Last updated: November 2018
1. Data Protection Declaration
Data Protection Declaration of E-2 Communications Malta Ltd. ("E2"; "we"), 10, Lapsi Street, Fl. No.1, STJ 1261 St. Julians, Malta, concerning the Website https://www.bahis-siteleri-analiz.com/ and the IOS and Android offered App ("App").
Below we inform you in detail to what extent we process your personal data and what rights you have in this regard. The protection of your privacy is a high priority to us. The following declaration is intended to inform you comprehensively on what (personal) data we collect while using our services as well as how we deal with it and which rights you have within this context. Our Data Protection Declaration complies with the General Data Protection Regulation of the European Union ("GDPR").
Data protection regulations must always be observed when personal data is processed. For the scope of this Data Protection Declaration, the definitions of the GDPR are relevant. Thus, the "processing" of personal data essentially includes any handling of the same. As far as data processed by us are human-related and—even if only through third parties, in a summary or by means of additional knowledge—make you identifiable as a person (in particular, have your full name brought to light), it is basically personal data.
This Data Protection Declaration refers exclusively to the above-mentioned Website. If you are forwarded to other websites via links on our Website, please inform yourself directly on the target page about the respective handling of your personal data. We cannot assume any responsibility or liability for the content of third party websites that are linked via our Website.
Our Website is designed as a sole information and comparison portal regarding sports betting as well as various bookmakers (Provider) in this sector. Betting contracts are concluded exclusively with the respective providers via their websites not related to or operated by E2. E2 has no influence on this and is not involved in these contracts.
2. Data Processing following the Access of Our Website
When you visit our Website, we collect the following data: IP address.
You may use our Website without providing any information about yourself. When accessing our Website, we will only process data regarding the access (e.g. IP-Address, surfing behaviours, additional meta data, date and time of retrieval, volume of transferred data, requesting provider) in server log files. This data processing is carried out for the purpose of visitor traceability, checking the effectiveness of advertising measures, playing off targeted advertising elements and messages as well as for the purpose of technical safety and improving the quality of our offer and is based on Art 6 paragraph 1 lit f GDPR (legitimate interests, namely achieving the above-mentioned purposes). However, this information does not allow us to draw any conclusions to you as a person. IP addresses are collected and stored exclusively in anonymous form by shortening the last three (3) digits. You can therefore to a large extent view all the contents of our Website without providing any personal data.
3. Data Processing when using the Contact Form on the Website
On our Website you have the possibility to fill in a contact form to make individual inquiries or to get in contact with us. You must at least enter your e-mail address and may additionally enter your full name (first name, last name). Your e-mail address is absolutely necessary for the transmission and answering of inquiries. In this context, we process your name, if you disclose it to us, on the basis of our legitimate interests pursuant to Art 6 paragraph 1 lit f GDPR for organisational and qualitative reasons, so that we can offer you our service in the present form including personal address. We process the information you enter there exclusively to answer your inquiry; after the last contact it is stored 6 months and then we will delete it.
On our Website, you also have the opportunity to register for our newsletter. To register, we must collect and store your e-mail address and your full name (first name, last name). Your e-mail address is required to send the newsletter (Art 6 paragraph 1 lit b GDPR); your name is required to address you correctly. We collect your name to maintain the quality of our newsletter and for organisational reasons, pursuant to Art 6 paragraph 1 lit f GDPR. The newsletter is sent exclusively to the e-mail addresses provided by interested parties. If you no longer wish to receive the newsletter, you may unsubscribe at any time by clicking on the "Unsubscribe Newsletter" button at the end of each newsletter. Unless otherwise provided for by law, and unless the data is processed on a separate legal basis, data collected for sending the newsletter will be deleted after unsubscribing.
Your data will only be used to send you the newsletter.
To send the newsletter, we use the service "dmaxepaper", which is operated by Dmax.tv, Cat Lane, Swatar, BKR 4402, Malta. Dmax.tv provides us with the software to create and automatically send the newsletter, and the data collected in connection with the newsletter is passed on to Dmax.tv. However, Dmax.tv will not process your personal data any further. Dmax.tv acts as our processor and is contractually bound to our privacy standards.
If you install and start our App on a mobile device, your IP address and other metadata that allow us to draw general conclusions in connection with the usage of our App are collected and processed automatically. The explanations under point 1 apply analogously. This also includes device-specific information (device ID, operating system, platform). This data processing is based on the overriding legitimate interest of E2 (Art 6 paragraph 1 lit f GDPR) and enables us, among other things, to continuously improve the quality of our App and to offer our users the best possible service. It also enables us to monitor the effectiveness of advertising measures and to implement correctives. Furthermore, the App does not request any specific authorisation from you, which is why we are unable to access any personal information (such as the address book).
Both on our Website and within our App, push notifications are offered to draw your attention to relevant information in connection with our offer.
