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INTEGRITY POLICY

FootballAddicts AB, a company organized under the laws of Sweden with company registration number 556880-8405 and registered address Korsgatan 24, 411 16 Gothenburg (below referred to as “FootballAddicts”) processes personal data in accordance with law, including the General Data Protection Regulation. When we below refer to “we, our and us”, we refer to FootballAddicts.

1 The type of data that FootballAddicts processes

FootballAddicts will process both non-personal data, i.e. information that cannot be attributed to a person, and personal data, i.e. information regarding an identifiable person.

1.1 Non-personal data

Non-personal data that FootballAddicts will collect from you

When you use our services, i.e. download and use our apps, such as “Forza Football”, “Forza Reporter” and “Forza Academy (“Services” ), we use tools or third party analytical software to automatically collect non-personal data about you and your use of our Services. Such non-personal data is information that is aggregated and de‑personalized and which cannot be used to identify you. We collect this information by using advertiser ID, which is a technology that differentiates smartphones and other devices from each other through a unique number. By tracking the number, advertiser ID makes it possible for us to collect information about your use of our Services. The types of non-personal data that FootballAddicts collects can, for example, consist of advertiser ID, information about your use of the Services, such as what teams and players you are interested in and your prediction in a specific game, your hardware, device software platform and firmware, software installation properties, including, but not limited to unique installation identifier and software version, your country specific settings and other non-personal data as reasonably required by FootballAddicts to enhance the Services.

1.2 Personal data

FootballAddicts will process both personal data submitted by you to FootballAddicts as well as personal data that FootballAddicts will collect from you.

Personal data submitted by you to FootballAddicts

When you contact FootballAddicts by requesting technical support, by requesting FootballAddicts to save your app settings (if you use an Android device) or by signing up for any of the services that we or our partners provide in the apps, such as competitions displayed in the apps, you will provide your personal data, such as name, e-mail address, phone number, address, personal identification number, birth date and/or sex. When you contribute to the content of our apps through Forza Reporter you may also provide us with other personal data, such as your nickname, photographs and any information and comments that you provide in the chat function. The personal data may be processed by both FootballAddicts and FootballAddicts’ eventual partner who provides the service, except for personal identification number which will not be processed by FootballAddicts. Apart from these situations, FootballAddicts will not require you to provide any personal data in order for you to use the Services and therefore not process any other personal data.

Personal data that FootballAddicts will collect from you

As described above, see section 1.1, FootballAddicts will collect and process data about you when you use our Services. When you request technical support, request us to save your app settings or sign up for any of the services provided by us or any of our partners in the apps, and provide us with your personal data mentioned above, we will be able to link your personal data to your advertiser ID. This means that all data (described above as non-personal data) that we have collected about you before this time through your advertiser ID, becomes identifiable information about you. Therefore, all data mentioned in section 1.1 will also be regarded by FootballAddicts as personal data after this point. For this reason, the information below also addresses such information. When referring to “personal data” below, non-personal data that has become personal data is included.

Personal data about third parties included in communication

FootballAddicts may receive e-mails or other information containing personal data about third parties and therefore process such personal data. If required, FootballAddicts will inform you as a third party of the processing separately.

2 What are the purposes of the processing of personal data and what is the legal basis for the processing?

It is important that you understand the purpose of FootballAddicts’ processing of your personal data and the legal basis for processing your data.

Providing of the Services

In order to make it possible for you to use our Services properly and for us to provide you with technical support and an opportunity for you to sign up for our services in the apps or to save your app settings (if you use an Android device and request that your app settings are being saved), FootballAddicts will process your personal data. FootballAddicts will also use the personal data provided by you through Forza Reporter to enhance our apps. The legal basis for FootballAddicts’ processing of your personal data is that the processing is necessary for the performance of our contract with you or to take steps to enter that contract.

In order to make it possible for you to sign up for any of the services provided by our partners in the apps, such as competitions displayed in the apps, FootballAddicts will process your personal data. The services are organized by our partners and FootballAddicts only displays and provides the possibility for you to sign up for it. It is the partner company that is responsible for the processing of your personal data and that is the controller of the personal data provided by you, and FootballAddicts processes your personal data as a processor. The legal basis for FootballAddicts’ processing of your personal data is that the processing is necessary for the performance of your contract with the partner company or to take steps to enter such a contract.

