Privacy policy (Semafor App)

1. INTRODUCTION

Welcome to Privacy Policy for Application HNS Semafor (hereinafter: "Application").

We are Croatian Football Federation, Ulica grada Vukovara 269 A, 10000 Zagreb, PIN: 08516152078 (hereinafter: "HNS," "we," "our" or "us").

HNS respects your privacy and is committed to protecting your data. This Privacy Policy will inform you about how we protect your data when you use the Application and how data protection regulations safeguard you.

HNS is controller of your personal data.

This Privacy Policy applies exclusively to users of the HNS Semafor application. The privacy policy related to players' personal data displayed in the Semafor application and in the Semafor subsection of the HNS website can be found HERE.

2. KEY TERMS

In order to facilitate your understanding of this Policy, below you can find a brief description of the most important terms mentioned in the following points.

TERM	WHAT DOES IT MEAN
Personal data	All data relating to an individual whose identity has been determined or can be determined.
Data subject	A person who can be identified directly or indirectly. In the context of this Policy, you are the data subject.
Controller	A natural or legal person who determines the purposes and means of personal data processing. In the context of this Policy, we are the data controller.
Processor	A natural or legal person who processes personal data on behalf of the data controller. In the context of this Policy, the processor is our partner Analyticom.
Processing	Any procedure or set of procedures performed on personal data.

3. PERSONAL DATA THAT WE COLLECT

 During your use of the Application, we may collect:

• data about the device through which you use the Application. This includes the IP address, language settings, device model, device operating system version, installed Application version, and unique device identifiers assigned by the operating system.
• data about how you use the Application, including information about your choices and preferences regarding content.
• data about your approximate and, in some cases, precise location, if you have consented to share location through your device settings.
• data about the Application and its performance, including logs of any potential errors in operation.

4. HOW DATA IS COLLECTED

 Data is collected through your use of the Application and the use of the device on which the Application is installed.

5. LEGAL BASIS FOR DATA PROCESSING

The processing of personal data necessary for the functioning of the Application is essential for the execution of a contract in which the data subject (you) is a party and is provided for by Article 6(1)(b) of the General Data Protection Regulation (GDPR). The contract is concluded by your acceptance of the Application's Terms of Use, where we commit to enabling you to use the Application, and you commit to using the Application as stipulated in the Terms of Use.

The processing of data that is not essential for the functioning of the Application, such as information about how you use the Application, is based on our legitimate interest in improving the Application's functionalities and offering you a better user experience. The right to process data based on legitimate interest is provided for by Article 6(1)(f) of the General Data Protection Regulation (GDPR).

6. HOW WE USE THE COLLECTED DATA

We use device information to optimize the functionality of the Application, ensure compatibility with different devices, personalize the experience based on language settings, enhance security, and prevent misuse (e.g., detection of suspicious activities).

Data on how the Application is used (choices, preferences) helps us understand how users interact with the Application, allows us to tailor content and recommendations, and improve the user experience based on user interests.

Location information, whether approximate or precise, is used to provide relevant content and services based on the user's location, such as displaying local information or services, and to analyse the usage of the Application in different regions.

Application data is used for diagnosing technical problems, improving Application stability, identifying and correcting errors, and enhancing the overall quality of the Application. 

7. COOKIES

When you use the Application, we may use cookies to ensure optimal functionality and collect information about how the Application is used. Cookies may be installed by HNS or by a third party. The information we collect in this manner will be used to enhance the user experience and add new functionalities to the Application.

For more information on how and why we use cookies, we recommend that you review our Cookie Policy.

8. DATA SECURITY

As the data controller, we take Application security measures to prevent your personal data from being accidentally lost, altered, disclosed, or used without authorization. During transmission, your data is always encrypted and transferred over a secure connection.

We note that, although we will do our best to protect your personal data, complete security is never possible. To this end, we have established necessary procedures for addressing information incidents, as well as procedures that allow us to promptly notify you and the supervisory authority of any suspected personal data breach, in the manner and within the timeframes prescribed by data protection regulations.

9. TRANSFER OF DATA

The personal data we have collected from you is treated as confidential; however, in order to successfully achieve the purposes for which the data is processed, we may make it available to some of our business partners. In such cases, we will take necessary measures to ensure the confidentiality of your personal data even under these circumstances. We do not allow our business partners to use your personal data for their own purposes or for any other purposes for which the data was not initially collected.

The Application displays current data from COMET, platform for managing football competitions of the HNS that has been developed for us by our business partner, a company Analyticom d.o.o., who has also developed the Application.  

For the purposes of maintaining the Application, the mentioned company acts as a data processor on our behalf and may have access to personal data from the Application.

When required by law or other applicable regulations, we are obligated to make the data collected through the use of the Application available to public authorities and public bodies that have the authority to process such data in the execution of their duties.

10. INTERNATIONAL DATA TRANSFER

Personal data collected through the use of the Application is currently not transferred outside the European Economic Area (EEA), nor is it transferred to international organizations or countries that are considered "third countries" according to the General Data Protection Regulation (GDPR).

11. AUTOMATED INDIVIDUAL DECISION-MAKING

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. The processing of personal data in the Application does not currently include automated individual decision-making.

12. DATA RETENTION PERIODS

The personal data we collect through the Application is retained for as long as necessary to achieve the specific purposes for which the data was collected, unless a longer retention period is required by law.

For example, device information and technical data (IP address, language settings, device model, operating system version, Application version) are retained for the duration of your use of the Application and may be kept for a reasonable period thereafter for the purposes of diagnostics, security, and improving the Application's functionality.

Data on how the Application is used (choices, preferences, interaction with the Application) may be retained even after you stop using the Application for the purpose of analysing and improving our services, but it will be anonymized or deleted once it is no longer needed.

Location data is retained only for as long as necessary to provide location-based services and will not be retained longer than necessary for that purpose. Aggregated data on the locations from which users access the Application may be retained for a longer period for the purpose of analysing and improving our services.

13. YOUR RIGHTS

In accordance with data protection regulations, in regard to data processing within the Application and when the necessary conditions are met, you have the right to:

• Access your personal data,
• Request the correction of inaccurate personal data,
• Request the deletion of personal data,
• Object to the processing of your personal data,
• Request the restriction of processing of personal data,
• Request the transfer of your personal data to another data controller,
• Withdraw consent if personal data is processed based on consent,
• Object to processing if personal data is processed based on legitimate interest,
• Lodge a complaint with the authorized supervisory authority in the Republic of Croatia, the Croatian Personal Data Protection Agency (www.azop.hr).

14. CONTACT

If you have any questions regarding this Privacy Policy or wish to exercise your rights, please contact us via email at [email protected] .