COMO TV
PRIVACY POLICY
This version is effective from: July 30 2024
This Privacy Policy (the “Policy”) sets out - pursuant to article 13 of the Regulation (EU) 2016/679 (hereinafter “GDPR”), the Legislative Decree 196/2003, as subsequently amended by Legislative Decree 101/2018 (hereinafter “Italian Privacy Code”), as well as all the provisions and guidelines of the Italian Data Protection Authority, as applicable from time to time - how Sent Entertainment Italy Srl, a company established under the laws of Italy, with registered office at Via Alessandro Volta n.70-22100 Como (hereinafter “COMO” or the “Controller” or “we”, “us”, “our”, as appropriate) processes your personal data in connection with our business, including the provision of our website at tv.comofootball.com, COMO mobile apps on various platform including but not limited to Android and iOS ("COMO TV Mobile Apps") and COMO large screen apps on various platform including but not limited to Android TV, Samsung Tizen and LG webOS ("COMO Large Screen Apps") and any other COMO digital property that refers to this Policy (together the “Platform”) and the services that we offer through our Platform (“Services”).
1 PURPOSE OF THIS POLICY
This Policy explains our approach to any personal data that we might collect from you or from a third party, and the purposes for which we process your personal data. This Policy also sets out your rights in respect of our processing of your personal data.
When we talk about “personal data”, we mean any information relating to an identified or identifiable natural person (so-called “Data Subject”’); an identifiable 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 Policy only applies to the use of your personal data obtained by us, whether from you directly or from a third party. It does not apply to personal data collected by third parties during your communications with those third parties or your use of their products or services (for example, where you follow links to third party websites over which we have no control, or you purchase goods or services from those third parties).
2 HOW TO CONTACT US
If you have any questions about this Policy including any requests to exercise your legal rights, please contact us by email at the following address: [email protected]
3 WHAT PERSONAL DATA WE COLLECT
In providing our Platform and our Services, we may collect and process different types of personal data about you for different processing purposes. The types of personal data we collect depends on who you are and how you use our Platform and our Services and includes the following (as applicable):
Identity Data | First name; last name; profile picture. |
Contact Data | Email address; and telephone number. |
Registration Data | Account username; account password. |
Analytics Data | Data observed about your use of our Platform, including content that you have viewed and data collected through the use of cookies, pixel tags and other similar technologies, including: data relating to your browsing activity on our Platform or interaction with our emails; information about when your current or previous sessions started; information about your viewing habits and content viewed on the Platform. |
IP address; browser type and operating system; geolocation; any other unique numbers assigned to a device. Where you use the COMO Mobile Apps and/or the COMO Large Screen Apps, Technical Data may include (i) device name (e.g. “Apple iPhone” or “Samsung Galaxy” or any other name that you have given your device); (ii) operating system and version; (iii) system language; (iv) general device data, such as voice and regional settings; (v) IP address of the device; (vi) date and time of use; and (vii) application ID to identify your installation of the app. | |
Cookies | In order to obtain information about Cookies and how COMO uses them, please see our Cookie Policy. |
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
4 HOW WE COLLECT AND RECEIVE PERSONAL DATA
We collect and receive personal data using different methods:
Personal data you provide to us | You may give us your personal data directly, for example, when you register an account on our Platform, contact us with enquiries, complete forms on our Platform, subscribe to receive our marketing communications or provide feedback to us. |
Personal data we collect using cookies and other similar technologies | When you access and use our Platform, we will collect certain data by using cookies and other similar technologies. For further information about Cookies and how we use them, please see our Cookie Policy. |
Personal data received from third parties | We may receive personal data about you from third parties. In particular, we may receive personal data about you from the third parties that enable access to the Platform as set out in Section 6 below. |
5 WHO WE COLLECT PERSONAL DATA ABOUT
We collect and process personal data from the following people:
Visitors to our Platform | If you visit our Platform, we will collect and process your personal data in connection with your interaction with us and our Platform. |
Account holders and recipients of our Services | If you register an account on our Platform and/or subscribe to our Services, we will collect and process your personal data in connection with your interaction with us and our Platform. |
People who contact us with enquiries | If you contact us with an enquiry through our Platform, submit a complaint through our Platform and our another customer support channel or provide any feedback to us in our surveys and feedback forms, we will collect and process your personal data in connection with your interaction with us and our Platform. |
6 HOW WE USE YOUR PERSONAL DATA
We use your personal data for the purposes set out in this section. If we wish to make any changes to these purposes, or if we wish to use your personal data for any purpose that is not listed in this section, we will notify you using the contact details we hold for you.
