Date: July 29, 2024 Version: V.1

The terms and definitions used in this Privacy Policy refer to the terms and definitions used in the Terms and Conditions.

This Privacy Policy describes how We collect, use, disclose, process and protect the personally identifiable information ("Personal Data") that You provide in accessing and using the Service Platform.

From time to time, We may revise this Privacy Policy to reflect changes in the law, Our collection and use practices of Your Personal Data, features in Our Service Platform, or advances in technology. If We make revisions that change the way We collect or use Your Personal Data, those changes will be contained in this Privacy Policy and the effective date will be noted at the beginning of this Privacy Policy. We will notify You of any revisions to the Privacy Policy before such revisions become effective. If You do not agree with the changes or modifications to this Privacy Policy, please do not continue to use the Service Platform and any part contained therein.

1. Information

We Collect and Process

We collect Your Personal Data provided to Us when accessing and/or using the Service Platform. Personal Data is data about an identified or identifiable individual individually or in combination with other information either directly or indirectly through electronic or non-electronic systems. Your Personal Data that We process, to the extent permitted by applicable laws and regulations, is as follows:

Your name, address, phone number, email address, date of birth, gender, and Service-related information such as device identity;
Information about the computer, device or any media you use, including IP address, operating system, browser used, URL, page, geographic location data, operating system type, nationality, geographic location and access times and other data related to your computer usage ("IP Details"); and
Financial information, including but not limited to credit card information (credit card number and credit card validity period) and other data that you enter during transactions through the Service Platform so that you can utilise the Services you need.

We are not responsible for any losses that may occur due to information and or data that is not true, clear, complete, accurate and misleading that you provide.

The Service Platform is intended for adults who are 18 (eighteen) years of age or older. In the event that You are not 18 (eighteen) years of age or older, please do not use the Service Platform and submit Your Personal Data to Us.

2. Our Use of Your Information

We recognise that Your Personal Data information is confidential and personal, therefore We are committed to protecting and keeping Personal Data confidential in accordance with applicable laws and regulations. To understand and fulfil Your needs when using the Service Platform, We may process Your Personal Data for several purposes and activities as set out in this article.

In principle, We will use Your Personal Data to provide the Service to You, including for accounting, billing, auditing, credit or payment verification purposes, as well as security, administrative and legal purposes, reward points or similar forms as relevant, testing, system maintenance and development, customer relations, promotion, and assist Us in the future in providing services to You. However, We may use Your Personal Data collected through the Service Platform for the purpose of resolving disputes or complaints and/or for other relevant purposes. To that end, Your Personal Data collected may be disclosed by Us to Our affiliates and/or third parties who are bound to cooperate with Us, including but not limited to hosting websites, data analysis, marketing, processing credit card transactions, and providing services, for one or more of the above purposes from time to time.

Your Personal Data collected may also be used by Us for marketing purposes either through email, social media or other media that we use from time to time, such as sending you new product information, special offers or other information that We think will be of interest to you. Please note that you may opt out of any marketing material that We may send to you at any time. Please follow the instructions to unsubscribe (for paid plans) set out in Our marketing materials if You choose to opt out of any marketing materials, and We will respect Your wishes.

We may also use and/or disclose your Personal Data in the following situations:

to enter into or defend against any claim or suit from any party;
to comply with a court order, judicial process, lawful request, warrant or equivalent by a law enforcement official or authorised party;
to investigate fraud or other wrongdoing, or as otherwise required or necessary in order to comply with applicable law, or to protect Our legitimate interests;
to enforce or apply the Terms and Conditions and Special Terms applicable to the Services;
to protect the rights, property or safety of COMO TV, other users of the Service Platform, or any other party at Our discretion; and
for every other situation permitted or required by law.

3. Basis for Our Processing of Personal Data

The basis on which We process Your Personal Data under this Privacy Policy will depend on the type of Personal Data and the purpose for which the Personal Data is collected. In processing Your Personal Data, We use the following bases for processing Personal Data:

If You have provided consent for Us to process Your Personal Data;
Processing is carried out to perform contractual obligations with you;
If necessary based on Our legitimate interests, as long as Your fundamental interests and rights do not outweigh those interests; and
If necessary to comply with the provisions of applicable laws and regulations, including if requested by authorised government agencies and law enforcement agencies.

