Privacy Statement and Cookie Directive
DFL Deutsche Fußball Liga GmbH, Guiollettstrasse 44-46, D-60325 Frankfurt am Main (the “DFL”) collects, processes and uses personal data which has been captured from visits to the website www.rookie-award.com (the “Website”) in compliance with the applicable data privacy provisions in the Federal Republic of Germany. This Privacy Statement and Cookie Directive (hereinafter together: the "Statement") sets out which visitor (“User”) data is captured on the Website and how this information is processed and used.
1. Personal data
Personal data are all information which relate to an identified or identifiable natural person. A natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. This includes, for example, the name, personalized email addresses, the residential address, the telephone number or the date of birth.
2. Data collection, processing and use when accessing the Website
Each time a User accesses the Website, the User’s Internet browser, for technical reasons, automatically supplies the following data to DFL’s web server:
- IP address of the end device
- date and time of access
- name and URL of accessed page
- transferred data volume
- access status (data file transmitted, data file not found, etc.)
- recognition data of the used browser and operating system of the User's end device
- name of the User’s Internet service provider
- website from which the access was made
The collection, processing and use of these data occur for the purposes of enabling the use of the Website (connection set-up), system security and technical administration of the network infrastructure. A comparison with other data sets or a transmission to third parties, even in excerpts, does not take place.
The legal basis for processing is Art. 6 para. 1 b) General Data Protection Regulation (“GDPR”).
With regard to data collection, processing, and use for the purpose of optimizing the Website through web analytics, additional reference is made to Section 3 of this Statement.
3. Data collection, processing and use in the context of web analytics
3.1 Google Analytics
The information about the use of the Website by a User produced by the cookie is normally transmitted to a server of Google in the USA and stored there.
However, DFL has expanded Google Analytics with the code “gat._anonymizeIp();“ in order to assure anonymized collection of IP addresses (so-called IP masking). This means that the IP addresses of Users are shortened within the Member States of the European Union or in other States which are a party to the Convention on the European Economic Area before the transmission to the USA. So, the full IP address is transmitted to a server of Google in the USA and shortened there only in exceptional situations. Google is a registered member of the EU-US Privacy Shield.
Upon request of DFL, Google will use this information in order to analyze the use of the Website by the Users for the purpose of compiling reports about the Website activity to provide additional services to DFL which are related to the use of the Website and Internet use. Google does not combine the IP address of a User's browser with other data under Google Analytics.
The User can prevent the storage of cookies with a corresponding setting on the User's browser software. Furthermore, the User can prevent Google from collecting the data generated by the cookie and relating to his/her use of the Website (including the User’s IP address) by downloading and installing the browser plugin available via the following link. The User can also refuse the use of Google Analytics by clicking on the following link. An opt-out cookie which prevents the future collection of his/her data when visiting the Website will be placed: Disable Google Analytics. However, the DFL hereby informs the User that in this case it is possible that the User cannot completely use all functions of the Website.
The legal basis for processing is Art. 6 para. 1 f) GDPR, whereby the legitmate interest for DFL results from the fact that, in the first place, DFL has an interest in evaluating the Website data for purposes of its optimization. Secondly, a data subject can reasonably foresee that data might possibly be processed for this purpose at the time the personal data is collected and in light of the circumstances under which this occurs (especially the above-mentioned measures).
3.2 Google Ad Manager the insertion of online advertising
DFL uses the Google Ad Manager (formerly: DoubleClick for Publishers (Small Business)) by Google to insert online advertising in the Website. This helps DFL to serve online advertisements to Users. DFL does only insert advertising marketed directly by DFL and no interest-related advertising of third party networks.
The legal basis for processing is Art. 6 para. 1 f) GDPR, whereby the legitimate interest for DFL results from the fact that, DFL also wants to use its invest for operating the Website for direct advertising. The User - after weighing his reasonable expectations based on his relationship with the DFL as the Website operator - will not incur any particular disadvantages.
4. Data collection, processing and use within the scope of the Services offered on the Website
The use of certain services on the Website, in particular the participation in the competition for the voting for the Bundesliga Rookie of the season 2018/2019 (“Competition”) and the Bundesliga Newsletter, requires prior registration, including the submission of personal data (first and last name, email address and country) by the User.
The collection, processing and use of these personal data are carried out solely for the purpose of providing the User with the information and these services and only in the manner and extent to which the User has given prior express consent. The User can withdraw his or her issued consent at any time with effect for the future.
The following is a description of the basis of the data processing for the aforementioned services:
4.1 Registration for the participation in the Competition and the Bundesliga Newsletter
DFL uses the Customer Identity Management Platform provided by Gigya Inc. (USA) (“Gigya”) for the registration for the participation in the Competition and the Bundesliga Newsletter. The use of these data will only be processed for the purposes of enabling the use and the technical administration of the aforementioned services, as well as the establishment, execution or termination of the contractual relationship with the User regarding the participation in the Competition or the Bundesliga Newsletter subscription. The legal basis for processing is Art. 6 para. 1 a) GDPR and Art. 6 para. 1 b) GDPR.
