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DAZN PRIVACY POLICY

 

Last updated: 05/07/2021

 

Your trust and the privacy of your personal information is important to us. This privacy policy (“Privacy Policy”) explains the ways in which any personal information we collect from or about you will be processed by or on behalf of DAZN Limited (“DAZN”, “we”, “us”, “our”). We are a member of a group of companies controlled by DAZN Group Limited (“DAZN Group”).

 

What this Privacy Policy applies to: This Privacy Policy applies to your access and use of our websites, applications, products, services and/or content that reference this Privacy Policy (together the “Services”), regardless of how you access or use our Services (including via web browsers, mobile devices, apps, smart TVs, games consoles, set top boxes and/or other streaming media devices). Your use of our Services is subject to both our terms of use (“Terms of Use”) and this Privacy Policy. Please read both the Terms of Use and this Privacy Policy carefully before you use our Services.

 

What this Privacy Policy does not apply to:

 

• any third party services that we do not own or control, including any third party services, websites, applications, interfaces and platforms which we link out to, offer or integrate, via our Services (e.g. if you click an advert and it takes you to an advertiser website/application);
• any direct marketing communications sent by third parties even when these relate to our Services (e.g. by a sports rights holder whose content is made available by our Services, or a mobile carrier, TV/games console manufacturer, or set top box operator who make available our Services to its customers); and
• any services owned or controlled by other members/business divisions of the DAZN Group (e.g. the media business division who operate various paid-for and free-to-use digital sports media properties such as Goal.com and Sportingnews.com, and a video-content streaming service called “DAZN Player” which is used by third party digital publishers to stream sports video content on their own digital platforms).

 

For each of the above services, we recommend you review the separate privacy policy relevant to the service provider or sender of the direct marketing communications, which we are not responsible for.

 

Contact us: If you do not understand, or have any questions about our Terms of Use or this Privacy Policy, please contact us via the contact form available at https://my.dazn.com/contactus.

 

Changes to our Privacy Policy: We keep this Privacy Policy under regular review and may change it at any time. It was last updated on the date at the top of this Privacy Policy. When we make any changes to the Privacy Policy we will post the revised Privacy Policy on our Services and indicate the effective date of the revised Privacy Policy (i.e. the date it was last updated). You will be notified of any material changes to this Privacy Policy by email, push notification, or in-app notification.
 

1. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION? 

 

If you register for, subscribe to, buy or otherwise use our Services, DAZN is responsible for how and why your personal information is collected and processed. We are registered with the Information Commissioner’s Office in the United Kingdom (“ICO”) (registration number ZA253941) as a data controller. Our registered office is DAZN Limited, Hanover House, Plane Tree Crescent, Feltham TW13 7BZ.

 

Any personal information about you will be treated in accordance with applicable law, including the Brazilian General Data Protection Law (in Portuguese, Lei Geral de Proteção de Dados) (“LGPD”) and, to the extent applicable to the processing of your personal information, the UK Data Protection Act 2018 (“UK DPA”) and/or the EU General Data Protection Regulation (“GDPR”) and, in each case, any superseding laws.

 

2. WHAT DO WE MEAN BY PERSONAL INFORMATION?

 

We use the term “personal information” to describe information about an individual from which that person can be directly identified (e.g. your email address) or indirectly identified through combination with another piece of information (e.g. the Internet Protocol (“IP”) address used to connect your computer to the Internet). “Personal information” does not include information where the identity of an individual has been removed (i.e. anonymous information).

 

We receive, store, use and share different types of personal information and other information from and about you. For simplicity, we have grouped these into various categories below.

 

Category of personal information	Description
“Account Information”	This includes your first name, last name, email address, address, country of residence, postcode/ZIP code, account ID, subscription type, and may include your date of birth and telephone number and any additional proof of identity, age and/or contact information e.g. where we need to verify your age to access and stream age-restricted sports content. It also includes your preferences in the 'My Account' and/or 'Settings' sections of our Services.
“Payment Information”	This includes your payment details (e.g. account number, payment card or other payment method details) together with details of payments to and from you directly or indirectly (e.g. including where you choose to pay for our Services via a charge to your mobile phone bill), and your invoice and transaction details.
“Usage Information”	This includes details of your use, activity and interaction with: ·         our Services, including content made available and advertising displayed through our Services (e.g. your navigation, pages visited, content selection and streams (including time and date of stream), watch history, playback details and errors, search queries and history, and any other content or advertising interaction or behavioural information e.g. scrolling, clicks and mouse-overs); and ·         our direct marketing communications and/or service communications via email, push notification, in-app notification, text and any other form of electronic method of communication.
“Technical Information”	This includes details of your device or browser used to access our Services and other technical information, including: ·         your device type, browser type and version, your operating system and platform; ·         the IP address used to connect your computer to the Internet; ·         referral Uniform Resource Locators (“URLs”); ·         device identifiers or other unique identifiers (including resettable device identifiers, such as mobile advertising identifiers (“MAIDs”) from your mobile or tablet, any identifiers for advertising (“IFAs”) from your smart TV, games console, set top box or other streaming media device, our publisher provided identifier (“PPID”) (see “Advertising on DAZN” for more information) and any identifiers associated with browser cookies such as cookie IDs); ·         your time zone and language settings; ·         your general location (via your IP address); ·         your network and connection information (including your internet service provider); ·         any errors or event failures; ·         standard web log information; and ·         your cookie preferences and, subject to those preferences, personal information and other information collected through cookies and similar technologies (see our “Cookie Notice” below).
“Customer Service Information”	This includes details of your interactions with our customer services teams and any automated customer service functionality available through our Services, including: ·         the date, time, channel and reason for contacting us; ·         the transcripts of chat conversations; ·         your previously visited DAZN help pages; and ·         your contact information used to contact us (e.g. your name, email address and/or telephone number).
“Feedback and Survey Information”	This includes your information where you choose to participate in any surveys and/or other feedback interactivity through our Services (e.g. your reviews or ratings, favourite sports, tournaments, teams, events or personalities).
“Marketing Information”	This includes your: ·         preferences to receive marketing communications from us and (where relevant) the DAZN Group and any third party (see “Direct Marketing Communications” below for more information); and ·         information where you register for, subscribe to, or otherwise participate in our surveys and/or marketing promotions (e.g. prize draws, competitions, customer referral schemes), including your entry and response information.
“Advertising Information”	This includes your preferences to receive tailored ads on our Services, Technical Information (see above) we collect about you together with your Usage Information, audience segments which we assign to you, all of which we and our ad technology providers (including Google) use to select, display and measure tailored ads and non-tailored ads on our Services, subject to your preferences (see “Advertising on DAZN” for more information).

