Privacy policy

This Privacy Policy, in accordance with Articles 13 and 14 of Regulation (EU) No 2016/679 (“Privacy Policy”), describes you how Nextwin s.r.l collects users infomation pertaining to each unregistered visitors of www.punterz.club website ("PUNTERZ website") and registered users who download PUNTERZ mobile application ("PUNTERZApp"), in connection with their access to and use of PUNTERZ services ("the Service"). 

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  1. Who is responsible for my personal data?

Nextwin Srl (also called "Data controller") is the legal entity responsible for all personal information that is collected and used about PUNTERZ customers. It is located in Via Emanuele Filiberto, n. 1, 00185 – Rome (RM), Italy, registered under n. RM-1405214 with the C.C.I.A.A. of Rome, C.F. 12853861008, P. IVA 12853861008. The shared Capital entirely subscribed and paid-up consisted of Euro 17.808,00.

  1. I'm a visitor of PUNTERZ website and/or a user of PUNTERZApp. What types of personal data do you collect?

When you navigate and use PUNTERZ website and/or PUNTERZApp, the Platform will collect the following categories of information for the following purposes, wheter or not you are registered user:

Navigation data: information systems and software procedures used to operate the PUNTERZ website and/or PUNTERZApp collect your personal data whose transmission is implied in the use of communication protocols of internet. It concerns information that is not collected to be associated with specific individuals, but by their own very nature, could enable the identification of the customers by processings and associating data of third parties. This category of data includes IP adresses or domain names of computers used by user who connects to the website and/or App, URI (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc..) and other parameters related to the operating system and the users. The collected data are used only in order to draw some statistical information about the use of the sites and also to periodically check its correct functioning. Data may be used for the purposes of ascertaining responsibility in the event of hypothetical IT crimes jeopardising website and/or App security (art. 6, co. 1, let. f)).

Personal data that you provide to us: information provided directly by you through letters/e-mail: the optional, explicit and voluntary mailing of data as requested by the various sections of this site are used for the purpose of processing the user’s requests in a matter of Site and/or App (art. 6, co. 1, let. b) ). You are able to deny the access to these data. Their absence, however, may make impossible to process the request;

through contact forms on PUNTERZ website and/or PUNTERZApp: on our website and mobile application there are contact forms (for example“Contact”). If you decide to fill in them, we will collect and store your personal information to process your request (art. 6, co. 1, let. b)). You are able to deny the access to these data. Their absence, however, may make impossible to process the request.

We also employ cookies on the website. You will find additional information on this subject in paragraph 12.

  1. I'm a visitor of PUNTERZ website and/or a user of PUNTERZApp. How do you use such information?

If you decide to register to PUNTERZ website and/or PUNTERZApp, your personal data will be processed for the further purposes described below:

must be used to implement a contract or deliver a service you have requested (art. 6, co.1, let. b)): to complete the registration procedure, and to conclude and execute the agreement for the supply of service through the PUNTERZ website and/or PUNTERZApp according to the General Terms and Conditions of use and other agreements to which you are a party (for example Terms and Conditions that regulate specific promotional iniatives and contests), and to carry out any pre-contractual disclosures and procedures that you have requested, such as a when you contact us to receive information about our products and services before deciding whether or not to purchase and use them. 

To fulfil legal requirements or respecting orders issued by public authorities (art. 6, co. 1, let. c)): if required by the applicable law provisions, we will process your personal data to fulfil legal tax obligtions and consumer protection.

To fulfil our legal interest to build and increase our community of subscribers and to increase the frequency of the regular visits on PUNTERZ website and/or PUNTERZApp (art. 6., co. 1, let. f)): when you sign in our Site and/or App, you can insert your username (nickname) and browse our Site and/or App as registered user. To fulfil our legal interest to build and increase our community of subscribers and to increase the frequency of the regular visits on PUNTERZ website and/or PUNTERZApp , our systems will automatically assign a score to each action you could do on Site and/or App as registered user (for example, when you visit one of our Site and/or App pages) and they will generate and publish rankings with our users' scores. After having assign you a score, we don't store information on the specific action which score is related on (for example, the specific page which you have visit or the specific video you have viewed). Your scores as well as the those of other users of our Site and/or App can help us to know the frequency of users' interaction with our Site and/or App and to increase the frequency of visits on our Site and/or App. Under no circumstances may other users of our Site and/or App be aware of your detailed information on the types of actions you have done and the score you have obtained on PUNTERZ. Scores can be used to award prizes in contests or initiatives with optional registration unless Regulation makes provision therefor;