Marketing

As a user of FootballAddicts’s Services, we will provide you with information about our Services and our partners’ services that we believe you will find interesting and relevant due to your user behavior, for example by displaying ads and other marketing from us and our partners in the Services and in social media. FootballAddicts will process your relevant personal data for such marketing purposes. The advertisement serving technologies that are used in order to enable us to provide you with customized marketing information are integrated into the Services. If you do not wish to be subject to this technology you can turn off the advertisement serving technologies in the settings of the device that you are using. If you turn the advertisement technologies off it will not limit the function of the Services and affect your user experience. The legal basis for FootballAddicts’s processing of your personal data for marketing purposes is that the processing is necessary for the purpose of a legitimate interest which is not overridden by your interests, rights or freedoms. Such a legitimate interest, e.g. to market FootballAddicts’ and FootballAddicts partners’ products and services, exists based on our interest to develop our business and to offer you services that match your interests and needs. FootballAddicts’s interest in processing your personal data for marketing purposes overrides your potential interest in protecting your personal privacy.

3 For how long will FootballAddicts process the personal data?

FootballAddicts will store your personal data for as long as is needed for the processing related to the purposes and legal grounds described above. Your personal data may be stored in different locations in our systems and for different purposes. In light of this, personal data which has been deleted from one system because it is no longer needed there, may still exist in another system for a different purpose.

[Personal data that FootballAddicts processes in order to provide the Services within Forza Reporter will be stored for as long as you use Forza Reporter or until the game you have reported on has been played.] Personal data that FootballAddicts processes in order to provide the other Services, including technical support, will be stored for up to three years after your request for support. The reason for this is to make it easier for you to get assistance from FootballAddicts. It is often the same technical problem that users experience. Therefore FootballAddicts needs to see the history of technical problems that have arisen when you have used the apps. Personal data that FootballAddicts processes in order to provide you with the opportunity to save your app settings (when using an Android device), will be stored for as long as you request the app settings to be saved. Personal data that FootballAddicts processes in order to make it possible for you to sign up for any of the services provided by us or our partners in the apps, will be stored by FootballAddicts for no longer than one year after the service has been provided or for as long as is requested by the partner company.

Personal data that FootballAddicts processes for marketing purposes will be stored no longer than two years after either your last contact with FootballAddicts or your last active use of the Services. It is not possible for FootballAddicts to see if you remove the apps from your device or if you stop using the apps. This is since some users use the Services only to receive the apps’ push notifications (a use of the apps which we are not able to track), while some users browse and use the apps very actively (which enables for us to track the use). Therefore, FootballAddicts will regard you as a customer and user of the Services for two years from your last contact with FootballAddicts or your last active use of the Services, and may use your personal data for marketing purposes during this time.

Your personal data may be processed for a longer period than stated above if necessary to comply with legal requirements or authority decisions.

4 To whom does FootballAddicts transfer your personal data and where is your personal data processed geographically?

In addition to the processing performed by FootballAddicts, your personal data may also be processed by others. Your personal data will be disclosed to and processed by FootballAddicts’ parent company FootballAddicts Holding AB and Aktiebolaget Grundstenen and its affiliates, and FootballAddicts’ partners, such as gambling companies that you have signed up for in the app.

Your personal data will also be disclosed to companies who process personal data on FootballAddicts’ behalf, so-called processors. FootballAddicts has contracts in place that ensure that the processors process your personal data in accordance with this integrity policy and FootballAddicts’ instructions.

FootballAddicts may also disclose your personal data in order to permit a merger, an acquisition or a sale of all or parts of FootballAddicts’ assets.

FootballAddicts may also disclose your personal data to authorities that require that FootballAddicts disclose such personal data.

Your personal data will be disclosed to entities both within and outside of the EU and EEA.

Your personal data will be disclosed to and processed by the companies listed on the following website [insert a link to a website where those companies are listed].

5 Your LEGAL rights

You have the right to free of charge, upon written request to the e-mail address listed below, receive information about what personal data FootballAddicts stores about you and how that personal data is used and processed. In the event that your personal data is inaccurate or wrong, you have the right to request that FootballAddicts corrects or removes the personal data.

If your request is unfounded or your request is excessive, e.g. should you frequently and within short intervals ask to receive information about what personal data FootballAddicts stores about you or that FootballAddicts shall provide a copy of or remove the personal data in question, FootballAddicts have the right to refuse to act on your request, or to charge a reasonable fee which covers the administrative costs of the action requested by you.

Your right to object

You may object to your personal data being processed for direct marketing purposes at any time. If you do not want your data to be used for direct marketing, you can notify FootballAddicts by sending an e-mail to FootballAddicts at support@forzafootball.com. We will then, as far as possible, stop processing and delete the personal data. However, we cannot delete the personal data if we need to continue processing it for any of the other purposes mentioned above.

You may also contact FootballAddicts if you are unhappy with the way FootballAddicts is processing your personal data. You have the right to file a complaint with the supervisory authority regarding FootballAddicts’s processing of your personal data or handling of any inquires related to it.

FootballAddicts may change this integrity policy. Such changes will enter into force no earlier than 30 days after FootballAddicts has informed you of the revised integrity policy in the apps or by other notification.

Last updated: 2018-05-17