Privacy Policy

INTRODUCTION

We have a Publication certificate for some of our the streaming services and our web sites. These parts therefore largely fall outside the scope of the GDPR. However, the security requirements of the GDPR must always be followed.

This Privacy Notice describes how Sportway ApS

(“Sportway”, “we” or “us”) collects, uses and shares your personal data for the activities that falls within GDPR in connection with our live and on-demand video streaming platform (the “Video Platform”) and services (together the “Services”), this website, our digital channels, when you communicate with us and when you participate in activities that we carry out.

The Privacy Notice also explains your rights in relation to your personal data in accordance with the General Data Protection Regulation (GDPR) and supplementary data protection regulations.

This Privacy Notice covers you who:

· is a player, coach, team member, spectator, or individual attending a game or practice that is recorded for distribution through our Video Platform,

· use our Video Platform and Services,

· use this website and our digital channels,

· contacts us or otherwise communicates with us, for example via e-mail,

· is a representative of a supplier or partner to us,

· signs up for our newsletter,

· follows us or interacts with us on our social media, and

· signs up for or attends an event or similar activities that we arrange.

EXPLANATION OF CERTAIN TERMS

· Personal data means any information or combination of information that, directly or indirectly, identifies you.

· Processing means any action taken in relation to personal data, including for example collection, compilation, disclosure by transmission and deletion.

RESPONSIBILITY FOR THE USE OF YOUR PERSONAL DATA

Sportway is, as a starting point, responsible (the controller) for the use of your personal data as described in this Privacy Notice.

Joint responsibility for certain use of your personal data

For certain use of your personal data, we are, however, jointly responsible (joint controller) with the partners that use our Video Platform. To be transparent, we have specifically stated for which purposes outlined in this Privacy Notice that we are jointly responsible for the use of your personal data with the relevant partner. To ensure that your personal data is protected, we enter into joint arrangements with our partners regarding the use and protection of your personal data. This Privacy Notice reflect the essence of our joint arrangements with partners, but if you wish further information on the arrangements, please contact us by emailing support@sportway.com.

We act as a processor for certain use of your personal data

Moreover, in connection with the provision of our Video Platform, we also process personal data as a processor on behalf of our partners that use the platform, for example to enable coaching and game and player analysis using the Video Platform and to enable situation analysis for player safety and training using the Video Platform. Where the partner is responsible (the controller) for the use of your personal data in connection with our live and on-demand video streaming platform, the partner’s privacy notice applies to its use of your personal data.

FROM WHICH SOURCES WE COLLECT PERSONAL DATA

The personal data that we collect about you is mainly collected directly from yourself when you provide your personal data to us, for example when we record games or practices in connection that you participate in or attend in connection with the provision of our Video Platform, when you use our website, our digital channels, our Video Platform or Services, participate in a survey or an event, or contact or otherwise communicates with us.

We also collect where necessary personal data from other sources:

The team that you are a member of if you are a player, coach, or otherwise work for the relevant team,

The company or organisation that you work for,

Social network platforms if you follow or interact with us on social media,

Partners that we collaborate with,

Publicly available sources, for example websites or social media,

External persons that provide your personal data to us, for example in connection with communication or an event or similar activity, and

Employees or hired persons that provide your personal data to us.

PERSONAL DATA THAT WE COLLECT AND USE

The categories of personal data that we collect, and use, include:

Identification information, which makes it possible to identify you, for example your name.

Contact information, which makes it possible to contact you, for example your address, e-mail address and telephone number.

User generated information that is generated based on your activity and use of our website, digital channels, our Video Platform and Services, for example clicks and visits on our website, and the number of games watched in our Video Platform,

Profile information, which concerns your profile for example your title, and name and address to the company or organisation that you work for or, if you are a player or team member, player number, team role, team affiliation and match events, for example goals scored or penalties received.
Communication with us, for example contents in e-mail or the responses you provide when participating in a survey.

Picture, video and audio material which includes video footage of you, your picture or voice, for example on-demand and streaming video and audio recordings of games and practices.