To fulfil our legal interest to know how much and how long users are on Site and/or App (art. 6., co. 1, let. f)): To fulfil our legal interest to know how much and how long Site and/or App are used by visitors, we acquire data and generate reports, directly or by means of third party suppliers, in order to strictly monitor the number of visited pages of our Site and/or App, the number of visitors and, generally, how they use our Site and/or App, without trace back to an identifiable person. Our suppliers use cookie technologies to acquire data and generate reports, (you will find additional information on this subject in paragraph 12);

To fulfil our legal interest to exercise or defence of legal claims (art. 6., co. 1, let. f)): we can process your personal data to fulfil our legal interest to exercise or defence of legal claims, even in the case of any non-compliance with the General Conditions contained on Site and/or App or in case of violation of law.

Additionally, with your free and voluntary consent, we may process your personal data for marketing purposes and/or customer profiling activities. In relation to the above mentioned data treatment, please read the following paragraphs.

  1. Do you use my data for promotional messages?

We will process your personal data for marketing purposes (for example direct marketing advertising, commercial communications, customer satisfaction surveys) only with your free and voluntary consent, that is expressible by checking the dedicated box of the registration form set into user's personal area of our Site and/or App. 

By giving your consent, we will contact you via mail with information regarding promotions on our goods and/or services, special offers sponsored by our partners as well as customers satisfaction surveys and market research materials. 

By checking the box, you agree to be contacted via e-mail for marketing purposes. You will have the choice to opt in or opt out of receiving such communications by indicating what you no longer wish to receive (for example, you can decide to receive communications exclusively via traditional mail). 

You can fully or partially withdraw your consent to process your personal data for marketing purposes at any time (for example, you can decide to receive communications exclusively via traditional mail), asking for it as described in paragraph 17. 

You can withdraw your consent to process your e-mail address for marketing purposes also by clicking on the opt-out link (opt-out) in every communication from PUNTERZ. 

Additionally, with your free and voluntary consent, we will share your personal data with third parties for marketing purposes. In relation to the above mentioned data treatment, please read the following paragraph 6. 

  1. Do you process my personal data for the purpose of customer profiling?

By providing any personal data you explicitly agree that we may use it to perform profiling activities in accordance with this Privacy Policy. We will process your personal data for the purpose of profiling to grant you coherent promotional communications only after having received your free and voluntary consent, that is expressible by checking the dedicated box of the registration form set into user's personal area of our Site and/or App. For example, we can send only promotional communications most suitable for your personality and age. Your consent is free and voluntary. You can deny it and mantain a full use of our Site and/or App features. By giving your consent, you can fully or partially withdraw it, asking for it as described in paragraph 17. 

  1. Do you share personal information with third parties for commercial purpose?

By giving your consent, we will communicate your personal data (i) to companies belonging to the same corporate group (ii) and to third parties operating in the betting market. They can contact you for marketing purposes via e-mail with information regarding promotions on goods and/or services, special offers, customers satisfaction surveys and market research materials. 

Your consent is free and voluntary. You can deny it and mantain a full use of our Site and/or App features. You can withdraw your consent at any time, by asking for it as described inb paragraph 17. 

You will have the choice to opt in or opt out of receiving such communications. You will also be given the opportunity to contact third parties and indicate them thaat you no longer wish to receive direct marketing material, as described in their Privacy Policies.

  1. Do you share personal information with third parties for other business operations?

We may communicate your personal data to third parties at the request of a judicial authority. We may also disclose your personal data to lawyers and law firms to fulfil our legal interest to enforce or defend legal claims.

  1. Who becomes aware of my personal data?

We may also avail of the following categories of individuals/entities which may, in the course of their work, become aware of your personal details: approved entities such as IT service and analytics service suppliers (which provide us information and reports about users behaviour on our Site and/or App); management systems providers, external consultants, advertising and marketing companies which work for us. 