Use of our Platform
Registering and accessing an account on our Platform | You are required to register an account with us in order to gain access to certain features and functionality on our Platform. To create an account, you may need to provide Identity Data, Contact Data and Registration Data. Alternatively, we may provide you with functionality to login to our Platform using your login details to a third party platform, such as Facebook, and we may receive this information automatically from the third party platform. |
When you browse our Platform, we collect and process Analytics Data and Technical Data to help us understand how you are using and navigating our Platform. | |
To provide the correct version of our Platform | We use Technical Data to determine your approximate geolocation to ensure we provide you with the correct version of our Platform, including content, notices and information that is specific to your location. The processing of your data for that purposes does not require your consent as it is based on the need to take pre-contractual measures and/or perform a contract to which you are a party pursuant to article 6(1)(b) of the GDPR. |
To provide enhanced functionality in respect of our COMO Mobile Apps and COMO Large Screen Apps | When you open our apps for the first time, we may ask you for permission to send you push notifications via the app. If you allow this feature, the relevant app will send you push notifications, for example, reminders, alerts, updates and other information. You can configure and turn off push notifications via your device settings at any time. |
If you link to social media sites and interact with our social media pages | If you click on one of the social media links on our Platform or otherwise interact with our social media pages such as on Facebook or Instagram (including interacting with any ‘like’ or similar embedded features on our Platform or social media accounts), we will receive information relating to such interaction, such as certain Analytics Data and Technical Data. |
Receipt and use of our Services
To make our Platform work and keep it secure
To ensure that our Platform works as intended and for security reasons, including to detect fraudulent or illegal activity | To ensure that our Platform can operate properly and securely, we may collect certain Technical Data, including through the use of cookies and other similar technologies. The data may be automatically collected and transmitted to us from your device during your use of the Platform, including the use of cookies and other similar technologies. |
Customer service and enquiries
If you have a general question or need help with any issue concerning our Platform | There are various ways in which you are able to contact us (please see How to contact us) and from time to time, you may also be able to submit specific enquiries on other pages of our Platform, including in secure account areas. |
Customer insight and analysis
To help us understand more about our customers and users and to improve our Platform | We collect Analytics Data and Technical Data when you use our Platform and our Services and when you interact with our emails. We may collect this data from the devices that you use to access our Platform through the use of cookies, web beacons, pixel tags and other similar technologies (which we generically refer to as “Cookies”). |
Marketing and Profiling activities
Marketing activities | We use your Identity Data and Contact Data to send you marketing communications. In particular, we will conduct promotional activities (so-called "marketing") and send you information and promotional communications concerning our services, by mail, internet, telephone, e-mail - including newsletters and direct e-mail marketing - SMS, also in order to carry out market research (c.d. “customer satisfaction”). |
Profiling activities | We use your Identity Data and Contact Data to send you personalised marketing communications. In particular, we will conduct profiling activities in order to allow the analysis of your tastes, preferences, habits, needs and consumption choices and in order to send you personalized offers based on your purchasing preferences. |
Business administration and legal compliance
If we need to use your personal data to comply with our legal obligations or in connection with the administration of our business | We may use your personal data: (i) to comply with our legal obligations; (ii) to enforce our legal rights; (iii) to protect the rights of third parties; and (iv) in connection with a business transition such as a merger, reorganisation, acquisition by another company, or sale of any of our assets. Our legal basis for processing |
7 IF YOU FAIL TO PROVIDE YOUR PERSONAL DATA
Sometimes, the provision of personal data for the purposes indicated above constitutes a legal and contractual obligation. In all these cases, failure to provide data would make it impossible for the Controller to provide the Service to you or allow your access to the Platform.
In other cases, the provision of the personal data is necessary for the pursuit of the legitimate interests of the Controller. In this case, failure to provide the Data could make it impossible for the Controller to pursue such legitimate interests and, for the you, to use the Service.