4.2 Special terms and conditions for the Bundesliga Newsletter
The User has been informed in detail about the nature, scope, location and purpose of the collection, processing and use of the personal data. The Users of the Bundesliga Newsletter are assigned a UserID, which allows DFL to determine when the respective Bundesliga Newsletter was opened and which links or functions from the respective Bundesliga Newsletter were activated. This tracking (tracing) takes place for the internal optimization of the Bundesliga Newsletter. These data will not be disclosed.
The legal basis for this data processing is Art. 6 para. 1 f) GDPR, whereby the legitimate interest for DFL results from the fact that, in the first place, DFL has an interest in optimizing such services. Secondly, the User will not incur any particular disadvantages when comparing the User’s reasonable expectations based on his or her relation to DFL as the Website operator and newsletter provider.
If the User of the Bundesliga Newsletter does not want this tracking to take place, he/she can unsubscribe from the Bundesliga Newsletter.
5. Sharing of content
DFL provides Users of the Website with the opportunity to share the Website's content. The legal basis for the following processings is Art. 6 para. 1 a) GDPR (consent).
5.1 Use of social media platforms Facebook, Twitter and Google+
Users can share the Website's content on social media services provided by Facebook, Twitter and Google+.
The use of these plugins will normally result in the transfer of data to Facebook, Twitter or Google+ with each content visited, without the User's explicit permission. Along with the web address of the content visited, an identifier will also be transmitted which enables a direct connection to be made between the User and his/her profile on the respective platform.
The platform operators do not pass on any specific details pertaining to what other data is transmitted. The platform operators are moreover constantly developing their services and make available information as to how the accompanying data is used. The currently valid data protection regulations of the platform providers can be found here: Facebook, Twitter and Google+.
In order to prevent any unwanted transmission of Users' data to Facebook, Twitter and Google+ and to give Users a choice as to whether they wish to use social media services, DFL only offers social sharing links. This ensures no data will be transferred to third parties without the permission of the User. Only when the User activates the social media services, therefore consenting to connect with Facebook, Twitter and Google+, the connection with their services will be established and the social sharing links be provided.
5.2 Email forwarding
The User can also share content of the Website via email by clicking on the email logo button or recommend this content. The email addresses of the recipients entered in by the User will not be used, processed or stored by DFL.
6. Limited purpose for processing and using personal data
All processing or use of personal data of the User occurs only for the purposes mentioned in this Statement and to the extent necessary to achieve the respective purpose.
Personal data are not published by DFL or disclosed to unauthorized third parties.
Transmissions of personal data to government agencies and public authorities occur only in accordance with mandatory national provisions in the law or if the disclosure is necessary in the case of attacks on the network infrastructure in order to pursue rights and for purposes of criminal prosecution. The legal basis for this processing is Art. 6 para. 1 c) GDPR in conjunction with § 24 para. 1 no. 1 b) German Data Protection Act [Bundesdatenschutzgesetz, "BDSG"].
7. Storage and deletion of personal data
All stored personal data and pseudonymized usage data are deleted immediately and permanently as soon as the data are no longer needed for the purposes for which they were collected or the User demands this unless DFL is required by law to do preserve the data. If DFL is required on the basis of provisions in the law to preserve the data, the stored personal data and pseudonymized usage data will be permanently deleted upon expiration of the time periods for preserving data required by law.
DFL uses technical and organizational security measures in order to protect the personal data of the Users against accidental or intentional manipulation, loss, destruction or access by unauthorized persons. The security measures are continuously adapted in accordance with technological developments.
9. Links to other websites
The Website may contain links to other websites. This Statement applies solely to the Website of DFL. DFL has no influence over, and does not control whether other providers comply with applicable data privacy provisions.
10. Rights of the User
The User has a right to information with regard to the stored personal data of the User. The User also has a right to have incorrect data corrected and to restriction of the processing and to have data deleted, as well as a right to object against the processing and the right for data transferability.
The User can contact DFL by email at firstname.lastname@example.org. The data privacy officer of DFL can be contacted at email@example.com. Please note that only data privacy-related messages will be answered at this email address. For all other inquiries please use the email address firstname.lastname@example.org.
It is pointed out that there is a right to file an objection with the supervisory authority.
11. Applicability, validity and timeliness of the Statement
The provisions in this Statement on collection, processing and use of the User’s data apply for the User when using the Website. This Statement is current valid and is dated as of 20 May 2019. DFL reserves the right to amend this Statement at any time as needed with effect for the future, especially for the purposes of adaption to a further development of the Website or the implementation of new technologies.