PRIVACY POLICY OF NBN23 S.L.U

BASIC INFORMATION

Data Controller
NBN23 SL
CIF: B40634206
Calle Juan de la Cierva y Codorniu, 27, Edificio Wellness 1, 3rd Floor – Postal Code 46980, Madrid, Spain
Email: DPO@nbn23.tech
Data Protection Officer: DPO@nbn23.tech

Purposes of Processing Personal Data

  • Managing user registration in NBN23’s different applications (Swish, FIP Stats, SwishVerse, DBB.Scores, Swiss Basketball, Basketball Challenges) based on the selected program, as well as periodic billing if applicable.
  • Providing commercial and advertising information based on user permissions.
  • Responding to information requests.
  • Sending commercial communications from NBN23 or third parties.
  • Offering personalized commercial communications and services through profiling and segmentation activities.
  • Managing user data when accessed through social media.

Data Retention Periods
Data will be retained as long as the commercial relationship is maintained or until the user requests its deletion. However, data will not be deleted if required for legal obligations or to establish, exercise, or defend legal claims.

Source of Data

  • Provided directly by the user when making inquiries, requesting information, or registering as a user (name, surname, email, phone, age, gender).
  • Obtained through user login via social media.
  • Inferred from the user’s activity in NBN23 applications (Device ID, Advertising ID, Mobile Advertising ID, advertiser identifier to track user activity across NBN23 and third-party apps, interactions with sent communications).

Legal Basis

  • Execution of the contract with the user.
  • NBN23’s legal obligations.
  • NBN23’s legitimate interest in fraud prevention and commercial communications related to its products and services.
  • User consent for commercial communications, data transfers to third parties, evaluation of user habits for personalized content, and NBN23 app promotions.

For iOS users, Apple will request permission for NBN23 to use the device’s advertising identifier for any required purposes.

Data Transfers
All transfers are necessary for the purposes mentioned above or to comply with legal obligations. Data may be shared with public administrations, service providers, collaborating companies, and entities.

User Rights
Users can exercise their rights by emailing DPO@nbn23.tech or visiting NBN23’s registered office at Calle Juan de la Cierva y Codorniu, 27, Edificio Wellness 1, 3rd Floor – Postal Code 46980, Madrid, Spain.

Users may exercise the right to:

  • Access, rectify, or delete their data.
  • Restrict processing.
  • Object to processing.
  • Data portability.
  • Not be subject to automated decision-making.
  • Withdraw consent.

Users may also file complaints with the Spanish Data Protection Agency (AEPD) at www.aepd.es.

For more details, please refer to the full Privacy Policy document.

1. Identification of the Data Controller and Scope of the Privacy Policy

NBN23 SL (hereinafter, “NBN23”) is responsible for processing your personal data to provide the services available in our applications: Swish, FIP Stats, SwishVerse, DBB.Scores, Swiss Basketball, and Basketball Challenges.

NBN23 is a company registered at Calle Juan de la Cierva y Codorniu, 27, Edificio Wellness 1, 3rd Floor – Postal Code 46980, Madrid, Spain, with Tax Identification Number B40634206.

NBN23 is committed to the fundamental right to personal data protection, and this privacy policy aims to inform you about your rights. This document explains how personal data is processed within our applications. If any specific processing rules apply to certain applications, we will highlight them accordingly.

We inform you that NBN23 has a Data Protection Officer (DPO) in accordance with the GDPR, available for any queries or concerns regarding data protection. You may contact the DPO at DPO@nbn23.tech.


What Information Will We Collect from You?

NBN23 collects personal data in different ways:

a. Data You Provide Directly

We collect information about you when you:

  • Register for an account.
  • Contact us through available channels (such as a contact form).
  • Provide any information voluntarily for participating in promotions, activating user profiles, or answering surveys.

All fields marked with an asterisk (*) in our forms are mandatory. Failure to complete them may prevent us from providing the requested services. You must provide accurate information, and impersonation of another person is strictly prohibited.