Order information for goods and services, for example information on the product or service, price or fee, delivery date or assignment period.

Technical information about the device that you use when using our website, digital channels and our video platform and services, for example type of device, version of browser and operating system.

FOR WHICH PURPOSES WE USE PERSONAL DATA

We use your personal data for the following purposes outlined below. The purposes for which we in practice use your personal data may, however, vary, depending on your interactions with us.

If you participate in or attend a game or practice that we record for the Video Platform

· Record games and practices for distribution using the Video Platform
· Distribute produced games and practices live and on-demand using the Video Platform

If you use our Video Platform and Services

·       Provide access to and manage the Video Platform
·       Analyse the use of the Services
·       Communicate about the Services
·       Provide support and respond to questions regarding the Services
·       Develop, test and improve the Services
·       Detect and prevent misuse of the Services
·       Ensure technical functionality and security

If you otherwise interact with us

·       Manage the relationship with partners and suppliers
·       Manage orders of goods and services
·       Communicate about us and our business
·       Provide offers and direct marketing
·       Communicate in the course of the business
·       Provide our newsletter
·       Carry out surveys
·       Carry out meetings, events and other activities

When we carry out different analyses

·       Follow-up and analyse the business
·       Develop and improve the business
·       Analyse the use of this website and our digital channels
·       Follow-up on and evaluate activities carried out

When we need to use your personal data for legal reasons

·       Fulfill legal obligations
·       Manage, defend and exercise legal claims and rights
·       Manage re-organisations and restructuring of the business
·       Respond to legal requests
·       Protect and ensure the safety of our employees and hired persons

For more information on which activities that we carry out, which categories of personal data that we use, the legal basis and for how long we store your personal data for the purposes outlined above, please see our detailed information on our use of personal data. You can also click on each purpose above, which will take you directly to the relevant section with this information.

HOW WE SHARE PERSONAL DATA

We share your personal data with different recipients:

Users of our Video Platform in connection with the provision of the Video Platform.

· The company or organistation that you work for, for example in connection with communication.

· Partners that we collaborate with and which uses our video platform.

External persons, for example when our employees and personnel communicate in the course of the business.

Other recipients, including public authorities, legal advisors and insurance companies for legal purposes, for example to manage, defend or exercise legal claims and rights in connection with a court dispute.

In addition, to the recipients outlined below, we share personal data with service providers that we have engaged and which needs access to your personal data to provide services to us. These service providers provide, for example, IT services (for example infrastructure services for our video platform) and communication services (which enable us to send you messages and newsletters). The services providers which process personal data on our behalf and in accordance with our instructions.

WHERE WE PROCESS PERSONAL DATA

We use service providers, which also may use sub-contractors, that are established in third countries outside the EU/EEA. To ensure an essentially equivalent level of protection for your personal data when transferred (or otherwise made available) to service providers in third countries outside of the EU/EEA which do not provide an adequate level of protection, we use the EU Commission’s adopted standard contractual clauses for international transfers according to decision 2021/914 and implement – in light of the law and practices of the third country – necessary supplementary measures. Supplementary measures include technical, contractual and organisational measures that are necessary to bring the level of protection of the personal data transferred to an essentially equivalent level protection.

For more information on to which countries your personal data is transferred and the safeguards that we have taken to protect personal data, please contact us at by emailing support@sportway.com.

YOUR RIGHTS

You have certain rights in relation to your personal data. If you wish to exercise your rights, please contact us by e-mailing support@sportway.com. We normally respond to your request within one month following the date we received your request. However, if your request is complicated or if you have submitted several requests, we may need additional time to handle your request. We will in such a case notify you and the reasons of the delay. If we cannot, wholly or in part, comply with your request we will notify you and the reasons for this.

When you submit a request to exercise your rights, we need to confirm your identity to ensure that you are not somebody else than who you claim to be. This to avoid that we for example disclose personal data to an unauthorised person or in error delete personal data. If we do not have sufficient information to confirm your identity, we can request that you provide supplementary information about yourself needed to confirm your identity. We only request such information that is reasonable and necessary to your identity. The time to respond to your requests starts when we have confirmed your identity.

