Last updated: 29/03/2023
The DAZN Party Privacy Notice outlines how we collect and use your personal information when you access or otherwise make use of the DAZN Party ("Party") service. It should be read and understood in in conjunction with our local Terms and Conditions, our Community Guidelines, our Global Privacy Notice and our Global Cookie Notice.
1. WHO WE ARE
We are DAZN Limited (“we”, “us”, or “our”) – better known as DAZN – and we act as the data controller of your personal information. We are registered with the UK Information Commissioner’s Office (ICO):- Registration number: ZA253941
- Registered office: DAZN Limited, 12 Hammersmith Grove, London, W6 7AP, United Kingdom
DAZN's representative in the European Union for the purposes of the General Data Protection Regulation (GDPR) is DAZN DACH GmbH of Münchener Str. 101 Gebäude 24.5 Nord, 85737 Ismaning, Germany.
2. TYPES OF INFORMATION WE COLLECT
We collect and use various types of personal information about you to provide, manage and improve our Party service. For simplicity, we have grouped the information we collect into different categories set out below.Account information
Subject to your consent where required, additional information collected for the purpose with personalising your account, including your Party ‘nickname’, age, and gender.Usage information
Information about your use, activity, and interaction with our Party service, including platform navigation, creation of and reaction to user generated content on the Party live chat function, and flagging or reporting of content for moderation.Aggregated information
We also collect, store, use and share aggregated information such as statistical or demographic information. This could be derived from your personal information but is not itself considered personal information. Should this data be combined with any personal identifier, the provisions of this Privacy Notice will apply, and the aggregate data would be treated as personal.We do not collect any special categories of personal information 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. Please note that, in compliance with the Party Terms & Conditions, you are not allowed to disclose personal information concerning yourself or third parties and this include also any special categories of personal information[EC1] [FS2] [EC3] .
3. HOW WE COLLECT YOUR INFORMATION
Information you give us
For the most part we collect and use your personal information that is provided when you begin the Party service. Examples of information you may give us include the following categories outlined in Types of Information We Collect: Account information.Information we collect automatically
We may automatically collect and use personal information about your device and your use of, and interactions with, the PWP services.4. PURPOSES AND USE OF YOUR INFORMATION
Legal Basis
We may use your personal information for justified and specified purposes, and in each instance, relying on an applicable lawful basis under applicable data protection law. These bases include:- Performance of contract: where processing your personal information is necessary for a contract to which you are a party.
- Legal Obligation: where processing your personal information is necessary for us meet our legal and regulatory compliance requirements in the countries where we operate.
- Legitimate Interests: where processing your personal information is necessary for our own or a third parties justified legitimate interests, and where your rights and freedoms do not override those interests.
For Party, we process your personal information for the following purposes under each lawful basis as set out below.
Contract
- To register you as a new user on Party, including creating and administering your Party ‘nickname’ and identifying and authenticating you (e.g. associating your actions with your DAZN account).
- To provide you with location-based services (e.g. to enforce territorial restrictions of Party based on your location).
- To administer and monitor the Party services, including notify you about changes or any issues with our services, such as unavailability.
- To provide technical and customer support, including dealing with reports of unacceptable, harmful or illegal content.
Legal Obligation
- To enable us to comply with any legal or regulatory requirements and otherwise comply with the direction of any relevant 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.
Legitimate Interests
For processing purposes based on our legitimate interests, we have provided the information from our balancing test when assessing whether each processing purpose constitutes ‘necessary’ processing for our own or a third party’s own purposes, to ensure processing does not override your rights and freedoms.| Our processing purpose | Ours or a third party’s legitimate interest |
| To prevent, detect, mitigate and investigate suspected or actual fraud, security breaches and other unlawful or harmful activities on the Party service. | Protect our business, our Party service and its users from fraudulent or otherwise unlawful or harmful activities, including moderation activities. |
| To use data analytics, research, development, testing and analysis to improve and enhance our Party service, to diagnose and fix problems and develop and test new features. | Keep our Party service updated and relevant, to optimise user experience. |
| To detect abuse of our Party service. | Protect our business and mitigate the risk of unauthorised use of Party (including piracy). |
| To monitor compliance with and to enforce our Terms and Conditions, Community Guidelines, this Privacy Notice and other rules and policies | Protect our business and mitigate the risk of unauthorised use, including content moderation activities. |
| To compile and use Aggregated Information for internal and external business purposes. | To use Aggregated Information to better understand our users and how they use our Party service, to inform our 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:
| Better understand our users and how they use our Party service, to provide a more personalised and tailored user, content, advertising and marketing communication experience to you, and to develop and grow our business. |
5. HOW WE SHARE YOUR INFORMATION
We share your personal information and other information as set out below. Where we disclose your personal information to service providers or third parties, we require them to respect the security of your personal information, to treat it in accordance with applicable law, and to use it only for specified and authorised purposes.Service providers
We disclose your information to third party service providers authorised by us and acting on our behalf to operate functions of our services. 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).DAZN entities
We share your personal information to other DAZN entities as required for the purposes of IT and system administration and as set out in the Purposes and Use of Your Information section above, including:- to provide a more personalised experience across the DAZN’s different products and services;
- to 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.