 

Where we need to collect personal information by law and you fail to provide that data when requested, we may not be able to provide you with access to certain content available through our Services (e.g. where you fail to provide Account Information required to verify your age to access and stream age-gated sports content).

 

We also collect, store, use and share aggregated information such as statistical or demographic information (“Aggregated Information”). Aggregated Information could be derived from your personal information but is not itself considered personal information e.g. where we aggregate (in other words combine) your Usage Information with the Usage Information of other users (e.g. to calculate the most popular content or sports event available through our Services). However, if we combine or associate Aggregated Information with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be collected, stored, used and shared in accordance with this Privacy Policy.

 

We do not collect any “sensitive personal data” (as defined in the LGPD) or “special categories” of personal information (as defined in the GDPR) about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic or biometric information).

 

3. INFORMATION WE COLLECT ABOUT YOU

 

Information you give us

We receive, store, use and share personal information and information you provide to us when registering for, subscribing to, buying or otherwise using our Services. Examples of information you may give us include:

 

• your Account Information (including any updates you make to this personal information);
• Customer Service Information you provide to our customer service teams;
• Marketing Information, including when you register for, subscribe to, or otherwise participate in our marketing promotions;
• your preferences to receive tailored, non-tailored, or generic advertising on our Services (see “Advertising on DAZN” for more information);
• any Feedback and Survey Information you choose to provide;
• other information that we are required or entitled by applicable law to collect and process and that we need for your authentication or identification, or for the verification of the information we collect; and
• personal information you otherwise provide to us through our Services or elsewhere.

 

Information we collect automatically 
 

We automatically receive, store, use and share personal information and information about you, your device, and your use of, and interactions with, our Services. We do this through a variety of technical methods, including the collection of personal information and information via cookies and similar technologies. For more information, please see our “Cookie Notice” below. Examples of information we automatically receive and store relating to your use of, and interaction with, our Services include:

 

• your Technical Information;
• your Payment Information relating to any transactions you make for or through our Services;
• Customer Service Information automatically collected by or on behalf of us through our Services;
• Usage Information generated through your use of our Services (including any advertising displayed on our Services);
• Advertising Information; and
• personal information which is otherwise automatically collected including but not limited to:
  • information on social media networks you use together with your associated profile information if you choose to mention, connect with or contact us through a social media account; and
  • personal information and information collected via the use of cookies, pixels, web beacons and other similar technologies, including:
    • about how you access, use and interact with our Services (including the full URLs to, through and from our Services together with the applicable dates and times);
    • information about your activities and interactions with our advertising partners including information about the ads you were shown, when and where they were shown, how often they were shown, your dwell time (i.e. the duration of time you viewed the ad), and whether you took any action (e.g. clicking on an ad and/or making a purchase); and
    • information on the audience segments to which you belong for the purposes of selecting, serving, measuring and reporting ad campaigns on our Services and our own ad campaigns online.

 

Information we receive from other sources

 

We receive, store, use and share personal information about you from other sources and from third parties to the extent permitted by applicable law. Examples of information we might receive include personal information and information:

 

• from third party databases, including publicly available databases;
• from other members of the DAZN Group;
• from our third party service providers and/or partners, which include:
  • third party payment service providers and payment processors, who provide us with your Payment Information and other personal information relating to payments, and any updates to that information, based on their relationship with you;
  • partners who deliver services to us and/or with whom you have a relationship (e.g. a mobile carrier or set top box operator who makes available our Services on its device);
  • other third party service providers (e.g. location data to customise our Services and content available to you, online and offline demographic information, interest-based and online advertising related information);
  • third party providers of identity/account authorisation and authentication services including access tokens (e.g. where you choose to login to our Services via a third party account e.g. Google); and
  • voice assistant platform providers who enable interaction with our Services through voice commands.