When entering information, you must not use offensive expressions, brand names, trademarks, names of public figures, or pseudonyms unless authorized to do so.

It is essential that you keep your login credentials, passwords, and access keys secure at all times. You are solely responsible for the use of your personal account. You must use it diligently, not share it with third parties, and inform us immediately in case of loss or theft.

To keep your information up to date and error-free, you should notify NBN23 as soon as possible of any changes to your personal data.

By clicking the “I Accept” (or equivalent) button in our forms, you confirm that the provided information is accurate and truthful.


b. Data Obtained Indirectly

When using our applications (Swish, FIP Stats, SwishVerse, DBB.Scores, Swiss Basketball, and Basketball Challenges), we process both data you provide directly and data inferred from your activity, including:

  • Email, name, surname, country, teams, and players.
  • Device ID, Advertising ID, Mobile Advertising ID (a unique identifier that allows tracking your activity across NBN23 and third-party applications).
  • Operating system and device model.
  • Interactions with push notifications and in-app communications.

Additionally, we may obtain personal data through social media logins when you choose this option to subscribe to our applications (name, surname, ID, and email address).


What Is the Source of Your Data?

We assume that all data processed by NBN23 has been provided freely by the user.

If you provide personal data belonging to a third party, you guarantee that you have informed them of this Privacy Policy and obtained their consent for sharing their data with NBN23 for the specified purposes.

You are also responsible for ensuring that the information provided is accurate and up to date. Any direct or indirect damage or harm caused by failing to comply with this obligation will be your sole responsibility.


How Will We Use Your Personal Information, and What Services Will We Provide?

NBN23 acts as a data controller for the following purposes:

1. Based on Compliance with a Legal Obligation:

a. Allowing users to exercise their rights.
b. Complying with applicable regulations and cooperating with competent authorities.


2. Based on the Management of the Contractual or Pre-Contractual Relationship:

a. Managing your user registration in our applications and granting you access.
b. Providing the services and content you have requested, responding to your inquiries, and facilitating the exercise of your rights.
c. Managing challenges, points, and rewards available in our applications.
d. Sending in-app notifications related to the application, such as updates to the privacy policy, legal notices, terms and conditions, and announcements of new features.


3. Based on NBN23’s Legitimate Interest:

a. Keeping you informed about NBN23’s products and services and sending you news, events, and activities via conventional and electronic means (pop-ups, emails) related to our products and services that may be of interest to you.
b. Sending push notifications related to the application’s services.
c. Conducting periodic reviews of our services and community to promote basketball, develop new content and services, conduct market analysis, and assess customer satisfaction to improve service quality.
d. Performing internal audits and fraud prevention measures, moderating challenge content, and contacting users in cases of suspected fraud, identity theft, or other legitimate concerns.

If you do not wish your data to be processed for these purposes, you may object at any time by contacting us at DPO@nbn23.tech, as indicated in the Rights Management section of this Privacy Policy.


4. Based on Your Explicit, Free, and Unambiguous Consent:

a. Conducting segmentation and profiling based on your interests by analyzing your use of our services (such as browsing history or bookings) to customize content, challenges, and promotions to your preferences.
b. Keeping you informed about third-party products and services—always sent via NBN23 and only with your explicit consent—through emails, SMS, in-app push notifications, related to basketball, entertainment, travel, culture, art, music, gastronomy, environment, sports, or technology. For this purpose, NBN23 will process your email address, phone number, and user ID.
c. Sharing your personal data with third parties for the promotion of their products and services.
d. Sharing your challenge content on NBN23’s social media channels and other communications to promote the website and application.
e. Profiling for personalized marketing: If you give your consent, NBN23 will create a detailed profile of you to improve marketing campaigns by offering personalized advertisements, content, services, and product recommendations via email, SMS, push notifications, in-app messaging, and personalized banners on websites, applications, or social media. This processing will involve your name, surname, app ID, operating system, telemetry data (e.g., clicks on specific content, time spent on content), etc.
f. Authorizing international data transfers for commercial purposes, based on the consents granted.