Below we describe the rights that you have in relation to your personal data. For further information on your rights, please see the website of your supervisory authority. In Sweden, the supervisory authority is the Swedish Authority for Privacy Protection(IMY).

Right to access (Article 15 of the GDPR)

You have the right to request confirmation from us as to whether we handle your personal data and in such a case receive a copy of your personal data together with additional information on our use of your personal data. Please note that the right to a copy of your personal data may not adversely affect the rights of others.

Right to rectification (Article 16 of the GDPR)

You have the right to request that we rectify or supplement your personal data if you consider that your personal data is incorrect, incomplete, or misleading.

Right to withdraw your consent (Article 7 of the GDPR)

For certain use of your personal data, we rely on your consent. For information on when we rely on your consent for the use of your personal data, please see the information on the purposes for which we collect, use and share your personal data. When we use your personal data based on your consent, you have the right to at any time withdraw your consent. When you have withdrawn your consent, we will not continue to use your personal data based on the consent previously provided.

Right to erasure (Article 17 of the GDPR)

You have in certain situations the right to request erasure of your personal data (“the right to be forgotten”). Accordingly, the right to erasure is subject to certain conditions. For example, the right to erasure applies if we keep your personal data but no longer the personal data for the purposes for which it was collected, if you withdraw your consent which we rely on for our use of your personal data, or if you object to our use of your personal data and we cannot show a compelling reason to further use your personal data notwithstanding your objection.

There are also several exemptions from the right to erasure, including if we are obligated under law to keep your personal data or if the personal data is needed to exercise, manage, and defend legal claims.

Right to object to our use of personal data (Article 21 of the GDPR)

In certain situations, you have the right to object to our use of your personal data. Where we rely on our or another’s legitimate interest for the use of your personal data, you have the right to object to the use
for reasons which relates to your particular situation. You can see above in relation to each purpose for which we collect, use and share your personal data if we rely on a legitimate interest for the use of your personal data. If we cannot show a compelling reason to continue to use your personal data, we will stop using your personal data for the relevant purpose.

You always have an unconditional right to object to our use of your personal data for direct marketing purposes.

Right to request restriction of your personal data (Article 18 of the GDPR)

In certain situations, you have the right to request restriction of your personal data which means that you can, at least for a certain period, stop us from using your personal data. The right to request restriction of your personal data applies if you consider that the personal data about you is incorrect and during the period that we verify this, if the use of your personal data is unlawful and if you wish that we continue to store your personal data instead of deleting the personal data, and if we no longer need your personal data for the purposes for which we collected the personal data, but you need the personal data to manage, defend or exercise legal claims and rights.

You also have the right to request restriction of your personal data if you have objected to our use of your personal data and during the period, we verify whether we have a compelling reason to continue to use your personal data.

If the use of your personal data has been restricted, we are normally only allowed to store your personal data and not use them for any other purpose than to manage, defend or exercise legal claims and rights. We can also use your personal data for other purposes if you have given your consent to such use.

Right to copy of certain personal data and transfer of the personal data to an external recipient (data portability) (Article 20 of the GDPR)

The right to data portability means that you have a right to receive a copy of the personal data that you yourself has provided to us in a structured commonly used format. Moreover, where it is technically feasible, you also have the right to request that the copy of your personal data is transferred directly to an external recipient.

The right to data portability only applies, however, to personal data that we handle based on your consent (Article 6.1 (b) of the GDPR) or for the performance of an agreement with you (Article 6.1 (a) of the GDPR). We have above in relation to each purpose for which we collect, use and share your personal data outlined which legal bases we rely on for the use of your personal data.

Right to lodge a complaint

You have the right to lodge a complaint with your supervisory authority. In Sweden, the supervisory authority is the Swedish Authority for Privacy Protection (IMY).

Automated individual decision-making

We do not carry out any automated individual decision-making which have legal effects or similar significant effects on you.

USE OF COOKIES AND SIMILAR TECHNOLOGIES

We use cookies and other technologies on our websites. To read more about our use of cookies and similar technologies, please see our cookie policy.

