Information on the processing of personal data for journalistic purposes

Sure Soccer Tips operates sports news content on its website and apps for mobile phones, tablets and similar devices (together, the „Platform“). Through the Platform, Sure Soccer Tips may gather your personal information („you“ or „yours“). This document, concerning the handling of personal data for journalistic purposes ("Information"), delineates how Sure Soccer Tips collects, utilizes, and safeguards your personal data in conjunction with the news content accessible on Sure Soccer Tips's Platform, regardless of language version or geographic location.

1. Sure Soccer Tips - who we are and how to contact us,
1. For any reason whatsoever, you can to contact Sure Soccer Tips:
   1. via the contact form on Sure Soccer Tips's website: https://suresoccertips.com;
   2. by e-mail sent to the e-mail address support@suresoccertips.com.

2. Personal data processed

1. The personal data published within the scope of journalistic content on Sure Soccer Tips's Platform, or processed during the creation of such content, is determined by the public's interest in sports information. It encompasses a diverse range of information concerning individuals, potentially including your personal data, alongside details regarding sports personalities, clubs, organizations, matches, performances, and related events. Specifically, this information comprises:
   1. Identifying information, specifically including name, age, and nationality.
   2. Visual and auditory materials of a personal nature, particularly interviews and statements attributed to you.
   3. Affiliation details, pertaining to your involvement in sports, public life, or membership in specific groups (e.g., sports clubs).
   4. Sporting activity data, encompassing information on your participation in sports events, performances, and related statistics.
   5. Special categories of personal data directly linked to your sports or professional activities (e.g., injury and associated medical conditions). Sure Soccer Tips will process and, when necessary, disclose these special categories of personal data only if Sure Soccer Tips determines that there is a significant general public interest in their processing and disclosure.
   6. Sure Soccer Tips may also include supplementary information about you, such as family relations, employment, financial status, achievements etc. Sure Soccer Tips handles and discloses this data in a balanced manner, based on substantial public interest.

3. The purpose and legal basis of the processing

The processing of personal data is based on legal provisions outlined in Act No. 110/2019 Coll., on personal data processing, as amended („the Act“). This includes processing for journalistic, academic, artistic, or literary expression, as well as constitutionally guaranteed freedom of expression and the right to information. Sure Soccer Tips's legitimate interest in safeguarding against legal claims and ensuring content accuracy also serves as a legal basis for processing personal data.
1. The specific purposes of the processing are as follows:
   1. Preparation, processing and publication of content
      Sure Soccer Tips utilizes your personal data for the preparation, creation, and processing of content into its final format, as well as for its subsequent publication on Platform to operate news-based platforms primarily focused on sports. This includes:
      • Serving as foundational material for the preparation and publication of textual, visual, or audio media content.
      • Demonstrating a legitimate interest in processing personal data and validating the accuracy of content published by Sure Soccer Tips.
      • Inclusion within a photo library or audiovisual content repository, provided it is an image or audiovisual recording for which Sure Soccer Tips has authorization to publish.
        

   2. Generating keywords and profiles

      Additionally, Sure Soccer Tips employs your personal data in the Platform's operation to construct databases, categorize and organize journalistic content, and generate keywords, facilitating public search and enhancing content clarity.
      Sure Soccer Tips assures you that Sure Soccer Tips does not engage in any automated individual decision-making regarding your profile, as defined in 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 concerning the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (hereinafter referred to as the „Regulation“).

4. Processing time
   

1. Sure Soccer Tips will process your personal data for the duration of the legal basis for processing.
2. If personal data is processed for the purpose of preparing journalistic content, Sure Soccer Tips will cease processing it if it is no longer utilized for this purpose, and if Sure Soccer Tips does not anticipate its use in any other forthcoming material.
3. If personal data is published as part of journalistic content, it will be electronically processed by storing it in the pertinent data storage utilized for operating the corresponding Platform or for archiving journalistic content on the Platform electronically, with no time limitation.
4. If personal data is processed to substantiate a legitimate interest in personal data processing, in the event of disputes, and to verify the accuracy of the content Sure Soccer Tips publishes, it may be processed indefinitely based on its nature. Sure Soccer Tips will cease processing on Sure Soccer Tips's own accord if the justification for processing no longer applies.
5. If personal data is processed for the generation of keywords and profiles, it will be electronically processed by storing it in the appropriate data storage utilized for the operation of the relevant Platform for the duration of storing the corresponding content to which it pertains.
6. If personal data is processed by storing it in a photobank or another database of audiovisual content, it will be processed for the duration of the license or other authorization to publish the relevant audiovisual content (potentially without a time limit in certain cases) or for the duration of the copyright in that content.

