GDPR and Journalism

INFORMATION ON THE PROCESSING OF PERSONAL DATA FOR JOURNALISTIC PURPOSES

Livesport s.r.o. ("we", "our" or "us") operates sports news content on its website and apps for mobile phones, tablets and similar devices (together, the "Platforms"), which may include your personal information ("you" or "yours"). 

This information about the processing of personal data for journalistic purposes ("Information") explains how we collect, use and protect your personal data in connection with news content available on our platforms in any language version or location.

1. OUR IDENTITY AND CONTACT DETAILS

1.    1.1. We, as the controller of your personal data, are Livesport s.r.o., a limited liability company, with registered office at Bucharova 2928/14a, Stodůlky, 158 00 Prague 5, company identification number 27433722, registered in the Commercial Register maintained by the Municipal Court in Prague, file number C 113331. 

      1.2. If you want to contact us, you can: 

        1.2.1. via the contact form on our platforms;

        1.2.2.by e-mail sent to the e-mail address privacy@livesport.eu;

        1.2.3.by letter sent to the above postal address. 

      1.3. We have appointed a data protection officer who you can contact for all matters related to the processing of your personal data and the exercise of your rights by e-mail at dpo@livesport.eu.

   2. PERSONAL DATA PROCESSED

      2.1. The personal data that is published in the context of journalistic content in various forms on our platforms or processed in the preparation of such content, the content of which is determined by the extent of the public's interest in sports information, includes a wide variety of information relating to the persons concerned and, where applicable, your personal data, as well as information relating to sports personalities, sports clubs and organizations, sports matches, sports performances and other related events. This information includes in particular: 

        2.1.1. Identifying information, in particular name, age and nationality.

        2.1.2. Photographs, audiovisual recordings and speeches of a personal nature, especially your interviews and comments. 

        2.1.3. Details of your affiliations, which relate to your involvement in sport and public life or your affiliation to a particular group (e.g. a sports club). 

        2.1.4. Sports activity data, i.e. data related to your sporting or professional activity (e.g. no/participation in sports matches, sports performance and statistics). 

        2.1.5. Special categories of personal data that are directly related to your sport or professional activity (e.g. your injury and related medical condition). We will only process and, where appropriate, disclose these special categories of personal data in a proportionate way if we have concluded that there is a significant general public interest in processing and disclosing them.

        2.1.6. Further details in the table of contents. This is any additional information about you that may be contained in the content, such as information related to your marriage, information about family members, information about your employment and financial circumstances, including income, achievements and education. We also process and, where appropriate, disclose these categories of personal data in a proportionate manner only if we have concluded that there is a significant public interest in processing and disclosing them.

   3. THE PURPOSE AND LEGAL BASIS OF THE PROCESSING

      3.1. The legal basis for the processing of personal data is the provisions of Section 17(1) et seq. of Act No. 110/2019 Coll., on the processing of personal data, as amended (hereinafter referred to as "the Act"). Your personal data may be processed in a reasonable manner for journalistic purposes or for the purposes of academic, artistic or literary expression. Another legal basis for the processing of your personal data is also the exercise of the constitutionally guaranteed freedom of expression and the right to information and, last but not least, our legitimate interest in protecting ourselves against legal claims by the persons concerned or third parties and for the possible substantiation of the truthfulness of the content published by us.

      3.2. The specific purposes of the processing are as follows:

        3.2.1. Preparation, processing and publication of content

We use your personal data for the preparation, creation and processing of content into its final form and for its subsequent publication on platforms for the purpose of operating platforms based on news content primarily in the field of sports, namely:

• as a basis for the preparation and publication of text, image or audio media content 

• to prove a legitimate interest in the processing of personal data and to prove the truthfulness of the content published by us;

• as part of a photo library or audiovisual content repository if it is an image or audiovisual recording that we are authorised to publish.

       3.2.2. Creating keywords and profiles

We also use your personal data in the operation of the platforms to create databases, to categorize and sort journalistic content, and to create keywords to make it easier for the public to search for information and to make the content clearer for them.

We do not carry out any automated individual decision-making in connection with your profile within the meaning of Article 22 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as the "Regulation").

4. PROCESSING PERIOD

4.    4.1. We will process your personal data for the duration of the legal basis for processing.

      4.2. If personal data is processed for the preparation of journalistic content, we will cease processing it if it is not used in this way and we do not consider that the data will be used in other material being prepared or considered for preparation.

      4.3. If the personal data is published as part of journalistic content, it will be processed in electronic form by storing it in the relevant data storage used for the operation of the relevant platform or for archiving the journalistic content on the platform in electronic form without time limitation.

      4.4. If the personal data is processed to prove a legitimate interest in the processing of personal data, for litigation purposes, and to prove the veracity of the content published by us, it may be processed without time limitation depending on its nature. We will terminate the processing ourselves if the reason for it ceases to exist.

      4.5. If personal data is processed for the creation of keywords and profiles, it will be processed in electronic form by storing it in the relevant data storage used for the operation of the relevant platform for the duration of the storage of the relevant content to which it refers.