Instead, the provision of personal data for marketing and profiling purposes is optional. In these cases, failure to provide the data will make it impossible for the Controller to send you personalised and/or non-personalised marketing communications.
8 How we obtain your consent
Where our use of your personal data requires consent, you can provide such consent at the time we collect your personal data following the instructions provided.
9 MODALITIES OF PROCESSING
Your personal data will be processed through electronic procedures and computerized tools. The Controller adopts specific security measures in order to prevent data loss, illicit or incorrect use and unauthorized access to the data. In any case, the personal data will be processed with logics strictly related to the purposes indicated below.
10 THIRD-PARTY LINKS
This Policy only applies to personal data processed by us through your use of our Platform and/or in connection with our business operations. However, from time to time, our Platform may contain links to third-party websites and services. We have no control over these websites and services and this Policy does not apply to your interaction with the relevant third parties.
When you use a link to go from our Platform to another website (even if you don’t leave our Platform) or you request a service from a third party, your browsing and interactions on any other websites, or your dealings with any other third-party service provider, are subject to that website’s or third-party service provider’s own rules and policies. For example, our Platform invites you to connect with us on social media platforms such as Facebook and Instagram. When you click on the links we provide to such third-party platforms, you will be transferred from our Platform to the relevant third-party platform and the Policy (and other terms and conditions) of that platform will apply to you.
We do not monitor, control or endorse the privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you use in connection with your interaction with us and to contact them if you have any questions about their respective privacy policies and practices.
11 SHARING PERSONAL DATA
We only share personal data with others when we are legally permitted to do so. When we share personal data with others, we put contractual arrangements and security mechanisms in place to protect the personal data shared and to comply with our data protection, confidentiality and security standards and obligations.
When processing your personal data, we may need to share it with third parties (including other entities within our group of companies), as set out in the table below. This list is non-exhaustive and there may be circumstances where we need to share personal data with other third parties. In particular, personal data may be communicated to and processed by the following subjects in their capacity of Autonomous Controllers, or Data Processors, as duly appointed by the Controller.
Third-party suppliers who provide applications/ functionality, data processing or IT services | We share personal data with third parties who support us in providing our Platform and help provide, run and manage our internal IT systems. Such third parties may also include, for example, other entities within our group of companies, providers of information technology, cloud-based software-as-a-service providers, identity management, website design, hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centres around the world, and personal data is stored in Milan, Italy. We also share your personal data with third-party service providers to assist us with insight analytics. |
Third-party email marketing and CRM specialists | We share personal data with specialist suppliers who assist us in managing our marketing database and sending out our post and email marketing communications and account-related communications. |
Auditors, lawyers, accountants and other professional advisers | We share personal data with professional services firms who advise and assist us in relation to the lawful and effective management of our organisation and in relation to any disputes we may become involved in. |
Law enforcement or other government and regulatory agencies and bodies | We share personal data with law enforcement or other government and regulatory agencies or other third parties as required by, and in accordance with, applicable law or regulation. |
Other third parties | Occasionally, we may receive requests from third parties with authority to obtain disclosure of personal data, such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, or to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation. |
12 TRANSFER OF DATA TO THIRD PARTIES
As part of the services offered to you, the personal information you provide may be transferred to countries outside the European Economic Area (hereinafter, the “EEA”) and, merely by way of example, your personal data may be transferred to the other companies belonging to the Controller’s Group which need to process your data dealing with the services that the Controller is providing to You. In these cases, countries outside the EEA to which your data shall be transferred may not have the same level of data protection as countries within the EEA. However, whenever we intend to do this, before any transfer takes place, we ensure that transfer to extra-EU countries is carried out in a way that provides appropriate and opportune guarantees according to Chapter V of the GDPR. In particular, a similar level of protection to European data protection regulations is afforded by ensuring at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
- where we use certain service providers, we may use specific standard contractual clauses approved by the European Commission which give personal data the same protection it has in EEA.
13 HOW LONG WE KEEP YOUR PERSONAL DATA
Your personal data will only be processed for the time necessary to achieve the above-mentioned purposes.
