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.
- WHO IS RESPONSIBLE FOR LOOKING AFTER YOUR PERSONAL DATA?
- WHAT PERSONAL DATA DO WE PROCESS?
- WHAT DO WE USE YOUR PERSONAL DATA FOR AND WHEN DO WE PROCESS YOUR PERSONAL DATA?
- WHO DO WE SHARE YOUR PERSONAL DATA WITH?
- INTERNATIONAL TRANSFERS
- DIRECT MARKETING
- HOW LONG DO WE KEEP YOUR PERSONAL DATA?
- WHAT ARE YOUR RIGHTS?
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:
- Email address
- Date of Registration
- IP address
- Content you submit, for example opinions, complaints, chats you submit when you contact us via our Support Centre
- Payment Gateway Customer Number
- Payment Gateway transaction charge number
- If made available, last 4 digits and expiration date of user's Credit Card.
We do not collect data such as your payment instrument number (for example your full credit card number) or security code associated with your payment instrument. All such payment data is securely passed, processed and stored by our 3 rd party payment gateway providers, Paypal and Stripe, and therefore your personal data is processed in accordance with their respective privacy policies, which we advise you to consult. See also Section 4 below for more info on third parties who have access to your personal data.
- Location data
- Website usage
- You may choose to provide other information directly to us or we might require other information from you. For example, we may collect other information when you decide to get in contact with us via our Support Centre or otherwise communicate with us.
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:
- create and manage your account and subscription with us
- provide, maintain, enhance and personalize the services you subscribed to
- send you service information about your account and subscriptions, for example we will send you information about or to make you aware of any changes to the services you subscribed
- communicate with you and respond to your inquiries, for example via our Support Centre
- if you gave your permission, send out promotional emails relating to products and services. You can opt-out at any time. See also Section 6 below on Direct marketing
- to improve our marketing communications, we use a similar technology to cookies to confirm whether you have opened a marketing email or clicked on a link in the email
- 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 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, for example when you have requested or consented to receive direct marketing from us, or
- it is necessary for the performance of a contract, for example to finalize and administer your subscription
- our use of your personal data is necessary to support 'legitimate interests' that we have as a business (for example, to receive communication from us, to improve our products or marketing communications, to carry out analytics across our datasets or to respond to your inquiries via out Support Centre), 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 payment gateway providers who process personal data on our behalf:
- PayPal (Europe) S.a.r.l. et Cie, S.C.A. and
- Stripe, Inc. based in the USA who is Privacy Shield certified as you may see here;
- Our subscription management platform Chargebee Inc. based in the USA who is Privacy Shield certified as you may see here and processes personal data on our behalf;
- Our mailing application provider GetResponse Sp. z o.o. based in Poland and processes personal data on our behalf;
- Our hosting provider Amazon Web Services, Inc. based in the USA who is Privacy Shield certified as you may see here and processes personal data on our behalf;
- 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.
The processing of your personal data for marketing purposes will be based on your permission. When permitted by law, it will be based on our legitimate interest (see Section 3 above). We will use a third-party to help us with processing of your personal data for marketing purposes (see Section 4 above).
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@example.com 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:
|Right||What this means|
You can ask us to:
You can ask us to rectify inaccurate personal data.
We may seek to verify the accuracy of the data before rectifying it.
You can ask us to erase your personal data, but only where:
We are not required to comply with your request to erase your personal data if the processing of your personal data is necessary:
There are certain other circumstances in which we are not required to comply with your erasure request, although these two are the most likely circumstances in which we would deny that request
You can ask us to restrict (i.e. keep but not use) your personal data, but only where:
We can continue to use your personal data following a request for restriction, where:
You can ask us to provide your personal data to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another Data Controller, but in each case only where:
You can object to any processing of your personal data which has our 'legitimate interests' as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.
We have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.
You can ask to obtain a copy of, or reference to, the safeguards under which your personal data is transferred outside of the European Economic Area.
We may redact data transfer agreements or related documents (i.e. obscure certain information contained within these documents) for reasons of commercial sensitivity.
You have a right to lodge a complaint with the responsible local supervisory authority about our processing of your personal data.
We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.