FOOTBALL FAN PRIVACY POLICY

This Privacy Policy describes the policies and procedures of Football Fan Limited (“we”, “our” or “us”) on the collection, use and disclosure of your information in connection with your use of the Football Fan application (the “App”) and any associated services, features, content or applications we offer through the App (collectively, the “Services”). We receive information about you from various sources, including without limitation: (i) if you register for the App and the Services, through your user account on the Services (your “Account”); and (ii) your use of the Services generally. When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy.

What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personally identifiable information (“Personal Information”) gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Information that our business partners share with us or that we share with our business partners. We do not sell or trade to outside parties your Personally Information.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications (e.g. iTunes, YouTube, Google Play, Twitter, Facebook, Instagram, etc.) (each a “Third Party Service”) that you elect to access through the Service or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third-Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third-Party Services. We encourage you to carefully review the privacy policies of any Third-Party Services you access.

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.

What Information Do We Collect?

The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Information. We collect the following types of information from our users.

Account Information:

If you create an account on the Services (“Account”), you may be required to provide information that could be Personal Information, such as your name, phone number and/or email address. You acknowledge that this information may be personal to you, and by creating an Account and providing Personal Information to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you information about our Services. You may unsubscribe from some of these messages by emailing us at support@footballfanapp.com. However, we reserve the right to contact you when we believe it is necessary, such as for account recovery purposes.

User Content:

Some features of the Services allow you to provide content to the Services, such as photos, video clips, comments, etc. All content submitted by you to the Services may be retained by us indefinitely, even after you terminate your Account. We may continue to disclose such content to third parties in a manner that does not reveal Personal Information, as described in this Privacy Policy.

Location Information:

Some of our Services may include features based on users’ approximate locations (“Location-Based Services”). To the extent you voluntarily opt to use any Location-Based Services, we may collect and store information about your approximate location at the time you use those Location-Based Services.

IP Address Information and Other Information Collected Automatically:

• Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the App and users of the Services. We may use this data in aggregate form, that is, as a statistical measure, or in other anonymous forms, but not in a manner that would identify you personally. This type of data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.
• We automatically receive and record information from your web browser and device when you interact with the Services, including your IP address and cookie information and other mobile identifiers. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g., what links you have clicked on).
• We may collect some device-specific information if you access the Services using a mobile device. Device information may include but is not limited to unique device identifiers, network information, and hardware model, as well as information about how the device interacts with our Services.

Email, Text, and Push Notification Communications:

We may communicate with you via push notifications, email, or other text message (“Message”) (to the extent you permit us to do so), and we may collect information regarding such communications, such as confirmation when you open an email, read a Message or receive a push notification. We use this information to improve our Services, including without limitation our customer service.

Aggregate Information:

We collect statistical information about how both unregistered and registered users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. This statistical information is not Personal Information and cannot be tied back to you, your Account or your web browser or applications.

How, and With Whom, Is My Information Shared?

Public Information About Your Activity on the Services:

Some of your activity on and through the Services is public. This may include, but is not limited to, content you have posted publicly on, through or in connection with the Services, including without limitation on public portions of Third-Party Services, such as your social media accounts.

Registered users may have some of this information associated with their Accounts. Unregistered users will not have this association, but information concerning their use of the Services (such as what App features they have accessed) may be tracked anonymously and stored by us.

Please remember that if you choose to provide Personal Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

IP Address and Device Information:

While we collect and store IP address and device information, that information is not made public. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

Information You Elect to Share:

You may access other Third-Party Services through the Services, for example by clicking on links to those Third-Party Services from within our Services. We are not responsible for the privacy policies and/or practices of these Third-Party Services, and you are responsible for reading and understanding those Third-Party Services’ privacy policies. This Privacy Policy only governs information collected on the Services.

Aggregate and Non-Personally Identifiable Information:

We share Aggregate Information with our partners, service providers and other persons with whom we conduct business (“Business Partners”). We may also share information with our Business Partners that is (i) not Personal Information or (ii) derived from Personal Information but has been anonymized so that it is no longer personally identifiable (collectively with Aggregate Information, “Non-Personal Information”). We use and share this type of data so that we and our Business Partners can understand how and how often people use our and their services or websites, which facilitates improving our Services, their services and how our Services interface with their services. In addition, these Business Partners may share with us non-private, aggregated or otherwise non-Personal Information about you that they have independently developed or acquired.

Push Notifications and Email from Us:

As part of the Services, you may occasionally receive push notifications, email or other communications from us, such as communications relating to your Account.

User Profile Information:

User profile information including your username and other information you enter may be displayed to other users to facilitate user interaction within the Services. We will not directly reveal user email addresses to other users. We may share your User Content (as defined in the Terms of Use), or some derivative thereof, on our company-branded social media channels, and we may tag you in such post using your name, social media name, handle or other identifier.

Information Shared with Our Agents:

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Information with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents.

Information Disclosed Pursuant to Business Transfers:

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

Information Disclosed for Our Protection and the Protection of Others:

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request; (ii) enforce this Privacy Policy and our Terms of Use, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security or technical issues; (iv) respond to user support requests or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Is Information About Me Secure?