If you visit our Website and the browser you are using supports push notifications, a window will appear. You will be asked if you want to allow push notifications from our Website. If you choose to block our push notifications, the browser will not display any information or news in this way. You must explicitly confirm if you would like to receive notifications. Push notifications can also be managed in the browser settings. Instructions for the most common browsers can be found at https://pushassist.com/knowledgebase/how-to-enable-or-disable-push-notifications-on-chrome-firefox-safari-b/.
After installing the App, push notifications are automatically activated on your device, depending on the software, or you may be asked whether the App is allowed to display notifications. However, push notifications can also be deactivated for individual apps in the settings of the mobile device, although differences may occur depending on the platform and operating system.
7. Data processing when displaying Advertising Content
We are reliant on the marketing of our advertising opportunities on our Website by advertisers. Only then is it possible for us to operate this Website. Advertisers provide you with online advertising based on your usage; concurrently, they are interested in valid information about the scope of their advertisement. If you want to deselect this tracking, you will find detailed instructions at http://www.youronlinechoices.com/uk/your-ad-choices.
By using tracking applications, we as publishers are responsible for the processing of data together with our partner, E-Quadrat Communications GmbH ("E2"), Rathausstraße 19, 1010 Vienna, Austria, email: firstname.lastname@example.org. E2 cooperates when it comes to Website marketing with different companies, which take on different functions depending on the tasks involved. According to the GDPR we are to be qualified as publisher and E2 as independent controller or processor. In the context of data processing when displaying advertising content, however, there is joint responsibility with E2 according to Article 26 GDPR.
E2 uses the tracking tool Cxense of Cxense ASA, Karenslyst Allé 4, 0278 Oslo, Norway as well as the adsystem Oddsserve using the adserver of ADITION technologies AG, Oststraße 55, 40211 Düsseldorf, Germany. In order to correctly provide online advertising based on usage, your behavior on the Website is analyzed and enriched by additional sources, device data or profile parts from registration areas, but only in a pseudonymized form, what makes you unidentifiable as a person.
The processing of data when providing advertising content is carried out for the purpose of measuring reach, providing online advertising based on usage and targeted advertising elements and messages, checking the effectiveness of advertising measures, as well as for the marketing and monetization of the Website and is based on Article 6 (1) (f) GDPR (overriding legitimate interests, namely the attainment of the stated purposes, in particular the financing of the Website, measurement of range, marketing of advertising spaces and display and provision of usage-based online advertising as well as the targeting of advertising elements).
The following link https://www.e-2.at/en/privacy-policy/ provides specific information about the applications of Cxense and Oddsserve, the technology on which they are based, the collected data categories, the rights of the data subjects, the opt-out options, the right of appeal, the competent supervisory authority, the storage period, the data processing as well as the purpose of the processing by E2, the recipients of data as well as the possibility to contact the data protection officer of E2.
8. Rights of the Data Subject
A central aspect of data protection regulation is the implementation of adequate opportunities to allow for the disposition of personal data even after such data has been processed. For this purpose, a series of rights of the data subject are set in place. E2 shall comply with your corresponding requests to exercise your rights without undue delay and in any event within 1 (one) month after receipt of the request. To exercise your rights, please contact us at the following email address: email@example.com. Specifically, the following rights are entailed:
- If you exercise your right to information and there are no legal restrictions, we will inform you in detail about our processing of your data. To this end, we will send you (i) copies of the data (emails, database extracts, etc.), as well as information on (ii) specifically processed data, (iii) processing purposes, (iv) categories of processed data, (v) recipients, (vi) the storage period or the criteria for its determination, (vii) the origin of the data and (viii) further information as the case may be. Please note, however, that we cannot hand over any documents that could impair the rights of other persons.
- With the right to correct, you may request that we correct incorrectly recorded, incorrect or (for the respective processing purpose) incomplete data. Your request will then be reviewed and the data processing concerned may be restricted upon request for the duration of the examination.
- The right to (data) deletion may be exercised (i) in the absence of any need for processing purposes, (ii) in the event of the revocation of a consent granted by you, (iii) in the event of a special objection, provided that the data processing concerned is based on the legitimate interests of E2, (iv) in the event of unlawful data processing, (v) in the event of a legal obligation to delete and (vi) in the event of data processing by minors under 16 years of age.
- In special cases there is an accompanying right to restrictions, after the exercise of which the data concerned may be stored. In addition to the possibility of restricting the examination period for data corrections, (i) the unlawful data processing (if no deletion is requested) and (ii) the duration of the examination of a special request for objection are covered.
- With the right to data portability, you may request to receive the data in a structured, commonly used and machine-readable format and transmit those data to another controller.
- In addition, you have a fundamental right to object to data processing at any time. However, this only applies if the processing is based on the legitimate interests of E2.
