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PRIVACY POLICY LALIGA.COM
The purpose of this Privacy Policy (hereinafter, the "Policy") is to regulate the processing of personal data carried out by LaLiga Group International, S.L. (hereinafter, "LALIGA") through the laliga.com website (hereinafter, the "laliga.com" or the "WEBSITE").
To access LALIGA Fans you need to register on LALIGA Ecosistema, through which you access an environment created by LALIGA composed of different applications and websites, both from LALIGA and affiliated football clubs with which LALIGA has partnership agreements. Through a common registration implemented by LALIGA in these assets (LALIGA Single Sign-On), each user receives a unique identifier so that any selection or modification of preferences or deletion request made in one of the applications or websites that are part of the ecosystem will affect the rest of the LALIGA Ecosistema environment and the entities that comprise it. Access the link to learn more about LALIGA Ecosistema and the entities that are part of it.
Who is responsible for processing your personal data?
Your personal data will be processed by LALIGA, with NIF: B05421805 and address at Calle Torrelaguna 60, 28043, Madrid.
Contact LALIGA's Data Protection Officer: dpo@laliga.es
Where do we get your personal data from?
LALIGA will process the data you provide through the registration form (email, mandatory data), your profile (first name, surname(s), avatar or photo, date of birth, gender, language, country of residence, province, city, address, postcode, phone number and favourite team, requested as optional data) and other data inferred as a result of your use and activity on the website (registered user ID, device ID, operating system, device model and telemetry, for example, when you click on particular content, or the time spent on the asset) and your interactions with communications we send you via web notification or email, where applicable (for example, clicking on content in a communication).
Similarly, in the event that you are a user of another asset under the responsibility of LALIGA or in which LALIGA acts as joint data controller, and which is part of LALIGA Ecosistema, LALIGA may process on the website the aforementioned personal data, declared or inferred in those assets.
Importing data from social networks
We hereby inform you that you can use the social networks of which you are a user to register on LALIGA Ecosistema. Also, if you so consent, the social network you have chosen may share with LALIGA additional information to complete your profile in the LALIGA asset.
Data shared through Facebook:
LALIGA will obtain the following inferred data through page likes and bio posts:
Data shared through Google:
Use (of the application) and transfer of information received from Google APIs to any other application will adhere to the Google API Services User Data Policy, including limited use requirements.
In this regard, we hereby inform you that LALIGA uses the tool of a third-party technical provider for the collection and structuring of the information provided by Facebook and Google.
Likewise, we remind you that LALIGA is not responsible for the legal alignment of the social network that you use for the registration on the LALIGA asset. For this reason, we recommend that you review the terms of use and privacy policy of the social networks you are going to use for this purpose so you can verify that the processing of your personal data is in accordance with your expectations of privacy and the data protection regulations applicable in each case.
Once the data have been imported and incorporated into your registered user account, your data will be integrated into LALIGA Ecosistema and processed by LALIGA for the purposes described in this Privacy Policy.
For what purposes do we process your personal data?
Main purposes:
/ Provision of the services offered through the laliga.com environment and the laliga.com Gamification platform: Your personal data (in this case email and all the profile data you have provided) will be processed by LALIGA for the purpose of facilitating your registration and access to LALIGA Fans, as well as managing your participation in it. LALIGA will also use them to enable your access to the other LALIGA Ecosistema assets.
In order to identify yourself on the platform you will have the option of uploading your own photo as an avatar, which can be seen by other users of the platform; LALIGA uses technical providers to provide these services.
In this regard, we hereby inform you that LALIGA uses the services of a third-party provider (RP Solutions, Inc.) which involves 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, including this provider.
/ Participation in prize draws through the laliga.com Gamification platform: Your email address will be processed by LALIGA for the purpose of managing your participation in the prize draws run through the website. Once the draw has been held, the prizes will be published on LALIGA Fans or you will be notified by email. Likewise, in the event of being chosen as the winner of a prize draw, we will contact you to ask you for additional information such as your ID card and your home postal address in order to send you the prize.
The legal basis for the aforementioned purposes is that the processing is necessary for the performance of a contract to which the data subject is a party in accordance with Article 6(1)(b) of the General Data Protection Regulation. The only data required is the email address and Fan ID for access to the website and for participation in the prize draws. If you do not provide this information you will not be able to participate in the draws.
/ Sending of LALIGA's regular monthly newsletter with institutional information related to LALIGA that may be of interest to the international football industry. To do so, LALIGA will process your email address, first name, surname(s), country, language of the newsletter and the sector to which you belong.