We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. We store all of our information, including your IP address and device information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. Additionally, you are responsible for preventing unauthorized access to your Account and Personal Information by protecting your Account credentials and limiting access to Service Device (as defined in the Terms of Use).

What Information of Mine Can I Access?

If you are a registered user, you can access information associated with your Account by emailing us at support@footballfanapp.com.

How Can I Delete My Account?

Should you ever decide to delete your Account, you may do so by deleting the App and by emailing us at support@footballfanapp.com. If you terminate your Account, any association between your Account and the information we store about you will no longer be accessible through your Account. However, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

What Choices Do I Have Regarding My Information?

• You can use some of the features of the Services without registering, thereby limiting the type of information that we collect.
• You can always opt not to disclose certain information to us, but please note that certain information may be needed to take advantage of some of our features.
• You can delete your Account. Please note that we will need to verify that you have the authority to delete the Account, and activity generated prior to deletion will remain stored by us and may be publicly accessible.
• You can choose to opt out of certain communications or communication methods; however, if you do so, you may not be able to take advantage of some of our Services’ best features.

What Happens When There Are Changes to this Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email. A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.

What If I Have Questions or Concerns?

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to support@footballfanapp.com. We will make every effort to resolve your concerns.

ADDITIONAL INFORMATION AS PER THE REQUIREMENT OF THE EUROPEAN LAWS (GDPR) TO BE READ IN CONJUNCTION WITH THE AFOREMENTIONED PRIVACY POLICY CLAUSES:

OUR APPROACH TO PRIVACY

• Football Fan Limited ("we", "our", or "us") is committed to protecting and respecting your privacy. This privacy policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") and information regarding our use of cookies and similar technologies.
• Football Fan Limited operates a fan engagement platform for football called as Football Fan App (the "Service").
• This privacy policy applies to our Service. Before accessing or using our Service, please ensure that you have read and understood how we collect, store, use and disclose your personal information as described in this privacy policy.
• Football Fan Limited is the data controller of the personal information we hold about you.

PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

• We collect personal information that you voluntarily submit directly to us when you use our Service. This may include information you provide to us when you register for an account, create or edit your user profile on the Service, correspond with us by phone, e-mail or otherwise, respond to trivia questions, post comments using the banter room function on our Service, or use some other feature of our Service.
• We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the Service. If you choose not to provide such personal information, we may not be able to provide the Service to you or respond to your other requests.
• The table atAnnex 1sets out the categories of personal information we collect about you and how we use that information, as well as the legal basis which we rely on to process the personal information.
• We also automatically collect personal information indirectly about how you access and use the Service and information about the device you use to access the Service.
• The table atAnnex 2sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information.
• We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us.
• We may anonymize and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving our Service and developing new products and features. We may also share such anonymized information with others.
• We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 and Annex 2 and in accordance with our legal obligations and legitimate business interests.

RECIPIENTS OF PERSONAL INFORMATION

We may share your personal information with the following (as required in accordance with the uses set out in Annexes 1 and 2):

• Service providers and advisors:we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing payment, email or chat services, fraud prevention, web hosting, or providing analytical services.
• Social media:where you have connected a social media account with our Service, we may post your comments and opinions to our social media pages and tag you in those posts.
• Purchasers and third parties in connection with a business transaction:your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business.
• Law enforcement, regulators and other parties for legal reasons:we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Use; and/or (iii) exercise or protect the rights, property, or personal safety of Football Fan Limited, its users or others.

STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

• Security. We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers. All electronic transactions entered into our App will be protected by TLS encryption technology in transit. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
• International Transfers of your Personal Information. Any information we collect from you will initially be collected and stored within the EU or EEA, this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will take reasonable steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy policy.

YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

1. Right of access. You have the right to obtain:

1. Confirmation of whether, and where, we are processing your personal information;
2. Information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
3. Information about the categories of recipients with whom we may share your personal information; and
4. A copy of the personal information we hold about you.

2. Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.
3. Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
4. Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
5. Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
6. Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

If you wish to exercise any of these rights, please contact us using the contact details at the end of this privacy policy. You may also review and edit the personal information you have submitted to us by logging into your account on the App.

You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

LINKS TO THIRD PARTY SITES

Our Service may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites. Our Privacy Policy does not apply to such websites or services and we're not responsible for the content, privacy or security practices and policies of those websites or services. To protect your information, we recommend that you carefully review the privacy policies of other websites and services that you access.

OUR POLICY TOWARDS CHILDREN

Our Service is not directed at persons under 12 years of age and we do not knowingly collect personal information from children under 12. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

CHANGES TO THIS POLICY

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

NOTICE TO YOU

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Service. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

CONTACTING US

Please contact support@footballfanapp.com if you have any questions, comments and requests regarding this Privacy Policy.

ANNEX 1 – PERSONAL INFORMATION WE COLLECT

ANNEX 2 – PERSONAL INFORMATION COLLECTED AUTOMATICALLY

This privacy policy was last modified on Feb 3^rd, 2021.