At Catena Media (as defined below), we process the personal data of our customers and visitors to our websites (‘you‘). We make every effort to handle your personal data with care, keep it secure and comply with data protection laws.
Catena Media is engaged in performance marketing and lead generation online. Its headquarters are located in Malta but it also has subsidiaries in several other countries.
You are only allowed to use and access our websites and services if you are over 18 (or the age of legal consent per the laws of any jurisdiction – whichever is higher).
HOW THIS POLICY WORKS
The purpose of this policy is to explain when, why and how we process information which may relate to you (‘personal data‘). It also provides important information on your statutory rights. This policy is not intended to override the terms of any contract you have with us or to override any rights that you may have under data protection laws.
Click on a topic in the list below to find out more about individual topics in more detail by following the various links. We have labelled sections of the Policy to make it easy for you to navigate to the information most relevant to you.
1. Who is responsible for looking after your personal data?
2. What personal data do we process?
3. What do we use your personal data for and when do we process your personal data?
4. Who do we share your personal data with?
5. International Transfers
6. Direct Marketing
7. How long do we keep your personal data?
8. What are your rights?
Who is responsible for looking after your personal data?
Catena Operations Ltd (‘Catena Media”, “we‘, ‘us‘), Quantum Place, Triq Ix Xatt Ta Xbiex, Gzira, GZR 1338, Malta is principally responsible for looking after your personal data (your ‘Data Controller‘). The Data Controller is the company that determines the means and purposes of processing of personal data.
You should be aware that although we are principally responsible for looking after your personal data, information may be held in databases that can be accessed by other companies. When accessing your personal data, all companies will comply with the standards set out in this Policy. See also Section 4 below.
Catena Media is a group of companies with subsidiaries in several countries, for example in the European Union, Australia, Japan and the USA (“Catena Media Group”).
What personal data do we process?
We may process the following personal data about you:
- Date and place of birth
- Email address
- Phone number
- Date of registration
- Content that you submit, such as, posts, comments, personal preferences, opinions, complaints, chats
- IP address
- Location data
- Website usage
- You may choose to provide other information directly to us or we may require other information from you. For example, we may collect other information when you participate in some of our offers or competitions or when you use the forum, if we one make available. We may also collect other information should you decide to get in touch with us or connect with us through social media or another third-party application (your social media service provider or third-party application may allow you to share information with us. If you choose to share, your social media provider will generally tell you which information will be shared).
We do not collect personal data on people under the age of 18 (or the age of legal consent per the laws of any jurisdiction, whichever is higher). If personal data on minors is collected without our knowledge, please contact us at the address indicated in Section 8 below.
What do we use your personal data for and when do we process your personal data?
The Data Controller will collect information from you directly when you use our services or visit our websites.
We use your personal data to:
- create and manage your account and subscriptions
- provide, maintain, enhance and personalise the services that you subscribed to
- meet or exercise any of our legal obligations or rights
- send you service information about your account and subscriptions. For example, we will send information about – or to make you aware of any changes to – the services that you subscribed to
- if you gave your permission, send direct marketing messages and other types of promotional communication, for example by email, SMS, social media (e.g. on Facebook, Telegram, Whatsapp) regarding products or services offered by Catena Media Group and its advertising partners (as defined in Section 4 below). You can unsubscribe at any time. See also Section 6 for more information on direct marketing.
- improve our marketing communications, we may use a similar technology to cookies to confirm whether you have opened a marketing email or clicked on a link in the email
- otherwise communicate with you and respond to your enquiries, for example via our customer support
- analyse information in our systems and databases to improve the way we run our business and websites according to user preferences, to provide a better service and user experience
- personalise, customise, target and improve the content delivered to you based on your preferences and the data we collect
- improve and target advertisements and content that you receive from us and our advertising partners
- do audience segmentation and media campaigns
- register you for a chat forum or community, if we make one available, where you can comment.
- if we make one available, check if you are eligible to claim our bonuses and offers
- if we make one available, conduct contests, surveys and competitions
- understand, diagnose, troubleshoot and fix issues with our services
- meet or exercise any of our legal obligations or rights
Who do we share your personal data with?
We will only process your personal data for the purposes set out in this Section 3 and where we are satisfied that:
- you have provided your consent to us using the data in that way, for example when you have requested or consented to receive direct marketing from us; or
- our use of your personal data is necessary to support ‘legitimate interests’ that we have as a business (for example, so that you can receive certain communications from us, to analyse and share the underlying personal data collected via cookies for analytics and advertising purposes, to improve our products or marketing communications or to carry out analytics across our data sets, or to respond to your enquiries via our customer support service, if we make one available), in a way that is proportionate and respects your privacy.
We work with many third parties to help manage our business and deliver services. From time to time, these third parties may require access to your personal data:
- mailing and SMS application providers, which process personal data on our behalf as data processors
- plugin providers and hosts, which process personal data on our behalf as data processors
- chatbot platforms and providers, which process personal data on our behalf as data processors
- other service providers (e.g. cloud services providers, hosting providers, authentication providers etc), which process personal data on our behalf as data processors
- advertising partners (e.g. ad networks such as third-party ad servers, ad agencies, ad technology suppliers and research firms, affiliate links partners) who also process personal data for their own purposes as Data Controllers. These are identified through our cookie consent management platform. Please read their privacy policies to find out how they collect and process your personal data
- third-party applications or social media services (for example Facebook or Telegram Messenger, Whatsapp messaging), which also process personal data for their own purposes as Data Controllers. These may be integrated with the site in various ways (for example, we may integrate social media messaging or chatbots on our site, use social media accounts or groups that allow you to interact with us and the site or send you various communications in other ways, which will involve us collecting some of your personal data or the social media provider or third-party application receiving some of your information (see more in Section 1 above)
- our subsidiaries in the Catena Media Group, located inside or outside the EU/EEA, for internal administrative and marketing purposes. Personal data transfers will be subject to Catena Media intra-group data transfer agreements, on the basis of our legitimate interest and your consent when transferred to another Catena Media Group subsidiary for its own marketing purposes.