 

We combine and connect the personal information we collect from and about you with personal information we receive from these other sources. Where personal information is transferred to us from third parties we take steps to verify that these third parties are legally permitted to disclose your personal information to us.

4. 
   USES MADE OF YOUR INFORMATION
    

We receive, store, use and share the above personal information when applicable law allows us to. We do this for a variety of purposes, each of which is justified by a lawful basis. The most typical lawful bases we use to justify the processing of your personal information are:

 

• where we need to perform the contract we are about to enter into or have entered into with you;
• where we need to comply with a legal obligation; and
• where it is necessary for our legitimate interests (or the legitimate interests of a third party) and your interests and fundamental rights do not override those interests.

 

We may also ask for your consent to process your personal information for a specific purpose that we communicate to you. When you consent to such processing, you can withdraw your consent at any time and we will stop any further processing of your personal information for that purpose.

 

In the table below, we have set out a description of the ways we use or plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified a summary of the legitimate interests pursued, where applicable.

 

 

Lawful basis for processing	Purpose (including our legitimate interest, where relevant)
To perform the contract we are about to or have entered into with you	To register you as a new user and create your account.
	To provide you with our Services, including administering your account, identifying and authenticating you, sending statements and invoices to you, collecting and processing payments from you, and playing content.
	To provide you with location-based services (e.g. to enforce territorial restrictions of content available based on your location).
	To administer and monitor our Services, including notify you about changes or updates to our Services and any issues with our Services, such as unavailability.
	To provide technical and customer support, including dealing with enquiries and complaints.
	To notify you about changes to our Terms of Use, this Privacy Policy and/or any other terms and conditions relevant to our Services.
	To personalise content you receive and provide you with tailored content that will be of interest to you.
To comply with a legal obligation	To enable us to comply with any legal or regulatory requirements and otherwise comply with the direction of any regulatory or competent authority.
	To prevent, detect, investigate and mitigate prohibited or illegal activities, including fraud and money laundering.
	To ensure information security of your personal information.
	To retain and store your personal information to comply with specific legal retention requirements, regulatory audits, and other record keeping purposes (including to meet internal and external audit requirements).
Where it is necessary for our legitimate interests (or the legitimate interests of a third party) and your interests and fundamental rights do not override those interests	To prevent, detect, mitigate and investigate suspected or actual fraud, security breaches and other unlawful or harmful activities. This is necessary for our legitimate interest to protect our business, our Services and its users from fraudulent or otherwise unlawful or harmful activities.
	To monitor and improve the information security of our Services. This is necessary for our legitimate interest to keep our Services (including our related intellectual property rights) and your personal information secure and to mitigate the risk of accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal information.
	To use data analytics, research, development, testing and analysis to improve and enhance our Services, to diagnose and fix problems and develop and test new content, products, services and features. This is necessary for our legitimate interest to keep our Services updated and relevant, to optimise user experience, to inform our marketing, advertising and content strategy, and otherwise to develop and grow our business.
	To detect abuse of our Services. This is necessary for our legitimate interest to protect our business and mitigate the risk of unauthorised use (including piracy).
	To monitor compliance with and to enforce our Terms of Use (including, but not limited to, determining free trial eligibility), this Privacy Policy and other rules and policies. This is necessary for our legitimate interest to protect our business and mitigate the risk of unauthorised use.
	To compile and use Aggregated Information for internal and external business purposes. This is necessary for our legitimate interest to use Aggregated Information to better understand our users and how they use our Services, to report on the effectiveness of content to rights holders and advertising campaigns to ad partners, to inform our marketing, advertising and content strategy, and otherwise to develop and grow our business.
	For profiling purposes so that we can (subject to any preferences you have expressed (including consent, where required)) build a profile about you and your interests to:   ·         understand and respect your preferences; ·         understand and analyse customer trends and patterns, so that we can enhance and improve our Services; ·         offer you on-product personalisation of content, including by suggesting and delivering recommended content (e.g. via in-app notifications and/or push notifications) and providing personalised search and content; ·         show you tailored ads that are relevant to you; and ·         send more effective direct marketing communications related to our Services.   This is necessary for our legitimate interest to better understand our users and how they use our Services, to provide a more personalised and tailored user, content, advertising and marketing communication experience to you, and to develop and grow our business. Please note that you are free to opt-out of:   ·         personalisation of content on our Services at any time in the Settings section of our Services; and ·         tailored ads on our Services at any time via the Privacy Preference Centre accessible from the Settings section of our Services (see “Advertising on DAZN” for more information).
	To technically deliver ads and/or content on our Services. This is necessary for our legitimate interest (and our advertising partners’ legitimate interest) to allow you to see and interact with ads on our Services.
	To select and display generic and non-tailored ads, measure ad performance, and generate audience insights from ads displayed to you on our Services (subject to any preferences you have expressed (including consent, where required)). This is necessary for our legitimate interest (and our advertising partners’ legitimate interest) to:   ·         display ads to you based on the content you are viewing, the app you are using, your general location, or your device type (including to control the frequency and sequence of ads shown to you); and ·         measure the performance and effectiveness of ads that you see or interact with.
	To make ads displayed to you on our Services more relevant and tailored to you and your interests (subject to any preferences you have expressed (including consent, where required)). This is necessary for our legitimate interest to use the information we and our advertising partners hold about you to help us sell our ad inventory and to make the ads you see more relevant and tailored to your interests. You are free to opt-out of tailored ads on our Services at any time via the Privacy Preference Centre accessible from the Settings section of our Services (see “Advertising on DAZN” and “Your rights” below for further information).
	To market our Services (subject to any preferences you have expressed (including consent, where required)) including:   ·         delivering direct marketing communications to you across various channels/platforms, such as email, text message, online, device notifications (both push and in-app) or otherwise to inform you about news, products, services, promotions and special offers which we think might be of interest to you; ·         showing you targeted and relevant marketing communications and ads about our Services on a selection of websites across the Internet and social media platforms using both cookies (see our “Cookie Notice” below) and ‘protected identifier matching’ (see “Direct Marketing Communications” below); ·         contacting you in respect of market research, surveys and beta testing programmes, so that we can improve the Services we offer; and ·         measuring and analysing the effectiveness and reach of such marketing communications and ads.   This is necessary for our legitimate interest to show you more relevant marketing and advertising related to our Services, to better target prospective customers who have shown an interest in our Services (e.g. by navigating to our websites or applications), and to analyse the performance of our marketing communications and advertising. You are free to opt-out of direct marketing communications by email, text, and push, as well as ‘protected identifier matching’ at any time (see “Direct Marketing Communications” below for further information).
	To administer competitions and other offers/promotions which you enter into, including sending you prizes won.
	To geo-block content on our Services. This is necessary for our legitimate interest (and the legitimate interest of the rights holders of content made available on our Services) to only show you content when you are in the relevant territories, except when legally permitted.
	To provide our commercial partners with information about users’ use of any co-branded parts of our Services, including historical use data.
Consent	To transfer your contact information (e.g. email address) to third parties to send you direct marketing communications about their products and services where you have consented to this (if applicable) (see “Direct Marketing Communications” below).
	Where legally required, we will collect your consent to the use of cookies or other unique identifiers (e.g. MAIDs and/or IFAs) and the collection, sharing and use of personal information for the personalisation of ads on our Services, as well as to combat fraud and abuse, to prevent you seeing the same ad repeatedly and for aggregated ad reporting (see “Personalised Advertising on DAZN” and our “Cookie Notice” below for further information).