UPDATES TO THIS PRIVACY NOTICE

We regularly update this Privacy Notice. Our use of personal data may change, for example we may collect personal data for new purposes, collect additional categories of personal data or share your personal data with other recipients than outlined in this Privacy Notice. If our use of personal data changes, we will update this Privacy Notice to reflect such changes. At the top of this page, you can see when this Privacy Notice was last updated. If we make material changes that are not only editorial to this Privacy Notice, we will notify you of any such changes and what they mean to you in advance.

IF YOU HAVE QUESTIONS

If you have any questions in relation to our use of your personal data, please contact us by emailing support@sportway.com.

Sportway AB
Reg. no.: 556965-9708
Address: Virkesvägen 12, 120 30 Stockholm
E-mail: support@sportway.com
Telephone: +46 73 051 49 60

Detailed information on our use of personal data

WHEN WE USE PERSONAL DATA

Below we explain the purposes for which we use personal data, examples of activities carried out for each purpose, the categories of personal data used for each purpose, the legal basis for the use and for how long we store personal data.

Record games and practices for distribution using the Video Platform

Responsibility for the use of your personal data:

We are jointly responsible together with the relevant partner for the use of your personal data for this purpose.

Examples of activities that we do for this purpose:

· Use of automated unmanned cameras using AI technology to record games and practices for distribution using the Video Platform.

Categories of personal data:

Legal basis:
· Identification information

· Profile information

· Picture, video and audio material

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our and the relevant partner’s legitimate interest of recording games and practices for distribution using the Video Platform. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose, since the use of your personal data, where relevant, is essential to provide the Video Platform as such and give users access to the recorded games and practices.

Storage period:

Personal data is stored for this purpose for as long as the Services are provided.

Distribute produced games and practices live and on-demand using the Video Platform

Responsibility for the use of your personal data:

We are jointly responsible together with the relevant partner for the use of your personal data for this purpose.

Examples of activities that we do for this purpose:

· Storing of produced games and training in the Video Platform.

· Make available recorded games and practices live and on-demand using the Video Platform.

Categories of personal data:

Legal basis:
· Identification information

· Profile information

· Picture, video and audio material

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our and the relevant partner’s legitimate interest of distributing games and practices live and on-demand using the Video Platform. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose, since the use of your personal data, where relevant, is essential to provide the Video Platform as such and give users access to the recorded games and practices.

Storage period:

Personal data is stored for this purpose for as long as the Services are provided.

Provide access to and manage the Video Platform

Examples of activities that we do for this purpose:

· Set up and administrate your user account for access to the Video Platform. You need to provide the information that we request when you sign up for the Video Platform and our Services as the information is necessary for the performance of the contract with you. If you do not provide the information requested, we cannot create your user account which gives you access to the Video Platform and our Services.

Categories of personal data:

Legal basis:
· Contact information

· Identification information

· Picture, video and audio material

· Profile information

· Technical information

· User generated information

Performance of the agreement with you (Article 6.1 (b) of the GDPR). The use of your personal data is necessary to fulfil the terms and conditions for accessing and using the Video Platform.

Storage period:

Personal data is stored for this purpose for as long as the user account is active. The user account is active for as long as the user has an active subscription or is otherwise authorised to use the Video Platform and for a period of three (3) months thereafter.

Analyse the use of the Services

Examples of activities that we do for this purpose:

· Collect and analyse information about how the Services are used, including information on which videos that are watched and that you interact with. This helps us better understand how the Services are used and how we can continue to develop and improve the Services.

Categories of personal data:

Legal basis:

· Identification information

· Technical information

· User generated information

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of analysing the use of the Services. This helps us better understand how the Services are used and how we can continue to develop and improve the Services. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose, especially since the purpose is to develop and improve the Services to the benefit of all users.

Storage period:

Communicate about the Services

Examples of activities that we do for this purpose:

· Send you communications about the Services, for example via e-mail. This to for example to notify you of updates to the Services and if we need to carry out any maintenance which means that the Services will be temporarily unavailable.

