Privacy Policy

This Policy was designed to inform you, the app’s visitors, about how your personal data is gathered, used, stored or otherwise processed while browsing the app. We are the owner of this app and we are deemed as the data controller over your personal data. We are: Better Collective A/S, Sankt Annæ Plads 28 1250 Copenhagen K (Hovedstaden), Denmark (DK).

This Privacy Policy may be modified from time to time. Please review it for any essential or minor modifications that may have been made in the meantime. Our Policy is also reviewed once a year. 

This Privacy Policy was reviewed on the 1st of October 2024.

Types of data we collect

By using our services you may disclose various pieces of information, including those that are considered as personal data. When your personal data is processed, you are considered to be data subject and you are entitled to exercise your rights guaranteed by relevant data protection legislation, as explained in this Policy. 

Taking into account that we determine the purposes and means of processing personal data, we are legally considered to be data controller over your personal data on this app. Being a data controller provides us with the opportunity to process your personal data, but also obligates us to protect it in the way regulated by applicable legislation including the EU General Data Protection Regulation (“GDPR”).

Please note that not all mentioned categories of personal data will be processed, in case you choose not to reveal them. Also, different categories will be processed in different situations. Please read more about the purposes for processing your personal data in the “How we use your data” section of this Policy. 

Check the types of personal data we collect, below:

Identification data

Personally identifiable information 

When you create an account, we process your email and username. 

In the event that you decide to participate in a competition organized by us, we may process the following personal data:

• Your email address and username that you used to create your account. If you register for the competition via social media accounts or other platforms, your credentials will also be processed.
• In the event that you win the competition, we will process:

The winner’s name and surname, a copy of your identity card and postal address.

Electronic identification data

When you use our app, we may process the IP address of the device you use, the type and version of browser and operating system you use, as well as the time of logging in, and social media authentication credentials. 

Images

If you choose to upload a profile picture we may process your image.

Preferences

We process information about your favorite team, league and player if you choose to disclose it. We will also know if you like or share our content on your social network profile.

When you enable push notifications, we collect and process certain data that allow us to deliver these alerts to your device. The data processed includes a unique device identifier, the type of operating system and data regarding the use of the application. This information ensures that notifications are tailored and delivered to your device.

The Content You Create

On this app, you can comment on articles you read.

How we use your data

By using our services you may disclose various categories of personal data. You may check which categories of personal data we process in the “Types of data we collect” section of this Policy. Please note that not all mentioned categories of personal data will be processed, in case you choose not to reveal them. Also, different categories will be processed in different situations.

Check below the purposes for processing your personal data.

Identification data

Your PII, which we process when you create an account (e-mail and username) are used to distinguish you from other users. 

The processing of the above data is also necessary for the purposes of authentication (registration for the competition) and to distinguish participants. E-mail addresses will also be used to contact the winner of the competition. Usernames can be used to publish information about the winner on our application. Please be aware that we must announce who the winner of the competition is, in accordance with the transparency obligation regulated by the relevant national regulations.

The processing of the name and surname of the winner is necessary to deliver the prize. Processing a copy of the winner’s ID is necessary to ensure compliance with legal requirements regarding the age threshold for gambling and to identify the winner for the purpose of delivering/paying the prize. The postal address will be processed for the purpose of delivering the prize.

We process the IP address of the device you are using to enable communication between your device and our server, as well as to determine your approximate geographic location, which can be used to further improve our services (for example, showing you content in your language or gambling games that are legal in your country), as well as for analysis and security purposes.

Processing details about your browser and operating system is necessary for us to ensure that our services work properly for you. We will also sometimes need this data to resolve any technical issues that may arise.

Recordings

We may process your recordings such as an image you upload to your profile, for the purpose of profile personalization.

Preferences

Information about the people you follow and those who follow you is available to all users and visitors of this application. We believe that transparency is a very important value, and for this reason, we allow each user, potential user, and even each visitor to this application to assess the trustworthiness of other users of the application and share their knowledge with others.