 

 

5. DIRECT MARKETING COMMUNICATIONS

 

Subject to your preferences (including consent, where required), we receive, store, use and share your personal information to send you direct marketing communications about our Services via email, push notification, ‘protected identifier matching’, and text message. You are free to opt-out of direct marketing communications at any time, as specified below.

 

• Emails from DAZN: If you no longer want to receive direct marketing communications by email from us about our Services, you can opt-out at any time through the Settings section of our Services or by clicking the ‘unsubscribe’ link in the footer of one of our email marketing communications.
• Texts from DAZN: Where we collect your telephone number to send you direct marketing communications by text message, you can opt-out at any time through the Settings section of our Services or by replying STOP (or as otherwise instructed) to the text message. Please note that the Settings section of our Services will not include a preference in relation to direct marketing communications by text message where we do not collect your telephone number for this purpose.
• Emails and/or texts from third parties: Where you have consented to us passing your email address and/or telephone number to another member of the DAZN Group or a third party to send you direct marketing communications about their products and services by email or text message, you will be able to withdraw your consent at any time via the Settings section of our Services. Please note that the Settings section of our Services will not include a preference relating to third party direct marketing communications where you have not originally consented to this.
• Push notifications: We may send you direct marketing communications by push notification, subject to your device operating system settings. If you do not want to receive direct marketing communications by push notification, you can change your device operating system settings to turn them off.
• Protected identifier matching: We use your personal information to send marketing communications about our Services to you on third party platforms, such as Twitter, Facebook and Google. This involves sharing a protected identifier (e.g. your email address, telephone number or resettable device identifier e.g. MAID) which has been ‘hashed’ (i.e. converted into a value) to keep it from being revealed. The third party matches this protected identifier against its own database of user identifiers. If there is a match, DAZN determines whether or not to display its marketing to you on the relevant platform. If you want to opt-out of your protected identifiers being shared with third parties in this manner, you can opt-out at any time through the Settings section of our Services. You will still receive personalised marketing of our Services on these third party platforms through the use of cookies and pixels, subject to your cookie preferences (see our “Cookie Notice” below for more information). Please note that the Settings section of our Services will not include a preference relating to protected identifier matching where we do not do this in your country of residence.

 

Alternatively, you can amend any of the above marketing communication preferences by contacting us via the contact form available at https://my.dazn.com/contactus. Please note that our systems take up to 72 hours to update your preferences following any opt-out.