  1. How do you disclose my personal data?

By deciding to comments and share contents on our Site and/or App, they shall be accessible to all registered and unregistered visitors. If the contents that you share contains personal data, they will be disclosed. Contents and comments on PUNTERZ website and/or PUNTERZApp always refers to your nickname.

  1. Is the provision of personal data optional and voluntary?

The provision of your personal data through contact forms on our Site and/or App is always optional. However in case of refusal to process your personal data, we could not be able to reply or provide our assistance. 

The provision of your personal data during subscription to our Site and/or App is optional but necessary to use all features reserved to registered users. 

Further optional personal data which you can insert into the dedicated personal area on our Site and/or App are not required. This information is necessary if you give us the consent to process your data for for the purpose of customer profiling, in order to grant you the most suitable promotional communications to your personality. By deciding not to insert all the optional personal data into the dedicated personal area on our Site and/or App, you will have no prejudiccial consequences; However, our promotional communication may be less interesting for you.

  1. Can I sign into Site and/or App with my Social network credentials?

Yes, you can do it using Facebook or other social network credentials available on Site and/or App according to the features provided by Social Network owners. By registering with social network credentials, we will obtain some personal data about you, which are described in details by social network procedures. For further information, please consult the Privacy Policy of social networks that you have decided to use. 

  1. Do you set Cookies or similar tracking tools on Site or App?

Yes, we use cookies on our Site and App. Please read our Cookie Policy for further details. 

  1. What do you use my personal data for and how long do you store them?

You data will be processed by automated and non-automated means, with logic strictly related to the purposes and in any event to ensure the security and confidentiality of data. 

Your navigation data will be stored for a maximum retention period of seven days, unless they are necessary for administrative or judicial authorities in case of hypotetical computer crimes and damages to our Site and/or App. 

By asking us for specific information about our services via e-mail or by means of the contact forms available on our Site and/or App, your personal data will be stored for a maximum retention period of 60 days from the day when we would have provided you what you have asked for, unless they are necessary for administrative or judicial authorities in case of hypotetical computer crimes and damages to our Site and/or App. 

 We will store your personal data provided during registration procedure to our Site and/or App until your account will be disabled and your personal information will be immediately deleted.

We will store data on purchases and sales on our Site and/or App for 10 years, by complying the requirements of applicable tax legislation.

By giving your consent to process your personal data for marketing purposes, they will be processed until you withdraw your consent for all or part of the contract method. Your contact details will be stored to pursue other purposes which they are processed for.

The optional personal data that you have insert on our Site and/or App will be stored and processed only with your free and voluntary consent for purposes of customer profiling until you decide to delete them or to disable your personal account on our Site and/or App.

  1. Do you transfer my personal data outside the European Economic Area?

Some of our service providers are based in countries outside the European Economic Area (“EEA”) or for times to times they can ask other suppliers outside the European Economic Area to be responsible for your personal data. This third Countries do not provide adequate protection like Regulation and, a Commission's decision on adequacy pursuant does not exist for third Countries. In order to protect your personal data, our providers as well as we have adopted particular cautions required by Regulation and we transfer your personal data outside EEA, facendo affidamento sulle garanzie adeguate previste dal Regolamento.

  1. What are my rights?

We will guarantee the following rights according to artt. from 15 to 22 of Regulation: you have the right to access, rectify, port and delete your data according to art. 15-18 of Regulation.

You have also the right to object to our processing of your data. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal. 

Yoy can may lodge a complaint with the European Data Protection Supervisor (www.garanteprivacy.it) or with the supervisory authority in the Member State within which you are located and/or operate. We wish you to inform that companies have joint a proprietorship of a Community processing of data.

You can ask for information about the contents of this regulation.

  1. Do the Regulation give me the right to object the processing of personal data? 

Yes, you have the right to object the processing of your personal data on grounds relating to your particular situation at any time under art. 6, paragraph 1, letter e) (the performance of a public interest task or the legitimate interests pursued by the controller) o f) (the legitimate interests) of Regulation, including customer profiling activities on the basis of these provisions.