In this regard, we hereby inform you that LALIGA uses the mailing services of Sendgrid (Twilio, INC.) which involves 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, including this provider.
The legal basis for processing your data for the above-mentioned purpose is the consent you have given us 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 this affecting the lawfulness of the consent-based processing prior to its withdrawal.
/ Internal reporting: LALIGA will process in aggregate form the personal data you have provided through the registration (in this case, date of birth, gender, language, country of residence, province, city, address, postcode, phone number and favourite team) or social login (where applicable, birthday, gender, page likes and current city), usage data of the website and other LALIGA Ecosistema assets you use (user ID, device ID (IDFA, or if applicable, IDFV), device model, operating system and telemetry, for example, clicking on particular content or the time spent on the asset) and finally, interactions with communications of any kind that you receive (for example, clicking on the content of a communication), for the preparation of relevant metrics and statistics that allow LALIGA to analyse the use made of the website by the different user segments generated and the impact of its campaigns, evaluating the interest that these campaigns have aroused among the aforementioned segments based on the data analysed. In particular, LALIGA will carry out aggregate segmentations based on the aforementioned data, including:
In this regard, we hereby inform you that LALIGA uses technical providers to carry out internal reporting.
The legal basis for the aforementioned purposes is that the processing is necessary to satisfy 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 to enable it to improve the website and optimise the communication campaigns it carries out based on the interest they generate among the different groups of users. Before doing so, we would like to inform you that LALIGA has carried out a proportionality analysis between its legitimate interest and the rights and freedoms of its users. You can request the conclusions of this analysis at lopd@laliga.es.
You have the right to object to the above-mentioned 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?".
/ Security and quality control of assets: LALIGA will process Platform usage data (user ID, device ID, device model, operating system and telemetry, e.g. user actions performed within the Platform) for the detection of errors and problems, as well as the optimisation of the services provided through the Platform. In this regard, we hereby inform you that LALIGA uses technical providers for the security and quality control of the assets.
The legal basis for the aforementioned purpose is that the processing is necessary to satisfy the legitimate interest of LALIGA under the provisions of Art. 6(1)(f) of the General Data Protection Regulation, consisting of offering a Platform with the highest possible quality and the best possible experience for its users. Before doing so, we would like to inform you that LALIGA has carried out a proportionality analysis 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 above-mentioned 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
The additional purposes for which LALIGA will process your personal data are set out below:
/ LALIGA commercial communications: So that LALIGA can send you commercial communications via email, push notifications, in-app, SMS or other instant messaging channels about its activities (the competitions it organises, campaigns, public viewings, shows or live events), products (applications, web platforms and games developed by LALIGA), services, competitions, offers, prize draws and/or promotions run by LALIGA itself, or competitions, offers, prize draws 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 email address, your user ID in the registration form.
We also hereby 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 which 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 which are adhered to the Data Privacy Framework, including this provider.
The legal basis for processing your data for the above-mentioned purpose is the consent you have given us 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 this 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 products and services. These communications will be made based on the information you have provided through the registration (for example, we will send you communications about products that may be of interest to you based on your age, favourite team or your province of residence).
The information used for the development of segments will be only that declared by the data subject in the registration of any of the assets that make up LALIGA Ecosistema (in this case, gender, country, city, age and favourite team or sport), with a low level of detail on the user profile, without using information inferred from the data subject or from third-party sources, with the segmentation in any case not being in depth. In this way, commercial communications can be sent according to the simple segments created with the aforementioned information, avoiding sending content that has no connection to you.
In this regard, we hereby inform you that LALIGA uses consulting and technical support providers to carry out simple user segmentations.
The legal basis for the aforementioned purpose is that the processing is necessary to satisfy the legitimate interest of LALIGA under the provisions of Art. 6(1)(f) of the General Data Protection Regulation, consisting of making effective use of the personal data provided by the user to achieve greater interest and return from the communications sent. Before doing so, we would like to inform you that LALIGA has carried out a proportionality analysis 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 above-mentioned 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?".
Under no circumstances will the development of segments by LALIGA have any legal effect or significantly affect you in any similar way.
/ Development of comprehensive profiles: If you give us your permission, LALIGA will create a comprehensive profile of you so that it can offer you personalised experiences, information and products by sending personalised commercial communications via email, SMS or other instant messaging channels, sending you personalised push or in-app notifications (provided that you have given your consent for the purpose "LALIGA commercial communications") or showing you banners with personalised advertising on websites, apps 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 personalised incentives, such as a football shirt of your favourite team).