 

6. ADVERTISING ON DAZN

 

Ads on DAZN: Our Services are part-funded by the sale of ads. You will see ads when accessing content on our Services, but you can control whether and how we and our advertising technology partners (including Google) use your personal information to make the ads you see more relevant to you and your interests. We categorise ads on our Services into three broad categories:

 

• Tailored ads: These ads are selected, displayed and measured by our ad serving partner, Google. Tailored ads involve Google storing and accessing information on your device (e.g. cookies / mobile identifiers) and using personal information related to the use of our Services and other websites/apps to build a profile about you and your interests, and to show you ads that are more relevant to you and your interests (see “How personal information is used for tailored ads” below for more information).
• Non-tailored ads: These ads are selected, displayed and measured by our ad serving partner, Google. Non-tailored ads involve Google storing and accessing information on your device (e.g. cookie / mobile identifiers) but otherwise do not use your personal information to build a profile about you and your interests in order to show you ads. To make non-tailored ads more relevant to you, we and Google use contextual information such as your general location and the type of content you view on our Services.
• Generic ads: These ads are pre-recorded and inserted by DAZN into the content you access and view. Unlike non-tailored ads (see above), generic ads do not involve our ad serving partner, Google. Generic ads do not involve Google storing and accessing information on your device (e.g. cookie / mobile identifiers) or the use of your personal information to build a profile about you and your interests in order to show you ads. To make generic ads more relevant to you, we use contextual information such as your general location and the type of content you view on our Services.

 

You are always free at any time to choose which of the above ads you see on our Services (see “How to control your ad preferences on our Services” for further information).

 

Our ad serving platform for tailored and non-tailored ads: As described above, we use Google Ad Manager as our ad serving platform for tailored and non-tailored ads.  Subject to any preferences you have expressed (including consent, where required), Google will store and/or access information on your device (e.g. IP address, cookie ID, MAID, IFA) using its Google tag, software development kit (“SDK”) or application programming interface (“API”) integrated with our Services in order to carry out the following:

 

• To create a tailored ads profile about you (unless you opt out of tailored ads).
• To select tailored and non-tailored ads on our Services (subject to your preferences).
• To technically deliver tailored and non-tailored ads on our Services (subject to your preferences).
• To measure ad performance of tailored and non-tailored ads on our Services (subject to your preferences).
• To stop you seeing the same ad repeatedly.
• To detect and combat fraud and abuse.

 

How personal information is used for tailored ads: We understand the importance of transparency in relation to how we and our partner ad technology providers (including Google) use your personal information to tailor ads on our Services. The following is a breakdown of the personal information processing activities involved to select, display and measure tailored ads to you on our Services:

 

• First, Google and other partner ad technology providers (whose identities are available via our Privacy Preference Centre, which is accessible from Settings) store and access information on your device (e.g. cookies, IP address, MAIDs and IFAs) to select, display and measure tailored ads. If you opt-out of information storage and access via Settings, you will receive only generic ads.
• Secondly, and subject to your preferences, Google and its partner ad technology providers will use a combination of the following personal information to build a profile about you and your interests, and to select, display and measure tailored ads to you on our Services:

 

• Information we collect and share with Google about your use of our Services: We collect Advertising Information about your use of our Services, which we then aggregate (or otherwise combine) with Advertising Information of other similar users and subsequently share this with Google. Please note that we do not provide any direct identifiers (e.g. your name, email address) or any attributes or behavioural characteristics of the audience segments assigned to you with Google or other partner ad technology providers for the purpose of selecting, displaying and/or measuring tailored ads on our Services.

• Information independently collected and used by Google and other ad technology providers: Google and other ad technology providers (whose identities are available via our Privacy Preference Centre, which is accessible from Settings) independently collect personal information on the sites you visit, your search history, the apps you use, and other information, which Google may combine with the information shared by us in order to work with its partner ad technology providers to select, display and measure tailored ads on our Services. Please note that we do not control and take no responsibility for the personal information Google and other partner ad technology providers independently collect on third party sites and apps for the purposes of selecting, displaying and/or measuring tailored ads on our Services.

 

You are always free at any time to opt-out of tailored ads via the Privacy Preference Centre, which is accessible from Settings. We have set out below how you can control the information we share, and the information Google and other partner ad technology providers independently collect (see “How to control your ad preferences on our Services” for further information).

 

How personal information is used for non-tailored ads: By contrast to tailored ads, non-tailored ads use very limited personal information. We do not share personal information with Google, and Google and other partner ad technology providers do not use personal information to build a profile about you and your interests (see “How personal information is used for tailored ads” above for further information) to select, display and measure ads. However, non-tailored ads do require Google to store and access information on your device (e.g. cookies, IP address, MAIDs and IFAs) to technically deliver non-tailored ads,  to combat fraud and abuse, to prevent you from seeing the same ad repeatedly, and for aggregated ad reporting. If you disable this information storage and access via the Privacy Preference Centre accessible from Settings, you will receive only generic ads.

 

Consent: Where legally required, we will collect your consent to the storage and/or access to information on your device, and the collection, sharing and use of personal information to select, display and/or measure tailored and non-tailored ads on our Services.