Categories of personal data:

Legal basis:
· Identification information

· Contact information

· Profile information

· Communication

Performance of the agreement with you (Article 6.1 (b) of the GDPR). The use of your personal data is necessary to fulfil the terms and conditions for accessing and using the Video Platform.

Legitimate interest (Article 6.1 (f) of the GDPR). To the extent you have access and authorised to use the Video Platform in accordance with a separate agreement, the use of your personal data is necessary to satisfy our legitimate interest of communicating about our Services. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose, especially since you always can unsubscribe from our communications at any time.

Storage period:

Provide support and respond to questions

Examples of activities that we do for this purpose:

· Respond to questions when you contact us.

· Register and manage support matters.

· Investigate, identify and resolve identified issues, errors and incidents.

· Communicate with you and other for the same purpose.

Categories of personal data:

Legal basis:
· Communication

· Contact information

· Identity information

· Order information

· Profile information

· Technical information

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of responding to questions that you have and to provide customer service, for example providing customer support and managing any potential issues, errors and incidents that the customer may experience using our Services. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose, especially when you yourself has reached out to us.

Storage period:

Personal data is stored for this purpose for a period of 18 months calculated from the date the support matter was closed or the last communication in the same matter.

Develop, test and improve the Services

Examples of activities that we do for this purpose:

· Develop and test new functionality to improve the Services. It is important to us to continuously develop and improve our Services to meet our user’s expectations and needs.

· Investigate, identify and resolve identified issues, errors and bugs.

Categories of personal data:

Legal basis:
· Identification information

· Profile information

· Technical information

· User generated information

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of testing, developing and improving our services, including resolving errors, bugs and other software issues. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose, especially since the purpose is to develop and improve the Services to the benefit of all users.

Storage period:

Personal data is stored for this purpose for the period necessary to anonymise personal data, test functionality, and carry out and verify corrections, which normally is a period of up to (3) months calculated from the date of the commencement of the measure.

Detect and prevent misuse of the Services

Examples of activities that we do for this purpose:

· Ensure and follow-up on access controls to ensure that only authorized users have access to the Services.

· Investigate any suspected misuse of the Services and take necessary measures to resolve any identified issues or incidents.

Categories of personal data:

Legal basis:
· Identification information

· Technical information

Legitimate interest (Article 6.1 f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of detecting and preventing misuse of our Services. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose.

Storage period:

Ensure technical functionality and security

Examples of activities that we do for this purpose:

· Ensure that personal data that we use are only accessed by authorized individuals by having access controls in place.

· Logging for troubleshooting and incident management.

· Backup of personal data to ensure the availability of the personal data in case of a technical or physical incident.

Categories of personal data:

Legal basis:
Relevant categories of personal data that are stated in relation to the purposes of the use of personal data.

Legitimate interest (Article 6.1 f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of ensuring technical functionality and security of our IT systems and services. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose.

Storage period:

Personal data is stored for the same period as stated in relation to each relevant purpose of the processing.

Personal data in logs is retained in order to satisfy our legitimate interest of troubleshooting and incident management for a period of 13 months from the date and time of the log entry.

Personal data in backups are stored for a period of 13 months from the date of the backup.

Manage the relationship with partners and suppliers

Examples of activities that we do for this purpose:

· Register you as a contact person of the partner or supplier and keep your information in our registers.

· Manage invoices received and created.

· Communicate with you and others for the same purpose

Categories of personal data:

Legal basis:
· Communication

· Contact information

· Identification information

· Order information

· Profile information

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of managing the business relationship with our partners and suppliers. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose.

Storage period:

Personal data is stored for this purpose as long as there is an active relationship.

Manage orders of goods and services

Examples of activities that we do for this purpose:

· Register orders for goods and services.

· Respond to requests for proposals (RFPs).

· Communicate with you and other for the same purpose.

Categories of personal data:

Legal basis:
· Communication

· Contact information

· Identification information

· Order information

· Profile information

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of managing orders for products and services. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose.