Additionally, you have the right to withdraw the consent to process personal data for marketing purposes at any time, including customer profiling activities if they are connected to direct marketing.

  1. How can I contact you to exercise my rights?

Requests for the exercise of your rights shall be submitted via e-mail to info@punterz.bet. PUNTERZ will receive and manage your requests and your mail address can be used to obtain further information in the subject of Privacy and Protection of Personal Data.

  1. How can I consult the updated version of your Privacy Policy?

This Privacy Policy may be subject to change following regulatory changes and technological innovations. The current Privacy Policy is to be considered in line with Regulation modifications. We invite you to check it constantly for updates. We will send you a new version of our Privacy Policy via e-mail or during log-in on our Site and/or App when we will change it.

COOKIE POLICY 

Nextwin S.r.l. ("We" or the "Company") takes your privacy and the protection of your personal data very seriously. 

We would like to inform you that we use cookies on this website (the "Site") and on PUNTERZ APP (the ”App”).

This Cookie Policy provides you with all information needed to understand what are cookies, how we use them on our Site and/or App and what are your rights. This Cookie Policy is provided under art. 122 Legislative Decree n. 196/2003 (Data protection Law) and under art. 14 UE 2016/679 ("Regulation") to understand how and why we process your personal data and what we can do by means of cookie technologies placed on our Site and/or App. 

We provide this Cookie Policy in addition to the Privacy Policy of our Site and/or App, which we invite to read. 

  1. What are cookies?

A cookie is a small piece of data that is stored on your device to help websites and mobile apps collect certain basic information on its users.

The cookies we use on our Site and/or App generally fall into one of the following categories:

  1. a) referring to its user:

(i) Internal cookie or first-party cookies: are saved directly by PUNTERZ;

(ii) third-party cookies: are saved by third companies, which are our partners;

  1. b) referring to time they remain active:

(i) session cookies: they are deleted from your computer or device when you close your web-browser;

(ii) persistent cookies: they will remain stored on your computer or device until deleted or until they reach their expiry date.

  1. c) referring to their purpose:

Cookies are used for pusuing different purposes. We use them, for example, to remember your preferences, helping you to customise your experience on our site with special promotions, to remember you when you return to our site and to direct you to the homepage and protect your data.

Each cookie falls within one of these following categories according to its function on our Site and/or App:

  • Technical cookies
  • Analytics cookies
  1. What are the technical cookies and how do they work?

Technical cookies are used for the sole purpose of providing our service by means of our Site and/or App.

These can be divided into:

browsing cookies: which guarantee normal navigation and use of the Site and/or App (making it possible for example, to make purchases or be authenticated in order to access reserved areas). They usually are session cookies which are delete automatically when you close your web-browser.

Funtional cookies: which allow you to navigate in relation to a series of select criteria (for example, the language or the country where you come from) in order to improve the service provided by the Site and/or the App. They are persistent cookies that will remain stored on your computer or device until deleted or until they reach their expiry date.

We do not use technical cookies for different purposes and they are installed directly by us.

Your consent for the installation of these cookies is not required, as provided by the privacy regulations in force. We offer you the choice of refusing technical cookie installation by following the procedure described in paragraph 5.

N.B.: Please note that, by refusing the instalation of technical cookies, deleting them from your computer, some functions can fully or partially compromised.

  1. What are Analytics cookies and how do they work?

We use Analytics cookies on our Site and/or App to collect aggregate and non-aggregate statistical information about the number of users who visit our Site and/or App as well as how they use them.

We do not install directly Analytics cookies on our Site and/or App. Third parties are the sole data controllers. 

You can withdraw your consent to analytics cookies at any time, as provided by the privacy regulations in force.

When you visit our website for the first time, a banner informs you of (i) the use of third-parties cookies and provides a direct link to this information page. By closing the banner, scolling home page or clicking on any element in home page outside banner area, you allow the use of cookies. By giving your consent to install analytics cookies, we will track your consent with a technical cookie and we shall also avoid to display the banner every time you browse our Site and/or App.

By blocking this technical cookie on your browser as described in paragraph 5, let. (A), your consent will be denied and a banner on cookies will appear to your next visit on our Site and/or App. 

You can block the installation of analytics cookies at any time, provided that safety is not compromised thereby. 

