Data Protection and Data Security Provisions (DSP) concerning Utilisation of the Android Application Sports Mates and its website - https://sportsmates.appLast amendment on 01 December 2021
1. Responsible entity/ data protection officer / representative
Responsible for the data processing described herein, unless otherwise stated, is Null Ltd. Bulgaria, c/o Nikolay Ninarski, Prof. Georgi Zlatarski 9A, Sofia 1700. If you have any data protection requests, you can send them to us at the following contact address: Null Ltd. Bulgaria, Data Protection, c/o SpaceP5 GmbH, Prof. Georgi Zlatarski 9A, Sofia 1700, e-mail: firstname.lastname@example.org.
Our representative in the EEA according to Art. 27 GDPR is: Nikolay Ninarski, Null Ltd. Bulgaria, Prof. Georgi Zlatarski 9, 1700 Sofia, Bulgaria, email@example.com.
2. Collection and processing of personal data
We primarily process the personal information that we receive from our customers and other business partners in the course of our business relationship with them and other individuals involved or that we collect from users when operating our websites, apps and other applications.
Insofar as this is permitted, we also extract certain data from publicly accessible sources (e.g. debt collection registers, land registers, commercial registers, media, Internet). In addition to the data that you disclose directly to us, the categories of personal data that we receive about you from third parties, in particular information from public records, information about you from the media and the internet (as far as this is indicated in a specific case, e.g. in the context of a job application, press review, marketing/sales, etc.), include your addresses and, if applicable, your interests and other socio-demographic data (for marketing purposes) and data in connection with the use of the website (e.g. IP address, MAC address of the smartphone or computer, information about your device and settings, cookies, date and time of the visit, pages and content accessed, functions used, referring website, location information).
3. Purposes of data processing and legal basis
We use the personal data collected by us primarily in order to execute and fulfil our contracts with our customers and business partners, in particular in the context of the use of our internet applications, as well as to comply with our legal obligations at home and abroad. If you work for such a customer or business partner, you may also be affected with your personal data in this role.
In addition, we process personal data from you and further persons, to the extent permitted and deemed necessary by us, also for the following purposes in which we (and occasionally also third parties) have a legitimate interest corresponding to the purpose:
- Offering and development of our offers, services and websites, apps and other platforms on which we are present;
- Communication with third parties and processing of their inquiries (e.g. applications, media inquiries);
- Review and optimisation of procedures for needs analysis for the purpose of directly addressing customers as well as collection of personal data from publicly accessible sources for the purpose of customer acquisition;
- Advertising and marketing (including the organisation of events), provided that you have not objected to the use of your data (if we send you as an existing customer advertising from us, you can object to this at any time, we will then put you on a blocking list against further advertising messages);
- Market and opinion research, media monitoring;
- Prevention and investigation of criminal offences and other misconduct (e.g. conducting internal investigations, data analysis to combat fraud);
- Ensuring operations, in particular IT, of our websites, apps and further platforms;
- Purchase and sale of business units, companies or parts of companies and other transactions under company law and the related transfer of personal data as well as measures for business management and compliance with legal and regulatory obligations.
If you have given us consent to process your personal data for specific purposes (e.g. upon your registration to receive newsletters or conduct of a background check), we will process your personal data within the scope of and based on this consent, provided we have no other legal basis and we require such a legal basis. A given consent can be revoked at any time, but this has no effect on previous data processing.
4. Cookies / Tracking and other technologies related to the use of our website
We typically use "cookies" and similar techniques that can identify your browser or device on our websites and apps. A cookie is a small file that is sent to your computer or is automatically stored on your computer or mobile device by the web browser used when you visit our website or install an app. In addition to cookies, which are only used during a session and deleted after your visit to our website ("session cookies"), cookies can also be used for a certain period of time (e.g. two years) to store user settings and other information ("permanent cookies"). However, you can set your browser to reject cookies, save them only for one session or otherwise delete them prematurely. Most browsers are preset to accept cookies. We use permanent cookies to save user settings (e.g. language, autologin), so that we can better understand how you use our offers and content, and so that we can display offers and advertisements tailored to you (which may also happen if your surf on websites of other companies, even though they do not know who you are from us, if we even know that ourselves, but only that you previously accessed one of our websites). Certain cookies are set by us, some also by contractual partners with whom we cooperate. If you disable cookies, certain functionalities (such as language selection, login, autologin) may no longer work.
In our newsletters and other marketing e-mails, sometimes and as far as permitted, we also incorporate visible and invisible pictorial elements, by whose retrieval from our servers we can determine whether and when you have opened the e-mail, so that we can measure and better understand how you use our offers and tailor them to you. You can block this in your email program; most are preset to do so.
Through the use of our websites, apps and the consent to receive newsletters and other marketing emails, you agree to the use of these methods. If you do not want that, you must adjust your browser or e-mail program accordingly, or uninstall the app if this cannot be adjusted via the settings.
We may use Google Analytics or similar services on our websites. This is a service provided by third parties who may be located in any country in the world (in the case of Google Analytics, it is Google LLC in the U.S., www.google.com) that enables us to measure and evaluate the use (non-personal) of the website. Permanent cookies set by the service provider are also used for this purpose. The service provider does not receive any personal data from us (nor does it keep any IP addresses), but can track your use of the website, combine this information with data from other websites that you have visited and which are also tracked by service providers, and use this information for its own purposes (e.g. advertising control). If you have registered with the service provider yourself, the service provider will also know you. The processing of your personal data by the service provider is then the responsibility of the service provider in accordance with its data protection provisions. The service provider merely informs us how our respective website is used (no information about you personally).
