Privacy policy

1. Preliminary statements

The desktop website and/or mobile application Ourmatch (ref: www.ourmatchapp.com) (hereinafter collectively referred to as our “Platform”) has been developed and currently operated by Ourmatch Ltd, a private limited liability company dully incorporated and registered pursuant to the laws of the Republic of Cyprus (EU), with registration number HE 451858 and having its registered address at Evagorou 31, Evagoras Tower, 3rd Floor Office 32, 1065 Nicosia Cyprus (hereinafter collectively referred to as the “Company”, ”we”, “us” or “our”).

Our Platform only provides data and content related to football such as football matches’ scores; football statistics; and football news. In its current version of our Platform, NO Personal Data (meaning any data allowing for the identification or identifiability of a natural person) or other sensitive information (Sensitive Data) in relation to any natural person (including any minor) will be actively collected; and/or processed and/or stored. As explained below, it could be the case however that Personal Data of natural person(s) are disclosed to us via other digital or physical methods (eg. when a User send us an email).

We know that you care how information about you (whether this is qualified as personal data or not) is used and shared and we appreciate your trust in us to do that carefully and sensibly. We hereby confirm that we are committed to protecting any information/data related to you. Our Company will always collect, process and use any information/data about you strictly and exclusively in compliance with all applicable laws and regulatory obligations, including, but not limited to, in accordance with the Regulation (EU) 2016/679 of The European Parliament and of The Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data (hereinafter the “GDPR”).

This privacy policy is provided in a structured form covering specific areas in relation to data and information collected and/or processed by our Company. It thus aims to give you information on how and for what purposes our Company uses, processes and looks after your data or other information received through your use and/or digital navigation of our Platform and/or otherwise.

PLEASE READ THIS POLICY CAREFULLY BEFORE USING OUR PLATFORM. It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing data about you so that you are fully aware of how and why we are using your data/information. This privacy policy supplements the other notices and/or terms and is not intended to override them.

At the end of this privacy policy there is a dedicate section with some useful definitions which can help you better understand its content. We recommend that you print a copy of this privacy policy for future reference.

2. Who is responsible for your personal data and who you can contact

Subject to the terms of this privacy policy, the entity responsible for your data, including your Personal Data (known as the “Controller” for the purposes of the GDPR) is our Company (ref: details in the preliminary statement).

We have also appointed a data protection officer (hereinafter referred to as the “DPO”) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions, or want more details about this privacy policy and/or on how we use your data/information or in case you would like to exercise your data related rights, please contact our DPO by sending an email at: support@ourmatchapp.com

3. Changes to our privacy policy

We reserve the right to modify this privacy policy from time to time. Every time you wish to use our Platform and/or to enter into any other commercial relationship with us, please check this privacy policy to ensure you understand the terms that apply at that particular time. For the avoidance of any doubt, you are responsible for staying informed of any changes. Each time you access, use and/or digitally navigating through our Platform you reaffirm your acceptance of the then-current terms of the privacy policy. If you do not agree with the modified terms, you should discontinue using our Platform and/or digitally navigating through it and/or you should terminate any other commercial relationship in place between us (as the case may be).

Without prejudice to the generality of the preceding paragraph, any change to this privacy policy which materially affects your rights and/or the processing of your data will be actively communicated and/or otherwise disclosed to you and/or your acceptance to the new version of the said terms will be required prior using our Platform.

You can review the most current version of this privacy policy at any time on this page.

4. Third-party links

Our Platform may include third-party advertisements, content, plug-ins and data, along with links redirecting you to other websites, mobile applications and resources. Clicking on those links or enabling those connections may allow third parties to collect or share information/data about you. For the avoidance of any doubt, such links should not be interpreted as approval by us of those linked websites or of the information you may obtain from them. We do not control these third-party websites and we are not responsible for their privacy statements. When you leave our Platform, we encourage you to read the privacy policy of every website you visit.

5. The data/information we collect

Pursuant to the provisions of the applicable local and EU legislation(s), “Personal Data” or “information of personal nature”, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (known as “Anonymised Data”).