All processing activities under this section are conditioned on your freely given, specific, informed, and unambiguous consent.

If you no longer wish for your data to be processed for any of these purposes, you may withdraw your consent at any time by contacting DPO@nbn23.tech, as detailed in the “Exercise of Your Rights” section of this Privacy Policy.


Use of the Identifier for Advertisers on iOS Devices (Apple)

  • Using the ID for advertisers requires user tracking permission within the iOS operating system.
  • At any time, users can accept or reject tracking permissions in their Apple device’s iOS settings.

Data Sharing and International Transfers

All data transfers are necessary to fulfill the purposes mentioned earlier or to comply with legal obligations. Personal data may be shared with:

a. Public administrations, courts, and law enforcement agencies, as required by law.
b. Relevant sports federations responsible for managing sports competitions.
c. Courier companies we work with to deliver your orders.
d. Payment service providers (banks, payment gateways, etc.) when payments are processed through these companies.
e. IT service providers that support NBN23’s services, such as hosting providers, CRM tools, and email service providers.

NBN23 ensures that all data transfers comply with legal guarantees and that contracts are in place with all service providers as required by regulations. Additionally, when international data transfers occur, NBN23 applies the necessary safeguards to ensure security, such as European Commission Standard Contractual Clauses or applicable legal exceptions.


Exercising Your Rights

You have the right to:

  1. Access your personal data and understand how it is processed.
  2. Rectify any inaccurate personal data.
  3. Delete your personal data, when legally possible.
  4. Request restriction of processing, if the accuracy, legality, or necessity of the data is in question.
  5. Object to data processing, when the legal basis is NBN23’s legitimate interest.
  6. Request data portability, if processing is based on a contractual relationship or consent.
  7. Withdraw consent at any time.

You may exercise your rights free of charge by:

  • Emailing DPO@nbn23.tech, stating the right you wish to exercise and providing identification details.
  • Sending a written request to:
    Calle Juan de la Cierva y Codorniu, 27. Edificio Wellness 1, 3rd Floor – 46980, Madrid, Spain, stating your request and personal information.
  • Clicking the unsubscribe link in any commercial communication you receive from us.

Additionally, you can file a complaint with the Spanish Data Protection Agency (AEPD) if you believe we have violated data protection laws.

You can also register with the Robinson List (www.listarobinson.es), a system managed by the Spanish Association for Digital Economy (ADIGITAL), to prevent receiving commercial communications.

For mobile app users (Android or iOS), you can unsubscribe and delete your account via the “Profile” section under “Consent Management”.


Data Retention Periods & Cookies

Your data is retained only as long as necessary to provide our services. Once no longer needed, data will be blocked and only accessible in cases of legal obligations (e.g., government requests) or for exercising your rights.

  • App Registration Data: Retained until you request deletion or the purpose expires, plus the statutory limitation period.
  • In-App Notifications: Retained until you request deletion or opt-out.
  • Push Notifications: Retained until you opt out.
  • Marketing Communications: Retained until you opt out, revoke consent, or limit processing.
  • Profiling Data: Retained until you opt out, revoke consent, or limit processing.

Once retention periods expire, data will be deleted.

For website and app data, NBN23 uses Cookies per its Cookie Policy, available [here].


Security & Confidentiality

We prioritize your data security and implement technical, physical, and administrative safeguards to prevent unauthorized access or disclosure.


Minors’ Use of NBN23 Services

Children under 16 years old cannot use NBN23 services requiring registration (Swish, FIO Stats, SwishVerse, DBB.Scores, Swiss Basketball, Basketball Challenges), even with parental or legal guardian consent.


Privacy Policy Updates

We regularly update this Privacy Policy. Changes will be clearly visible (e.g., notifications in the app or via email).

This Privacy Policy was last reviewed and published on October 9, 2024.