II. Responsible body
The service provider responsible for the collection, processing and usage of your personal data within data protection laws is Bepro Company Co., Ltd. (hereinafter “Bepro” or ”We”). You can reach us as follows: Bepro Company Co., Ltd.
3/119, 50, Jong-ro 1-gil, Jongno-gu, Seoul, Republic of Korea (03142)
You can contact our external Data Protection Officer at email@example.com.
III. Collection, processing and use of personal data on our website and via Cookies
Personal data is individual information about personal or factual circumstances of a specific or identifiable individual. These are for example your name and your e-mail address. Within the framework of our internet presence and our services, personal data is only collected, processed and used within the legally permitted extent. This also applies to the transfer of personal data.
We use session cookies to make our website more user-friendly. Some elements of our website require for the visiting browser to also be identifiable after changing pages (e.g. for saving a user’s language settings).
We also use services and consequently cookies of third parties to further improve and analyse your interactions with our website. Legal basis for the usage of non-necessary cookies is your consent according to Art. 6 paragraph 1 (a) GDPR, which we collect via our cookie banner.
1. Our App: bepro11
Bepro is the responsible provider and operator of the software application "bepro11", which is available as software installed on mobile device or browser based through Bepro’s website (hereinafter "bepro11" or "App"). The App is designed as "Software as a Service". It is a tool offering video-based analysis and evaluations of football matches, which can be used by cooperating football clubs and teams, (hereinafter "Teams") and stored in a centralised digital location (hereinafter "Cloud"). To provide the Cloud services required to use the App, We use external service providers to process your data.
1.1. Downloading the App
You can either use our App through an internet browser or easily download it to your devices (e.g. your smartphones, tablets). When downloading from our website, data will be transmitted from your browser to enable the download and the collecting of those data. Information required when downloading is transferred to the respective App Store. In particular but depending on the specific App Store, will be transferred and collected the username, e-mail address, customer number of your account, the time of download, payment information and the individual device identification number. However, we have no influence on this data collection. We only process this data to the extent necessary for downloading the App. This is valid according to Art. 6 paragraph 1 (b) GDPR. Furthermore, the data will not be stored.
1.2. Registration in the App
a) Setting up the user account
For the initial log-in through the App users have to click the "register" button. You have to provide the following information, which is necessary for the registration and the creation of a user account: name, password, e-mail address or mobile phone number, nationality.
b) IP address and date of registration
In addition, the date of registration is stored to prevent abuse of the registration function. Processing of such data as a pre-contractual measure is in accordance with Art. 6 paragraph 1 (b) GDPR as well as considerations of our interests according to Art. 6 paragraph 1 (f) GDPR in order to ensure protection against e.g. cyberattacks.
1.3. Usage of the App
When using bepro11 on a mobile device, We collect the following additional personal data to enable the functions of the App: device identification or name of your mobile device, manufacturer, platform, country code (e.g. DE), iOS / Android Version, screen width and height, time zone, time stamp, system standard (local), User agent, MAC address for wi-fi.
You can upload your football games on our website or platform in order to be analysed if you have the permission to do so. Those videos cannot be accessed by other users. In some cases, depending on the agreement between the Clubs and/or the league and Bepro, the analysed video will be shared between the Clubs within the same league. In such case all users of the same league would be able to see those videos. Bepro processes and stores this data in the Cloud in accordance with the consent of the user within the scope and functions of the App.
Processing and storage of your data is necessary to fulfill our contractual agreement. This is therefore in accordance with Art. 6 paragraph 1 (b) GDPR.
2. Contacting us
Our service also allows you to contact us. This can be done, for example, by e-mailing us or using the chat function on our website. The information you provide when contacting us will be stored in order to process your request and any subsequent correspondence. Legal basis is either the performing of a contract obligation or our legitimate interest in providing a contact service (Art. 6(1)(b) GDPR or Art. 6(1)(f) GDPR).
3. Informational use
4. Creation of a user profile
We attempt to identify user preferences by analysing usage data, diagnose technical problems and analysing developments to improve the experience on our website or App for our visitors and, developing and providing tailored services to our users. In order to evaluate the web or App users, for market research and for demand-oriented design of the App, We use technologies to evaluate information about the type and scope of the App usage and to create pseudonymous user profiles (so-called tracking tools), unless you object to this. Processing and storing of your data are carried out to ensure the aforementioned, valid interests of Bepro and is therefore in accordance with Art. 6 paragraph 1 (f) GDPR.
5. Integration of third-party services and content
To expand our services, it is senseful to include third-party content in our service. Maps from Google Maps, for example, could be used in this respect. In order to download this content from the servers of the third-party provider, it is necessary to transmit your IP address to them.
We are using third-party services to improve the user experience and provide interesting content on our website, which is our legitimate interest according to Art. 6 paragraph 1 (f) GDPR.
6. Newsletter (Mailchimp)
You may register for our e-mail newsletter to receive current information about our products, events or competitions.
When you register for the newsletter, you will receive a one-time confirmation e-mail in which you must confirm with a click that you wish to receive further e-mails. This confirmation mail is used to verify that the owner of the e-mail address has authorized the receipt of the newsletter.
