- Soccerment.com collects some Personal Data from its Users according to EU Regulation n. 679/2016 (the “General Data Protection Regulation” or “GDPR”) and Italian Legislative Decree n. 196/2003 (the “Privacy Code”).
Owner and Data Controller
- Soccerment s.r.l.
Via Pietro Paleocapa 6
20121 Milano (Italy)
- Owner contact email: firstname.lastname@example.org
Types of Data collected
- Among the types of Personal Data that soccerment.com collects, by itself or through third parties, there are: email address; first name; last name; Cookies; Usage Data.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using soccerment.com.
Unless specified otherwise, all Data requested by soccerment.com for sign-up to its subscription services is mandatory and failure to provide this Data may make it impossible for soccerment.com to provide its subscription services and the relevant purchase. In cases where soccerment.com specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Data Controller.
- Users are responsible for any third-party Personal Data obtained, spontaneously published or shared through soccerment.com and confirm that they have the third party's consent to provide the Data to the Data Controller.
Mode and place of processing the Data
Methods of processing
- The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of soccerment.com (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Data Controller. The updated list of these parties may be requested from the Data Controller at any time. Furthermore, the Personal Data may be communicated to parties authorized to access the data by law or authorities’ orders.
Legal basis of processing
- The Data Controller may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes: this happens, in particular, when the User registers on the mailing list or for the newsletter, by inserting his/her name and email address and ticks the relevant tick box;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof: this happens, in particular, when the User purchases our Services;
- processing is necessary for compliance with a legal obligation to which the Data Controller is subject, provided for by regulations, national and European laws as well as provisions issued by competent Authorities;
- processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party, for example for legal defense, the management of claims and disputes which may arise, the prevention of fraud and/or illegal activities, as well as for carrying out statistical analysis to improve the Data Controller’s technical assistance and services offered to the User, for developing the platform and the website contents;
Place of processing
- The Data is processed at the Data Controller's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own, for example when the external Data Processors are located. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data and request more information by contacting the Data Controller.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Data Controller using the information provided in the contact section.
- Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
- Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User, in case of purchase of the Soccerment Services, shall be retained until such contract has been fully performed. After the provision of the Services, the Personal Data will be stored only for the provision of the execution of the Data Controller’s legitimate interests, and for carrying out the activities of aggregated analysis, and legal obligations, as set out above.
- In relation to newsletters and marketing activities, the Data Controller may retain the Personal Data for a reasonable time whenever the User has given consent to such processing, as long as such consent is not withdrawn, or until the User opposes the processing (for example by clicking in the “unsubscribe link” in the emails): .
- Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation, for defending and/or ascertaining legal rights and legitimate interests of the Data Controller and/or third parties, for the statutory limitation period provided by law or upon order of an authority.
Once the retention period expires, Personal Data will be deleted o anonymized for aggregated analysis purposes. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
- The Data concerning the User is collected to allow the Data Controller to provide its Services, as well as for the following purposes: Contacting the User, Managing contacts and sending messages, Handling payments, Analytics, Managing data collection and online surveys, Heat mapping and session recording on anonymous basis, Managing landing and invitation pages, Interaction with external social networks and platforms, Displaying content from external platforms, Platform services and hosting and Registration and authentication.
- Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.
Detailed information on the processing of Personal Data
- Personal Data is collected for the following purposes and using the following tools:
- The tools contained in this section enable the Data Controller to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics cookies
- Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on the location soccerment.com is accessed from (“Google”). Google utilizes the Data collected to track and examine the use of soccerment.com, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
- Personal Data collected: Cookies; Usage Data.
Mailing list or newsletter (soccerment.com)
- By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning soccerment.com, with the User’s voluntary and optional consent, which refusal will not affect the possibility for the User of using Soccerment Services. Your email address might also be added to this list as a result of signing up to soccerment.com, always with your previous voluntary and optional consent, which refusal will not affect the possibility for the User of signing up.
- Additionally, we may use the email address provided by the User for the purpose of purchasing Soccerment Services, also without his/her previous consent, for the sending of informative and marketing communication by the Data Controller concerning Soccerment’s services, initiatives and/or offers similar to those previously purchased by the User. The processing, in this case, is based on the Data Controller’s legitimate interest, as provided by art. n. 130.4 of the Privacy Code and recital n. 47 of the GDPR; in relation to this purpose the User will be always allowed to object to such processing by clicking on the “unsubscribe link” in all emails sent .
- Personal Data collected: email address; first name; last name.
- Unless otherwise specified, soccerment.com processes any payments by credit card, bank transfer or other means via external payment service providers, acting as autonomous data controllers. In general, Users are requested to provide their payment details and personal information directly to such payment service providers: we invite the User to consult their relevant privacy policies. Soccerment.com isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Stripe (Stripe Inc)
- Stripe is a payment service provided by Stripe Inc.