We process information about your favorite team, league, and player to remember your preferences and provide you with more tailored content.

We process information about the content from our app that you have liked or shared.

By analyzing data on the use of the application, we can customize notifications to better match your interests and preferences, thus increasing their relevance.

Content You Create

We allow you to write comments on this application because we care about your opinion. It is crucial to improving this application, and in this way you can share it with other users.

When and how we collect data

Legal basis

According to the Art. 6. 1. (f) of the General Data Protection Regulation, processing shall be lawful when the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. Our use of your personal data, specifically electronic identification data, may be based on the legitimate interest to ensure the improvement of our product’s effectiveness and our service, measure the current effectiveness of the advertising campaigns that are implemented on our app, solving technical problems should they emerge. We rely on our legitimate interest to enable communication between your device and our server and to determine your approximate geolocation, which may be further used for service customisation and for analytical purposes. 

According to the Art. 6. 1. (a) of the General Data Protection Regulation, processing shall be lawful when the the data subject has given consent to the processing of his or her personal data for one or more specific purposes. We rely on your consent when using your personal data for direct marketing purposes, creating your profile, conducting a competition, enabling the use of our forums and interactions with other users.

Retention and security

We do not collect or retain your personal data longer than is necessary for the purposes explained in this Policy. We store your personal data for different time periods depending on the purpose ot was collected. 

Some personal data may be deleted automatically based on specific schedule (we delete personal data of inactive users after 12 months, or for example after cookie session expire).

We delete personal data when you withdraw previously given consent, such as data collected for the direct marketing purposes. Those would be your personally identifiable information, private habits and interests, personal preferences. 

Personal data we hold about you will be deleted when you chose to exercise your right to deletion. 

We may further retain some personal data for business practices based on our legitimate interests, such as for the product and services improvement, misuse prevention, record – keeping or enforcing our legal rights. Mostly, this refers to your electronic identification data.

We regularly make sure that your data is kept up to date and stored securely. In order to achieve that we apply different technical and organisational measures to ensure the protection of your personal data against accidental or unlawful loss, alteration, theft, unauthorised disclosure or access, unauthorised use, potential data breaches and against all other unlawful forms of data processing.

Based on business needs and security requirements we apply restrictions of access control to your personal data. Access to your personal data is only granted to trained staff with authorisation, whose knowledge and skills are necessary to process personal data we gather adequately.

Know your rights

Processing of personal data that may occur is about you and your personal data. Therefore, you are regarded as a data subject, under the relevant EU Data Protection Law, namely General Data Protection Regulation (‘GDPR’). 

As a data subject, you are entitled to exercise the rights listed below:

Right of access

You have the right to obtain confirmation from us as to whether or not personal data concerning you is being processed, information about the processing of your data, your rights and where applicable to request access to the data.

Right to erasure (right to be forgotten)

In certain circumstances, you have the right to request that we erase the information we hold about you. These are as follows:

• Where the data is no longer needed for the purposes it was collected
• Where you have withdrawn consent for the processing of your data and there is no other lawful basis on which we can continue to process your data
• Where you objected to the processing and there are no overriding legitimate grounds to continue
• Where the data has been unlawfully processed
• Where the data has to be erased for the purpose of the compliance with a legal obligation.

We will be exempt from this obligation if it is impossible to comply with or if the identity of the requester cannot be verified, as we are able to act only upon verifiable consumers’ requests.

Right to rectification

You have the right to ask us to delete inaccurate personal data concerning you. Taking into account the purposes of the data processing, you have the right to have incomplete personal data completed and inaccurate data to be corrected.

Right to object to the processing of your personal data

At any time you have the right to object to our processing of your data on grounds relating to your particular situation. Upon your objection, we will stop processing your data unless we can demonstrate compelling legitimate grounds for continuing the processing which override interests of your fundamental freedoms and rights, or if further processing is necessary for the establishment, exercise or defence of legal claims.