 

How to control your ad preferences on our Services: You can control whether you receive tailored ads on our Services via Settings at any time. More specifically in relation to Google, to opt out or revoke consent (where applicable), you can:

 

• Control Google’s (and other partner ad technology providers’) ability to access and/or store information on your device: You can disable information storage and access to your device by Google from the Settings section of our Services. If you disable this for Google, you will only receive generic ads on our Services as both tailored ads and non-tailored ads rely on this information storage and access by Google.
• Control us sharing your information with Google: You can control the inclusion of your Advertising Information within audience segments shared with Google to tailor ads on our Service (as described above) via the contact form available at https://my.dazn.com/contactus or disabling the tailored ads setting from within our Privacy Preference Centre accessible from the Settings section of our Services.
• Control the information that Google independently collects and uses: You can control the personal information and other information Google independently collects and uses (as well as find out more about how Google receives, collects, uses and shares your personal information) by following Google’s instructions here.

 

The effect of turning off tailored ads: If you turn off your tailored ads within our Privacy Preference Centre (by following the above instructions), you will still see either non-tailored ads or generic ads (subject to your preferences), but they will not be as relevant to you.

 

7. DISCLOSURE OF YOUR INFORMATION

 

We share your personal information and other information as set out below. Where we disclose your personal information to third parties, we require them to respect the security of your personal information, to treat in in accordance with applicable law, and to use it only for specified and authorised purposes.

 

• Our service providers: We disclose your information to third party service providers authorised by us and acting on our behalf to operate particular functions of our Services, including but not limited to account set up, identity verification and authentication, customer support, customer relationship management, data management platform services, payment processing and related services, content delivery and play back, marketing, advertising, data analysis, market and audience research, beta testing and surveys. We have agreements in place with these third party service providers to ensure that they keep your information secure, they only process it in accordance with our instructions and as necessary to perform authorised purposes necessary for the relevant part of our Services to operate (and for no other purpose).
• Rights holders of content on our Services: We share your information with third party rights holders in relation to the content which is viewed by you when using our Services. Such information shall be shared on an anonymous basis.
• Our partners: Where legally permitted, we share your personal information and information with partners such as mobile carriers, TV/games console manufacturers, and/or set top box operators to coordinate with them on providing our Services to their customers.
• Third parties with your consent: We will share your personal information with third parties where you have consented to this or otherwise to the extent legally permitted.
• DAZN Group entities: We share your personal information to members of the DAZN Group as required for the purposes of IT and system administration and as set out in the “Uses Made of your Information” section above, including to:
  • provide a more personalised experience across the DAZN Group’s different products and services (e.g. Goal.com, Sportingnews.com etc.);
  • provide other similar products and services you request or which might be of interest to you, where legally permitted; and
  • to administer intra-group products and services.
• Professional advisers: We share your personal information to our professional advisers and the professional advisers of the DAZN Group (including lawyers, bankers, auditors, insurers and accountants).
• Business transfers and transactions: In the event of any reorganisation, restructuring, merger or sale, or other transfer of assets, we will transfer information, including your personal information, provided that the receiving party agrees to treat your personal information in a manner that is consistent with this Privacy Policy.
• Fraud prevention: In order to detect, investigate and prevent fraud, money laundering and other harmful or unlawful activities, we may disclose your personal information and information to third parties including, but not limited to, any relevant regulator, financial institutions and law enforcement agencies or any other body that deals with the investigation of alleged offences or unlawful activities.
• Other lawful reasons: We share your personal information and other information with third parties where we are under a duty to, or reasonably believe we need to, disclose or share your personal information in order to:
  • comply with any applicable law, regulation, legal obligation or regulatory/law enforcement authority request;
  • enforce or apply our Terms of Use (including any related investigations); and
  • protect against harm to the rights of DAZN, its rights holders and/or its users (including related to piracy or the threat of piracy), as permitted by applicable law.

 

8. INTERNATIONAL TRANSFERS

 

Personal information and information that we collect and process is transferred, stored and processed between any of the countries in which we or the DAZN Group operates. This will involve transferring your personal information:

 

• collected and stored in Brazil to a country outside (e.g. the UK and/or the European Economic Areas (“EEA”) or other countries in which we or the DAZN Group operates). In these circumstances, we will only transfer your personal information in accordance with applicable law (i.e. LGPD), including where:
  • an adequate level of protection for your personal information is in place in the country to which we transfer your personal information; or
  • we can ensure compliance with the principles, your rights and the data protection regime set out in the LGPD, by means of: (i) specific contractual clauses for a given transfer; (ii) standard contractual clauses; (iii) global corporate rules; or (iv) valid seals of quality, certificates and codes of conduct.

 

• collected and stored in the UK or the EEA to a country outside (including Brazil). In these circumstances, we will only transfer your personal information in accordance with applicable law (i.e. the UK DPA and/or GDPR), including where:

 

• the European Commission or UK government has determined that an adequate level of protection for your personal information is in place in the country to which we transfer your personal information (e.g. Canada and Japan);
• standard data protection clauses as adopted by the European Commission or UK government are in place governing the transfer (a copy of which is available on request via the contact form available at https://my.dazn.com/contactus);
• for transfers to the USA, the recipient is a participant in the EU-US Privacy Shield programme (or equivalent with the UK as and when created); or
• other appropriate safeguards in accordance with applicable law have been put in place.