Storage period:

Personal data is stored for this purpose as long as it is necessary to manage the order or to respond to the specific request.

Communicate about us and our business

Examples of activities that we do for this purpose:

· Publish information about us and our business on this website and in our digital channels.

· Send you communications about us and our business in different channels, for example via e-mail. This to for example provide you with updates regarding our business, information about new features in our Services and changes to our Services.

Categories of personal data:

Legal basis:
· Contact information

· Identification information

· Profile information

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of communicating about us, our business and our services. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose, especially when you always can unsubscribe from our communications at any time.

Storage period:

Personal data is stored for this purpose as long as there is an active relationship and for a period of twelve (12) months thereafter. If there is no relationship the personal data is stored for a period of three (3) months calculated from the date of the collection.

Provide offers and direct marketing

Examples of activities that we do for this purpose:

· Send you offers and direct marketing, including for you relevant and personalised marketing in different channels, for example via e-mail and in other digital channels.

· To provide relevant and personalised offers and marketing to you, we carry out certain profiling of your personal data by analysing for example your user behaviour on our website and in our digital channels and your communication history.

Categories of personal data:

Legal basis:
· Communication

· Contact information

· Identification information

· Profile information

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of providing offers and direct marketing. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose, especially when you always can unsubscribe from our communications at any time.

Storage period:

Communicate in the course of the business

Examples of activities that we do for this purpose:

· Communicate internally and externally in the course of the business, for example when our employees communicate with each other, with you and with external persons by e-mail and in digital meetings.

Categories of personal data:

Legal basis:
· Communication

· Contact information

· Identification information

· Picture, video and audio material

· Profile information

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of communicating internally and externally in the course of the business. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose, since the communication is essential in order for us to carry out our business.

Storage period:

Personal data is stored for this purpose for a period of twelve (12) months calculated from the date of the last communication in the same conversation.

Provide our newsletter

Examples of activities that we do for this purpose:

· If you have signed up for our newsletter, we use your personal data to send you our newsletter.

· Manage your subscription for our newsletter.

Categories of personal data:

Legal basis:
· Identification information

· Contact information

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of providing our newsletter. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose, especially when you have voluntarily signed up for our newsletter.

Storage period:

Personal data is stored for this purpose until further notice or until you unsubscribe from the newsletter.

Carry out surveys

Examples of activities that we do for this purpose:

· If you participate in a survey that we carry out, we collect the personal data that you provide to us in connection with the survey. Your opinions about our business and services are important to us.

· Compile the results of a survey that we have carried out in a report.

Categories of personal data:

Legal basis:
· Identification information

· Contact information

· Profile information

· Communication

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of carrying out surveys in order to better understand what you think about or business and services. This enables us to improve our business and services. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose, especially when you voluntarily participate in the survey.

Storage period:

Personal data is stored for this purpose during the period the survey is carried out and for a period of three (3) months thereafter to compile the responses in a report.

Carry out meetings, events and other activities

Examples of activities that we do for this purpose:

· Register your participation in meetings, events and other activities that you participate in.

· Communicate with you and others regarding the activity.

Categories of personal data:

Legal basis:
· Communication

· Identification information

· Profile information

· Picture, video and audio material

· Contact information

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of carrying out meetings, events and similar activities. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose, especially if you have voluntarily signed up for or participates in the activity.

Storage period:

Personal data is stored for this purpose during the period the meeting, webinar or activity is carried out. If the meeting is recorded to document the meeting, the recording is, as starting point, stored until further notice.

Follow-up and analyse the business

Examples of activities that we do for this purpose:

· Compile reports – based in information collected – to generate statistics for example on orders for our products and services. This to better understand how our business performs.

Categories of personal data:

Legal basis:
· Identification information

· Profile information

· Order information

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of following-up and analysing the business. This to better understand how our business performs. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose.

Storage period:

Personal data is stored for this purpose for a period of 27 months calculated from the date of collection following which the personal data is anonymised or deleted for this purpose.