- law enforcement and data protection authorities, if we are under a duty to disclose to and comply with a legal obligation or protect our interests or security.
- in the event that we sell, buy or reorganise any business or assets or if our assets are acquired by a third party, including prospective sellers or buyers.
International Transfers mean that personal data is transferred to a country outside the European Union.
As set out in Section 4 above, we may grant third parties who may be located outside the European Union access to your personal data. In such instances, we shall ensure that the transfer of your personal data is carried out in accordance with applicable data protection laws and, in particular, that appropriate safeguards are in place, such as the Standard Contractual Clauses approved by the EU Commission.
We may also disclose your personal data if we receive a legal or regulatory request from a foreign law enforcement body outside the European Union.
We will always take steps to ensure that any international transfer of information is managed to protect your rights and interests. Any requests for information that we receive from law enforcement or regulators will be carefully checked before personal data is disclosed.
You have the right to ask us for more information about the safeguards we have put in place, as mentioned above. For further information, contact us (see Section 8).
We may use your personal data to send you direct marketing communications regarding products and services that the Catena Media Group and its advertising partners offer, for example in relation to online casino, sports betting and financial services. This may be in the form of emails, SMS, Whatsapp, Facebook or Telegram messenger or targeted online advertisements.
The use and processing of your personal data for the purpose of sending you electronic marketing messages will be based on your consent to receive such messages. When permitted by law, it will be based on our legitimate interest (see Section 3 above). Provided that we have received your consent, we will use third parties to help us to process your personal data for marketing purposes (see Section 4 above).
You retain the right to unsubscribe from any further electronic marketing communications at any time after giving us your consent to send such messages. You can use the opt-out link included in all direct electronic marketing communications or contact us (see Section 8).
We take steps to limit direct marketing to a reasonable and proportionate level and to send you communications that we believe may be of interest or relevance to you, based on the information we have about you.
How long do we keep your personal data?
We will retain your personal data for as long as reasonably necessary for the purposes listed in Section 3 of this Policy.
In some circumstances, we keep your personal data for a certain period of time in order to meet legal, tax or accounting requirements for example. Otherwise, we keep it for as long as we have a contractual obligation with you (e.g. if you are a registered user).
In terms of our marketing and targeting activities, we will collect and process your data until you have withdrawn your consent for collection. See also Section 8 below.
We maintain a data retention policy for personal data in our care. Where your personal data is no longer required, we will ensure that it is either securely deleted or made anonymous.
What are your rights?
You have a number of rights in relation to your personal data. More information on each of these rights can be found by referring to the table set out further below.
To exercise your rights, you may contact us by sending an email to [email protected] or writing to Catena Media at the address set out in Section 1 above.
Please note the following if you wish to exercise your rights:
|Right||What this means|
|Access||You can ask us to: confirm whether we are processing your personal data; give you a copy of that data; provide you with other information on your personal data, for example, what data we have, what we use it for, who we disclose it to, whether we transfer it outside the EU and how we protect it, how long we keep it for, what rights you have, how you can make a complaint, where we got your data from and whether we have carried out any Automated Decision Making or Profiling, to the extent that information has not already been provided to you in this Policy.|
|Rectification||You can ask us to rectify inaccurate personal data. We may seek to verify the accuracy of the data before rectifying it.|
|Erasure||You can ask us to erase your personal data but only where: · it is no longer required for the purposes for which it was collected; or · you have withdrawn your consent (where processing was based on consent); or · following a successful right to object (see ‘Objection’ below); or · it has been processed unlawfully; or to comply with a legal obligation. We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary: · for compliance with a legal obligation; or · for the establishment, exercise or defence of legal claims; There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request|
|Restriction||You can ask us to restrict (i.e. keep but not use) your personal data but only where: · its accuracy is contested (see Rectification), to allow us to verify its accuracy; or · the processing is unlawful but you do not want it to be erased; or · it is no longer required for the purposes for which it was collected but we still need it to establish, exercise or defend legal claims; or you have exercised the right to object, and verification of overriding grounds is pending. We can continue to use your personal data following a request for restriction, where: we have your consent; or to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.|
|Portability||You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format or you can ask to have it ‘ported’ directly to another Data Controller – but in each case, only where: · the processing is based on your consent or on the performance of a contract with you; and the processing is carried out by automated means.|
|Objection||You can object to any processing of your personal data which has our ‘legitimate interests’ as its legal basis, if you believe that your fundamental rights and freedoms outweigh our legitimate interests. We have an opportunity to demonstrate that we have compelling legitimate interests that override your rights and freedoms.|
|International Transfers||You can ask to obtain a copy of – or reference to – the safeguards under which your personal data is transferred outside of the European Economic Area. We may redact data transfer agreements or related documents (i.e. obscure certain information contained within these documents) for commercial sensitivity reasons.|
|Supervisory Authority||You have a right to lodge a complaint with the responsible local supervisory authority about our processing of your personal data. We kindly ask that you attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.|
Version 2.0 February 2022