Privacy Policy for Zenniz Smart Court Service

Purposes and legal basis for processing Personal Data 

We process Your Personal Data for the following purposes:

1. Performance of Contracts with You: We process Your Account Data in order to process and fulfill Your orders and to initiate and provide the Service to You and to authenticate You in the Service. The legal basis for this processing is to perform a contract with You in accordance with our User Terms provided to You by in the App or at our website.

2. Provide You Services: We process Your Personal Data to activate, manage and provide the Service in order to personalize Service to match Your needs; give You support with the use of the Service; and to ensure the functions and safety of our Products. The legal basis for this processing is our legitimate interest (provision of services, management of customer relationship).

3. Benchmarking Players: With Your consent we analyze and compare player data to create benchmark statistics to players, trainers and the public.

4. Improve Our Services: We process Your Personal Data to analyze the efficiency of our operations and to develop and improve our Services. The legal basis for this processing is our legitimate interest (provision of services, management of customer relationship). 

5. Non-marketing Communication: We analyze and process Your Personal Data to send You important information regarding the Services, changes to our User terms, and policies and/or other administrative information. You may not opt-out of receiving such communications. The legal basis for this processing is our legitimate interest (customer relationship).

6. Marketing: We may analyze and process Your Personal Data in order to display and send You information and advertisements regarding products and services personalized to Your needs:

   • We may send advertisements by email and other electronic communications on our products and services which are similar to or belong to the same product group with Your previously purchased products or services. The legal basis for this processing is our legitimate interest (customer relationship). With Your consent, we may send You electronic marketing of other Products and Services as well. Each communication we send You will contain instructions permitting You to opt-out of receiving future communications of that nature. 

   • We may display advertisements to you inside the App and at our website and other websites based on Your usage of our Services and websites. The legal basis for this processing is our legitimate interest (customer relationship) or consent when we use cookies for this purpose.

   • When You decide to participate in our lottery, contest or other promotions, or surveys relating to Your use of our Products we may use Your Personal Data to manage such activities based on our legitimate interests and to marketing purposes with Your consent.

7. Legal Compliance: We may process Your Personal Data as we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including You; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

8. Fraud prevention: We process Your mobile device information, usage data, location information and device related information to prevent and trace fraudulent or inappropriate usage. The legal basis for this processing is our legitimate interest (security).

9. Analyzing, profiling, segmentation of the users and their data in the context of and for the purposes explained above based Zenniz´s legitimate interest;

Videos and other data You transfer from the Court Unit to the Internet Service shall only be made available for Your own use and not used by us for any other purpose.

Social media login services and other social media features by Facebook and Google 

You can login or register on our Services by using social media login services like Facebook´s Login or Google´s Sign-In or Identity services. When using such a login button on our Services, You will be shown a consent screen which tells You what kind of data We ask to receive upon login and the terms that apply. At Your consent and dependent on the data protection settings You have applied on the login service provider We may receive for example Your user ID, name, public profile and email address for the purposes defined in this Privacy Policy.

Zenniz´s website may also include other social media features, such as like and share buttons and links to Zenniz´s social media sites. Zenniz can receive comments or links that the user shares from Zenniz´s social media sites. Zenniz can also receive user´s public profile data on social media sites, and any information that social media users share with Zenniz. 

When You use the social login service or other social media features, the social media provider may receive data including the type of Your device, IP address and data about how You use Our Service. It will process such data in accordance with its own Privacy Policy which is available at its website, for example:

o   https://policies.google.com/privacy

o   https://www.facebook.com/policy.php  

Who do we share Personal Data with?

We share Your Personal Data with the following recipients: 

• our third-party service providers or sub-contractors who perform certain business-related functions on behalf of us, such as website hosting, data analysis, payment and credit card processing, infrastructure provision, IT services, customer support service, e-mail delivery services, and other similar services to enable them to provide services to us. These sub-contractors include:

  • cloud & hosting service providers, e.g. Google Cloud

  • email and other communication and marketing services, e.g. Hubspot and Mailchimp 

• an affiliate or other third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings). In such an event, You will be notified via email and/or a prominent notice on our website of any change in ownership, incompatible new uses of Your Personal Data, and choices You may have regarding Your Personal Data.

• As we believe to be necessary or appropriate: (a) to comply with applicable laws and regulations; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside Your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, business and systems; (f) to protect our rights, privacy, safety or property, and/or that of other users, including You; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

• except for the third parties described above, to third parties only with Your consent. 

We conclude appropriate data processing or sharing agreements with our service providers and other data recipients to ensure the protection of your data. They are bound by our instructions and confidentiality terms of the agreements.

International Transfer of Information Collected

To facilitate our operation, we may transfer to, and store and process Your Personal Data in countries outside of the European Union (EU), the European Economic Area (EEA), and countries which have been approved to ensure an adequate level of data protection by the European Commission (GDPR Article 45). Transfers to these third countries include transfers to ICT service providers in USA (Google Cloud. These transfers shall be made only under the Standard Contractual Clauses (SCC) approved by European Commission available at https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc/standard-contractual-clauses-international-transfers_en 

Security

We use physical, electronic, and procedural safeguards to protect information we process. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Service. Please be aware that, although we endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

Data Retention

We retain Your Personal Data until the termination of the User Agreement or as long as your account is active or as needed to provide you the Service. We may for example periodically de-identify unused accounts, and we may regularly review and de-identify unnecessary data. Note that if you ask us to remove Your Personal Data, we will retain data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements

Your Rights Relating to Your Personal Data

You may:

• Request access to the Personal Data that we process about You;

• Request that we correct inaccurate or incomplete Personal Data about You;

• Request deletion of Personal Data about You;

• Request restrictions, temporarily or permanently, on our processing of some or all Personal Data about You;

• Request transfer of Personal Data to You or a third party where we process the data based on Your consent or a contract with You, and where our processing is automated;

• Opt-out or object to our use of Personal Data about You where the processing is based on our legitimate interests; and

• If the processing of personal data is based on Your consent, you have the right to revoke the consent at any time. The revocation of consent does not affect the lawfulness of the processing carried out before the revocation. 

• If you consider that our processing of your personal data infringes applicable law, You may lodge a complaint with the relevant supervisory authority Data Protection Ombudsman in Finland.

 You do not have to pay a fee for exercising Your rights and we will aim to respond You within 30 days. Please note that we may ask You to verify Your identity before taking further action on Your request, for security reasons. 

You may exercise part of Your rights in our Internet Service at www.zenniz.com. If You want to exercise other rights or if you have questions about data protection, please contact us 

e-mail: info@zenniz.com

mail: Zenniz Ltd /Privacy, Kutomokuja 4, 00380 Helsinki, Finland

phone: +358 40 5370277