We further use so-called plug-ins from social networks such as Facebook, Twitter, Youtube, Google+, Pinterest or Instagram on our websites.
This can be seen in each case (typically via corresponding symbols). We have configured these elements to be deactivated by default.
If you activate them (by clicking on them), the operators of the respective social networks can register that you are on our website and where and can use this information for their purposes. The processing of your personal data is then the responsibility of this operator in accordance with its data protection provisions. We do not receive any information about you from them.
5. Data transfer and data transmission abroad
We also disclose data to third parties within the scope of our business activities and the purposes set out in point 3, insofar as this is permitted and appears to us to be necessary, because they process it for us or we are legally obliged to do so. This applies in particular to the following entities:
- Service providers of ours, including contractors (such as IT providers);
- Merchants, suppliers, subcontractors and other business partners;
- Domestic and foreign authorities, offices or courts;
- The public, including visitors of web sites and social media;
- Competitors, industry organisations, associations, organisations and other bodies;
- Acquirers of or parties interested in acquiring business divisions, companies or other parts of Null Ltd. Bulgaria;
- other parties in potential or actual legal proceedings;
- all common recipients.
These recipients are partly in the country, but can be anywhere on earth. In particular, you must expect your data to be transferred to all countries in which SportsMates is represented by branches or other offices, e.g. in Sofia, Bulgaria, to other European countries and the USA, where the service providers we use are located (e.g. Microsoft, Google, Sentry). If we transfer data to a country without adequate legal data protection, we ensure as required by law an adequate level of protection by means of corresponding contracts (namely on the basis of the so-called standard contractual clauses of the European Commission, which can be accessed here, here and here) or so-called binding corporate rules, or we rely on the statutory exceptions of consent of the data subject, contract execution, the determination, exercise or enforcement of legal claims, overriding public interest, published personal data or because it is necessary to protect the integrity of the persons concerned. You can obtain a copy of the contractual guarantees mentioned above at any time from the contact person named under point 1, unless you can retrieve them using the link given above. However, we reserve the right to black out copies for reasons of data protection or confidentiality or to supply only excerpts.
6. Duration of retention of personal data
We process and store your personal data for as long as it is necessary for the fulfilment of our contractual and legal obligations or otherwise the purposes pursued with the processing, i.e. for example for the duration of the entire business relationship (from the initiation, processing to the termination of a contract) as well as beyond in accordance with the legal storage and documentation obligations. It is possible that personal data may be retained for the period in which claims may be asserted against our company and to the extent that we are otherwise required to do so by law or justified business interests require it. (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the above-mentioned purposes, it will be generally and as far as possible deleted or anonymised. For operational data (e.g. system protocols, logs), generally shorter retention periods of twelve months or less apply.
7. Data security
We take appropriate technical and organizational security precautions to protect your personal data from unauthorized access and misuse such as IT and network security solutions, encryption of data carriers and transmissions, pseudonymisation, access control of employees.
8. Obligation to provide personal data
In the context of our business relationship, you must provide the personal data that is necessary for the establishment and conduct of a business relationship and the fulfilment of the associated contractual obligations (you do not normally have a statutory obligation to provide us with data). Without this information, we will generally not be able to enter into or close a contract with you (or the entity or person you represent). Likewise, the website cannot be used if certain information is not disclosed in order to secure data traffic (e.g. IP address).
9. Profiling and automated decision making
We process your personal data partially automated with the objective of evaluating certain personal aspects (profiling). We use profiling in particular to inform and advise you on specific products. We thereby use evaluation tools that allow for demand-oriented communication and advertising, including market and opinion research.
10. Rights of the data subject
You have the right to information, correction, deletion, the right to restrict data processing and otherwise object to our data processing and to the surrender of certain personal data for the purpose of transfer to another location (so-called data portability) within the framework of the data protection law applicable to you and to the extent provided for therein (such as in the case of the GDPR). Please note, however, that we reserve the right to exercise the statutory restrictions on our part, for example if we are obliged to store or process certain data, if we have an overriding interest in it (to the extent that we may invoke it) or if we need it for the assertion of claims. If you incur any costs, we will inform you in advance. We have already informed you about the possibility of revoking your consent in section 3. Please note that the exercise of these rights may conflict with contractual agreements and this may have consequences such as premature termination of the contract or cost consequences. In this case, we will inform you in advance if this has not already been contractually agreed.
The exercise of such rights usually requires that you prove your identity unambiguously (e.g. by a copy of an identity document, where your identity is otherwise unclear or cannot be verified). To exercise your rights you may contact us at the address provided in paragraph 1.
In addition, every data subject has the right to assert his or her claims in court or to file a complaint with the respective data protection authority. The responsible data protection authority in Bulgaria is the Commission for Personal Data Protection (https://www.cpdp.bg/).
We can change this privacy statement at any time without notice. The current version published on our website applies. If the data protection declaration is part of an agreement with you, we will inform you of any changes by e-mail or other suitable means in the event of an update.