      4.6. If the personal data is processed by storing it in a photo bank or other database of audiovisual content, it will be processed for the duration of the license or other authorisation to publish the relevant audiovisual content (i.e. in some cases without time limit) or for the duration of the copyright in that content.

   5. CONTROLLER AND OTHER PROCESSORS

      5.1. All of the above-mentioned personal data are processed by us as the controller. This means that we determine for what purpose and by what means your personal data will be processed, i.e. in particular collected, recorded, sorted and, where appropriate, disclosed, and we are responsible for the proper implementation of such processing of your personal data.

      5.2. We also use the services of other processors for the processing of personal data, who process personal data only on our instructions and for the purposes described above. Such processors are persons who provide technical activities for us, including persons providing hosting and software development services, as well as our external processors of journalistic content and other companies in our group.

   6. DISCLOSURE AND TRANSFER OF DATA OUTSIDE THE EU

      6.1. Your personal data within the journalistic content will be published and will be available to the public on the Internet or to a limited number of our users. 

      6.2. We may place your personal data as part of journalistic content on social networks. In this case, your data may be "transferred to third countries (outside the EU)" within the meaning of the Regulation, even to countries for which the European Commission has not yet decided on adequate protection identical to EU law. In this case, we will ensure that your personal data is processed and protected in accordance with our standard privacy policy, but also through the appropriate safeguards set out in Article 46 of the Regulation and available, for example, here.

    

   7. YOUR RIGHTS 

      7.1. When processing your personal data, you have certain rights which we are obliged to exercise to the extent appropriate.

      7.2. However, as we process your personal data for journalistic purposes, certain exceptions apply to the exercise of rights. Pursuant to Section 20 of Act No. 110/2019 Coll., on the processing of personal data, the exercise of the rights to erasure (as described in (c) below) and rectification (as described in (b) below) is governed by other legislation, such as Section 82 of Act No. 89/2012 Coll., the Civil Code, or Section 10 et seq. of Act No. 46/2000 Coll., on rights and obligations in the publication of periodicals and on amendments to certain other acts. Specific conditions are also set out in the case of the right to restriction of processing (as described in paragraph 7.6 below).

      7.3. Right of access. You have the right to ask us to provide you with information about what personal data we process, for what purpose, and for how long it will be processed. We have the right to protect the source and content of the information. We are not obliged to provide you with the source from which the personal data originates, or information about whether it comes from publicly available sources. We may not comply with your request if the personal data is not published by us and is processed solely for journalistic purposes or for the purposes of academic, artistic or literary expression. In other cases, we may exclude access to personal data where justified, in particular where the legitimate purpose of processing the personal data would otherwise be jeopardized or frustrated or would require disproportionate effort. 

      7.4. Right to repair. If you discover that the personal data we process about you is inaccurate or incomplete, you have the right to have it corrected without undue delay (if technically possible) or to have it rectified if the inaccuracy or incompleteness has unreasonably affected your personality.

5.  

In the event of a correction of personal data, we will inform you of this fact by indicating the last update directly in the published content.

               7.5. Right to erasure. If you find that the processing of your personal data has unreasonably affected your personality, you have the right to request that we delete your personal data.

In the event of deletion of personal data, we will inform you of this fact by indicating the last update directly in the published content, if available, or by other appropriate means.

                7.6. Right to restrict processing. Even if your personal data is processed for journalistic purposes, you may in some cases exercise the right to restrict the processing of personal data. This right allows you to request that the data not be subject to any further processing operations for a limited period of time. We must restrict the processing of personal data when all of the following conditions are met:

                    a) We no longer need your personal data for the above processing purposes;

                    b) You require your personal data to establish, exercise or defend your legal claims; and at the same time, enabling us to exercise this right does not require disproportionate effort on our part.

                 7.7. Right to object to processing. You have the right to object, but always only to a specific disclosure or publication of personal data that is based on our legitimate interest. In this case, please provide specific reasons showing that in your case the legitimate interest in protecting your rights and freedoms outweighs the public interest in freedom of expression. If we consider that it has been demonstrated that your interest is overridden, we will stop disclosing the personal data in question.

                 7.8. Right to lodge a complaint. Exercising your rights in the above manner does not affect your right to lodge a complaint with the relevant supervisory authority. You can exercise this right in particular if you believe that we are processing your personal data unlawfully or in violation of generally binding legal regulations. You can file a complaint against our processing of personal data with the Office for Personal Data Protection, which is located at Pplk. Sochora 27, 170 00 Prague 7.

                 7.9. Exercising your rights. For all matters relating to the processing of your personal data, whether it is an enquiry, exercising a right, lodging a complaint or anything else, you can contact us in the ways set out above (most easily electronically via the form or by email). We will deal with your request without undue delay, but at most within one month. In exceptional cases, in particular due to the complexity of your request, we are entitled to extend this period by a further two months. We will, of course, inform you of any such extension and the reasons for it.

                 7.10. We reserve the right to modify or update this Information  from time to time; we always post the current version of the Information  on our Platforms. We therefore encourage you to check this Information periodically to stay informed about the terms and conditions of the processing of personal data and your rights. 

In Prague on 31.01.2023                                                                                                                                                           Livesport s.r.o.