your Facebook timeline posts and page likes);
  • Interactions with communications or notifications you receive (for example, clicking on the content of a communication);
  • Data inferred as a result of your use and activity on the Platform (device ID, registered user ID, device model, operating system, and telemetry, for example, clicking on specific content or the time spent on the asset).

Additionally, LALIGA will generate these segments considering the following profiling techniques:

  • Individual campaign performance measurement: LALIGA will use information related to open rates, average click rates, email bounces, or subscription cancellation rates to measure the performance of the campaign at the individual level. Consequently, we will segment you based on inferred information and declared data to re-target you with specific campaigns that are more aligned with your interests or include you only in those you have shown more interest in (for example, if you are highly active in certain communications, we may send you more frequent communications of the same type). To this end, we inform you that, through the data management tools provided by social networks where LALIGA has an account, user audiences will be created and shared, within each social network and in an encrypted form, with third-party entities outside of LALIGA to allow them to create their advertising campaigns within the social network.
  • Campaign optimization: You will be excluded from advertising campaigns related to contests you have participated in, apps you have registered for or downloaded, products you have purchased, or services you have previously acquired (for example, we will avoid offering you a LALIGA app if we know you have already downloaded it). To do this, we will cross-reference your information with data obtained from other LALIGA assets you are a user of.
  • Users with similar tastes and preferences: Thanks to the profile LALIGA creates of you, we can send you personalized content by considering other profiles similar to yours (for example, if we identify that other users like you are interested in eSports, we will show you advertising related to eSports).
  • User evaluation: LALIGA will derive an unknown variable from known variables provided or inferred about you in order to conduct an analysis of its users, aiming to identify those more likely to use or purchase LALIGA products and, if applicable, offer you LALIGA products and services.
  • Retargeting: If you have interacted with LALIGA without registering or using/downloading the corresponding LALIGA asset, LALIGA may use your device's identifying data and/or your email address to target you with advertising in other non-LALIGA environments to achieve the desired interaction.

In this regard, we inform you that LALIGA uses consulting and technical support providers to carry out complex profiling.

In no case will the profiling carried out by LALIGA have legal effects or significantly affect you in a similar way.

The legal basis for processing your data for the aforementioned purpose is the consent you have granted us for processing your data for the specific purposes selected in accordance with Article 6.1(a) of the General Data Protection Regulation. Your personal data will be retained for this purpose until you revoke the consent granted.

You have the right to withdraw your consent at any time in accordance with the procedure described in the section "What are your rights when you provide us with your personal data?" without affecting the legality of the processing based on the consent prior to its withdrawal.

 How long will we keep your personal data?

The personal data we process will be kept foras long as the purposes for which they were collected persist and/or you do not revoke any consent you may have given, or you do not exercise your rights of deletion, opposition or limitation of processing.

In this sense, once the above term has expired, LALIGA will keep your personal data duly blocked for the sole purpose of meeting any liability of any kind that may arise

  • Access and registration to the Platform: the data provided for access and, where appropriate, registration on the Platform, will be retained as long as you do not request the deletion of your data, this purpose persists and, once it is finished, during the period of limitation of legal actions that may arise from it.
  • Participation in Gamification: the data provided for participation in the gamification offered through the Platform will be kept as long as you do not request the deletion of your data, this purpose persists and, once it is finished, during the period of limitation of legal actions that may arise from it.
  • Internal reports: the data provided for interna! reports will be kept as long as you do not request the deletion of your data, this purpose persists, you do not object to the processing and, once this purpose has been fulfilled, during the period of limitation of the legal actions that may arise from it.
  • LALIGA commercial communications: the data provided for commercial communications made by LALIGA will be kept as long as you do not request the deletion of your data, this purpose persists, you do not revoke the consent given or limit the treatment and, once this purpose is fulfilled, during the period of limitation of legal actions that may arise from it.
  • Elaboration of simple segmentations: the data provided for the elaboration of simple profiles will be kept as long as you do not request the deletion of your data, this purpose persists, you do not object to the processing and, once this purpose has been fulfilled, during the period of limitation of the legal actions that may arise from it.
  • Elaboration of exhaustive profiles: the data provided for the elaboration of exhaustive profiles will be kept as long as you do not request the deletion of your data, this purpose persists, you do not revoke the consent granted or limit the treatment and, once this purpose has been fulfilled, during the period of limitation of the legal actions that may arise from it.

Such personal data will be deleted when these deadlines expire.

To which recipients will your personal data be communicated?