In its current version of our Platform, NO Personal Data (meaning any data allowing for the identification or identifiability of a natural person) or other sensitive information (Sensitive Data) in relation to any natural person (including any minor) will be actively collected; and/or processed and/or stored. It could be the case however that Personal Data of natural person are disclosed to us via other digital or physical methods (eg. when you send us an email).

• Anonymized Data/Information which do not directly or indirectly reveal the identity of a natural person: Among the types of Anonymized Data/information that our Platform collects, by itself or through third parties are the device information; country; app information; device logs; Usage Data; Technical Data; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); geography/region; number of Users; number of sessions; session duration; application opens; application updates; launches; and other operating systems. Such aggregated data do not directly or indirectly reveal your identity as a User. However, if we combine or connect aggregated data with any other data/information so that it can directly or indirectly identify you, we hereby confirm that we will treat the combined data as Personal Data and always in accordance with the applicable laws and regulations.
• Data/Information which reveal the identity of a natural person: Our Company may also collect Personal Data when such are actively communicated to us by you. This may include your name; age; identity card; email address; mobile phone number etc. It is hereby thus clarified that Personal Data may be freely and actively provided by the Users of our Platform (eg. by sending us an email), or, in case any natural person enters into a contractual commercial relationship with our Company.
• Special Categories of Personal Data known as “Sensitive Data”: Some types of information are classified as special categories of personal data known as “Sensitive Data” for the purposes of the European data protection law and there are additional restrictions on how we may use and hold this information/data. We DO NOT knowingly or actively collect any “Sensitive Data” about you or any other natural person either via our Platform or otherwise nor we will ever actively collect and/or process any Personal Data in relation to any minor/children. It may be the case however that, in rare instances, we collect and/or process Sensitive Data in order to meet our legal and regulatory obligations and to protect our business. This includes data as required by the Anti-Money Laundering Regulations as well as biometric data (such as through photograph and CCTV in our headquarters) and information about suspected fraud, theft or offences. If you come to an event that we host, Sensitive Data collected by us may include information/data you provide (such as dietary preferences or allergies or disability information).

6. How do we collect data/information?

We employ various methods to gather data/information from you and/or your device, including:

• Automated technologies or interactions: As you engage with our Platform, we may automatically collect Usage Data as well as Technical Data regarding your device, browsing activities, and patterns. This information is gathered through the use of cookies and similar technologies. Additionally, Technical Data about you may be received if you visit other websites that utilize our cookies or those of our advertising partners (see below). Please refer to our Cookie Policyfor more information.
• Directly from you: For instance, when you disclose your preferences, respond to our campaigns, engage in communication with us (ie. when you send us an email or when you contact us otherwise), and/or when you use and/or digitally navigate through our Platform and/or when you otherwise enter into any other commercial relationship with us.
• From third parties or publicly available sources: Third parties providing advertising and related services may furnish us with information/data about you (including Technical Data). These third parties encompass analytics providers situated within and beyond the EU (such as Google) and ad networks.
• From third parties with your consent or for co-branded services: Your identity data, contact data, and/or profile data may be provided to us by third parties with whom you have consented to share your information (such as for marketing purposes or when a third party provides recruitment services to us). Moreover, in cases where we offer co-branded services like competitions, promotions, or events in collaboration with a third party, that third party may share the information you have provided to them with us, in accordance with your consent preferences, for the purpose of delivering the co-branded services.

7. Why and how do we process data/information (purpose of the processing) and on what legal basis

In general, information/data concerning the User of our Platform is collected to allow our Company to provide and efficiently operate our Platform, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as for the following ancillary purposes: infrastructure monitoring, beta testing, platform services and hosting, advertising, analytics, displaying content from external platforms, managing contacts and sending marketing materials, hosting and backend infrastructure as well as traffic optimization and distribution.

In every case, we process the aforementioned data in compliance with the provisions of any applicable law and regulation including the GDPR.

Below you may find more details on how our Company processes data/information about you as well as on what legal basis.

Such cases include cases where the processing is necessary because of a legal obligation that applies to us.

We may process your data to comply with our legal and regulatory obligations eg preventing, investigating and detecting crime, fraud or anti-social behavior and prosecuting offenders, including working with law enforcement agencies.

