At Catena Operations Ltd (“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?
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.
2. What personal data do we process?
We may process the following personal data about you:
- Mobile number
- Email address
- Date of Registration
- IP address
- Location data
- Website usage
- Content you submit, such as, posts, comments, personal preferences, opinions, complaints, chats
- 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 participate in some of our offers or decide to get in contact with us or whenever you connect with us through social media or other third party application (your social media service provider or third party application may allow you to share information with us – if you choose to share, you will generally be told by your social media provider which information will be shared)
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/or 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 customer support or when you connect with us via social media;
- if we make available, check if you are eligible to claim our bonuses and offers;
- send out direct marketing and other types of marketing communications, for example via email, SMS, social media (e.g. Facebook, Telegram, Whatsapp) relating to products and services. You can opt-out at any time. See also Section 6 below for more on direct marketing;
- to improve our marketing communications, for example we may use a similar technology to cookies to confirm whether you have opened a marketing email or clicked on a link in the email;
- analyse 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;
- if we make available, 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;
- it is necessary for the performance of a contract, for example to finalize and administer your subscription; or
- our use of your personal data is necessary to support ‘legitimate interests’ that we have as a business (for example, to receive certain 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 customer support), in a way that is proportionate and respects your privacy.
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 mailing application providers:
- GetResponse Sp.z.o.o., (Polish limited liability company); and
- com EMEA Limited, a limited liability company incorporated in England. salesforce.com EMEA Limited operates as a subsidiary of salesforce.com, inc., who is Privacy Shield certified as you may see here;
- Our chatbot platform MobileMonkey Inc., based in the US, with which we have implemented appropriate safeguards (see Section 11 below) and which processes personal data on our behalf;
- Our plugin provider and host of WordPress.com Automattic, 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, hosting providers
- Third party applications or social media services (for example Facebook or Telegram Messenger, Whatsapp messaging) may be integrated with the site in various ways (for example, we may integrate social media messaging or chatbots on our site, social media accounts or groups to allow you to interact with us and the site), which will involve us collecting some of your personal data or the social media provider or third party application receiving some of your information (see more in Section 1 above);
- 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.
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.
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 emails, SMS, Whatsapp, Facebook or Telegram messenger 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.
We may display advertisements from third parties and other content that links to third-party websites. If you click on a third-party advertisement or link, please be aware that you are leaving our site and any data you provide will be processed in accordance with such third party’s respective privacy and cookie policies, which we advise you to consult beforehand.
8. 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.
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 protected] 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:
We are using Cookies
What are cookies?
A cookie, pixel or similar technology is a small file or information that is stored on your computer or device when you visit our website. Our website can thus remember your actions and settings (such as login, language, font size and other display settings) over a certain period of time, so that you do not have to enter them again and again when you return to the website or browse from one page to another.
By using our website, you consent to the use and storage of cookies on your computer or device.
In general, you can view our website without cookies, whereby certain parts of the website may not work properly or the navigation may be slower.
If you do not want cookies to be stored on your computer or device, you can deactivate the corresponding option in the system settings of your browser. You can also delete stored cookies at any time in the system settings of your browser.
Further information on deactivating or deleting cookies can be found here: http://www.allaboutcookies.org/ge/. However, we would like to point out that if you do not accept cookies, there may be functional restrictions in our offers.
Categories of cookies
are technically necessary (technical necessity)
are saved and used for a certain period of time (storage duration)
are stored and saved by us or a third party (cookie provider).
Session cookies: Some cookies are only required for the duration of your visit to our website. These are so-called session cookies. They will be deleted or invalid as soon as you leave our website or your current session expires. Session cookies are used, for example, to save certain information during your session.
Permanent cookies: Some cookies are stored for a longer period of time. For example, it detects when you visit our website again later and saved settings can be accessed. This allows you to access websites faster or more conveniently. For example, you don’t have to reset certain options, such as the language you choose. Persistent cookies are automatically deleted after a predetermined time.
Flow cookies: These cookies are used for communication between our internal servers within our group of companies. They are stored on your computer or device when you start navigating on the website and deleted after you have finished navigating on the website. Flow cookies receive a unique identification number, but do not allow any conclusions to be drawn about the respective customer or user.
Provider cookies: These are cookies that are placed by us or the operator of our website commissioned by us.
You can deactivate Google Analytics using a browser add-on if you do not want the website analysis to be carried out. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=.
This add-on stores “opt-out” information on your device so that your deactivation by Google Analytics is complied with. Please note that this type of “opt-out” only deactivates Google Analytics for the device and the browser from which the opt-out was activated. Furthermore, you may have to reactivate if you delete cookies on your device.
Our most common cookies are:
Cookie Name: Google Analytics
Cookie Provider: Google
Purpose: This cookie is stored by Google. This enables our website to learn information about the use of our website by our users, such as B. the time of the visit, the pages visited, whether the user has previously visited them and the websites that were visited before visiting our website.
Cookie Name: Facebook Pixel
Cookie Provider: Facebook
Purpose: This cookie is stored by Facebook. Our website can thus assess, optimize and build up the target group for advertising campaigns on Facebook.
Cookie Name: One Signal
Cookie Provider: One Signal
Purpose: This cookie is stored by One Signal. This allows our website to remember that you have registered to receive push notifications. It also helps deliver personalized notifications.
Cookie Name: VWO
Cookie Provider: VWO
Purpose: This cookie is stored by VWO. VWO places cookies in the browser of the end user and the customer in order to identify the user. Your personal data are not contained in cookies. Mechanisms such as web storage in the browser can also collect and store information locally on your device.
Cookie Name: Hotjar
Cookie Provider: Hotjar
Purpose: This cookie is stored by Hotjar. This will collect non-personal data with the aim of giving you a better experience on the website, diagnosing technical problems and analyzing trends.
Cookie Name: Unbounce
Cookie Provider: Catena Media
Purpose: Unbounce is a tool that helps us develop better landing pages. Unbounce cookies are used to collect non-personal information that is used to improve the landing pages and offer a better experience.
Cookie Name: AdWords
Cookie Provider: AdWords
Purpose: AdWords is used to activate Google PPC (Pay Per Click) campaigns.
Cookie Name: Double Click
Cookie Provider: Double Click
Purpose: Double Click is used for advertising media and for advertising on multiple display servers.
Version 1.0. 14. May 2018