 

In addition, where we disclose your personal information to third parties (see “Disclosure of your Information” above), some of these third parties are based outside of Brazil, the UK and/or EEA, or their processing of your personal information will involve a transfer of your personal information outside of Brazil, the UK or the EEA. In these circumstances, we will ensure that our agreements with these third parties include adequate safeguards (as set out above).

 

9. PARENTS AND GUARDIANS 

 

You must be 18 years of age or older to subscribe to our Services (or the relevant age of majority in your territory, state or province). While our Services are general audience services, if you are under the age of 18, you may only use our Services with the involvement of a parent or guardian. We do not knowingly collect and/or share personal information about children through the Services. If it comes our attention that we have collected and processed personal information from or about a child, we will delete it without notice. If you are a parent or guardian and have reason to believe that we have collected personal information from or about your child, please contact us via the contact form available at https://my.dazn.com/contactus.

 

10. SECURITY

 

The security of your personal information is important to us. We take precautions to protect personal information under our control. Our security measures include industry-standard physical, technical and administrative measures in the collection, storage, use and transfer of your personal information. For example, we take steps to limit access to personal information from or about you to those employees, agents and contractors who need to access it for our Services to operate. We also put in place a variety of security features and measures like encryption and hashing to help protect against unauthorised access in transit. These measures are designed to prevent any accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access to your personal information.

 

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to safeguard your personal information, we cannot guarantee its security. Any transmission of personal information is at your own risk and we are not responsible for circumvention of any privacy settings or security measures contained on our Services.

 

You also have a part to play to safeguard your personal information. It is important that you protect your password, computers, devices and applications from unauthorised access. You should not share these with anyone.

 

11. HOW LONG DOES DAZN KEEP YOUR INFORMATION?

 

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. We have given further details below for Account Information and Marketing Information.

 

Account Information: We retain your Account Information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services.  We also retain some of your Account Information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services.

 

Marketing Information: If you have elected to receive direct marketing communications from us, we retain your information about your marketing preferences and your contact information for a reasonable period of time from the date you terminate the Services. From our experience, termination is often based on the seasonality of your favourite sports and many users re-subscribe to the Services for the next season or desired event. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.  

 

In some circumstances we will anonymise your personal information (so that it can longer be used to directly or indirectly identify you) for research or statistical purposes, in which case we use this anonymous information indefinitely without further notice.

 

12. YOUR RIGHTS

 

Any personal information about you will be treated in accordance with applicable law. We are committed to delivering the rights available to individuals under these laws, including (but not limited to):

 

• Under the LGPD, the following rights:
  • to receive confirmation of data processing and to access your personal information;
  • to request the correction of incomplete, inaccurate or out-of-date personal information;
  • to request the anonymization, blocking or deletion of unnecessary or excessive personal information;
  • to request portability of your personal information to another service or product provider;
  • to request the deletion of personal information processed with your consent (except in the situations provided by law);
  • to request information about public and private entities with which we have shared your personal information;
  • to request information about the possibility of denying consent and the consequences of such denial;
  • to revoke consent; and
  • to request the review of decisions affecting your interests made solely on the basis of automated processing of personal information.
• If the UK DPA and/or the GDPR applies to the processing of your personal information, you will also have the following rights:
  • to access a copy of the personal information we hold about you (often referred to as a “subject access request”);
  • to object to your:
    • personal information being used for direct marketing (see “Direct Marketing Communications” above for more information on how to opt-out); or
    • to otherwise object to the processing of your personal information where the processing is based on our legitimate interests (see “Uses Made of your Information” above) except where the applicable processing is necessary for legal claims or for the provision of our Services to you;
  • to request correction of your personal information (often referred to as the “right of rectification”);
  • to request the deletion of your personal information (often referred to as “erasure” or the “right to be forgotten”) except where the applicable processing is necessary for legal claims or for compliance with a legal obligation or applicable law;
  • to request the restriction of processing of your personal information (often referred to as “right of restriction”);
  • to request transfer of your personal information (often referred to as the “right of portability”);
  • to withdraw consent, where we have asked for your consent to process your personal information; and
  • to not to be subject to decisions made automatically that produce legal effects or significantly affect you, however our use of profiling and automated decision-making (see “Uses Made of your Information” above) is not considered to produce legal effects or significantly affect users.

 

Please address your request using the contact form available at https://my.dazn.com/contactus or, where applicable, change the relevant preference in the Settings section of our Services. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other available rights). We may also contact you to ask you for further information in relation to your request to hopefully speed up our response. We aim to respond to all legitimate requests within one month. Occasionally, it could take us longer than one month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

 

We hope that we can satisfy queries you may have about the way we process your personal information. However, you also have the right to lodge a complaint with the relevant supervisory authority. To contact the ICO, please visit the ICO website (www.ico.org.uk) for instructions.

 

13. CONTACT

 

Questions, comments and requests regarding this Privacy Policy are welcomed and should be submitted via the contact form available at https://my.dazn.com/contactus.

 

For any specific queries or issues in respect of the processing of your personal information, you may contact our Data Protection Officer or authorised representative (where applicable) via the following methods:

• Email: DPO@dazn.com
• Post: The Data Protection Officer, DAZN Limited, Hanover House, Plane Tree Crescent, Feltham TW13 7BZ.