The personal data collected during registration for the newsletter is used exclusively for sending our product information. Consent to the storage of personal data, which the person concerned has given us for the purpose of sending the product information, can be revoked at any time. For the purpose of revoking this consent, there is a corresponding link in every newsletter.
The newsletters are tracked anonymously to evaluate if and when a newsletter was opened and which links in the newsletter were clicked. This enables us to create aggregated statistics, e.g. about the total number of open newsletters of all subscribers. In this context, technical information such as information about your browser and your system, but no personal data and also not your IP address are stored or processed. In particular, it is not possible for us to trace whether you have personally opened the newsletter or clicked on a link. We use the statistical evaluations to continuously optimise our newsletter. This analysis is done on our behalf by our service provider MailChimp. Legal basis for the analysis of the newsletter use is art. 6 para. 1 p. 1 lit. f) GDPR. Our legitimate interest is to provide you with a better newsletter and to improve it continuously. If you do not wish to receive an analysis of the newsletter use, we recommend that you unsubscribe from the newsletter by clicking on the unsubscribe link included in every newsletter.
7. Social Media presences
We maintain online presences within various social networks and platforms in order to be able to communicate with our customers, interested parties and users active there and to inform them about our services.
We point out that you use these pages and their functions on your own responsibility. This applies in particular to the use of the interactive functions (e.g. commenting, sharing, rating). Alternatively, you can also call up the information we offer on our website https://www.bepro11.com/.
When you visit our various online presences, the respective website provider records your IP address and other information that is available on your device in the form of cookies. The data collected about you in this context is processed by the respective provider and may be transferred to countries outside the European Union. Which information the service providers receive and how this information is used is described in general terms in their respective data use guidelines. There you will also find information on how to contact us and how to place advertisements.
We, as the provider of the information service, also collect and process data from your use of our service for the purposes of advertising and communication, to answer your questions and advertise various products, services and events, as well as for applicant management purposes. The legal basis is Art. 6 paragraph. 1 sentence 1 (f) and (b) DSGVO. Our legitimate interest is to provide you with a better user experience, products and a simple form of communication.
Also in the case of requests for information and the assertion of user rights, we point out that these can be asserted most effectively with the providers. Only the providers have access to the data of the users and can directly take appropriate measures and provide information. Should you nevertheless require assistance, you can of course contact us.
You can also find us at:
- https://de-de.facebook.com/bepro11/?ref=page_internal on Facebook.com. We use the technical platform and services of Facebook Ireland Ltd, 4 Grand Canal Square Grand Canal Harbour, Dublin 2, Ireland for the information service offered there. The complete data guidelines of Facebook can be found here: https://de-de.facebook.com/full_data_use_policy
- https://twitter.com/bepro11?lang=de on Twitter.com. We use the technical platform and services of Twitter International Company, One Cumberland Place, Fenian Street, Dublin 2, D02 AX07, Ireland for the information service offered there. The latest Twitter privacy information and supplementary information can be found on this website: https://twitter.com/de/privacy
- @bepro_eleven on Instagram.com. The Instagram Service is one of the Facebook products provided by Facebook Ireland Limited. We use the technical platform and services of Facebook Ireland Ltd, 4 Grand Canal Square Grand Canal Harbour, Dublin 2, Ireland for the information service offered there. Instagram's complete data policy can be found here: https://help.instagram.com/519522125107875?helpref=page_content
- https://www.youtube.com/channel/UCUKv438My58DvjhzRqNuCfw on youtube.com. We use the technical platform and services of Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland for the video service offered there. The complete data guidelines of Youtube can be found here: https://www.google.de/intl/de/policies/privacy
We are jointly responsible with Facebook Ireland Ltd. for collecting (but not further processing) data from visitors to our Facebook page (known as a "Fan Page") and on our Instagram page. This data includes information about the types of content users view or interact with, or the actions they take, as well as information about the devices users use. We have entered into a specific agreement with Facebook ("Page Insights Information", https://www.facebook.com/legal/terms/page_controller_addendum), which specifically sets out the security measures that Facebook must observe and in which Facebook has agreed to fulfil data subjects' rights (i.e. users can, for example, submit information or deletion requests directly to Facebook). Your rights are not restricted by the agreements with Facebook. You can assert your rights (information, correction, deletion, restriction of processing, data portability, objection and complaint) both against us and against Facebook.
8. Our Blog
We offer a blog on our website. On this blog, We publish posts on various subjects. You can leave comments on these posts. If you leave a comment, this will be published attached to the respective post under your stated username. We suggest you select a pseudonym instead of your real name when choosing a username. In order to use the comment function, stating your chosen username and your email address is mandatory. All other information you enter is optional. If you leave a comment, We will still store your IP address along with the data described above.