We may process your data when we need to perform a contract we are about to enter into or have entered into with you.

We may process your data where it is necessary for our legitimate interests (or those of a third party) and your data protection rights do not override those interests. Examples include but are not limited to:

• ensuring the security and integrity of our services and in ensuring that our Platform operates effectively;
• providing our services/Platform to our Users;
• protecting Users, employees and other individuals and maintaining their safety, health and welfare;
• sending alerts (upon request) which are relevant and tailored to individual Users;
• for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise;
• understanding our User’s behaviour, activities, preferences, and needs;
• improving existing products and services/features and developing new products and/or services and/or features;
• handling customer contacts, queries, complaints or disputes; and
• fulfilling our duties to our Users.

For the avoidance of any doubt, legitimate interest generally means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience.

We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your information/data for our legitimate interests. For the avoidance of any doubt, we do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us or our DPO using the details provided herein.

Generally, we do not rely on consent as a legal basis for processing your Personal Data other than in relation to sending third party direct marketing communications to you via email or text message.

Insofar as you have granted us consent to the processing of Personal Data for marketing purposes, the lawfulness of such processing is based on your consent. Any such consent granted, may be revoked at any time by contacting us or our DPO using the details provided herein.

We have set out below, in a table format, a description of all the ways we plan to use your information/data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Without prejudicing the above, please note that we will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us or our DPO using the details provided herein.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

8. Cookies

Our Platform may use technologies such as "cookies" to provide visitors with tailored information upon each visit. Cookies are a common part of commercial websites that allow small text files to be sent by a website, accepted by a web browser and then placed on your hard-drive in order to recognise repeat visits to the website/Platform. Every time you visit our Platform, our servers, through cookies, pixels and/or GIF files, collect basic technical information such as your domain name, the address of the last URL visited prior to clicking through to our Platform, and your browser and operating system. If you like, you can set your browser/device to notify you before you receive a cookie so you have the chance to accept or reject it and you can also set your browser to turn off all cookies. The website www.allaboutcookies.org (run by the Interactive Marketing Bureau) contains step-by-step guidance on how cookies can be switched off by users. You do not need to enable cookies to visit our Platform - however, some parts of our Platform and some services may be more difficult or impossible to use if cookies are disabled.

For the avoidance of any doubt cookies do not contain any information that could identify the individual user personally.

To learn more, Users may consult our Cookie policy.

9. Marketing

You can tell us whether or not you wish to be contacted for certain marketing purposes as set out below and, if so, how we can contact you.

Marketing communications may contain details about news articles, product updates or any new features, content, data, promotions, competitions, offers and other promotional information about our Platform or our brand, or about the content, data, promotions, competitions, offers and other promotional information and services of our carefully selected partners/third parties.

For certain marketing communications, such as online banner, interstitial and other pop-up notifications and/or advertisements (which may be tailored based on your interests and/or preferences as set out above), we will take into account any information you provide via our consent management tools where relevant. Where we are able to rely on our legitimate interests to make available such marketing communications, we will do so in accordance with the information set out above.

If you wish to stop receiving marketing communications from us, you can opt-out at any time by following the instructions below:

• Email marketing: To unsubscribe from emails, simply use the unsubscribe link provided within any email you receive.
• SMS marketing: To opt-out from SMS messages, utilize the STOP code provided in any SMS you receive.
• In-app push notifications: To opt-out from receiving push notifications from our Platform’s native mobile application, you can disable push notifications in your device settings or via the ‘Notifications’ page in the ‘Settings’ page of our Platform. Users must be aware however that disabling push notifications may negatively affect the utility/efficiency of our Platform.

Please further be informed that you can also contact us directly using the details set out in this policy and amend any marketing communication preferences in place.

In addition to the above, we may also carry out certain profiling of you and your activity on our Platforms in order to send you more relevant marketing communications. This may include profiling the way in which you engage with advertisements that may be served on our Platform or included in our marketing communications of the brands of our Platform, our group companies and our carefully selected third parties. This profiling will be undertaken based on your use of our Platform and your selected preferences for marketing communications. You can opt-out of such profiling by contacting using the contact details provided in this privacy policy.