Right to restriction of processing

You have the right to seek the restriction of the processing of your personal data in the following circumstances:

• If the accuracy of the data is contested, processing may be restricted for the period necessary to allow us to verify its’ accuracy;
• The processing is unlawful and you request restriction instead of erasure;
• We no longer need the data for the purposes it was collected, but data is still needed in connection with establishing, exercising and defending legal rights.
• If you objected to the processing of your personal data while awaiting verification on whether our legitimate interests for processing your data overrides the interest of your fundamental rights and freedoms.

Right not to be the subject of automated decision making

You have the right to object to our processing of your data for automated decision making, including profiling, where such processing produces legal effects concerning you or similarly significantly affects you. Upon your legitimate objection, your personal data will no longer be processed for automated decision making.

Right to data portability

Under certain circumstances you have right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format (i.e. in digital form). You have the right to request the transmission of those data to another entity without hindrance from us, if such transmission is technically feasible.

Right to withdraw consent

We rely on your consent to process some categories of your personal data. You can withdraw your consent at any time without giving any reason to us and without any charge to you.

The withdrawal of consent does not affect the lawfulness of processing based on consent before its’ withdrawal.

Right to lodge a complaint

If you feel that your personal data rights have been breached, you have the right to lodge a complaint with your local data protection authority. The relevant data protection authority in EU Member States may be determined either by your place of habitual residence, or the place where the alleged infringement emerged.

As we are established in Denmark you may choose to contact the Danish Data Protection Agency.

The Danish Data Protection Authority: 

Carl Jacobsens Vej 35

2500 Valby

Denmark

Phone no.: +45 33 19 32 00

www.datatilsynet.dk

How to exercise your rights

If you have any questions regarding the processing of your personal data explained in this Policy, or wish to exercise any of your rights listed above, please contact us via dataprotection@bettercollective.com.

In accordance with GDPR Section 4 you also have, as data subject, the right to contact our DPO who can be contacted on dpo@sixtus-compliance.dk.

Third parties who process your data

We may share your personal data with third-party vendors, and other service providers we engage to perform tasks on our behalf, in certain circumstances. This enables the improvement of our app functionalities, user experience on our products and providing you with our services. The categories of recipients to whom personal data may be disclosed are:

• Members of our corporate group, which includes the owner of this app and its’ subsidiaries. Please be aware that we determine the purpose and means of the processing of your data, as well as deciding which of your data is going to be processed by other members of our corporate group. All data processing relations with the subsidiaries are regulated with proper agreements.
• Your data may be shared with entities that help us improve and develop our products and services (e.g. marketing, advertising, analytics, development, security).

As such, they may need to process your personal data to perform tasks on our behalf. We use Google Analytics and Firebase to collect information about your browsing behavior on our app to improve your user experience and optimize our services.

For more information, please refer to the Google Privacy Policy and Terms of Use, the Google Analytics Terms of Use and the Firebase Privacy and Security Policy.

As defined in the GDPR, these third parties should be considered data processors. Data processors are engaged in processing activities under appropriate data protection agreements that are implemented to ensure the security of your personal data.

• Public authorities and law enforcement agencies when we are legally required or permitted to do so.

We may transfer your personal data outside of the EEA in order to provide our services on regular basis and/or to develop our services further. We take all measures in relation to the recipients of your personal data to ensure an adequate level of protection and appropriate safeguards, as defined by the applicable data protection law and particularly GDPR, are implemented.

Your personal data may be transferred to a recipient based in a country that the European Commission considers to have an adequate level of data protection. You may find out more about countries with an adequate level of protection here.

We will conclude Data Protection Agreements with recipients of your data where required. These will include, but not limited to,Standard Contractual Clauses (“SSC”) issued by the European Commission that would obligate the data recipient to provide an adequate level of protection and implement appropriate safeguards as defined by the applicable data protection law, and particularly GDPR, with regard to the processing your personal data.

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