 

14. COOKIE NOTICE

 

What are cookies? Our Services use cookies and technology that operates in a similar manner to cookies. Cookies contain information that is transferred to your computer’s hard drive. We and our approved third party partners process your personal information and other information using cookies and similar technologies in order to:

 

• recognise you and distinguish you from other users (including to identify and set your preferences e.g. whether you wish to receive tailored ads, personalised content, direct marketing communications etc.);
• deliver our Services;
• better understand how you interact with our Services;
• customise, measure and improve your experience of our Services;
• conduct research and diagnostics;
• prevent fraudulent and otherwise unlawful activities;
• improve information security;
• deliver personalised content and recommendations;
• deliver targeted and relevant marketing communications and ads about our Services on a selection of websites across the Internet and social media platforms;
• technically deliver ads on our Services;
• combat ad fraud and abuse, prevent you seeing the same ad repeatedly and for aggregated ad reporting; and
• collect, share and use personal information to select, display and/or measure tailored and non-tailored ads on our Services (see “Advertising on DAZN” above for further information).

 

Further information on cookies: The Interactive Advertising Bureau (IAB) is an industry body that develops standards and guidelines to support online business processes. It has produced a website (www.allaboutcookies.org) which explains how cookies work and how they can be managed.

 

What types of cookies do we use? We use the following categories of cookies and similar technologies on our Services:

 

• Strictly necessary or ‘essential': These cookies and similar technologies are necessary for the operation of our Service. They are usually only set in response to actions made by you which amount to a request for services, such as setting your cookie preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of our Services will not then work. They do not store any personal information.
• Performance: These optional cookies and similar technologies enable us to measure and improve our Services by collecting, analysing and reporting information on how you and others use it. They help us to improve the way our Services work for the benefit of all users. For example, Google Analytics helps us to understand how users arrive at our Services, and how they browse, use and interact with our Services (including which pages and content are the most and least popular). These cookies and similar technologies collect information in a way that does not directly identify you or anyone else. If you disable these cookies, we will not know when you have visited our Services and we won’t be able to properly monitor its performance for you.
• Functional: These optional cookies and similar technologies help us to provide enhanced functionality and content personalisation on our Services. For example, they help us to recognise you when you return to our Services, to personalise our content for you, greet you by name and remember your preferences e.g. your choice of language. They do not track your browsing activity on third party websites. If you disable these cookies, our enhanced functionality and content personalisation may not function properly.
• Targeting: These optional cookies and similar technologies are set through our Services by our advertising partners to improve your ad experience on other sites/apps. They are used by such partners to build a profile of your interests to show you more relevant and personalised marketing communications on other sites/apps, to measure the effectiveness of these marketing communications, and to prevent you from seeing the same ones repeatedly. These cookies and similar technologies do not store personal information that directly identifies you, but instead use a unique identifier to identify your browser or device (e.g. your IP address, MAID or IFA). If you disable these cookies, you will still see marketing communications and ads on other sites/apps, but they will not be as relevant to your interests. We will continue to personalise your experience on our Services through cookies you have not disabled.
• Tailored ads on our Services: These store information, or access information that is already stored, on your device, such as advertising identifiers (e.g. MAIDs), device identifiers, cookies and similar technologies. They enable the collection of personal information and other information (e.g. your Advertising Information) and, in combination with information independently collected by Google, enable Google and its ad technology providers to manage, deliver and measure tailored and non-tailored ads on our Services and to stop you from seeing the same ad repeatedly, and to detect and stop click fraud (see “Advertising on DAZN” for further information).

 

What do we mean by “similar technologies”? In addition to cookies, we and our partners use other technologies on our Services, including web beacons, pixels and SDKs. They are embedded in various parts of our Services to collect certain information about your device or browser (e.g. your IP address), mobile advertising identifiers (e.g. MAIDs and IFAs), together with information on your interaction and use of our Services (including your Usage Information). We also collect information through other types of local storage (otherwise known as “flash cookies”) for various features of our Services (e.g. to remember and apply your last volume settings).

 

Where you can review information about individual cookies and similar technologies: You can find out more information about the individual cookies and similar technologies that we use and the purposes for which we use them by accessing our Privacy Preference Centre, which also enables you to change your preferences individually and/or by category (except in respect of strictly necessary cookies). You can access our Privacy Preference Centre any time from the Settings section of our Services.

 

Third party cookies and similar technologies: Our Privacy Preference Centre details all approved third party cookies and similar technologies set on your browser or used to collect information on your device. Please note that we have no control over the operation of these third party cookies and similar technologies.

 

Disabling and enabling cookies:

You have the ability to accept or decline cookies by modifying the settings on your Internet browser or device. The IAB website (www.allaboutcookies.org) tells you how to remove cookies from your browser or device. However, if you use your browser or device settings to block all cookies (including essential cookies) or disable future cookies you may not be able to access all or parts of our Services.

 

If you have any questions about how to manage cookies or how we use your personal information collected via cookies and similar technologies, please contact us via https://my.dazn.com/contactus.