Your personal data may be communicated to other persons or companies to be used for their own purposes provided that you give us your consent by checking the box provided or on the occasion of the service you request. In this sense, we inform you that your personal data will be communicated to third parties that have a relationship with LALIGA depending on the purpose of processing

  • LALIGA will communicate your personal data obtained in the assets belonging to LALIGA Ecosystem of which you are a user (email and, where appropriate, name, surname, telephone and country), to your Favorite Team and to third parties so that they can send you commercial communications about their activities, products, services, contests, offers and/or promotions.

In this regard, we inform you that your personal data will only be communicated to third parties and soccer teams belonging to the first and second division of the National Professional Football League, which have formalized a collaboration agreement with LALIGA. In the following link, you have at your disposal a list of third parties and soccer teams that currently have an agreement with LALIGA and that, if you authorize us, may send you commercial communications.

We also inform you that the communication of your data to third parties may involve, in some cases, the international transfer of your data to countries that either have an adequate level of protection, comparable to that of the European Union, or do not guarantee it. In the latter case, LALIGA has taken appropriate measures to ensure that your data are treated by a level of protection equivalent to that of the European Union. For this reason, LALIGA has signed standard contractual clauses adopted by the European Commission with such third parties under the provisions of art. 46.2 c) of the General Data Protection Regulation, including additional guarantees and obligations, after analysis of the impact of the transfer made, addressed to them for greater security and transparency possible. The contents of the standard contractual clauses are available upon request at lopd@laliga.es 

The legal basis that legitimizes this communication of personal data is the consent you have given us under the provisions of art. 6.1 a) of the General Data Protection Regulation.

Also, LALIGA may provide personal data and any other user information when required by public authorities in the exercise of the functions that are legitimately attributed and in accordance with the provisions that may be applicable.

Similarly, LALIGA uses some subcontracted entities that will access personal data and information as processors or sub-processors to provide LALIGA with a necessary service. Thus, LALIGA uses technical suppliers and technical and business consulting in order to carry out the purposes indicated in the section "For what purposes do we process your personal data?".

These service providers signa contract that obligates them to use your personal information only for the provision of the services described in this policy.

What are your rights when you provide us with your personal data?

We inform you that, at any time, you can exercise your rights of access, rectification, opposition, deletion, portability, not to be subject to automated decisions, limitation of treatment and to revoke your consent at any time before LALIGA.

What are your rights as a user?

  • Right of access: you have the right to obtain confirmation as to whether LALIGA processes your personal data, as well as to access them.
  • Right of rectification you may request the modification or rectification of inaccurate personal data.
  • Right of deletion: you may request the deletion of your personal data
  • Right to limitation of processing: In certain circumstances, you may request the limitation of the processing of your data, in which case they will only be kept for the exercise or defense of claims.
  • Right of opposition you may oppose the processing of your data for the purpose you specify. LALIGA will cease processing the data, except for compelling legitimate reasons, or the exercise or defense of possible claims.
  • Right not to be subject to automated individual decisions: you have the right not to be subject to a decision based solely on automated processing, including profiling, that may produce legal effects on you or similarly significantly affect you.
  • Right of portability: if the WEBSITE allows it, you may exercise the right to the portability of your data, in a structured, commonly used and machine-readable format, and to transmit it to another data controller.

How do I exercise my rights?

By sending an email to lopd@laliga.es. The exercise of your rights will be completely free of charge.

lf you have given your consent for the purposes for which you have been asked for when accessing and, if applicable, registering on the website, you may revoke your consent at any time by following the procedure established in each of the commercial communications you receive, through the Subscription Center found in your user profile on the WEB or by sending an e-mail to the following address: lopd@laliga.es.

The opposition to a certain purpose or the revocation of the consents granted will not affect the use you can make of the WEBSITE or the lawfulness of the processing prior to the opposition or revocation of consent.

On the other hand, if you have registered on the web through a social network or similar service, you can exercise your right to the deletion of your data by disabling the service "LALIGA Ecosystem" within the services connected to your profile on the social network. For more information see the conditions of each service:

•    Google https://myaccount.google.com/permissions

•    Facebook: https://facebook.com/help/218345114850283

Finally, if you consider that you have not obtained satisfaction in the exercise of your rights or that the processing of your data has not been carried out in accordance with the applicable regulations, you can contact LALIGA's data protection officer at the e-mail address dpo@laliga.es or file a complaint with the Spanish Data Protection Agency through its website www.aepd.es.

Are there any limitations?

LALIGA informs you that to access and, where appropriate, register on the Platform you must be at least 14 years old.