Privacy

CATENA MEDIA PRIVACY AND COOKIES POLICY

At Catena Media (“Catena Media“, “we“, “us“), we process personal data about our customers and visitors on our websites (“you“). We make efforts 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, with headquarters in Malta and subsidiaries in a number of other countries.

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, nor rights you might have under data protection laws.

Click on a topic in the list below to find out more on 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.

Contents

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?
9. Cookie Policy – Appendix A.

1. Who is responsible for looking after your personal data?

Catena Operations Ltd having its registered address Quantum Place, Triq ix-Xatt, Ta´Xbiex, Gzira, Malta GZR 1052, is principally responsible for looking after your personal data (your Data Controller). Data Controller means 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 which can be accessed by other companies. When accessing your personal data, all companies will comply with the standards set out in this Policy.

Catena Media is a group of companies with subsidiaries in several countries, for example in the European Union, Australia, Japan and the USA.

2. What personal data do we process?

We may process the following personal data about you:

• Name
• Date of birth
• Email address
• Password
• IP address
• Location data
• Website usage
• Gender
• Age
• Occupation
• Personal preferences and opinions

3. What do we use your personal data for and when do we process your personal data?

Catena Media will collect information directly from you when you use our services or visit our websites.

We use your personal data to:

• send out promotional emails relating to products and services. See also Section 6 below on Direct marketing.
• analyze 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.
• Improve and target advertisements that you receive from us.
• register you for a chat forum or community, if we make available, in which you can provide comments.
• meet or exercise any of our legal obligations or rights

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, or
• our use of your personal data is necessary to support ‘legitimate interests’ that we have as a business (for example, to improve our products, or to carry out analytics across our datasets), in a way that is proportionate and respects your privacy.

4. Who do we share your personal data with?

We work with many third parties, to help manage our business and deliver services. These third parties may from time to time need to have access to your personal data:

• Our mailing application providers:
  • salesforce.com EMEA Limited, a limited liability company incorporated in England. salesforce.com EMEA Limited operates as a subsidiary of salesforce.com, inc., who is Privacy Shield certified as you may see here and processes personal data on our behalf; and
  • Aweber Systems, Inc., based in the USA, who is Privacy Shield certified as you may see here and processes personal data on our behalf;
• Our plugin provider and host of WordPress.com Automattic, Inc., based in the USA who is Privacy Shield certified as you may see here and processes personal data on our behalf;
• Our analytics service providers (such as Google, Hotjar and VWO), who process personal data for their own purposes as Data Controllers. Please refer to our Cookie Policy in the Appendix below in order to identify how you may prevent access to your personal data by analytics providers.
• Service providers or data processors that handle your personal data on our instructions, for example cloud services.
• Our subsidiaries in the Catena Media group, located inside or outside the EU/EEA. Transfers of personal data will be subject to Catena Media intra group data transfer agreements.
• If we are under a duty to disclose to comply with a legal obligation or protect our interests or security.
• In the event we sell, buy or re-organise any business or assets, or if our assets are acquired by a third party, including prospective sellers or buyers.

5. International Transfers

International Transfers mean that personal data is transferred to a country outside the European Union.

As set out in Section 4 above, we may allow access to your personal data to third parties who may be located outside the European Union.

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. Contact us (see Section 8) if you wish further information.

6. Direct Marketing

We will use your personal data to send you direct marketing communications regarding products and services that we and our partners offer regarding for example online casino, sports betting and financial services. This may be in the form of email or targeted online advertisements.

In some cases our processing of your personal data for marketing purposes will be based on our legitimate interests (see Section 3 above). When required by law it will be based on your consent.

You always have a right to say no to further direct marketing, at any time. You can use the opt-out link that you find in all direct marketing communications, or by contacting 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.

7. 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 during a certain period to meet for example legal, tax or accounting requirements.

We maintain a data retention policy for personal data in our care. Where your personal data is no longer required we will ensure it is either securely deleted or made anonymous.