The data will be stored according to the following criteria:
- the data processed for purposes related to the fulfilment of legal and contractual obligations will be stored for a period of 10 years from the collection, unless a need for further storage arises, in order to allow the Controller to defend its rights;
- the data processed for purposes related to the pursuit of COMO’s legitimate interests will be retained until the pursuit of those interests;
- i dati trattati per finalità di marketing saranno conservati fino all’eventuale revoca del consenso da parte dell’interessato;
- I dati trattati per finalità di profilazione saranno conservati fino all’eventuale revoca del consenso da parte dell’interessato e comunque per un massimo di 5 anni dalla raccolta del dato.
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Regarding retention periods in the context of the use of cookies, please see our Cookie Policy.
Where we process personal data in connection with the registration and use of an account on our Platform, we will retain your personal data for the duration of any Services that we provide in connection with that account (if applicable) and for such period of time as your account remains active. We will consider an account inactive if no Services are being provided in respect of that account and it has not been accessed for one year.
14 CONFIDENTIALITY AND SECURITY OF YOUR PERSONAL DATA
We are committed to keeping the personal data you provide to us secure and we have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorised access, improper use or disclosure, unauthorised modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of our Platform.
15 PERSONAL DATA OF MINORS
Our Platform is not intended for use by, or targeted at, minors (individuals under the age of 18) and we do not knowingly collect personal data of minors. However, this does not prevent minors from providing personal data to us. If we do collect personal data of minors, we will comply with all applicable laws and regulations relating to the processing of personal data of minors.
If you are under the age of 18, you must not use our Platform and you must not provide us with any personal information. If we discover that we are holding the personal data of a minor, we will delete that information as soon as possible. Please contact us if you have reason to believe that a minor may have submitted personal data to us (please see How to contact us for more information).
16 AUTOMATED PROCESSES
Si precisa che non si effettuano processi decisionali completamente automatizzati.
17 YOUR RIGHTS AS A DATA SUBJECT
We hereby inform you that at any time, in relation to your personal data, you may exercise the rights within the limits and under the conditions set out in Articles 15-22 of the GDPR.
You may exercise such rights by contacting the Controller to the following email address at [email protected] You will have a suitable reply without delay within one month from the receipt of the request.
In detail, as Data Subject, you will have the right to:
- obtain confirmation whether or not personal data concerning you is being processed;
- if processing is in progress, obtain access to personal data and information relating to the processing and request a copy of the personal data;
- obtain the rectification of inaccurate personal data and the integration of incomplete personal data;
- obtain, if one of the conditions provided for in Article 17 of the GDPR is met, the erasure of personal data concerning you;
- obtain, in the cases provided for in Article 18 of the GDPR, the restriction of processing;
- receive personal data concerning you in a structured, commonly used and machine-readable format and request their transmission to another controller, if technically feasible.
RIGHT TO OBJECT
Each Data Subject has the right to object at any time to the processing of his/her data carried out in the pursuit of a legitimate interest of the Controller. In case of objection, your data will no longer be processed unless there are legitimate grounds for the processing which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defence of legal claims.
RIGHT TO OBJECT AND TO WITHDRAW CONSENT IN RELATION TO PROCESSING CARRIED OUT FOR MARKETING AND/OR PROFILING PURPOSES
With regard to the processing of data for marketing and/or profiling purposes, each Data Subject may withdraw at any time the consent possibly given or object to their processing, by writing an email to the address. [email protected]
The withdrawal of your consent shall not affect the lawfulness of processing based on consent before its withdrawal.
Objection to the processing carried out through these methods also extends to the sending of commercial communications through the postal service or telephone calls with an operator, without prejudice to the possibility of exercising this right in part, for example by objecting only to processing carried out using automated communication systems.
RIGHT TO LODGE A COMPLAINT WITH THE ITALIAN DATA PROTECTION AUTHORITY
Finally, pursuant to Article 77 of the GDPR, we remind you that you have the right to lodge a complaint with the Italian Data Protection Authority, if you believe that your rights under the GDPR have been infringed, in the manner indicated on the website of the Italian Data Protection Authority accessible at the address www.garanteprivacy.it.
18 UPDATES OR CHANGES TO THE PRIVACY NOTICE
This notice was updated on July 30, 2024. It may be updated to take into account changes in the Controller’s organization or for example to reflect changes to regulation or legislation.
Updates to this notice will be posted on this page – You may therefore wish to check this page each time You submit personal information to COMO.