10. Our advertising partners

Some of the advertisements you receive/see while using and/or digitally navigating through our Platform are chosen and displayed to your device based on predictions about your interests generated from your visits to different websites in the browser you use and on other devices you may use. This type of ad customisation is sometimes called "online behavioural" or "interest-based" advertising. Such interest-based advertising helps support the free content, products and services/features you receive via our Platform.

The advertisements displayed in our Platform are sourced exclusively from authorized Google Play and Apple Store ad networks or meticulously selected advertising partnerships. Please be informed however that the advertising partners we work with may change from time to time. Please contact us directly using the details set out in this policy if would like to receive a complete and up-to-date list of our advertising partnerships.

In general, in order to deliver interest-based advertising that is more likely to be relevant to you, we deploy cookies, web beacons and similar technologies built by such advertising partners that collect usage data, namely the IP address of your device and the websites visited using that device. Our advertising do not receive any directly personally identifiable information such as your name, address or contact details.

If you would like to understand more about interest-based advertising and/or managing your cookies/opt-out options in relation to interest-based advertising, please see our Cookie Policy.

Further information on how to manage cookies via your website browser/mobile device can also be accessed via the following links:

• http://www.networkadvertising.org/choices
• http://www.youronlinechoices.eu
• http://www.youradchoices.com

If you are using the mobile app, you can manage certain preferences via your device's privacy setting (e.g., Apple iOS Limit Ad Tracking).

11. Disclosures of your personal data

Your information will only be shared with companies within our Company’s group and third parties outside this group in accordance with the terms outlined in this privacy policy.

We reserve the right to transfer your information to a third party company in the event of a business restructuring. Additionally, your information may be transferred to a third party if there is a change in the operator of our Platform, or in the event of a sale of all or part of our business or its assets. In such cases, the acquiring party will assume the rights and obligations described in this privacy policy.

We may also disclose your information to business partners and other organizations to assist us in meeting our contractual and regulatory obligations, including audit, legal, and compliance services. This also includes, Governmental authorities and third parties involved in a court action.

Furthermore, your information may be shared with affiliates and third parties from whom you have opted out of marketing communications, been barred, or self-excluded, to ensure that you do not receive unsolicited promotional material.

For identity verification and fraud prevention purposes, your information may be shared with fraud prevention agencies. This includes investigating and preventing underage, fraudulent, criminal, or suspicious activities, as required by law. In any case, we may disclose information that concerns you if we are legally required to do so pursuant to the provisions of any applicable legislation and/or regulation (including the GDPR) as amended from time to time.

Our Company may engage the services of third-party service providers and suppliers for various activities, such as processing your information and providing technical support to our Platform. These service providers may be engaged to provide services which include hosting our Platforms, data storage, sending marketing communications, data cleansing, marketing data segmentation, and data analytics.

Where the party to whom we share your personal information is a legal entity, we hereby affirm that we will take all reasonable steps and/or actions to confirm that the employees and/or representatives of such a third party will execute their duties in accordance with the highest industry standards and will comply with all provisions and requirements of the provisions of this privacy policy as well as of the local laws and regulations on the protection of data (as amended from time to time) including the GDPR and any legislation to success it or complement it.

If co-branded services, promotions, competitions, or events are offered in collaboration with a third party, our Company may share the information/data you provide with that third party will be governed by their privacy notice, which you should review. We require all third parties to respect the security of your information and to process it in accordance with the law. Third-party service providers are not permitted to use your information/data for their own purposes and are only authorized to process your information for specified purposes and in accordance with our instructions.

For the avoidance of any doubt, we note that by using our Platform you agree to have your information/data passed as described herein.

12. Data transferred to a country outside the European Economic Area – International Transfers

We may transfer personal data to partner(s) and/or associate(s) outside the European Economic Area ("EEA").

Please note that if partner (s) and/or associate(s) in a third country are used, all reasonable and practicable measures will be taken to ensure that they will comply with the data protection level in Europe in accordance with the GDPR and any other applicable legislative provision. In addition, any transfers to parties located outside the European Union will be in line with the legal and regulatory provisions of the GDPR and applicable local legislation as amended from time to time.