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 and Conditions (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.
6. INTERNATIONAL DATA TRANSFERS
DAZN is a global organisation, and your personal information may be transferred, stored and processed between any of the countries in which we, our entities or third parties operate for any of the purposes set out above.For such international transfers we ensure the appropriate safeguarding of your personal information through only transmitting information via transfer mechanisms approved by the applicable data protection laws:
- the European Commission or UK government, as[EC4] [FS5] [EC6] applicable based on the country whereby the DAZN services are offered, 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.
- for transfers to the USA, the recipient is a participant in an agreed EU-US data transfer programme (or equivalent with the UK) as and when created; or
- other appropriate safeguards in accordance with applicable law have been put in place.
Information in relation to mechanisms governing these transfers can be requested via the Contact Us section.
7. RETENTION OF YOUR INFORMATION
We will only retain your personal data for as long as necessary to fulfil the purpose for which it was collected, or to comply with legal, regulatory, or internal policy requirements. For the majority of information we hold, this will be between 30 days (e.g. Party chat logs) to seven [EC7] [FS8] [EC9] years (e.g. your age or gender stored on your customer account) from the retention event. To determine the appropriate retention periods, we consider:- the amount, nature and sensitivity of your 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.
- the applicable legal, regulatory, tax, accounting or other requirements for retention.
8. YOUR RIGHTS
Depending on applicable data protection laws, you are able to exercise your rights in respect of your personal information we process:- To request a copy of the personal information we hold about you.
- To request correction or rectification of your personal information where it is inaccurate or incomplete.
- To request the erasure of your personal information where processing is no longer necessary for the purposes for which it was collected.
- To request the restriction of processing of your personal information.
- To request transfer of your personal information to another data controller.
- To object to your personal information being used for direct marketing or where the processing is based on our legitimate interests except where we can demonstrate compelling grounds for continuing.
- To withdraw consent where we have asked for your consent to process your personal information; this includes withdrawal of consent from direct marketing communications.
- 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 is not considered to produce legal effects or significantly affect you.
To exercise your rights, please see the Contact Us section. We may not be unable to comply with your request based on exceptions that we can rely upon under applicable data protection laws associated with your country of residence. Should this be the case, we would inform you of this when you contact us.
We will acknowledge requests immediately and without delay and will aim to complete your request within one calendar month; such[EC10] [FS11] [EC12] a period may be extended by two further months where necessary, taking into account the complexity and number of the requests. If needed, we will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. Where required we will take reasonable and appropriate steps to verify your identify when making a request, or the authorisation of third parties making a request on your behalf, to comply with applicable data protection laws and ensure the security of your personal information.
9. DIRECT MARKETING
There is no direct marketing processed specifically for the Party service. For general information on direct marketing to users of DAZN products and services, please see Section 9 of the Global Privacy Notice.10. CHILDREN’S INFORMATION
There is no children’s information processed specifically for the Party service. For general information on processing children’s information DAZN products and services, please see Section 10 of the Global Privacy Notice.11. INFORMATION SECURITY
We are committed to protecting your personal information, and to do so we deploy industry-standard physical, technical and organisational security measures in the collection, storage, use and transfer of your information. Whilst no security measures are impenetrable, the controls we apply are designed to maintain the confidentiality, integrity and availability of your personal information.You also have a part to play to safeguard your personal information and you help can do this by:
- Keeping your username and password for your DAZN account secure.
- Using a different password on your DAZN account to those used on your other personal accounts.
- Updating your devices with the most recent software patches, and by installing an anti-virus product to help protect against malware.
Should you suspect malicious use of or access to your DAZN account or have received a suspicious email claiming to be from DAZN, please contact us via the methods in the Contact Us section.
12. CHANGES TO THIS PRIVACY NOTICE
We keep this notice under regular review to ensure it reflects how we process your personal information, including changes to our processing purposes, your rights in respect of your personal information, and substantive or material changes to how we process personal information. We may take proactive measures to notify you of any such changes via an appropriate means to ensure you remain informed, such as emails, and website pop ups.13. CONTACT US
If you have any questions in respect of this Privacy Notice, about the collection and processing of your personal information, or to exercise your rights, please contact datasubjectrights@dazn.com.14. COMPLAINTS
In the first instance, you can raise an issue regarding your personal information to DAZN’s Data Protection Officer (DPO) via DPO@dazn.com.If you have contacted us regarding your personal information and are still not satisfied with our response and in any other case[EC13] [FS14] [EC15] , you have the right to lodge a complaint with the Italian supervisory authority[EC16] [FS17] [EC18] , known as the Garante per la Protezione dei Dati Personali (Garante).
Please visit https://www.gpdp.it for the Garante’s current contact details.