- You may also exercise your right of appeal to the Supervisory Authority (see point 15).
Please also note that we may not be able to comply with your request due to compelling reasons worthy of protection for processing (balancing of interests) or processing due to the assertion, exercise or defence of legal claims (on our part). The same applies in the case of excessive requests, whereby a fee may be charged here as well as in the processing of manifestly unfounded requests.
9. Data Security; Deletion of data
E2 takes all appropriate technical and organizational measures to ensure that only personal data whose processing is absolutely necessary for business purposes are processed by default. The measures we have taken concern both the amount of data collected, the processing scope and its storage period and accessibility. On the basis of these measures, we ensure that personal data by default is only made available to a narrowly limited and necessary number of persons. Under no circumstances will other persons be granted access to personal data without the express consent of the data subject. We also use various protection mechanisms (backups, encryption) to secure the Website and other systems. This should serve to protect your (personal) data as best as possible from loss or theft, destruction, unauthorized access, alteration and dissemination.
In accordance with the provisions of the GDPR, all (personal) data collected by us via the Website or App will only be kept for as long as it is required with regard to the legal basis of the processing, unless long-term storage is provided for by law. We fulfil our deletion obligation on the basis of our specific internal company deletion policy, whereby we can provide you with further information on request.
All E2 employees have been sufficiently informed of all applicable data protection regulations, internal data protection regulations and data security precautions and are required to keep secret all information entrusted or made available to them in the context of their professional employment. The requirements of the GDPR are strictly observed and personal data is only made available to individual employees insofar as this is necessary with regard to the purpose of data collection and our obligations arising therefrom.
If we use contractors, they are also obliged to comply with all applicable data protection regulations on the basis of specific framework agreements. Furthermore, when handling your (personal) data, they are strictly bound to our guidelines, in particular with regard to type and scope.
10. Data transmission
For the purposes explained in this Data Protection Declaration, we will transfer your (personal) data to recipients of the following categories:
Within our organisation, those departments or employees who need your data to fulfil their contractual or legal obligations and as a result of data processing based on our legitimate interests, will receive it. Due to our organisational structure, it is also necessary for certain information to be transmitted to our parent company E-Quadrat Communications GmbH, Rathausstraße 19, 1010 Vienna, Austria.
Furthermore, (external) contractors commissioned by us receive your data if they require the data to provide their respective service (whereby access to personal data is sufficient). All contractors are contractually obliged to treat your data confidentially and to process it only within the scope of the provision of services. This includes the following categories of recipients:
- Customer Management
- Product Management
- Legal Department
- IT Support
- Hosting Provider
- Payment Provider
We have a constantly updated list of our recipient categories with regard to data transfers and contract processors.
Some of the recipients mentioned above are outside the EU or process your (personal) data there. However, we take measures to ensure that all recipients have an adequate level of data protection. To this end, we conclude standard contractual clauses, for example, which can be submitted on request. Alternatively, we use providers that are certified according to the EU-US Privacy Shield and for this reason have an appropriate level of data protection according to the GDPR (according to the adequacy decision of the European Commission).
If we use contract processors, they are bound to our data protection practice as previously mentioned and will treat your personal data strictly confidential. Under no circumstances will they transmit your data to third parties or use it for purposes other than those intended to fulfil their obligations towards E2 or in accordance with our express instructions without our express consent.
Most browsers automatically accept cookies. However, you have the option of adjusting your browser settings so that cookies are either generally rejected or only certain types are permitted (e.g. restriction of refusal to third-party cookies). If you change your browser's cookie settings, however, our Website may no longer be used in full. You will find the setting options for the most common browsers under the following links:
- Internet Explorer™: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
- Edge™: https://www.thewindowsclub.com/allow-or-block-cookies-in-microsoft-edge
- Safari™: https://support.apple.com/en-gb/guide/safari/sfri11471/mac
- Chrome™: https://support.google.com/chrome/answer/95647?hl=en&hlrm=en
- Firefox™: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Opera™: https://help.opera.com/en/latest/web-preferences/#cookies
12. Google Analytics
Our Website, web application and app use web analysis tools of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"), which enable us to analyse how you use this Websiteweb application and/or App. Since a login to our Website is not intended or possible, you will only be assigned a client ID, which will be regenerated for different devices. The tracking code analytics.js (Java Script) is used for tracking. In this context, we process your data on the basis of our legitimate interest in producing easy-to-use Website access statistics in a cost-efficient manner (Art 6 Paragraph 1 lit f GDPR).
By using the software, a cookie is set (for the client ID), which is stored on your computer. The information generated by the cookie about your use of this Website is usually transferred to a Google server in the USA and stored there. However, due to the activation of IP anonymization on this Website, your IP address will be reduced by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area prior to its transmission to a Google server in the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on Website activity and providing other services relating to Website and internet usage. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data. Google cannot find out who you are.