For the avoidance of any doubt, by accepting this privacy policy you provide your consent to transfer your data, subject to the safeguards included in the preceding paragraph, to partner(s) and/or associate(s) outside the EEA.

If you need more information in relation to the possible transfer of your data to a country outside the EU or the EEA please do not hesitate to contact us or our DPO using the details provided above.

13. Data retention

We will retain your information only for as long as necessary to fulfill the purposes for which we collected it, such as providing you access to our Platform and/or to satisfy any legal, accounting, or reporting requirements.

Once your data/information (including any Personal Data) is no longer needed for processing, we will either delete it or anonymize it by removing any details that identify you, in accordance with the applicable laws and regulations. For instance, if you withdraw your consent for processing your Personal Data, we will delete it unless retention is required to comply with any applicable legislative and/or regulatory provision.

The duration for which we retain your data/information depends on the purposes outlined in this privacy policy. For example, we may retain your information while you use our Platform to address queries related to them. Additionally, we will keep your email address as long as you remain subscribed to receive marketing communications (if applicable).

Please note that we may be obligated by legal and regulatory requirements to retain certain data/information (including certain types of Personal Data) for an extended period, particularly pursuant to any applicable statutory limitation period. If we do so, we will ensure that your privacy is always protected.

14. What data protection rights you have

The following are the rights you have pursuant to the provisions of the GDPR and the applicable legislation (as amended from time to time) in relation to the data protection:

• Request access to your Personal Data (commonly known as a “data subject access request”).
• Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. Please note however that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. In such a case, your data will be stored but not processed until expiration of the retention obligation.
• Subject to the legal basis on which the processing activity is based, you may object to processing of your Personal Data. Please note that in some cases, we may have compelling legitimate grounds to process your information which we need to comply with.
• Request restriction of processing of your Personal Data (a) if it is not accurate;(b) where processing may be unlawful but you do not want us to erase your data; (c) where you need us to hold the data even if we no longer require it; or (d) where you may have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your Personal Data to you or to a third party.
• In case the processing of the data is performed subject to your consent, you may withdraw consent at any time where we are relying on consent to process your Personal Data. However, we note that this will not affect the lawfulness of any processing carried out before you withdraw your consent. Kindly note however that if you withdraw your consent, we may not be able to provide certain products or services to you. We will of course advise you if this is the case at the time you withdraw your consent.

Please be informed that we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). Kindly note however that we may charge you with an administrative fee, in cases where requests are deemed manifestly unfounded or excessive, in particular because of their repetitive character.

If you wish to know more and/or exercise any of the rights set out above, please contact us or our DPO using the details provided in this privacy policy.

15. Data security

We have put in place appropriate security measures to prevent your information/data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. These individuals will only process your Personal Data according to our instructions and are bound by confidentiality obligations.

Furthermore, we have established protocols to address any suspected breaches of Personal Data and will notify you and any relevant regulatory authorities of such breaches where legally mandated to do so.

16. Lodging a complain

Please let us know if you are unhappy with how we have used your Personal Data. As stated above you can always contact us or our DPO anytime by using the contact details provided in this privacy policy.

You also have the right to make a complaint at any time to the Cyprus (EU) Data Protection Commissioner (www.dataprotection.gov.cy/) which is the relevant supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the authorities so please contact us in the first instance.

17. Queries

If you have any questions and/or concerns regarding this privacy policy or in case you wish to exercise your right(s) please contact our DPO by sending an email at: support@ourmatchapp.com

18. Glossary

Data sets that cannot be used to identify an individual.

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 our Platform. The Data Controller, unless otherwise specified, is our Company.

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

The natural person to whom the Personal Data refers.

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.

Data of sensitive nature which 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 and biometric data as well as information about criminal convictions and offences.

Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Platform.

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Information collected automatically through our Platform (or third-party services employed in our Platform), which can include: the IP addresses or domain names of the computers utilized by the Users who use our Platform, 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 our Platform) and the details about the path followed within our Platform 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 our Platform who, unless otherwise specified, coincides with the Data Subject.