4. Overseas Transmission of Your Personal Data

To fulfil Your needs when using the Service Platform, We may share Your Personal Data with Personal Data controllers or Personal Data processors based outside the territory of the Republic of Indonesia.

If We share your Personal Data outside of the Republic of Indonesia, We will endeavour to ensure that those who receive your Personal Data from us will:

process Personal Data in accordance with the purposes of processing as set out in the article of this Privacy Policy on Our Use of Your Information;
keep your Personal Data in accordance with applicable laws and regulations secure from unauthorised access, collection, use, disclosure and processing or similar risks; and
retain your Personal Data only for as long as your Personal Data is needed to achieve the purposes stated in this section.

Your consent to this Privacy Policy also includes your consent to the transfer of your Personal Data overseas.

5. Your Rights

As a data subject, You have rights that are regulated under applicable laws and regulations. Your rights as a Personal Data subject include:

the right to access Personal Data;
the right to withdraw consent (where the basis of processing is consent)
the right to rectify Personal Data;
delete or destroy Personal Data;
limit or suspend the processing of Personal Data; and
object to the processing of Personal Data.

If You wish to exercise Your rights against Us, please submit Your request to email comotv-support@comofootball.com.

To protect the privacy and security of You and other users of the Service Platform, We will verify Your identity before fulfilling Your request. We will try to follow up on requests for the fulfilment of the rights of the subject of Your Personal Data as soon as possible, in accordance with the provisions of the applicable laws and regulations.

However, please understand that the exercise of Your rights as a Personal Data subject is not absolute. Requests related to the exercise of Your rights as a Personal Data subject may be rejected by Us in circumstances where; (i) Your Personal Data contains references to other individuals and/or Your request to correct or delete Your Personal Data requires technical effort and We deem disproportionate or may pose operational risks; and (ii) to the extent permitted by applicable laws and regulations. For example, in accordance with applicable laws and regulations, Your right to delete, withdraw consent, or transfer Personal Data may be denied by Us if it is contrary to:

national defence and security interests;
the interests of the law enforcement process;
public interest in the context of state administration;
the interests of financial sector supervision, monetary, payment system, and financial system stability carried out in the context of state administration; or
statistical and scientific research purposes.

6. Security of Personal Data

We protect Personal Data under Our possession or control by maintaining reasonable security arrangements, including physical, technical and organisational procedures, to prevent unauthorised access, collection, use, disclosure, copying, modification, erasure or risk of the same

You are responsible for (i) maintaining the confidentiality of your account, including for passwords and payment details (for paid plans), and (ii) maintaining and ensuring the security of your devices used to access the Service Platform.

7. Transfer of Business

In the event of a change of control or change of ownership of all or part of COMO TV's business or companies, including the Service Platform, your Personal Data may be part of the transfer of such assets. In this case, as required by applicable laws and regulations, we will notify you before and after the change of control or change of ownership.

8. Personal Data Storage

We will only process and store Your Personal Data as long as We need it to provide the Service Platform to You or comply with Our legal obligations, or for other reasons permitted by applicable laws and regulations.

We will delete your Personal Data if it no longer needs to be stored or if required by applicable laws and regulations.

9. Third Party Links

It is possible that the Service Platform contains links to websites or platforms belonging to third parties. In such cases, such websites or platforms have their own privacy policies and We are not responsible for any harm suffered by you when accessing websites or platforms belonging to third parties. Accordingly, We recommend that you always read the privacy policy of any third party websites or platforms before providing any personal data to such websites or platforms.

10. Contact Us

If you have any questions regarding this Privacy Policy, or any requests or complaints that you wish to make to Us, please contact us via email address comotv-support@comofootball.com or by sending a letter to our office address at Via Alessandro Volta n.70 – 22100 Como, Italy.