In this way, the aforementioned information will be directed to the segments (groupings of users that are made according to the information obtained from them or the use you make of the Website or other assets in LALIGA Ecosistema) that we can develop based on the following data sources:
· The information you provide during registration (in this case, favourite team, country and region);
· The social login (in this case, first and last name(s), email address, birthday, gender, city and province in which you reside, interest categories, as well as inferred values - engagement, social, promotion and fan value - obtained from your Facebook bio posts and likes);
· Interactions with communications or notifications you receive (e.g. clicking on the content of a communication);
· Data inferred as a result of usage and activity on the Platform (device ID, registered user ID, device model, operating system and telemetry, e.g. clicking on particular content or time spent on the asset).
In addition, LALIGA will generate these segments taking into account the following profiling techniques:
· Measurement of individual campaign performance: LALIGA will use information relating to opening rates, average click-through rates, email bounces and unsubscription rates to measure the performance of the campaign at an individual level, and as a result, make segmentations based on the information inferred about you and the other information declared in order to impact you again with certain campaigns that are more connected to you or include you only in those in which you have shown more interest (for example, if you are a very active user in certain communications we may send you communications of the same type more frequently). For these purposes, we hereby inform you that through the data management tools provided by the social networks in which LALIGA has an account, user audiences will be created which may be shared, within each social network and in encrypted form, with third parties outside LALIGA, in order to create their advertising campaigns within the social network itself.
· Optimisation of campaigns: we will exclude you from advertising campaigns about prize draws in which you have participated, about applications in which you have registered or downloaded, about products you have purchased or about services you have previously purchased (for example, we will avoid offering you a LALIGA app if we know that you have previously downloaded it). To do so, we will cross-reference your information with information obtained from other LALIGA assets of which you are a user.
· Users with similar tastes and preferences: using the profile that LALIGA creates about you, we can send you personalised content taking into account other profiles similar to yours (for example, if we identify that other users similar to you like eSports, we will show you advertising related to eSports).
· Valuation of users: LALIGA will obtain an unknown variable from known variables provided or inferred from you so that it can carry out an analysis of its users with the aim of identifying those with a greater propensity to use or contract LALIGA products, and where appropriate, offer you LALIGA products and services.
· Retargeting: in the event that you have interacted with LALIGA without having registered or without having used or downloaded the corresponding LALIGA asset, LALIGA may use the identifying data of your device and/or your email address to impact you with advertising in other environments outside LALIGA in order to achieve the interaction desired by LALIGA.
In this regard, we hereby inform you that LALIGA uses consulting and technical support providers to carry out complex profiling.
Under no circumstances will profiling carried out by LALIGA have any legal effect or significantly affect you in any similar way.
How long will we keep your personal data?
The personal data we process will be kept for as 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 erasure, objection or restriction of processing.
In this regard, after the end of said period, LALIGA will keep your personal data, duly blocked, for the sole purpose of meeting any responsibilities that may arise:
/ Provision of the services offered through the laliga.com environment and the LALIGA.com Gamification platform: the data provided for the provision of the services offered through the laliga.com environment and the LALIGA.com Gamification platform will be kept as long as you do not request the deletion of your data, this purpose persists and, once this purpose has ended, during the period of limitation for the legal actions that could arise from it.
/ Participation in prize draws through the laliga.com Gamification platform: the data provided for participation in prize draws through the laliga.com Gamification platform will be kept as long as you do not request the deletion of your data, this purpose persists and, once this purpose has ended, during the period of limitation for the legal actions that could arise from it.
/ Sending of LALIGA’s regular newsletter: the data provided for sending LALIGA’s regular newsletter and answering queries 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 processing and, once this purpose has ended, during the period of limitation for the legal actions that could arise from it.
/ Internal reports: the data provided for internal 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 ended, during the period of limitation for the legal actions that could arise from it.
/ LALIGA commercial communications: the data provided for commercial communications carried out 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 granted or limit the processing and, once this purpose has ended, during the period of limitation for the legal actions that could arise from it.
/ Development of simple segmentations: the data provided for the development 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 ended, during the period of limitation for the legal actions that could arise from it.
/ Development of comprehensive profiles: the data provided for the development of comprehensive 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 processing and, once this purpose has ended, during the period of limitation for the legal actions that could arise from it.