Your e-mail address is stored for the purpose of contacting you if a third-party flags your comment as unlawful or if We need to defend ourselves against claims of third-parties in the case of the publication of unlawful contents by you. This also includes our legitimate interest. If you have given us your consent, Art. 6 (1) S.1 lit. (a) GDPR serves as legal basis for the processing. Insofar as the processing is otherwise based on our legitimate interests, Article 6 (1) S.1 lit. (f) GDPR serves as legal basis. We reserve the right to delete comments if they are flagged as unlawful by third-parties. We will store your e-mail address as long as your comment is visible publicly.
If you have given us your consent for storing your data, you can withdraw this consent at any time. You can object to the storage of the data described above at any time (via e-mail to the e-mail address stated in our legal notice).
9. Job applications
On our website and third party websites, such as LinkedIn, we publish current job postings. The collection and processing of your personal application data exclusively occurs for the purpose of filling vacancies within our business. Your data will be forwarded strictly to internal positions and departments within our group of businesses responsible for the specific application process. Your application data will not be used further, nor disclosed to third parties. Your personal application data is always deleted 3 months after the application process is concluded. This does not apply if legal regulations oppose deletion, if further storage is necessary to serve as evidence, or if you have given express consent to a longer storage. The legal basis for processing your personal Data are Sec. 26(1),(8)(2) German Federal Data Protection Act (“BDSG”) or Sec. 26(2),(8)(2) BDSG. We process your personal data for the purpose of contacting you and assessing whether or not you are the right candidate for the position.
10. Duration of data storage
If necessary, We process and store your personal data for the duration of your App usage. Your personal data will be deleted immediately if they are no longer necessary for the purposes (see Art. 17 GDPR), for which they were processed by us. Longer storage of data will only take place if the processing is necessary for the fulfilment of certain legal obligations or for certain tasks in public interest.
11. Data security
We maintain current technical measures to guarantee data security, in particular to protect your personal data from dangers during data transmission as well as attainment from third-party. These measures are adapted to the current appropriate state of the art on a regular basis.
12. Data Transfer
We only transfer personal data to third parties where necessary for the provision of our service or otherwise allowed by the law. Within the scope of the purposes stated here, personal data are transferred to service providers involved in the provision of our services. In addition to their legal obligation to comply with all data protection regulations, these service providers are bound to additional contractual data protection requirements. This includes in particular contractual obligations as a processor in accordance with Art. 28(3) GDPR.
Apart from that, we only transfer personal data to third parties if this is permitted by law or if you have given your prior consent. You can revoke any consent you may have given at any time with effect for the future.
If necessary, for our purposes, we may also transfer your data to recipients outside the EEA. We only do this within the framework of the data protection requirements for transfers to third countries if it is ensured that the recipient of the data guarantees an adequate level of data protection within the meaning of Chapter V of the GDPR and no other interests worthy of protection speak against the transfer of data. To ensure an adequate level of protection for the recipient of the data, we in particular use the standard contractual clauses of the EU Commission on the transfer of personal data to third countries, unless an adequacy decision within the meaning of Art. 45(1) GDPR has been taken by the EU Commission.
IV. Your rights
1. Revocation of given consent
At any time, you can revoke explicit or implied consent given to us which will be in effect thereafter.
You can request information regarding your stored personal data. Furthermore, you are entitled to the disclosure of information mentioned in Art. 15 GDPR.
3. Correction and deletion
You have the right to have inaccurate personal data corrected in accordance with Art. 16 GDPR. You also have the right to have your personal data deleted in accordance with Art. 17 GDPR.
4. Restriction of processing
You can restrict the processing of your personal data under the conditions of Art. 18 GDPR.
In accordance with Art. 21 GDPR you have the right to object to the processing of your personal data at any time, due to reasons based on your particular situation, as long as these are on the grounds of Art. 6 paragraph 1 (e) or (f) GDPR. In case of such an objection We will no longer process such data, unless We can prove that there are compelling compulsory reasons that outweigh your interests, rights and freedom or in case the processing serves to assert, exercise or defend legal claims.
6. Publication of data and data transmission
You have the right to receive the personal data that you had provided us in a structured, common, machine-readable format. You also have the right, as long as it is technically feasible, to ask us to transmit this data to a third-party.
7. Right to lodge a complaint
In connection with the processing of your personal data you have the right to lodge a complaint at the respective supervisory body, that is in charge of the protection of personal data. (e.g. Der Hamburgische Beauftragte für Datenschutz und Informationsfreiheit (HmbBfDI) Kurt-Schumacher-Allee 4, 20097 Hamburg, Germany firstname.lastname@example.org or the respective supervisory authority in your country of residency).
8. No automated individual Decision-Making
We do not use your personal data for automated individual decisions in the meaning of Art. 22(1) GDPR.
We reserve the right to occasionally adapt the data protection declaration to current legal requirements and changes to our services. For your visit and/or your use the current data protection declaration applies.
If you no longer consent with the storage of your personal data or if you wish to exercise your rights as a data subject, We will comply with your request within the scope of regulatory requirements. Please do not hesitate to contact email@example.com or the person listed in our legal notice with questions, requests and suggestions regarding the processing of your personal data and for information, correction, restriction or erasure of data, as well as objecting to a processing of your personal data.
Version: April 2021