8. What are your rights?

You have a number of rights in relation to your personal data. More information about each of these rights can be found by referring to the table set out further below.

To exercise your rights you may contact us as by sending an email to [email protected] or in writing to Catena Media at the address set out in Section 1 above.

Please note the following if you wish to exercise your rights:

9. Cookie Policy – Appendix A

We use Cookies

To offer you a full range of functions when you visit our website, recognize your preferences, and make the use of our website more comfortable and convenient, we use “cookies.”

What are Cookies?

A cookie, pixel or similar technology is a small file or information saved on your computer or device when you visit the website. It enables the website to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you don’t have to keep re-entering them whenever you come back to the site or browse from one page to another.

Your options

By using our website, you agree to the use and storage of cookies on your computer or device.

You can generally view our website without cookies, but certain parts of the website may not work properly or navigating be slower.

If you do not wish cookies to be stored on your computer or device, you can deactivate the relevant option in the system settings of your browser. You can also delete stored cookies in the system settings of your browser at any time.

More information on how to deactivate or delete cookies can be found here: https://www.aboutcookies.org/cookie-faq/. However, please keep in mind that if you do not accept any cookies this may restrict the functionality of our offerings.

Categories of cookies

We use cookies for different purposes and with different functions.

Some cookies are:

• necessary in technical terms (technical necessity)
• stored and used for a certain time period (storage duration)
• placed and stored by us or a third party (cookie provider).

Technical necessity

Cookies that are technically:

• Necessary: We use certain cookies because they are strictly necessary in order for the website and its functions to work properly. These cookies are automatically placed on your computer or device when you access the website or a certain function, unless you have set your browser to reject cookies.
• Not necessary: Cookies that are not strictly necessary are placed on your computer or device to improve convenience and performance of our website or save certain settings that you have made. We also use cookies that are not strictly necessary in technical terms to get information on the frequency of use of certain areas of our website, so that we can adapt to your needs and requirements on a more targeted basis.

Storage duration

Session cookies: Some cookies are only needed for the duration of your website session, so called “session cookies”. They will be erased or become invalid as soon as you leave our website or your current session expires. Session cookies are used, for example, to retain certain information during your session.

Permanent cookies: Some cookies are stored for a longer period. For example, it allows to recognize you when you access our website again at a later time and access saved settings. As a result, you can access webpages faster or with greater convenience, for example that you do not need to set certain options again, such as your chosen language. Permanent cookies are automatically deleted after a predefined period.

Flow cookies: These cookies are used for communication between our internal servers within our company group. They are placed on your computer or device when you start navigating the website and deleted after the end of your navigation on the website. Flow cookies are given a unique identification number but does not allow us to draw any conclusions regarding the actual customer or user.

Cookie providers

Provider cookies: These are cookies are placed by us or the operator of our website, who is commissioned by us.

Third-party cookies: “Third-party cookies” are stored and used by other organisations or websites, for example Web analytics tools. External providers may also use cookies to display advertising or to integrate content from social networks, such as social plugins. For further information on Web analytics tools and measurement of reach, please see below in this cookie policy.

Use of cookies for Web analytics and reach measurement

We use Google Analytics, a Web analytics service of Google Inc. (“Google”). Google Analytics uses cookies to identify the frequency of use of certain areas of our website and to identify preferences. The information regarding your use of this website that is generated by the cookie (including your truncated IP address) is transferred to a Google server in the United States and stored there. Google will use this information to analyze your use of the website, compile reports on website activity for us, and perform further services associated with website use and Internet use. Google may also transmit this information to third parties where required by law or to the extent third parties process these data on behalf of Google.

You can deactivate Google Analytics using a browser add-on if you do not wish the website analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=.

This add-on stores “opt-out” information on your device that serves to match up your deactivation of Google Analytics. Please note that this kind of “opt out” only leads to the deactivation of Google Analytics for the device and browser from which the opt out was activated. In addition, you may need to reactivate it if you delete cookies from your device.

Our most common cookies are:

V1.2 April 2019