Such personal data will be deleted when these time limits 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 ticking the box provided or for the purpose of the service you request. In this regard, we hereby inform you that your personal data will be communicated to third parties that have a relationship with LALIGA, depending on the purpose of the processing:
/ LALIGA will communicate your personal data, declared or inferred (identified in the section Where do we get your personal data from?) to the affiliated football clubs that are part of LALIGA Ecosistema in order for you to access their assets and have the same profile throughout the ecosystem. All this will be possible as long as you are a registered user of any of the assets under the responsibility of these clubs, in accordance with the privacy policies of the assets of each club and depending on the consents you have given to them.
The legal basis for this communication of personal data is that the processing is necessary for the performance of a contract to which the data subject is a party under the provisions of Art. 6(1)(b) of the General Data Protection Regulation, in particular, the provision of the services offered to users in LALIGA Ecosistema through LALIGA Single Sign-On, which are regulated in the conditions of use of the website, and in the conditions of the other assets that are part of the ecosystem. To learn more about LALIGA Ecosistema and which clubs are part of it, you can access the following link.
/ LALIGA will communicate your personal data obtained in the assets belonging to LALIGA Ecosistema of which you are a user (email and, where appropriate, first name, surname(s), phone number and country), to your Favourite Team and to third parties so that they can send you commercial communications about their activities, products, services, competitions, offers and/or promotions.
In this regard, we would like to inform you that your personal data will only be communicated to third parties and football teams belonging to the first and second division of the National Professional Football League that have signed a collaboration agreement with LALIGA. In the following link there is a list of third parties and football teams that currently have an agreement with LALIGA and that, if you authorise us, may send you commercial communications.
We also hereby inform you that the communication of your data to third parties may, in some cases, involve 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 adopted the corresponding measures to ensure that your data are treated with 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 these third parties under the provisions of Art. 46(2)(c) of the General Data Protection Regulation, including additional guarantees and obligations, following an analysis of the impact of the transfer carried out, aimed at these third parties for the greatest possible security and transparency. The content of the standard contractual clauses is available on request at lopd@laliga.es.
The legal basis for this communication of personal data is the consent you have given us in accordance with the provisions of Art. 6(1)(a) of the General Data Protection Regulation.
Likewise, LALIGA may provide the user's personal data and any other information when required to do so by public authorities exercising responsibilities that have been lawfully granted to them and in accordance with applicable regulations.
Similarly, LALIGA uses some subcontracted entities that will access personal data and information as data processors or sub-processors in order to provide LALIGA with a necessary service. As such, LALIGA uses technical providers and technical and business consultancy providers in order to carry out the purposes indicated in the section "For what purposes do we process your personal data".
These service providers sign a contract that obliges them to use your personal information only for the provision of the services set out in this policy.
What are your rights when you provide us with your personal data?
We hereby inform you that you can exercise your rights of access, rectification, objection, erasure, data portability, not to be subject to automated decisions, restriction of processing and to revoke your consent at any time with 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 the right to access your personal data.
/ Right to rectification: you may request the modification or rectification of inaccurate personal data.
/ Right to erasure: you may request the erasure of your personal data.
/ Right to restrict processing: in certain circumstances, you may request that we restrict the processing of your data, in which case it will only be kept for the purpose of pursuing or defending claims.
/ Right to object: you may object to the processing of your data for the purpose you specify. LALIGA will cease processing the data, except for compelling legitimate grounds, or the exercise or defence 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, which is likely to produce legal effects concerning you or similarly significantly affect you.
/ Right to data portability: if the WEBSITE so permits, you may exercise the right to the portability of your data, in a structured, commonly used and machine-readable format, and to transfer 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.
If on accessing and, where applicable, registering on the website you have given your consent for the purposes for which you were requested, you may revoke it at any time by following the procedure established in each of the commercial communications you receive, through the Subscription Centre found in your user profile on the WEBSITE or by sending an email to the following address: lopd@laliga.es.
Objection to a specific purpose or revocation of the consent granted will not affect the use you can make of the WEBSITE or the lawfulness of the processing prior to the objection or revocation of consent.
On the other hand, if you have registered on the website through a social network or similar service, you can exercise your right to the erasure of your data by deactivating the service "LALIGA Ecosistema" within the services connected to your profile on the social network. For more information, please consult the conditions of each service:
Finally, if you feel that your rights have not been exercised satisfactorily or that your data has not been processed in accordance with the applicable regulations, you may contact LALIGA's data protection officer at the email 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 would like to inform you that you must be at least 14 years old to access laliga.com and register on the gamification platform.