List of Cookies used on the Website and/or App with a link to each developer page to be informed on how to manage analytics cookies (opt-out):

Denominazione Cookie Tipologia di cookie Link all'informativa / Istruzioni sull'opt-out

Google Analytics - analytics cookie - permanent cookie https://policies.google.com/privacy

Facebook

Analytics - analytics cookie 

- permanent cookie https://analytics.facebook.com

  1. How do you change cookie preferences or block cookies?

There are different ways to change, disable and block cookies:

(A) Using browser settings:

Different browsers make different controls available to you. Generally, your browser will offer you the choice to accept, refuse or delete cookies at all times, or those from providers that website owners use i.e. third party cookies, or those from specific websites. Each browser’s website should contain instructions on how you can do this:


You can manage, disable and delete all types of cookies (technical, analytics and profiling ones) by changing your browser settings.

N.B.: If you block cookies on our website, you may be unable to access certain areas of our website and certain functions and pages will not work in the usual way. We also remind you that refusing cookies is likely to modify the terms of your access to our Site as well as its use (viewing our videos, saving identifying information, receiving personalized recommendations, etc.).

(B) By following third-parties procedures 

Please the privacy policy of third parties which install analytics cookies (paragraph 3) or profiling cookies (paragraph 4) to disable third-parties cookies and to know all the tools you can use to manage, disable and delete cookies or deny your consent to their use.  

By disabling third-parties cookies, you agree to oppose (i) the use of cookies not only on Site but also on (ii) all websites which these cookies are installed on. All functions on Site and/or App will not be compromised.

By disabling third-parties cookies, a banner will be displayed in home page; By closing the banner, scrolling home page or clicking on any element in home page outside it, you will receive third-parties cookie input anymore.

(C) By visiting web site www.youronlinechoices.eu/it/

Your Online Choice is a website managed by the European Interactive Digital Advertising Alliance (EDAA), non profit association, whose Italian version you can find at www.youronlinechoices.eu/it/, providing information on behavioral advertising based on profiling cookies (http://www.youronlinechoices.com/it/a-proposito) which allows internet users to easly opt out from the set-up of the main profiling cookies set-up by advertising operators which are used on websites (http://www.youronlinechoices.com/it/le-tue-scelte). Before choosing this tool, we advise you to read carefully the general service terms and conditions, the FAQ (http://www.youronlinechoices.com/it/faqs ) and the user’s guide (http://www.youronlinechoices.com/it/help ).

N.B.: Use Your Online Choices consciously. Notwithstanding the fact that Your Online Choices gathers the most important actors within the advertising field that use cookies, some of the third parties that set up the cookies through the Website may not have joined Your Online Choices. Therefore, the use of Your Online Choices does not guarantee that You will receive third party’s cookies while browsing on the Website. Please remember that by removing all cookies on your browser, also technical cookies released by Your Online Choices to store your choices, may be removed, thus enabling again third parties cookies.

  1. Further information

Nextwin S.r.l. acts as data controller processing data it has collected by means of internal cookies (first-party cookies).

We will process data collected by means of first and third-party technical cookies to fulfil our legal interest per perseguire il nostro legittimo interesse to ensure the security of website. We do not store data transmitted by third-party analytics cookies, we only use them to collect statistical data about the use of our site and/or App by our users. 

First and third-party personal data will be processed by automated systems for the time that is strictly necessary to attain the purposes which they have been collected for. 

Therefore, our employees and collaborators will never access the content of your personal data obtained through cookies. Some of our employees and collaborates, who we have appointed as persons in charge of the processing, may perform maintenance operations on the IT systems that host your data, without ever being able to access their actual content. Personal data may be stored on servers managed by third parties (e.g. supplier of IT services), which act as external data processors appointed in writing by the Company. 

Please note that, in compliance with the conditions and guarantees provided by the law, your data could be transferred to countries outside the European Economic Area, which may not provide a level of protection of privacy comparable to that guaranteed by the Italian and European privacy laws. Your personal date will not be communicated to third-party data controllers nor disseminated.

  1. What are my rights?

Please read the Privacy Policy on our site to know what rights you can exercise and when you are entitled to use them.

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