Develop and improve the business

Examples of activities that we do for this purpose:

· Carry out analyses on an aggregated level to develop and improve the business, our business methods and business strategies. It is important to us to continuously develop the business to ensure that that we work in an efficient way.

Categories of personal data:

Legal basis:
· Communication

· Profile information

· Order information

· Identification information

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of developing and improving the business, our business methods and business strategies. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose.

Storage period:

Personal data is stored for this purpose for a period of 27 months calculated from the date of collection following which the personal data is anonymised or deleted for this purpose.

Analyse the use of this website and our digital channels

Examples of activities that we do for this purpose:

· Collect and analyse information about for example which pages that you have visited on our website and in our digital channels to generate statistics on the use of this website and our digital channels.

Categories of personal data:

Legal basis:
· Identification information

· Technical information

· User generated information

Consent (Article 6.1 (a) of the GDPR). The use of your personal data relies on the consent that you provide by accepting the use of cookies and similar technologies for the same purpose.

Legitimate interest (Article 6.1 (f) of the GDPR). Where we do not use cookies (and similar technologies) for this purpose, we rely on our legitimate interest of analysing the use of our website and digital channels for the use of your personal data. This enables us to continuously improve our website and digital channels. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose.

Storage period:

Personal data is stored during the period stated in our cookie policy. Where we do not use cookies (and similar technologies) for this purpose, personal data is stored for a period of three (3) months for this purpose following which the personal data is anonymised or deleted for this purpose.

Follow-up on and evaluate activities carried out

Examples of activities that we do for this purpose:

· If you have participated in an activity that we have carried out, for example a meeting or event, we use your personal data to follow-up on and evaluate the activity, for example to compile reports with statistics on how many that attended the event.

· Plan future activities based on an evaluation of activities carried out.

Categories of personal data:

Legal basis:
· Communication

· Identification information

· Profile information

· Picture, video and audio material

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of following-up on and evaluating activities carried out. This helps us understand how we can improve and plan future activities. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose, especially if you have voluntarily signed up for or participates in the activity.

Storage period:

Personal data is stored for this purpose for a period of up to 13 months calculated from the date of the relevant activity.

Fulfill legal obligations

Examples of activities that we do for this purpose:

· Keep your personal data to comply with legal storage obligations, for ex. to fulfill accounting obligations.

· Share your personal data with public authorities when needed to comply with legal obligations.

Categories of personal data:

Legal basis:
Relevant categories of personal data that are necessary to fulfil the specific legal obligation.

Fulfill legal obligation (Article 6.1 (c) of the GDPR). The use of your personal data is necessary to fulfil our legal obligations.

Storage period:

Personal data is stored for such period that is necessary in order for us to fulfil the specific legal obligation.

Manage, defend and exercise legal claims and rights

Examples of activities that we do for this purpose:

· Make legal assessments with respect to the legal claim or right.

· Share personal data with other recipients, for example external legal advisors, insurance companies and public authorities in connection with a dispute or court proceeding.

Categories of personal data:

Legal basis:
Only the categories of personal data needed for managing and defending a legal claim in the individual case.

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of managing, defending and exercising legal claims and rights. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose.

Storage period:

Personal data is stored for this purpose during the relevant relationship and for a period of ten (10) years thereafter.

Manage re-organisations and restructuring of the business

Examples of activities that we do for this purpose:

· Compile information, including personal data, needed to manage the re-organisation or restructuring of the business.

· Share personal data with other recipients, for example the buyer of the business and legal advisors, for the same purpose.

Categories of personal data:

Legal basis:
Relevant categories of personal data that are necessary to manage the re-organisation or restructuring of the business.

Legitimate interest (Article 6.1 (f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of managing re-organisations and restructuring of the business. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose if the buyer carries out the same or similar type of business or if the buyer is an affiliate.

Storage period:

Personal data is stored for this purpose for the period that is necessary to manage the re-organisation or restructuring.

Respond to legal requests

Examples of activities that we do for this purpose:

· Receive and assess legal requests from public authorities, for example law enforcement.

· Carry out necessary investigations with respect to the request and respond to the legal request.