5. Administrator and other processors

1. All the aforementioned personal data is processed by Sure Soccer Tips as the controller. This signifies that Sure Soccer Tips determines the purpose and methods by which your personal data will be processed, including but not limited to collection, recording, sorting, and, when necessary, disclosure. Sure Soccer Tips bears responsibility for the proper execution of such processing of your personal data.
2. Sure Soccer Tips also engages the services of other processors for the processing of personal data, who handle personal data solely based on Sure Soccer Tips's instructions and for the purposes outlined above. These processors include individuals or entities involved in technical operations on Sure Soccer Tips's behalf, such as those providing hosting and software development services, as well as Sure Soccer Tips's external processors of journalistic content and other affiliated companies within Sure Soccer Tips's group.
   

6. 
   Other recipients

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 Sure Soccer Tips's users.
2. Sure Soccer Tips may include your personal data as part of journalistic content on social networks. In such instances, your data may be transferred to third countries (outside the EU) as defined by the Regulation, including countries for which the European Commission has not yet determined adequate protection equivalent to EU law. In such circumstances, Sure Soccer Tips will ensure that your personal data is processed and safeguarded in accordance with Sure Soccer Tips's standard Privacy policy, as well as through the appropriate safeguards outlined in Article 46 of the Regulation. Additional details on these safeguards are available, for example, here.

7. 
   Your rights

1. When handling your personal data, you possess certain rights that Sure Soccer Tips is obligated to uphold to the extent suitable.
2. However, as Sure Soccer Tips processes your personal data for journalistic purposes, certain exceptions apply to the exercise of rights. Pursuant to the Act on the Right of Access to Information (Official Gazette No. 25/13, 85/15, 69/22), all Croatian and foreign natural and legal persons have the right of access to information that is in the possession of public authorities, in an equal manner and on equal terms. Specific conditions are also set out in the case of the right to restriction of processing (as described in paragraph 7.6 below).
3. Right of access. You have the right to request information from Sure Soccer Tips about the personal data Sure Soccer Tips processes, its purpose, and duration. However, Sure Soccer Tips reserves the right to protect the source and content of the information. Sure Soccer Tips may decline to disclose the source or whether it's from publicly available sources. Access may be denied if the data is solely for journalistic or expressive purposes not published by Sure Soccer Tips, or if granting access would jeopardize processing purposes or require disproportionate effort.
   
4. Right to repair. If you find that the personal data Sure Soccer Tips processes about you is inaccurate or incomplete, you have the right to request correction without undue delay (if technically feasible) or rectification if the inaccuracies or incompleteness significantly affect your personality.
   Upon correcting personal data, Sure Soccer Tips will notify you of this action by indicating the last update directly in the published content.
5. Right to erasure. If you believe that the processing of your personal data has unreasonably impacted your personality, you have the right to request the deletion of your personal data. Sure Soccer Tips may decline deletion if Sure Soccer Tips determines that in the specific case, the public interest prevails, or if the data is solely for journalistic or expressive purposes, or if granting your request would jeopardize processing purposes or require disproportionate effort.
   
   If Sure Soccer Tips decides to delete personal data, Sure Soccer Tips will inform you of this action by indicating the last update directly in the published content, if available, or by other appropriate means.
6. Right to restriction of processing. Even if your personal data is processed for journalistic purposes, you may still exercise the right to limit the processing of personal data in certain instances. This right allows you to request that the data not undergo any further processing operations for a limited period. Sure Soccer Tips is obligated to restrict the processing of personal data when all of the following conditions are satisfied:
   1. Sure Soccer Tips no longer necessitates your personal data for the aforementioned processing purposes;
   2. You require your personal data to establish, exercise, or defend your legal claims, and simultaneously, enabling Sure Soccer Tips to accommodate this right does not necessitate disproportionate effort on Sure Soccer Tips's part.
7. Right to object to processing. You possess the right to object, albeit exclusively to a particular disclosure or publication of personal data grounded in Sure Soccer Tips's legitimate interest. In such instances, please furnish specific reasons indicating that, in your circumstances, the legitimate interest in safeguarding your rights and freedoms supersedes the public interest in freedom of expression. Should Sure Soccer Tips determine that your interest has indeed taken precedence, Sure Soccer Tips will cease disclosing the relevant personal data.
8. Right to lodge a complaint. Exercising your rights in the aforementioned manner does not impede your right to lodge a complaint with the relevant supervisory authority. You can exercise this right, especially if you believe that Sure Soccer Tips is unlawfully processing your personal data or breaching generally binding legal regulations.
9. Exercising your rights. For any inquiries, exercising of rights, or complaints regarding your personal data, please contact Sure Soccer Tips using the provided electronic methods, preferably via email (refer to article 1). Sure Soccer Tips aims to respond promptly, within one month. In complex cases, Sure Soccer Tips may extend this period by up to two months and will notify you accordingly with reasons for the delay.


10. Sure Soccer Tips retains the right to revise or update this Privacy Notice periodically; the latest version is consistently available on Sure Soccer Tips's website and mobile apps. Therefore, Sure Soccer Tips recommends checking this Information periodically to remain informed about the terms of personal data processing and your rights.