- Heat mapping and session recording
- Heat mapping services are used in an anonymous and aggregated basis, not able to identify the user, to display the areas of a page where Users most frequently move the mouse or click. This shows in a statistical way where the points of interest are. These services make it possible to anonymously monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
- Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
- Interaction with external social networks and platforms
- This type of service allows interaction with social networks or other external platforms directly from the pages of soccerment.com.
The interaction and information obtained through soccerment.com are always subject to the User’s privacy settings for each social network.
The social networks might collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective social networks in order to make sure that the processed data on soccerment.com isn’t being connected back to the User’s profile.
- Managing contacts and sending messages
- This type of service makes it possible to manage a database of email contacts, phone contacts (the latters only when voluntarily and autonomously inserted by the User in his/her profile in the personal area) or any other contact information to communicate with the User.
Mailchimp (The Rocket Science Group LLC)
- Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC.
- Personal Data collected: email address; first name; last name.
- Managing data collection and online surveys
- This type of service allows soccerment.com to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.
- These services may be integrated with a wide range of third-party services to enable the Data Controller to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing. Specific information notice and, when necessary, forms of consent could be submitted to Users in these cases.
Hotjar surveys (Hotjar Ltd.)
- Hotjar surveys is a survey builder and data collection platform provided by Hotjar Ltd.
- Hotjar surveys respects the Do Not Track option available in most modern browsers that, if activated, sends a special signal to stop tracking User activity. Users can find more information on how to enable Do Not Track for each supported browser here.
- Personal Data collected: email address.
- Managing landing and invitation pages
- This type of service helps with building and managing landing and invitation pages, i.e., pages for presenting a product or service, where you may add your contact information such as an email address.
Managing these pages means that these services will handle the Personal Data collected through the pages, including Usage Data.
Mailchimp Landing Page (The Rocket Science Group LLC)
- Mailchimp Landing Page is a landing page management service provided by The Rocket Science Group LLC, that allows soccerment.com to collect the email addresses of Users interested in its service.
Mailchimp Landing Page allows the Data Controller to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of the created landing pages.
- Personal Data collected: email address; first name; last name.
- Platform services and hosting
- These services have the purpose of hosting and running key components of soccerment.com, therefore allowing the provision of soccerment.com from within a unified platform. Such platforms provide a wide range of tools to the Data Controller – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
WordPress.com (Automattic Inc.)
- WordPress.com is a platform provided by Automattic Inc. that allows the Data Controller to build, run and host soccerment.com.
- Registration and authentication
- By registering or authenticating, Users allow soccerment.com to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, soccerment.com will be able to access some Data, stored by these third-party services, for registration and identification purposes.
WordPress.com Single Sign On (Automattic Inc.)
- WordPress.com Single Sign On is a registration and authentication service provided by Automattic Inc. and is connected to the WordPress.com network.
The rights of Users
- Users may exercise certain rights regarding their Data processed by the Data Controller.
- In particular, when applicable pursuant to the GDPR and the Privacy Code, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Data Controller, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Data Controller will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Data Controller.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority, in Italy the “Garante Privacy” (www.garanteprivacy.it ).
Details about the right to object to processing
- Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Data Controller or for the purposes of the legitimate interests pursued by the Data Controller, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
- Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Data Controller is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
- Any requests to exercise User rights can be directed to the Data Controller through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Data Controller as early as possible and always within one month.
Additional information about Data collection and processing
- The User's Personal Data may be used for legal purposes by the Data Controller in Court or in the stages leading to possible legal action arising from improper use of soccerment.com or the related Services.
The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
System logs and maintenance
- For operation and maintenance purposes, soccerment.com and any third-party services may collect files that record interaction with soccerment.com (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
- More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.
Should the changes affect processing activities performed on the basis of the User’s consent, the Data Controller shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
- Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
- Information collected automatically through soccerment.com (or third-party services employed in soccerment.com), which can include: the IP addresses or domain names of the computers utilized by the Users who use soccerment.com, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the website) and the details about the path followed within the website with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
- The individual using soccerment.com who, unless otherwise specified, coincides with the Data Subject.
- The natural person to whom the Personal Data refers.
- The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of soccerment.com. The Data Controller, unless otherwise specified, is the owner of soccerment.com.
Soccerment.com (or this website)
- The means by which the Personal Data of the User is collected and processed.
- The service provided by soccerment.com as described in the relative terms (if available) and on this site/application.
European Union (or EU)
- Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
- Small sets of data stored in the User's device.
- This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation or “GDPR”) and Legislative Decree 196/2003 as amended (the “Privacy Code”).