Google is a participant in the EU-US Privacy Shield, which obliges the company to comply with the agreement and to maintain a level of data protection in line with European data protection standards. The Privacy Shield certification can be viewed at https://www.privacyshield.gov/list
With the procedure described under point 11 you can prevent the storage of cookies by a corresponding setting of your browser software (possibly limited to third party cookies). You can also prevent Google from collecting data generated by cookies and relating to your use of the Website (including your IP address) and from processing this data by downloading and installing an appropriate browser plug-in (https://tools.google.com/dlpage/gaoptout?hl=en). Alternatively, you can also click here to set an opt-out cookie, which is stored on your device and also prevents Google Analytics from collecting your data. If you delete your saved cookies, however, this step is required again. However, we would like to point out that you may then not be able to use all functions of the Website to their full extent.
Further information on data protection in connection with Google Analytics and your options in this regard can be found at https://www.google.com/analytics/learn/privacy.html?hl=en-GB.
13. Social-Plugins and "2-Click-Solutions"
Our Website uses so-called social plugins ("Plugins") of the social networks Facebook and Google+ and the microblogging service Twitter.
Facebook is operated by Facebook Inc, 1601 Willow Road, Menlo Park, CA 94025, USA ("Facebook"). An overview of Facebook plugins and their appearance can be found here: https://developers.facebook.com/docs/plugins
Google+ is operated by Google. An overview of the Google+ plugins and their appearance can be found here: https://developers.google.com/+/web/
Twitter is operated by Twitter Inc, 1355 Market St, Suite 900, San Francisco, CA 94103, USA ("Twitter"). An overview of the Twitter buttons and their appearance can be found here: https://twitter.com/about/resources/buttons
In order to increase the protection of your data when you visit our Website, the plug-ins are integrated into the Website by means of a so-called "2-click solution". This integration ensures that when you visit a page of our Website that contains such Plugins, no connection to the Facebook, Google and Twitter servers is established. Your browser does not establish a direct connection to the Google, Facebook or Twitter servers until you activate the Plugins and thus give your consent to data transmission. The content of the respective Plugin is then transmitted directly to your browser and integrated into the page. By activating the Plugins, the providers receive the information that your browser has called up the corresponding page of our Website, even if you do not have a profile with the corresponding provider or are not currently logged in. This information (including your IP address) is transmitted directly from your browser to a server of the respective provider in the USA and stored there. If you are logged in to one of the services, the providers can immediately assign your visit to our Website to your profile on Facebook, Google+ or Twitter. If you interact with the Plugins, e.g. press the "Like", the "+1" or the "Twitter" button, the corresponding information is also transmitted directly to a server of the respective provider and stored there. The information is also published on the social network or on your Twitter account and displayed to your contacts there.
For information on data collection by the providers and your rights and setting options for protecting your privacy, please refer to the providers' data protection information.
If you do not want Google, Facebook or Twitter to associate the data collected via our Website directly with your profile at the respective service, you must log out of the corresponding service before activating the Plugins.
Please note that Facebook, Google and Twitter participate in the EU-US Privacy Shield, which obliges companies to comply with the agreement and to maintain a level of data protection that meets European data protection standards. The EU-US Privacy Shield has been granted an adequate level of data protection by an adequacy decision of the European Commission; data transfers to certified companies in the third country USA are therefore permitted to a large extent. The Privacy Shield certifications can be viewed at https://www.privacyshield.gov/list
14. Your Online Choices
The Website http://www.youronlinechoices.com/ of online advertising agencies of the "European Interactive Digital Advertising Alliance" (EDAA) provides you with sustainable information on use-based online advertising and online data protection. Furthermore, certain setting options are made available to you in the web interface ("preference management") at http://www.youronlinechoices.com/uk/your-ad-choices, which, for example, allow you to view/edit your cookie settings with regard to numerous companies. A beta plugin for the browsers Google Chrome and Mozilla Firefox is also available at http://www.youronlinechoices.com/uk/browser-extension to prevent the accidental deletion of cookies and save your preferences. Companies that are designated as "edaa certified" must comply with certain self-imposed industry guidelines.
15. Right of Appeal
If you are of the opinion that we violate applicable data protection laws when processing your data, you have the right to file a complaint with the relevant national data protection authority. The requirements for such a complaint are based on the respective national implementation law of the GDPR, as the GDPR itself does not provide for any regulation in this respect. However, we ask you to contact us in advance in order to clarify any questions or problems.
16. Contact Details regarding Data Protection Issues
In case you have any questions or requests concerning our privacy practices or if you would like to exercise your right of information, rectification or deletion, please send us a written request outlining your desire to:
E-2 Communications Malta Ltd.
10, Lapsi Street, Fl. No.1
STJ 1261 St. Julians