Categories of personal data:

Legal basis:
Relevant categories of personal data that are necessary to respond to the legal request in the specific case, which normally includes identification information, contact information, profile information and communication.

Fulfill legal obligation (Article 6.1 (c) of the GDPR). To the extent we are legally obligated to respond to a legal request, the use of your personal data is necessary to fulfil our legal obligation.

Legitimate interest (Article 6.1 f) of the GDPR). If there is no explicit legal obligation requiring that we respond to the legal request, but we consider that we and the public authority have a legitimate interest of that we respond to the legal request, we rely on this legitimate interest for the use of your personal data for this purpose, provided that we make the assessment that the legitimate interest in the specific case, considering the circumstances and context of the legal request, outweighs your interest of not having your personal data processed for this purpose.

Storage period:

Personal data is stored for this purpose for the period that is necessary to respond to the specific legal request and for a period of ten (10) years thereafter to document the request and our response to the request.

Protect and ensure the safety of our employees and hired persons

Examples of activities that we do for this purpose:

· Register, investigate and take other necessary measures to manage incidents involving our employees and hired persons, for example file a police report or report the incident to the public authority concerned.

Categories of personal data:

Legal basis:
· Communication

· Contact information

· Identification information

· Picture, video and audio material

· Profile information

Legitimate interest (Article 6.1 f) of the GDPR). The use of your personal data is necessary to satisfy our legitimate interest of protecting and ensuring the safety of our employees and personnel. It is our assessment that our legitimate interest outweighs your interest of not having your personal data processed for this purpose.

Storage period:

Personal data is stored for this purpose for the period necessary to investigate the incident and take necessary measures as a result of the incident, including for example file a police report or report the incident to the public authority concerned.

WHEN WE SHARE PERSONAL DATA

Below we explain for which purposes, which categories of personal data and on which legal bases we rely on to share your personal data with different recipients.

Purpose
Recipients
Categories of personal data

Legal basis
Distribute produced games and practices live and on-demand using the Video Platform

· Users of the Video Platform
· Identification information

· Profile information

· Picture, video and audio material

Provide support and respond to questions regarding the Services

· The company or organization that you work for
· Communication

· Contact information

· Identity information

· Order information

· Profile information

· Technical information

Manage the relationship with partners and suppliers

· The company or organization that you work for
· Communication

· Contact information

· Identification information

· Order information

· Profile information

Manage orders of goods and services

· The company or organization that you work for

· Communication

· Contact information

· Identification information

· Order information

· Profile information

Communicate in the course of the business

· The company or organization that you work for

· External persons

· Contact information

· Identification information

· Profile information

Carry out meetings, events and other activities

· The company or organization that you work for

· Persons that participate in the same activity

· External persons

· Communication

· Identification information

· Profile information

· Picture, video and audio material

· Contact information

Fulfill legal obligations

· Legal advisors

· Auditors

· Public authorities

· Law enforcement

Relevant categories of personal data that are necessary to fulfil the specific legal obligation.

Fulfill legal obligation (Article 6.1 (c) of the GDPR). The use of your personal data is necessary to fulfil our legal obligations.

Manage, defend and exercise legal claims and rights

· Opposing party

· Legal advisors

· Insurance companies

· Public authorities

· Law enforcement

· External persons

Only the categories of personal data needed for managing and defending a legal claim in the individual case.

Manage re-organisations and restructuring of the business

· The company or organization that you work for

· External persons

· Legal advisors

· Public authorities

· Buyer

Relevant categories of personal data that are necessary to manage the re-organisation or restructuring of the business.

Respond to legal requests

· Legal advisors

· Public authorities

· Law enforcement

Relevant categories of personal data that are necessary to respond to the legal request in the specific case, which normally includes identification information, contact information, profile information and communication.

Protect and ensure the safety of our employees and hired persons

· Legal advisors

· Public authorities

· Law enforcement

· Communication

· Contact information

· Identification information

· Picture, video and audio material

· Profile information

COOKIES AND WEB BEACONS

Like any other website, sportway.com uses ’cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information.